A13 JEFO_App_Host-Final-_Redacted2.pdf
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- Application Hosting Services
- Solicitation number
- 01090
About this file
This is a Justification for an Exception to Fair Opportunity (JEFO) document for a federal bridge task order under FAR 16.507-6(b)(3).
The Centers for Disease Control and Prevention (CDC), through the Office of Acquisition Services (OAS), seeks to award a sole-source bridge task order to the incumbent contractor, Digital Management, Inc. (DMI), for Application Hosting Services under GSA Alliant 2 contract 47QTCK18D0019. The bridge order covers a 5.5-month performance period from November 11, 2026, to April 28, 2027, with potential exercise of a six-month option if unforeseen delays prevent completion by April 28, 2027. The services include continued operational support for CDC mission-critical systems, specifically Tier II application hosting and monitoring support across CDC's on-premises private cloud and service provider environments, encompassing virtual server operations, operating systems, applications, databases, middleware support, and incident escalation necessary to maintain established service levels. The Government will issue a request for proposal to the incumbent and evaluate technical acceptability and price reasonableness using GSA Alliant 2 labor rates, applicable discounts, and inflationary adjustments as comparison benchmarks. Certified cost or pricing data will not be required as a commercial item exception applies.
The justification cites the logical follow-on rationale, as CDC is executing a competitive successor acquisition that consolidates this Application Hosting requirement with a separate Managed Service Provider (MSP) requirement, with planned award in August 2027. Acquisition planning began in December 2025, including industry outreach through an RFI in April 2026; however, Department-level review requirements, executive order compliance considerations (EO 14222 and EO 14402), and post-RFI acquisition strategy refinement extended timelines beyond available FY26 resources. The bridge is necessary to maintain uninterrupted services during active technology transition as CDC migrates mission-critical applications from a colocation facility to on-premises infrastructure and cloud service providers. Market research confirmed other Alliant 2 contractors possess general capabilities, but transition and knowledge transfer during this critical migration period would create unacceptable service disruption risk. Contracting officer approval authority is limited to $900,000, and CDC Advocate for Competition approval authority is limited to $20,000,000.
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exception to fair opportunity is appropriate for this acquisition based on the following rationale:
a. FAR 16.507-6(b)(3) - The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.
CDC OCIO is seeking an exception to fair opportunity to award the incumbent, Digital Management. Inc, a task order for the Application Hosting requirement. The bridge will maintain the existing service while CDC completes the planning, solicitation, evaluation, and award activities for a competitive successor acquisition which merges the current work with the DCMSM Managed Service Provider (MSP) requirement expected to start later in 2027. The acquisition planning efforts for the follow-on contract began in December 2025 with consideration of consolidating the Application Hosting Services requirement with the DCMSM Managed Service Provider (MSP) requirement. OAS held regular weekly and biweekly meetings with the program office and CORs to address key planning topics, including combining the two separate PWSs, developing the PALT and key milestones, preparing the consolidation D&F, conducting internal market research, and evaluating small-business set-aside considerations.
These efforts also included ad hoc discussions with HHS OSDBU and HHS OSDBU�s review of the RFI in April 2026. Following the RFI, OAS provided the responses to the program office, which prompted the program office to reevaluate its acquisition strategy. Because this occurred during the fourth quarter, CDC�s focus shifted to finalizing FY26 awards.
The interaction of multiple contracts requires careful planning, and the revised strategy must account for the appropriate allocation of work and coordination among the affected contracts.
These additional strategy and contract-development activities have extended the time needed to complete the acquisition.
Additionally, . This scope requires several months of additional review processes at the Department level, which was unanticipated at the beginning of the acquisition process. In order to maximize efficiency and comply with recent executive orders, OCIO must carefully determine the best path forward to ensure cost efficiency in alignment with EO 14222. More recently, the fixed-price contracting requirements associated with EO 14402 have added another layer of complexity.
The time available in FY26 was insufficient to complete the RFI process, finalize the acquisition strategy and requirements, issue the competitive solicitation, evaluate proposals, and make an award. The bridge is therefore necessary to maintain uninterrupted Application Hosting services while those activities are completed. The performance period for the bridge Application Hosting order is from November 11, 2026, to April 28, 2027.
The Application Hosting requirement provides CDC with Tier II application hosting and monitoring support for CDC mission critical systems operating across OCIO�s on-premises private cloud and service provider-supported environments. These services include operational support for virtual servers, operating systems, applications, databases, and middleware, as well as monitoring, incident escalation, and coordination necessary to maintain established service levels and continued availability of supported systems. A lapse or material delay in obtaining this support would create an unacceptable risk to the continuity and reliability of CDC IT operations.
CDC is managing the current Application Hosting requirement while transitioning its technology hosting environment and acquisition strategy. The supported environment is undergoing active transition as CDC mission critical applications and systems migrate from the colocation facility to on-premises infrastructure and cloud service providers. During this transition, CDC must simultaneously maintain legacy on-premises workloads, support applications operating within provider environments, and coordinate escalations and modernization activities among OCIO, the service provider, other CDC organizations, and application re-architecture and re-engineering contractors. The planned transition away from the colocation facility and the reduction in on-premises scope increases, rather than eliminating, the immediate need for continuity of operational support during the transition period; therefore continuity and disciplined coordination is critical until the successor acquisition is in place.
