04_ID07210013 Exception to Fair Oportunity (Redacted)_Redacted.pdf

Justification for an Exception to Fair Opportunity

1) Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for an Exception to Fair Opportunity.”

Procurement Office Assisted Acquisition Services Division, Region 7

Agency: General Services Administration (GSA)

ASSIST Task ID: ID07210013

Description of Requirement: Bridge Task Order for Information Assurance/Mission Assurance

(IA/MA) on behalf of the Air Force Life Cycle Management Center (AFLCMC)

Total Estimated Value of the Action:

Period of Performance (PoP):

Base (Four Months) 01/20/2021 – 05/19/2021

Option 1 (Two Months) 05/20/2021 – 07/19/2021

Contractor Name: Booz Allen Hamilton, Inc. Cage Code 17038 located at 8283 Greensboro Drive, McLean, VA 22102.

Procurement Vehicle: GSA Alliant 2 Government Wide Acquisition Contract (GWAC).

2) Description of action being approved:

In July 2015, GSA competitively awarded a task order under the GSA Alliant GWAC, to BAH, with a period of performance of July 20, 2015 through July 19, 2020 (a base year with four (4) one-year option periods). During the fourth option period, the primary Contracting Officer Representative (COR), who represents the VC-25’s Commercial Derivative Aircraft Division (CDAD), stated their organization would no longer support any Air Force or Army platforms (sub clients) outside of CDAD on the follow-on task order supporting VC-25. Therefore, all sub clients not covered under the CDAD program’s follow-on contract were required to pursue separate contract/task order options. In order to provide sufficient time for numerous AFLCMC organizations to pursue other contract avenues to provide this support, the VC-25 CDAD task order was extended by six months using the FAR Clause 52.217-8, Option to Extend Services. The revised project end date became January 19, 2021.

The contract extension is nearing completion and the Assisted Acquisition Service (AAS) is actively pursuing replacement contracts, however, due to funding delays and in anticipation of providing sufficient time to solicit, evaluate, award and transition required services, the AFLCMC, in conjunction with AAS, is seeking to award a bridge task order to ensure that the client experiences no break in services during this transitional period.

This Justification for Exception to Fair Opportunity is in support of a Severable Time & Material (T&M) Bridge Task Order (BTO) consisting of one (1) four-month base Period of Performance (PoP) with one (1) two-month option (six (6) months total) to allow for the continuance of the Information

Total Estimated Value of the Action:

Assurance and Mission Assurance services in support of the Air Force Life Cycle Management Center (AFLCMC), servicing Wright-Patterson AFB, OH and other Air Force bases. This effort is currently being provided by Booz Allen Hamilton (BAH) under the GSA Alliant GWAC contract number GS00Q09BGD0019, task order GSQ0715BG0058, project number ID07150012.

3) A description of the supplies or services required to meet the agency’s needs (including the estimated value):

This Justification for an Exception to Fair Opportunity is to support a bridge task for one (1) four-month base PoP and one (1) two-month option period, on a sole-source basis to the current incumbent contractor, BAH (ID07150012), to continue the provisioning of IA/MA support services to the Air Force Life Cycle Management Center on behalf of the United States Air Force.

Information Technology (IT) services required under the bridge Task Order (TO) include: Science and Technology Information (STI) Relevance Assessment and Gap Analysis, Mission Execution Through Strategic Planning and IA/MA Analysis, Compliance of Airborne Systems to Meet IA/MA Mission Requirements, Analyzation and Identification of IA/MA Capability Gaps and Requirements, Compliance of Ground Systems to Meet IA/MA Mission Requirements, Technical Analysis of Detailed and Viable Alternatives for Mission Requirements, Developments and Assessment of IA/MA Requirements, Assessment of Impacts of IA/MA Technology, Secure Data Management Systems/Lifecycle Management Program (LCMP), Assessment of the Vulnerability, Authenticity and Continuity of IA/MA Systems, Assessment of Capabilities in Real-World Environments, IA/MA Conference Planning and IA/MA Meeting Initiative and Post Award Orientation.

The total cost for the base period and option period for this requirement is estimated to be over a six (6) month period. The anticipated appropriation funding types are AF Appropriation Code 3400, 3600, and 3010.

4) Identification of Statutory Authority Permitting a Fair Opportunity Exception:

FAR 16.505(b)(1)(i) requires the Contracting Officer to provide each awardee under a multiple award contract, a fair opportunity to be considered for each order exceeding $3,000 unless a statutory exception applies. The specific exceptions set forth in 16.505(b)(2) that preclude the fair opportunity process are listed below. The authority pertaining to this specific acquisition is marked accordingly.

