Redacted_Bridge_Justification.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

AUTHORITY: FAR 16.505(b)(2)

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

This document is a Justification for an Exception to Fair Opportunity for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division I, Branch 2 and the Department of the Interior, Office of the Chief Information Officer (OCIO).

2. Nature and/or description of the action being approved.

This is an exception to fair opportunity action to award a sole-source logical follow-on of the requirement for Contractor support for the Information Management and Assurance Support (IMAPS) tasks which include:

Task Area 1: Risk Management and Information Security Continuous Monitoring (ISCM)

Task Area 2: Information System Security Officers and System Security Task Area 3: Records Management Task Area 4: Privacy Task Area 5: Freedom of Information Act (FOIA)

DOI maintains a robust and mature Information Technology (IT) infrastructure and provides advanced, highly functional, and continually improving technical services to support the business operations of DOI and its customers. To maintain and safeguard critical IT infrastructure, systems, and data; DOI provides a comprehensive set of information security support services that balance business needs with security risks while ensuring compliance with Federal regulations. These services are provided, in part, by IMAPS.

The current Task Order was competed on GSA 8 (a) STARS II Governmentwide Acquisition Contract (GWAC) among contract holders in Constellation II, Functional Area 4 and a Task Order was awarded to Spry Methods, Inc. against 8(a) STARS II contract GS06F0679Z. The current IMAPS Task Order expired on January 21, 2018.

This action will result in awarding a Labor-Hour Task Order to Spry Methods, Inc. for the estimated amount of .

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

The Department of the Interior, Office of the Chief Information Officer (OCIO) requires Contractor support in the following five Task Areas:

Task Area 1: Risk Management and Information Security Continuous

Monitoring (ISCM)

● Enter Plan of Action and Milestones (POA&Ms), received via email, into Cyber Security Assessment and Management System (CSAM) with a Weakness Completion Verification Form (WCVF) routed to the lead responder within 5 days of receipt.

● Schedule working sessions to ensure dates for completion are on target and to assist with recommending mitigation efforts, when needed.

● Process POA&Ms, received by the POA&M support desk, for further routing within 3 days of signature. Processing includes further routing for signature, or documentation updates, scanning, and filing in CSAM.

● Assist with the analysis and interpretations of risks associated with scan results as they pertain to individual systems within 5 days of receiving results.

● Creation and modification of Interconnection Security Agreements (ISA) documentation will be completed by provided deadlines for projects and Service Level Agreements (SLAs).

● ISA documentation for all customers to be reviewed and modified as necessary within 365 calendar days of previous update cycle.

Task Area 2: Information System Security Officers and System Security

● Incident response, as needed (includes Politicals forensics/support)

● Coordinate Incident Response with the agency System Owners (SO) to include all associated actions necessary to mitigate the risk to unit systems

● Prepare and coordinate Incident Responses with the agency Information

System Security Manager (ISSM) to include all associated actions necessary to mitigate the risk to unit systems.

● Computer investigations and forensics

● POA&M Review/Processing

● On a quarterly basis, update POA&M information in CSAM

● Assist in and/or prepare Weakness Completion Verification Forms

● Security architecture and engineering support

● Support security operations, troubleshoot, and report problems as needed.

● Respond to all after hour incidents.

Task Area 3: Records Management

● Create and maintain record disposition schedules for all offices within the Office of the Secretary (OS) and the Department including serving as liaison with National Archives and Records Administration (NARA) during the appraisal process. Accurately store and maintain records in the Department’s electronic records management system (eERDMS). Also administer the eERDMS system to securely and appropriately manage the Office of the Secretary’s electronic records.

● Assist OS (and Departmental) offices in preserving and maintaining records by performing a wide variety of standard records management practices, such as compiling inventories of records received and maintained (in any and all formats

– paper, electronic, graphic etc), removing duplicative or inactive material from files (for paper, electronic, or graphic records), securing confidential material, following legal holds or court orders and setting up more efficient retrieval systems for records.

● Assist OS (and Departmental) offices in identifying and maintaining Indian Fiduciary Trust records according to DOI standard and in accordance with any legal hold or court orders.

● Prepare OS and Departmental records for retirement either to the Federal Records Center or to the National Archives and Records Administration (for permanent storage).

● Prepare OS and Departmental records for destruction IAW all OS, Departmental, and NARA procedures, practices, standards and forms prior to records destruction.

Task Area 4: Privacy

● Provide Privacy Program Management services to the DOI Privacy Office in compliance with the Privacy Act of 1974, E-Government Act of 2002 and Office of Management and Budget privacy policy.

