2026.05.18_PfM_J&A_Redact_Redacted.pdf

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SOURCE SELECTION INFORMATION - See FAR 2.101 and 3.104

JUSTIFICATION & APPROVAL

UNITED STATES TRANSPORTATION COMMAND (USTRANSCOM)

DIRECTORATE OF ACQUISITION (TCAQ)

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

Portfolio Management Support (PfM) HTC711-22-F-D072

Justification Control Number: 26-19

1. CONTRACTING ACTIVITY.

United States Transpo1tation Command, Directorate of Acquisition, IT Programs & Suppo1t Services Division (USTRANSCOM/TCAQ-D), 508 Scott Drive, Scott AFB, IL 62225.

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

The proposed action is a modification to task order HTC71122FD072 to add one (1) twelve month option period for PfM services for CST Co1poration (CST) to generate impact, optimize operations, and complete analysis for the development and sustainment of info1mation technology (IT) capability investments for USTRANSCOM and its components. The services provide capability owners and IT managers assistance during policy assessment, capability perfo1mance assessment, capital planning & investment, electronic governance management, Clinger-Cohen Act compliance assessment, investment process governance, compliance perfo1mance audits and assessments, info1mation systems process improvement, project management, IT strategic planning, technology assessments, cyber security documentation development, and po1tfolio management.

3. DESCRIPTION OF SERVICES REQUIRED TO MEET THE AGENCY'S NEEDS

(INCLUDING ESTIMATED VALUE).

TCJ6 requires ongoing PfM services to successfully manage the command's IT capability investments, maintain compliance with statuto1y and regulato1y requirements, and align with the command's strategic priorities. These services provide Chief Info1mation Officer (CIO), Chief Financial Officer (CFO), and Chief Operations Officer (COO) assistance; logistics and transpo1tation analysis; and capability-based portfolio management. The work covers all USTRANSCOM IT systems, programs, and initiatives (SPis) within the command's purview, regardless of the funding source. This task order integrates capability management activities for the USTRANSCOM CIO, CFO, COO, capability owners, and IT managers.

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Controlled by: USTRANSCOM Controlled by: Directorate of Acquisition CUI Catego1y/ies: PROCURE Limited Dissemination Control: FED ONLY

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SOURCE SELECTION INFORMATION – See FAR 2.101 and 3.104

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C5T Corporation has performed these services since 2022 under task order HTC71122FD072, a competitively awarded 100% Service-Disabled Veteran-Owned Small Business (SDVOSB) set-aside. The current period of performance includes a one-year base period and three one-year options ending on 30 September 2026. The added option period runs 1 October 2026 – 30 September 2027 at an estimated value of and includes Firm Fixed Price contract line items and a Time and Materials line item for travel.

4. IDENTIFICATION OF THE EXCEPTION TO FAIR OPPORTUNITY AND

SUPPORTING RATIONALE.

After a significant personnel shift resulting from the Deferred Resignation Program (DRP), USTRANSCOM performed a strategic realignment, transferring overarching Mission Area Management responsibilities—specifically the oversight of IT investments—from the COO to CFO. This reorganization requires a transition period for the CFO to establish, codify, and implement new governance workflows and operational procedures. For this reason, the Government is adding an option period on a sole-source basis to C5T Corporation as a logical follow-on to a previous order, in accordance with FAR 16.507-6(b)(3). This regulation permits such action in the interest of economy and efficiency when all potential offerors received a fair opportunity to compete for the original order. For reasons that follow, C5T is the only capable source to meet the immediate needs for continued PfM services.

The 12-month option period allows sufficient time to re-define the scope of the work under the new CFO structure, identify areas of responsibility, document all new requirements and deliverables, and establish performance metrics in advance of preparing for a new competitive solicitation. This process requires time for impacted personnel to develop a requirements package that reflects the new needs.

The lead time for competitive procurements of this scope and dollar value is estimated to be at least 12 months. Given the Government’s direction to overhaul the requirement, there is not sufficient time to compete the new procurement before 30 September 2026 without creating an unacceptable gap in service. C5T possesses the institutional knowledge, personnel, and infrastructure necessary for uninterrupted service. Introducing a new vendor without proper transition time risks system failures, data integrity issues, and operational disruptions.

Onboarding of another vendor during this interim phase would have severe and far-reaching consequences across USTRANSCOM, impacting compliance with legal mandates, stalling critical missions, and ultimately degrading the Command’s ability to successfully accomplish its global mission.

