JA 20026 FBO_Redacted.pdf

UNITED STATES MARINE CORPS

MARINE CORPS SYSTEMS COMMAND

2200 LESTER STREET

QUANTICO, VIRGINIA 22134-6050

Code: CT-2.4

J&A Number: 20,026

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity

Marine Corps Systems Command Portfolio Manager Supporting Establishment Systems Program Manager Customer Support and Strategic Sourcing 2200 Lester Street Quantico, VA 22134-6050

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

This is an Exception to Fair Opportunity acquisition to procure Public Key Infrastructure (PKI) operational support for the Marine Corps Cyber Operations Group (MCCOG). This procurement will use the General Services Administration’s (GSA) Alliant 2 Government-wide Acquisition Contract (GWAC) under an urgent need for services exception to the fair opportunity procedures, contained in Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(A).

The proposed action is to award a sole source task order to Smartronix, Incorporated (Smartronix) 44150 Smartronix Way, Hollywood, MD 20636.

3. Description of Supplies/Services

Public Key Infrastructure (PKI) is a set of roles, policies, hardware, software and procedures needed to create, manage, distribute, use, store and revoke digital certificates and manage public-key encryption. The purpose of PKI is to facilitate the secure electronic transfer of information for a range of network activities such as e-commerce, internet banking and confidential email. It is required for activities where simple passwords are an inadequate authentication method and more rigorous proof is required to confirm the identity of the parties involved in the communication and to validate the information being transferred.

The proposed contract action is to procure PKI operational support services for the MCCOG. Specifically, these services unexpectedly terminated1 the order for convenience effective 31 October 2019. HHS has not responded to numerous requests to transfer administration responsibilities of the current task order to the Marine Corps. As such, without this expedited action, a lapse in service would be unavoidable.

A lapse in PKI operational support for MCCOG will have a tremendous negative impact as the United States Marine Corps (USMC) will not be able to meet mandatory Department of Defense (DoD) PKI implementation requirements, nor will the USMC be able to provide PKI support across the Marine Corps Enterprise Network (MCEN).

Awarding an order to Smartronix utilizing an exception to fair opportunity will mitigate these risks.

5. Determination of Fair and Reasonable Cost

The Contractor has agreed to price this task order consistent with the pricing in the fourth option year of the terminated effort. Although the HHS Contracting Officer already determined the initial pricing to be fair and reasonable at the time the initial contract was competitively awarded by HHS, the MCSC Contracting Officer will further ensure the quoted price for this proposed order is fair and reasonable by comparing the pricing on the current task order to established pricing on the GSA Alliant 2 GWAC, as well as other commercially available pricing for similar support services.

1 HHS notified the Contractor on 25 Oct 2019 that it was terminating the contract for convenience only five days later on 31 Oct 2019. Neither the end user customer (MCCOG), nor MCSC was contacted directly by HHS.

6. Description of Market Research Conducted

A synopsis for this action was not posted per FAR 5.202(a)(6).

No other sources were identified as the agency need for the supplies or services is so urgent that providing for a fair opportunity would result in unacceptable delays. Market research was not conducted with this procurement due to the urgency; however, market research will be conducted to inform the next procurement of PKI operational support for the MCCOG.

7. Other Facts Supporting the Justification

8. Actions to Remove Barriers to Future Competition

Marine Corps Systems Command is currently conducting market research to determine a strategy for a competitive re-procurement of PKI operational support for the MCCOG. Several options have been identified to provide competition including:

future utilization of the United States Navy (USN) Seaport vehicle, competition among all GSA Alliant 2 GWAC contract holders, or a full and open competition. This task order, which is expected to last up to one year, represents the minimum amount of time required to plan and conduct a follow-on procurement for these critical support services.