From gap analysis to sole source on a capacity case

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1. Start with the role, not the equipment

Under the Security Assistance Management Manual (SAMM), Building Partner Capacity (BPC) planning starts with the Requesting Authority (RA). The RA defines the military roles a partner needs to meet its security objectives (SAMM C15.2.6). The assessment should include a gap analysis for each capability, covering doctrine and organization, training and materiel, leadership and personnel, and facilities and policy. The manual explains the purpose: to avoid an overly narrow focus on equipment or training solutions.

The same assessment, captured in the country campaign plan of the Combatant Command (CCMD), should weigh three more things (SAMM C15.2.6). They are the partner’s political will to use the capabilities, the national legal framework that allows or limits their use, and the capacity of the defense ministry and other institutions to sustain them. The campaign plan links the desired roles to the CCMD’s and national strategic objectives. The embassy reflects the partner objectives in its Integrated Country Strategy and resource request. Who holds which role on a program is covered in who does what on a capacity building program.

2. Prioritizing and packaging

The RA then produces a prioritized list of capability shortfalls (SAMM C15.2.6.1). The list covers shortfalls the partner is willing to address after initial planning, where the embassy country team, or the American Institute in Taiwan, shows the will to support. Ranking does four things. It steers resources to the most urgent needs, sequences new capabilities properly, helps build capability packages, and lets the program scale down if only part of the funding arrives. The RA should coordinate the ranking with the implementing agencies (IAs) and the CCMD staff, bearing in mind any known limits on the funds.

The ranked requirements become packages of specific, actionable and sustainable program requests (SAMM C15.2.6.2). For complex efforts, or where a firmer assessment is needed, American subject matter experts may visit. They consult partner representatives, inspect equipment, judge institutional capacity and help the RA plan the packages.

3. The whole package, on a deadline

The RA should apply the Total Package Approach to the articles and services in its pre-planning documents (SAMM C15.2.6.3). That means addressing follow-on support and sustainability during planning. The manual adds a constraint: BPC programs are limited by the time available to obligate the appropriated funds. Proper sustainment may need extra spares, training, consumables and possibly contractor logistics support beyond what the authority and appropriation allow in time. In that case a follow-on program may be needed. How the pre-planning documents become a case is covered in writing a capacity building case.

4. Checking feasibility

The Defense Security Cooperation Agency (DSCA) and the IA run a feasibility assessment on the pre-planning documents (SAMM C15.2.6.4). It checks that requirements are actionable and that the materiel and training can be provided within the limits of the authorizing law. The IA should use the feasibility checklist early where a training and equipment list is used. The formal period is 7 to 14 days, during which implementers confirm they can buy the assigned equipment, training and services. DSCA’s country portfolio director may, by exception, extend it for more complex programs, in coordination with the regional director or program manager.

Where something cannot be provided because of availability or releasability, the IA proposes an alternative giving a similar capability, allowed by the law and the period of availability of the funds (SAMM C15.2.6.4). The RA must confirm any substitute and revise its documents. DSCA may also move programs or lines to another IA if the original IA identifies issues executing a program. The assessment should list any documents still needed. These include a country team assessment and CCMD endorsement, technology security and disclosure releases, and cost estimates. Transportation plans, third-party transfer approvals, nonrecurring cost waivers for cooperatively produced articles and special contracting needs may also be on the list.

5. Asking for one source

Every sole source request needs a justification and approval under the federal acquisition rules, approved by the IA’s contracting authority under 10 U.S.C. 3204 (SAMM C15.2.6.5). The manual suggests what RAs should include where only one source is available. That covers a description of the articles or services, including brand name, their intended use, and how the program would suffer without them. It also covers the critical features that limit the item to one source, with minimum essential requirements stated.

The manual gives examples of such features (SAMM C15.2.6.5). Equipment may need to match existing systems in form, fit and function, and a patent, copyright or proprietary data may limit competition. Parts may be direct replacements for existing equipment, in which case the government’s cost to duplicate the capability should be estimated. The request should explain the steps, such as market research or a search for sources, that led to the conclusion, show that the expected cost is fair and reasonable, and add anything else that justifies an exception.

6. Which exceptions apply

An urgency exception needs a statement of urgency from the RA (SAMM C15.2.6.5.1). Neither the partner’s preference nor expiring funds is enough to justify urgency. Where there is only one responsible source, or a brand name is needed to support a logistics chain the partner already has, the RA completes a justification under the single-source exception (SAMM C15.2.6.5.2).

The international agreement exception works differently for grant programs (SAMM C15.2.6.5.3). On a sale, the Letter of Offer and Acceptance is a binding agreement under American law and can support a sole source under that exception. BPC programs have no international agreement with the partner, so the exception cannot be used for them, except under 10 U.S.C. 333. Under that authority, with State Department concurrence, the Defense Department may let a partner direct the source and enter into an agreement providing for it (SAMM C15.2.6.5.3.1). Other grounds for a sole source are set out in the federal acquisition regulations and the defense supplement (SAMM C15.2.6.5.4).

Key terms

Gap analysis	A review of each capability across eight areas, from doctrine and organization to facilities and policy.
Capability package	A specific, actionable and sustainable set of program requests built from ranked requirements.
Total Package Approach	Planning follow-on support and sustainment alongside the articles and services.
Feasibility assessment	The 7 to 14 day check that a program can be executed within the law.
Justification and approval	The document needed for any sole source request.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

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