__X____16.505(b)(2)(i)A) The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

______16.505(b)(2)(i)(B) Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

__ _16.505(b)(2)(i)(C) 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.

______16.505(b)(2)(i)(D) It is necessary to place an order to satisfy a minimum guarantee.

______16.505(b)(2)(i)(E) For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

_______16.505(b)(2)(i)(F) In accordance with section 1331 of Public Law 111-240 (15 U.S.C. 644(r)), contracting officers may, at their discretion, set aside orders for any of the small business concerns identified in 19.000(a)(3). When setting aside orders for small business concerns, the specific small business program eligibility requirements identified in part 19 apply

4a.) Supporting rationale (for the authority cited in 4 above) including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited:

There exists a need to put in place a new bridge task order for the IA/MA and LCMP support services using an Exception to Fair Opportunity in order to provide critical mission support until all long-term follow-on task orders can be successfully awarded. The currently awarded task order number GSQ0714BG0058, under contract number GS00Q09BGD0019, is due to expire on January 19, 2021.

GSA is in the pre-award phase of all three (3) follow-on acquisitions, with one acquisition in the Award Decision phase.

The base PoP and optional extension anticipated by this bridge task order will allow work to continue on this critical task under the incumbent vendor, BAH, without interruption to AFLCMC organizations and will allow for long-term awards to be finalized, for pre-work meetings, and for transition-in of the awarded vendor(s) into the new task orders. The vendor has workers currently in place who can continue to support the IA/MA requirements and provide unbroken services at all locations to all associated AFLCMC offices and platforms. As such, AFLCMC has requested that these services be continued through BAH in order to prevent any break in or degradation to support services during the process of awarding all necessary long-term task orders.

The shortened duration of the bridge task order PoP will enable GSA and the various AFLCMC organizations to complete vendor evaluation of any sole-source follow-ons and vendor selection of any competitive follow-ons, as well as enable vendors sufficient time to transition services into the new task orders without incurring a break in service and loss of critical support functions. These follow-on task orders are currently in the evaluation phases, and no vendor other than BAH currently has a ready pool of in-place, cleared support staff available with the appropriate IA/MA and LCMP systems and process knowledge ready to perform these requirements immediately after GSQ0714BG0058 expires on January 19, 2021.

AFLCMC is charged with life cycle management of Air Force weapon systems from their inception to retirement. BAH provides services to support AFLCMC’s holistic management of weapon systems across their lifecycle by simplifying and consolidating staff functions and processes to curtail redundancy and enhance efficiency. BAH provides IT services that assess and make recommendations on IA/MA requirements and provides services, as needed, to assist AFLCMC in the accomplishment of its mission. BAH conducts IA/MA technical research, analysis, recommends capability acquisition procedures, and prepares IA/MA requirements documents to accomplish dynamic AFLCMC mission requirements. BAH is providing IA/MA services on the current task order, GSQ0714BG0058, project number ID07150012, which expires January 19, 2021.

Failure to award this BTO would result in no fewer than three (3) subclient AF platforms losing critical support in the implementation, processing and documentation of platform and weapon systems upgrades and updates, which could negatively impact mission readiness of major weapons systems in deployed areas by preventing troops, supplies and ammo/weapons from being supplied to warfighters. .

Task order ID07150012 entailed over forty (40) CLINs in Option Year 4 and approximately twenty

(20) into the FAR 542.217-8 six-month option period, which represented numerous subclients and AF platforms that were receiving IA/MA and LCMP support. During these final option periods, GSA awarded follow-on task orders for five (5) of these subclients and platforms, including:

ID07190007 : E4-B and E6-B (Awarded 10/11/2019) ID07200030 : VC-25 CDAD (Awarded 07/16/2020) ID07190093 : B-52 SPO and CERP (Awarded 07/16/2020) ID07200016 : Propulsion (Awarded 07/17/2020) ID07200033 : PEO Digital (Awarded 07/15/2020)

GSA was unable, during this time, however, to finalize the awards of the three (3) remaining follow-on task orders. The follow-on task orders yet to be awarded include:

ID07200018 : KC-135 (Tanker Support) ID07200015 : Special Access Program IT Services (AFLCMC) ID07210009 : T-6 and C-130

This Justification for an Exception to Fair Opportunity supports GSA’s homestretch efforts to finalize the process of awarding these three (3) remaining follow-on orders in order to prevent a break in critical IA/MA and LCMP services to these sub clients and platforms.

Therefore, the decision to award this bridge TO through an Exception to Fair Opportunity takes into account the Government’s need for continuity operations and the potential costs of disrupting operations. The Government determined that executing the bridge TO to keep in place the previous TO Contractor with its support personnel would be the most advantageous and cost-effective option available to the Government, price and other factors considered.

