04 Limited Sources Justification - AMSG - Final 06-17-2025 redacted.pdf

Limited Sources Justification Advanced Management Strategies Group 89233120FNA400258 Page 1

LIMITED SOURCES JUSTIFICATION

NATIONAL NUCLEAR SECURITY ADMINISTRATION

OFFICE OF SECURE TRANSPORTATION

GSA NO. GS-00F-024CA ORDER NO. 89233120FNA400258

June 16, 2025

I. AGENCY IDENTITY AND CONTRACTING OFFICE

The United States Department of Energy/National Nuclear Security Administration’s (DOE/NNSA) Office of Secure Transportation (OST) plans to extend GSA Schedule GS-00F-024CA Order No. 89233120FNA400258, which was awarded to Advanced Management Strategies Group (AMSG) for administrative support services by using an authority for limited sources. The contracting activity is the NNSA Office of Partnership and Acquisition Services, Contracting Operations Division (NA-PAS-31).

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

The purpose of this action is to modify Order No. 89233120FNA400258 to extend the administrative support services currently being provided by AMSG, 3800 Fettler Park Dr, Suite 201, Dumfries, VA 22025-2045, for up to three months, beginning August 17, 2025, through November 16, 2025, with a one-month guarantee and two (2) one-month options. The current Order expires August 16, 2025. A ceiling increase will be needed for this action. The total anticipated value of this Order extension is approximately $736,679.87. The extension will enable the Government to continue services while the follow-on Order is resolved based on a post-award bid protest by AMSG at the U.S. Court of Federal Claims.

III. DESCRIPTION OF SUPPLIES AND/OR SERVICES

OST is responsible for the safe and secure transportation of the Nation’s nuclear weapons, nuclear weapon components, and special nuclear materials throughout the continental United States. This mission requires contracted administrative support services to maintain operational continuity, continuing regulatory compliance, and providing mission-critical functions for the OST, to include daily travel and procurement of services and equipment to support training missions and national security nuclear transportation missions for the nuclear enterprise. This Order provides Federal Agent travel support and timekeeping support, OST budget and staffing/administrative support, and a substantial portion of procurement support. Elimination of these essential functions will have a direct and immediate effect on OST’s ability to support Federal Agents as they execute secure transport missions involving nuclear weapons and special nuclear material.

To carry out its mission, OST operates three Federal Agent Operations Commands:

Advanced Management Strategies Group 89233120FNA400258 Page 2

(1) Agent Operations Western Command, located in Albuquerque, New Mexico;(2) Agent Operations Central Command, located in Amarillo, Texas; and (3) Agent Operations Commands Eastern Command, located in Oak Ridge, Tennessee. OST also operates a primary Training Command (TRACOM) located at Fort Chaffee, Arkansas.

IV. LIMITED SOURCES AUTHORITY

The statutory authority permitting limiting sources as implemented by the Federal Acquisition Regulation (FAR) is Subpart 8.405-6(a)(1)(C) which allows the agency to limit sources on a proposed order or BPA exceeding the micro-purchase threshold where “In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.”

As relevant here, not only is this Order extension necessitated because it is based on a direct result of a Pre-Filing Notice dated April 17, 2025 to the U.S. Court of Federal Claims (COFC) by AMSG challenging the award decision pursuant to DOE/NNSA Solicitation No. 89233124QNA000363 and follow-on Order

89233120FNA400258,0F

1 this Order extension is also a logical follow-on in accordance with FAR Subpart 8.405-6(a)(1)(C) as the new work is for the continued administrative support that is imperative to maintaining operational continuity, regulatory compliance, and mission-critical functions-including payroll processing, budget analysis, procurement, and document control-while directly supporting the Office of Chief of Staff, the Office of Program Integration, and the Office of Training Resources.2 Collectively, these critical and time-sensitive administrative support functions fulfill the essential role of ensuring and maintaining the safe and secure transportation of nuclear weapons and special nuclear materials, without which national security, workforce efficiency, and resource management would be severely compromised. Therefore, at this time, awarding to another source (apparent awardee) is likely to result in disruption to the administrative services, including substantial duplication of costs to the Government that is not expected to be recovered through competition if the COFC issues a decision sustaining AMSG’s protest which will also result in unacceptable delays in the transition of the administrative support services. Accordingly, NNSA has determined that it is in its best interest to minimize its risk by keeping the core administrative functions and services intact with this temporary extension for up to three months while the protest is resolved by COFC.