● Develop and update System of Records Notices (SORNs) and Privacy Impact Assessments (PIAs), and prepare related documents as needed from draft through publication, and provide comprehensive guidance to system owners and managers to ensure complete and accurate development of SORNs and PIAs.

● Monitor status of privacy compliance activities for systems in CSAM and ensure current privacy documents are posted, including SORNs, PIAs, and system privacy plans.

● Monitor OS/IBC system and program compliance with the Privacy Act and related Federal legal and policy requirements in accordance with the DOI Privacy Program Plan and Privacy Continuous Monitoring Strategy.

● Evaluate privacy controls and work with system owners and other officials to implement controls as part of the DOI risk management framework, to mitigate risk and protect privacy in accordance with Federal law and policy.

● Attend Privacy-related meetings and provide updates and support on topics or agenda items.

● Provide responses, comments and develop materials for privacy reviews and assignments, as required.

● Provide updates and reports as requested to include weekly status reports.

● Update DOI Privacy Office activities in tracking systems to capture all relevant information pertaining to SORNs, PIAs, reports, and other compliance activities, including surname, publication, comments, status updates, and next steps.

● Support and facilitate privacy training and awareness program.

● Support the Privacy Officer in any privacy compliance activity as required.

Task Area 5: Freedom of Information Act (FOIA)

● Acknowledge all FOIA requests using standard agency formats.

● Review all documentation received from OS, offices or the appellant for each letter accepted, to determine what additional documents must be gathered to enable the OS FOIA Officer to process the request or for Appeals Administrator to adjudicate the appeal.

● Accurately enter information about each letter into the appropriate FOIA Tracking/logging systems and into a manual log in a timely manner.

● Support the processing of FOIAs and administrative and legal appeals.

● Make all redactions necessary to all documents involving FOIA processing and/or appeals where legal issues of withholdings are involved, following guidance provided in the legal review.

● Draft the agency's response to FOIA requests and appeals, utilizing DOI standard language, and prepare them for signature and mailing.

The estimated amount of this requirement is .

4. Identification of the exception to fair opportunity (see 16.505(b)(2)) and the supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited. If the contracting officer uses the logical follow-on exception, the rationale shall describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value).

The original Task Order was competitively awarded under the authority of FAR

16.505. As cited in the exception FAR 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.”

Spry Methods’ personnel provide IMAPS support in all five Task Areas. The services provided help DOI provide a comprehensive set of information security support services that balance business needs with security risks while ensuring compliance with Federal regulations. Hence, given the amount of support provided by Spry Methods, it is clear a lengthy break in support services would negatively impact DOI. Furthermore, awarding a bridge contract to a Contractor other than Spry Methods could result in additional time needed for transition and would be inefficient given that a second transition period may be required in the subsequent competitive acquisition for IMAPS detailed in section 7.

The solicitation for the competed original Task Order was sent to all ninety-six (96) GSA 8(a) STARS II contract holders in Constellation 2, Functional Area 4 and seven

(7) quotes were received and thus all awardees were given a fair opportunity to be considered for the original order. Spry Methods’ quote was determined to be the best value to the Government. This determination was based on Spry Methods being the Vendor whose quote, in conforming to the Request for Quotation, provided the best overall value to the Government, technical and price considered. This rationale is the same for this requirement and thus, a sole-source award to Spry Methods for IMAPS is appropriate.

It is in the best interest of the Government to award a bridge GSA 8(a) STARS II Task Order to Spry Methods for a base period of 6 months. The bridge Task Order will only be utilized for the minimum amount of time until the competitive Task Order is awarded and a transition period is completed; if necessary.

5. A determination by the contracting officer that the anticipated cost to the

Government will be fair and reasonable.

The estimated amount for the full period of performance of the bridge award is

The Contracting Officer determines that the anticipated labor category rates will be fair and reasonable based on the fact that the original Task Order labor categories and rates provided by Spry Methods in their price quote were discounted from their GSA 8(a) STARS II rates and similar discounts are anticipated for the this award.

6. Any other facts supporting the justification.

All facts have been documented in other sections. There are no additional facts to be documented in this section.

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 Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division I, Branch 2 is preparing an Acquisition Plan and Request for Quotation to compete the IMAPS requirement on GSA 8(a) STARS II, Constellation 2, Functional Area 4. All awardees will be given a fair opportunity on the subsequent acquisition.

As stated above, the bridge Task Order will only be utilized until the competitive Task Order is awarded under GSA 8(a) STARS II GWAC.