In order to maintain continuity of support for the client until all long-term TOs are awarded, a BTO is found to be the most logical and cost-effective alternative to the Government.

5) Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable

A quote will be requested from BAH for the BTO, consisting of one (1) four-month base period of performance and one (1) two-month option period. The pricing will be reviewed to ensure it is fair and reasonable before any award is made. BAH will be requested to provide similar types and levels of services required in the Performance Work Statement (PWS) for the current TO, GSQ0715BG0058, in its current final six-month option period. The current TO rates were previously approved and found to be fair and reasonable and in accordance with GSA’s Alliant 2 GWAC. The GSA Contracting Officer (CO) will review pricing and make a fair and reasonableness determination in the Award Decision Document (ADD). The total estimated value of this BTO if all options are exercised is .

The CO has determined that, under the circumstances described herein, an Alliant 2 GWAC task order, issued to BAH, for the single four-month base period of performance and the two-month option period, represents the best option for maintaining IA/MA and LCMP-IDE program support and keeping in-place existing personnel with program and process knowledge and clearances, as well as representing the overall best value (including the level of effort and pricing) for the accomplishment of this BTO.

This BTO shall be prepared and fully executed by the GSA CO upon approval of this Justification for an Exception to Fair Opportunity. The Justification, in accordance with FAR 16.505(b)(2)(ii)(D), shall be posted on beta.SAM.gov (previously FBO.gov) within fourteen (14) days of the award of the bridge TO and shall remain posted for a period of at least thirty (30) days.

6) Any other facts supporting the justification

In order to ensure that this BTO is only for a limited and defined period of time described above, GSA is concurrently approving the pre-award documents for two of the long-term effort TOs, and working on the award decision on the third long-term effort TO. This means GSA has, at the time of issuance of this bridge TO, all documents necessary to finalize the three (3) TO awards in support of all clients that will utilize this bridge. Having these documents in hand reduces the risk of delays and provides assurance that the bridge TO is truly a temporary measure and that a long-term TO will be issued in the very near future.

7) A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made

The portion of this TO that supports IA/MA services on behalf of the AFLCMC Special Access Program office was competed as ID07200015. The solicitation closed on December 4, 2020 and multiple offers were submitted. The task order evaluation team is currently evaluating all offers.

The portion of this TO that will support IA/MA and LCMP-IDE services on behalf of the T-6 & C-130 is ready to issue for solicitation to BAH on a sole-sourced basis based upon proprietary aspects of the LCMP-IDE system.

The portion of this TO that represents KC 135 Tanker Support was issued to BAH on a sole-sourced basis based upon proprietary aspects of the LCMP-IDE system. The proposal was received and is currently under evaluation.

The short base PoP for this BTO represents the shortest time possible to enable GSA and the subclient agencies to complete their evaluation of the long-term TOs, coordinate award announcements, host kick-off meetings and allow transition time, without incurring a break in services. The option period was added so that the Government may utilize this bridge TO to continue to meet the subclients’ requirements and to allow GSA flexibility to respond to unknowns. The option will not be issued unless justified and necessary.

8) The Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief.

The Contracting Officer’s signature on the Signature/Approval page evidences that she has determined this document to be both accurate and complete to the best of her knowledge and belief.

9) Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for an exception to fair opportunity) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

See Technical Representative’s signature on Signature/Approval page.

10) Written determination by the approving official that the noted exception above applies to this order.

The Contracting Officer’s statement and signature on the Signature/Approval page evidences that she has determined that the statutory authority for the exception noted in section 4 applies to this task order.

SIGNATURE/APPROVAL ROUTING

Task ID# ID07210013

* Technical Representative’s Certification: By signature below, I state that I have read, understand, and agree with the technical information/representation made herein. I have provided the Agency and site specific technical information expressed herein, which is current and accurate to the best of my knowledge.

Technical Representative Date

By signature(s) below, I state that I determine the statutory authority as cited herein and expressed in FAR 16.505(b)(2)(i)(A) applies to this justification, and the justification is hereby approved on its merits as noted.

Technical information was presented as being accurate and complete as received from the client and was fully relied upon to document the request for an “Exception to Fair Opportunity,” as described herein.

Contracting Officer’s Certification/Approval:

Name Date

Branch Chief, Assisted Acquisition Services Coordination/Review/Approval:

Date

*Legal Counsel Review/Approval:

Acting Director, Assisted Acquisition Services Coordination Review/Approval:

13 January 2021

Competition Advocate Coordination Review/Approval:

Certificate Of Completion Envelope Id: 343CC27716194D92BD7F69D9245C73FD Status: Completed Subject: Please DocuSign: 04 ID07210013 Exception to Fair Opportunity Final Mellott signed.pdf Source Envelope:

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