In this case, on April 25, 2025, the assigned Department of Justice (DOJ) Trial Attorney representing DOE/NNSA, provided the Court the requested information stating DOE/NNSA would exercise its final option for AMSG’s contract covering the period of

1 AMSG v. US, Inc., Case No. 1:25-cv-00695, filed April 17, 2025.

2 AMSG v. US, Inc., Case No. 1:25-cv-00695, filed April 17, 2025.

Advanced Management Strategies Group 89233120FNA400258 Page 3

June 17, 2025 – August 16, 2025, to litigate a motion for preliminary injunctive relief.

This was based on DOE/NNSA’s agreement to do a voluntary Stay of Performance to obviate the need to litigate a motion for preliminary injunctive relief from AMSG. On April 30, 2025, the Joint Status Report (JSR) and Scheduling Order was submitted to the COFC meeting the deadline set by the Court. Accordingly, following the Status Conference, both parties, Plaintiff (AMSG) and Defendant (DOE/NNSA) decided to move forward with merging supplementation of the Administrative Record and Motion for Judgement on the Administrative Record (MJAR) briefing with a voluntary Stay of Performance to include an additional three months after August 16, 2025. The three-month timeline was derived from a tentative order schedule with proceedings starting May 9, 2025 – June 26, 2025, with oral arguments following as determined. The three months would be executed as a bridge contract to allow month-to-month options to be exercised continuing performance under AMSG’s contract until the Court issues its decision.

This current requirement (Order 89233120FNA400258) was competed among the TEPS II BPA holders and awarded to AMSG. The work that will be performed under this extension is a continuation of the services provided by AMSG to DOE/NNSA/OST under Order 89233120FNA400258.

V. CONTRACTING OFFICER DETERMINATION OF BEST VALUE

The Contracting Officer (CO) has determined after considering the level of effort and the mix of skills available for the tasks needed, that the proposed action represents a reasonable total price and will be the best value for the Department consistent with FAR 8.404(d). The CO also determined that the estimated price of the Order extension is in line with the current contract prices which were competitively awarded.

VI. MARKET RESEARCH

Additional market research was not conducted for this action because the work is an extension of incumbent services during the pendency of a post-award bid protest.

VII. OTHER FACTS

The scope of this action is to extend OST’s administrative support services currently being provided by AMSG up to three months starting August 17, 2025 potentially through November 16, 2025, while awaiting the COFC Decision on AMSG’s Bid Protest Complaint against DOE/NNSA’s Order award under Solicitation Number 89233124QNA000363. The anticipated three months extension will be exercised on a month-by-month basis awaiting the COFC decision.

VIII. STEPS TO FOSTER COMPETITION

As discussed under paragraph VI, the anticipated three-month extension is to avoid a gap in services while waiting on the outcome of the Bid Protest.

Advanced Management Strategies Group 89233120FNA400258 Page 4

IX. TECHNICAL OR REQUIREMENTS PERSONNEL CERTIFICATIONS

Acquisition Initiator/Technical Representative:

I certify that the facts and representations under my cognizance, which are included in this justification, and which form a basis for this justification, are complete and accurate.

06/17/2025

Signature Date

X. CONTRACTING OFFICER CERTIFICATIONS

Contracting Officer:

I have reviewed this Limited Sources Justification and find it to be accurate and complete to the best of my knowledge and belief. Since this justification does not exceed $750K, this review serves as approval.

06/17/2025

Signature Date

ROMIL MENDOZA MENDOZA

Digitally signed by ROMIL

Date: 2025.06.17 07:49:25 -06'00'

Amber Doan Digitally signed by Amber Doan Date: 2025.06.17 08:05:12 -06'00'

06/17/2025