FedRamp Mainframe Documentation Services
Justification for Exception to Fair Opportunity
United States Department of Agriculture
FAR 16.505
1. Identification of the agency and the contracting activity.
United States Department of Agriculture, National Information Technology Center, 8930 Ward
Parkway, Kansas City, MO 64114
2. The nature and/or description of the action being approved.
The USDA proposes to issue a direct award task order on a firm fixed-price basis with ECCO
Systems to perform system documentation updates for a FedRAMP system.
3. A description of the supplies or services required to meet the agency’s needs (including
estimated value).
The DISC intends to expand its FedRAMP Agency ATO for its DISC vGov cloud services system
to include the Mainframe services offering which will allow DISC to expand its support non-USDA
Mainframe customers.
The objective of this effort is to obtain services from a FedRAMP-certified third-party assessment
organization (3PAO) to create the proper documentation to support a FedRAMP Agency ATO and
an IL4 ATO for the DISC using the most up to date templates from FedRAMP.
This project will include updating and creating the documentation required to support a FedRAMP
Agency ATO of DISC’s PaaS and IaaS Services. The updated documentation will include the
current vGov Cloud services system, along with the DISC Mainframe PaaS and IaaS offerings into
the most up to date templates provided by FedRAMP and DISA.
Base year estimated value is $250K, each option year after that is the same, there are 4 anticipated
option periods for a total estimated cost of approximately $1M.
4. Identification of the exception to fair opportunity and supporting rationale.
FAR 16.505(b)(2)(i)(E) - a statute expressly authorizes or requires that the purchase be made from a
specified source.
The 8(a) STARS II GWAC (STARS II) is a competitively awarded, multiple-award, indefinitedelivery,
indefinite-quantity contract. STARS II was authorized under the provisions of Section 8(a)
of the Small Business Act 15 U.S.C. 637(a) and retains the 8(a) sole source, or “directed order,”
authority found in FAR 19.8. STARS II resulted from a competitive 8(a) procurement, which was
offered to and accepted into the SBA 8(a) program. Given that STARS II was established for
exclusive participation among 8(a) contractors, the entire GWAC was accepted into the 8(a)
program and all industry partners were verified by SBA as 8(a) eligible prior to GWAC award, as a
result individual orders do not have to be offered and accepted into the 8(a) program and 8(a)
eligibility of the industry partners has already been verified by GSA.
STARS II allows for directed orders under the competitive threshold, currently $4.0 million, per
FAR 19.805-1(a)(2), and has the same, per order, ceiling on directed orders for all industry partners.
The rationale at FAR 19.804-2(a)10, (i) or (ii), is germane to directed orders.
5. A determination by the Contracting Officer that the anticipated cost to the Government
will be fair and reasonable.
The order is priced with GSA rates which are previously determined to be fair and reasonable.
6. Any other facts to support the justification.
Initial market research indicated that the products were available via NASA SEWP and GSA
schedule. Two RFQs were posted in an attempt to achieve price competition and get a quote
howver no quotes were received in response to either RFQ. Additional market research was
conducted and it was determined that the requirement for 3PAO was preventing vendors from
submitting a quote. The CO determined that in order to meet the agency need quickly after being
delayed by the two failed RFQs was to contract with an 8(a) GSA STARS II vendor who can
partner with a 3PAO vendor to meet the requirement. USDA has an exceptional working
relationship with ECCO Select for 24x7x365 services at DISC, the same customer requiring the
3PAO services. Awarding to ECCO Select would reduce contractor security onboarding time and
allow for the vendor to start work almost immediately.
7. A statement of actions, if any, the agency may take to remove or overcome any barriers to
competition if subsequent acquisitions are anticipated.
This is a one-time purchase in support of final certification of the FedRAMP environment. Awarded contract 12314420F0110 to ECCO Select Corp for 241293.60 on 2020-01-02.
12314420F0110 Department of Agriculture Assistant Secretary for Departmental Management
2/5/20, 3:01 PM