1.5.1 Justification and Approval - TASS - FY24_Redacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. § 3204

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.3, the following facts and rationale justify the use of such authority:

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Office of Contract Operations (CG-912) Formal Contracts Division I, on behalf of FORCECOM, prepared this justification for other than full and open competition.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the action: Force Readiness Command (FORCECOM) requires continued support for Training and Analysis Support Services for six months to ensure continuity of services for instructional, training, and assessment support services for the U.S. Coast Guard. USCG intends to procure on a sole source basis.

(b) Name and address of the contractor:

Metris, LLC 3259 Progress Drive Orlando, FL 32826

(c) Type of action: Firm Fixed-Price Contract

(d) Estimated total value (including options):

Period Unit Price Total

Base Year

3 mo.

Option Year 1 1 mo.

Option Year 2 1 mo.

Option Year 3 1 mo.

Travel 1 ea.

Total

These services were previously awarded under contract number, 70Z02323CFFCT0001. The period of performance end date for that contract is February 27, 2024.

(e) Type of funding: Operations and Support funds

(f) Year of funding: Fiscal Year 2024

(g) Solicitation number: 70Z02324RFFCT0001

(h) Background information about the requirement: CG 9121-1 is currently procuring TASS services; however, the need for continued support is needed to meet mission requirements while ongoing competition for the follow-on acquisition is being completed. The six-month contract, consisting of a three-month base period and three one-month options, will potentially extend the current period of performance through August 27, 2024. The current period of performance ends on February 27, 2024.

3. Description of Supplies/Services.

Force Readiness Command’s (FORCECOM) focus is to deliver tailored, on-demand training and learning activities to promote modernized learning that maximizes the continuous growth of a mission ready total workforce ensuring the Coast Guard's workforce is prepared to execute the full range of their responsibilities. Training is the backbone of a mission ready total workforce framework designed to facilitate professional growth. Today, FORCECOM delivers best-in-class performance-based training that grows the Coast Guard workforce into technically proficient leaders. To maintain the Coast Guard's competitive advantage in a world becoming increasingly virtual, our legacy training must be transformed. Modernized Ready Learning represents the course correction necessary to execute that transformation. Our call to action is to deliver individually tailored, on-the-spot services that prepare our Coast Guard for the work of tomorrow. There are four inter-related priorities:

· Maximize training opportunities

· Modernize training delivery

· Tailor training programs

· Advance workforce resilience through training.

Modernized Ready Learning is a term that reaffirms a commitment from the Force Readiness Command to deliver tailored training, education, and experiential learning at the moment of need. Our goal is a modernized state-of-the-industry training system by 2030. Modernized Ready Learning is the heart of the Training Chapter within the Mission Ready Total Workforce Framework.

The U.S. Coast Guard is responsible for managing the training, education, and development programs to meet the needs of its active duty, reserve, and civilian workforce. The purpose of this contract is to obtain contractor instructional, training, and assessment support services for the U.S. Coast Guard. Contractor support services include performance analysis, instructional systems development (analysis, design, development, implementation, and evaluation), training support services and training delivery.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(a) implemented by the FAR Subpart 6.302-1 entitled “Only One Responsible Source and No

Other Supplies or Services Will Satisfy Agency Requirements.”

In accordance with FAR 6.302-1(a)(2)(iii)(B) and U.S.C. 2304(d)(1)(B)(ii), for DoD, NASA, and the Coast Guard, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result unacceptable delays in fulfilling the agency’s requirements.

5. Identification of Exception to the Buy American Act.

Not Applicable

6. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

Metris has been providing these highly specialized services to the USCG since 2017 under contract numbers, HSCG23-16-D-PFC999 and currently 70Z02323CFFCT0001. It would take a significant amount of time and resources to re-solicit to a new contractor and recruit proper staff to perform these highly specialized services. A transition period would be necessary to ensure the new offeror has expertise with the Coast Guard Training System Standard Operating Procedure (SOP)s.

Any interruptions in the FORCECOM’s instructional, training, and assessment support would severely impact the Coast Guard’s ability to prepare a Mission Ready Total Workforce. The services provided by this contract are instrumental to FORCECOM’s training capability and ability to effectively deliver required training programs for mission critical functions.

Specifically, delays could possibly result in untrained pilots leading to grounded aircraft or the inability for FORCECOM to continue to provide trained petty officers to their rating. If the J&A is not approved, the Coast Guard would be forced to prioritize mission readiness and these impacts could be detrimental.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

The USCG utilizes the Department of Homeland Security’s Acquisition Planning Forecast System (APFS) to notify industry of potential procurement opportunities as early as possible in the acquisition cycle. The AFPS Record for TASS, F2021053741, was published on April 27, 2021 to alert industry of this opportunity. A sources sought notice was posted to SAM.gov on August 31, 2022 informing the public of the Government’s intent to award an IDIQ contract as a set aside for Service-Disabled Veteran Owned Small Businesses (SDVOSB) IAW FAR 19.

The sources sought explained the FORCECOM support effort and requested interested parties provide a capabilities statement. Responses to the sources sought were received. Solicitation 70Z02322RFCT0001 was published to SAM.gov on November 9, 2022 and closed January 5, 2023. The current competition is in the evaluation phase and is projected to award NLT March 2, 2024.

This approved and redacted Justification and Approval will be made publicly available IAW

FAR Subpart 6.305(a), within 14 days after award.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The contracting officer determines that the anticipated price(s) will be fair and reasonable based on prior acquisition IAW FAR 15.404-1(b)(2)(ii).

9. Description of Market Research.

Market research began in November 2020 and concluded that there are numerous small businesses that fall under the NAICS code 611519. APFS F2021053741 was published April 27, 2021. A search on the Interagency contract directory resulted in 42 contracts that can be used, but none had remaining ceiling to accommodate the size of this effort. A search on SAM resulted in 15 capable vendors under NAICS code 611519. The DHS strategic source Human Capital and Training Solutions (HCaTS) contract vehicle was considered and appeared to be within scope of the work but lacked the flexibility needed by the program. In reviewing GSA, it was determined that a few small businesses may be able to provide the services but also lacked flexibility. This effort requires multiple annual task orders with requirements varying from year to year. TASS requires the flexibility to add new task orders and/or modify task orders when additional work is necessary.

USCG posted an RFI to SAM.gov and received 24 responses. Of those responses, the following were deemed capable by the technical office: 2 large businesses, 1 small business, 2 8(a) small businesses, 3 women owned small businesses, 1 HUBZone small business, and 5 service-disabled veteran-owned small businesses. Based on the largest response which includes the incumbent, it was determined that the government could achieve maximum competition from the Service-Disabled Veteran Owned Small Business (SDVOSB) socioeconomic class.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

None

11. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

A synopsis was issued on SAM.gov on 31 August 2022 requesting that parties express their interest in writing to the contracting officer. Five SDVOSBs responded.

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

The solicitation for subsequent effort was posted 09 November 2022 and closed 05 January 2023. This subsequent effort is being competed amongst SDVOSB for a five-year IDIQ contract and is anticipated to be awarded NLT March 2, 2024.

13. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Date

Contracting Officer

14. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Chief, Mission Support Branch FC-Tms

RECOMMENDED FOR APPROVAL

Contracting Officer

APPROVAL

Command Procuring Activity Advocate for Competition (CPAAC)