Requiring fair opportunity for the bridge task order would require CDC to solicit, evaluate, award, and transition support to another contractor during the same period in which CDC is completing the competitive successor acquisition. That process would create an unacceptable risk of creating a gap in essential services. Such a gap would disrupt application monitoring, incident response and escalation, database and middleware support, and the maintenance of required service levels for CDC mission critical systems. It would also impair ongoing migration and modernization activities because effective transition depends upon continuity of technical knowledge concerning existing applications, infrastructure, dependencies, configurations, and operating environments. Loss of that knowledge or an interruption in support during migration could increase the likelihood of service disruptions, delay migrations, and complicate the transfer of responsibilities. The urgency is further heightened by the need to maintain applicable security and compliance requirements while workloads and responsibilities continue to move among environments. CDC must continue to support required FedRAMP, FISMA, and CDC-specific security controls during this transition period.
The logical follow-on is the best option for the Government during this transition period because it preserves continuity for the minimum period needed to complete the competitive acquisition, avoids a duplicative interim transition, and permits CDC to use the incumbent�s existing technical knowledge while responsibilities are being reallocated. The requirement for the Application Hosting is also changing and will be consolidated with as a new requirement as stated above so a full five year contract is not necessary. Extending the current support for a limited time avoids the cost and risk of establishing a separate interim provider and then transitioning again before the competitive successor acquisition is complete. This exception is temporary, does not establish a long-term noncompetitive solution, and is limited to the period necessary to address CDC�s immediate continuity need and complete the competitive award.
5. Agency actions to take to remove barriers that led to Fair Opportunity Exception (if applicable):
CDC OCIO initiated acquisition planning in FY26 and issued an RFI to industry as part of its market research. The time available in FY26 was insufficient to complete the RFI process and the subsequent requirements development, solicitation, evaluation, and award activities. CDC is continuing those activities with the contracting office to support a competitive successor acquisition expected in August 2027. This exception to fair opportunity is temporary and limited to the period necessary to maintain continuity of the existing Application Hosting services while the new competitive consolidated acquisition is completed. OCIO will check the procurement timeline to make sure the award happens on time.
6. Market Research:
Market research was conducted and included a review of the current task order, the existing PWS, the incumbent contractor�s performance, the Governments� technical and mission requirements, and the FY26 RFI issued to industry. The Government also reviewed the scope and ordering procedures of the GSA Alliant 2 GWAC to confirm that the bridge requirement remains within scope and to identify available qualified contract sources.
Because this action is a short-term bridge order intended to prevent a lapse in critical services, the Government did not issue a new sources-sought notice, draft solicitation, or conduct broad industry outreach. The market research showed that other Alliant 2 contractors may possess general capabilities, but a new provider would require transition, knowledge transfer, access provisioning, and validation of operating procedures during the same period in which CDC is migrating service boundaries and completing the competitive successor acquisition. Award to the incumbent is justified under FAR 16.507-6(b)(3) for the limited bridge period. The bridge does not prejudge the outcome of the competitive successor acquisition and does not expand the current requirement beyond the services necessary to maintain continuity.
7. Procurement History:
Historical contracts reviewed were predominantly Time and Materials (T&M)/Labor Hour (LH), indicating the labor intensive, variable nature of the support work and the historical use of T&M/LH contract types for similar services. The following are the previous awards:
a. Contractor: Dell Services Contract or Order Number: 200201037209-0004 Award Date and Period of Performance: 2/23/2017-9/24/2021
Competitive Status: Unknown Authority formerly relied upon if Not Competed:
b. Contractor: NTT Data Services Federal Government, LLC Contract or Order Number: HHSN316201200017W / 75D30122F13294 Award Date and Period of Performance: 02/11/2022-02/10/2023
Competitive Status: Competed amongst qualified vendors via the NITAAC CIO-SP3 Governmentwide Acquisition Contract Authority formerly relied upon if Not Competed: N/A
c. Contractor: Digital Management Inc.
Contract or Order Number: 47QTCK18D0019 / 75D30123F17456 Award Date and Period of Performance: 9/11/2023-11/10/2026
Competitive Status: Competed amongst qualified vendors via GSA Alliant 2 Governmentwide Acquisition Contract Authority formerly relied upon if Not Competed: N/A
8. Additional Information or Other Facts:
The Application Hosting requirement is being planned as part of a competitive successor acquisition. The bridge order is limited to the current Application Hosting requirement and is intended to maintain uninterrupted services while CDC completes the successor acquisition and related transition activities. The base bridge period will end on August 28, 2027. If an unforeseen delay prevents completion of the successor award or transition by that date, the Government may exercise the FAR 52.217-8 option, subject to the required determinations, approvals, and availability of funds.
9. Technical or Requirements Program Management Certification: I certify that the supporting data under my cognizance which are included in this justification (e.g., verifying the Government�s minimum needs or requirements or other rationale for an exception to fair opportunity are accurate and complete to the best of my knowledge and belief. (Always required.)
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