F03_JA_Under_SAT_FAR_16_505(b)_Redacted_1.pdf

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

ORDERS OVER THE MICRO-PURCHASE THRESHOLD AND

UNDER THE SIMPLIFIED ACQUISITION THRESHOLD

AUTHORITY: FAR 16.505(b)(2)

140D0425F0261 Microsoft Unified Support

1. Contracting activity/agency. Department of the Interior, Interior Business Center, Acquisition Services Directorate, Division I, Branch IV, on behalf of the Business Integration Office (BIO).

2. Description of supplies or services required to meet agency needs. Microsoft support is required to operate the Financial and Business Management System (FBMS), Department's system of record for all financial and business management transactions. FBMS is critical for mission execution across all of DOI, including leadership priorities. Without this contract in place, the Department will be unable to get Microsoft support to address system outages or security incidents which could slow or even completely stop DOI's administrative operations. Contract number 140D0425F0261 was put in place to bridge the Microsoft support gap until DOI's Enterprise Unified Support Contract is available. It was expected that the enterprise-wide contract would be awarded in June 2025, but it has been delayed until September 2025. Therefore, three months of additional support is required to bridge service until the Enterprise contract is awarded. Microsoft will provide a credit to the new Enterprise contract for any support on this extension that goes beyond the start date of the new award. Contract number 140D0425F0261 has period of performance from February 28, 2025, through July 14, 2025, and the contract value is .

The Department is requesting additional support for the following period:

July 15, 2025, through October 12, 2025, estimated to be .

3. Identification of the limited source(s) to be solicited. The current contract was competed among authorized small business resellers on NASA SEWP. CounterTrade Products, Inc. was awarded the contract and will need to provide the additional support.

CounterTrade Products, Inc. (CounterTrade) 7585 W. 66th Ave.

Arvada, CO 80003

UEI CN4KSKX2UQY5

4. Reason for authority cited. The contracting officer has determined the circumstances of the contract action deem only one source reasonably available.

� FAR 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.

5. Rationale.

Support for this contract will expire on July 14, 2025. A larger enterprise-wide contract for this support is underway and is expected to be awarded by September 2025. Due to the short timeline, there is not time to conduct another procurement.

CounterTrade is currently providing the support and was awarded the contract on a lowest price technically acceptable basis. CounterTrade is the only company in a position to provide this continued support on this timeline. It is also unreasonable to bring on a new contractor when an enterprise-wide contract is being procured.

6. Market Research.

Market research was conducted January 2025 prior to the current award. Market research was conducted through NASA SEWP and found 105 available Microsoft Unified vendors of which 62 of them are small businesses. As a result of market research, the procurement was solicited on a brand name basis to authorized resellers on NASA SEWP in Group B, C, and D as a small business set-aside. Due to the short timeframe, CounterTrade is the only company in a position to provide the continued support. Given that CounterTrade was the lowest price at time of award and the timeframe for this extension is only a few months from when the award was made, it stands to reason that CounterTrade would still provide the lowest price.

Under the authority of FAR 16.505(b)(2), the undersigned hereby determines the circumstances of this contract action deem only one source is reasonably available as supported herein.

Approve

Heather Watroba, Contracting Officer

AQD

Concur

Stacy Zellers, Contracting Officer’s Representative

BIO

STACY

ZELLERS

Digitally signed by

STACY ZELLERS

Date: 2025.07.07 11:14:09 -04'00'

HEATHER WATROBA

Digitally signed by HEATHER

WATROBA

Date: 2025.07.07 11:28:53 -04'00'