Specifically, a lapse in PfM services would directly prevent USTRANSCOM from meeting its statutory and regulatory obligations. Without C5T's continued sustainment, the Command faces several unacceptable risks:

Clinger-Cohen Act Violations: The contractor must gather and analyze data required for the annual CIO Statement of Compliance (Performance Work Statement (PWS) (Task tcvarejm Cross-Out tcvarejm Cross-Out tcvarejm Cross-Out

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SOURCE SELECTION INFORMATION – See FAR 2.101 and 3.104

2.3.1)). A service gap would result in failure to deliver this report, risking immediate suspension of IT funding authorities due to statutory non-compliance.

Cybersecurity Reporting and Oversight: The contractor must generate weekly and monthly Cybersecurity Compliance Scorecards (PWS, Task 2.3.1), informing leadership of the real-time cybersecurity posture of Programs of Record. A disruption would blind leadership to current vulnerabilities and directly violate the Federal Information Security Management Act requirements for continuous monitoring.

DoD IT Portfolio Repository (DITPR) Reporting: The contractor must monitor and validate data reported to the DITPR (PWS, Task 2.3.2). Failure to perform this function would result in flawed data being sent to the DoD CIO, degrading the accuracy of the overarching DoD IT budget and jeopardizing future USTRANSCOM funding allocations.

Furthermore, PfM is directly embedded in the command’s operational and strategic implementation. A service interruption immediately impacts the following :

Capital Planning & Investment Control Failure: The contractor’s assistance for the

Defense Business Council and Investment Review Board (PWS, Task 3) is the linchpin for justifying and securing funding. Halting this work would derail the upcoming budget cycle for all USTRANSCOM IT systems, delaying critical command-and-control modernization work by at least one full fiscal year.

Halt to Requirements Management Process: The contractor must contribute to the vetting of all new IT requirements (PWS, Task 3.1.1). A work stoppage would create an immediate bottleneck, halting the progress of new capabilities designed to stand by the warfighter and forcing the continued use of outdated, less capable, and less secure systems.

Loss of Portfolio Optimization: The contractor must maintain the IT Portfolio Optimization Presentation (PWS, Task 3.1.2), a comprehensive analysis used to identify and eliminate duplicative capabilities. A service gap would end this vital cost-saving analysis, allowing redundant and obsolete systems to consume critical funds.

The J6's process to redefine the PWS is a full-scale, multi-phase approach tied directly to the DoD’s Planning, Programming, Budgeting, and Execution cycle. A shorter duration would not allow sufficient time for a proper competitive procurement. The estimated timeline is as follows:

Months 1-3: Finalize PWS requirements based on the FY27 President’s Budget and

Program Objective Memorandum submissions—a process C5T is currently sustaining (PWS, Task 3.3.5). This guarantees the new requirement is accurately funded and aligned with strategic priorities.

Months 4-6: Conduct comprehensive market research and develop an acquisition strategy for a complex, multi-million-dollar requirement.

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• Months 7-12: Draft and release the solicitation, allow adequate time for industry to prepare high-quality proposals, conduct a thorough source selection evaluation, and provide for a sufficient b.'ansition period to the new awardee to prevent service disrnption.

5. DETERMINATION BY THE CONTRACTING OFFICER THAT ANTICIPATED

COST TO THE GOVERNMENT WILL BE FAIR AND REASONABLE.

The ContJ.·acting Officer will dete1mine price reasonableness by perfo1ming a detailed price analysis under FAR 15.404-l(b). The analysis will directly compare C5T's proposed price against historical pricing on task order HTC71122FD072 and the Independent Government Cost Estimate (IGCE). The ContJ.·acting Officer will apply additional price analysis techniques as wairnnted, document the findings in the Price Negotiation Memorandum, and finalize the modification only upon confoming the proposed price is fair and reasonable.

6. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION.

NIA

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.

During this option period, TCJ6 will finalize all critical PWS updates to establish a stable, mature requirements baseline-the foundation for full and open competition. The contJ.·acting activity will then start a comprehensive acquisition sb.'ategy, conduct market reseai·ch to identify all potential sources, and restore fair opportunity for the follow-on action.

8. CONTRACTING OFFICER'S CERTIFICATION.

I certify that the justification is accurate and complete to the best of my knowledge and belief.

KRAFT.LISA. ��r.ii1•1 f1 ---- Date: 2026.05.15 12:10:20

.QS'OO'

LISA A. KRAFT

ContJ.·acting Officer

9. TECHNICAL OR REQUIREMENTS PERSONNEL CERTIFICATION.

I certify that the supporting data which fo1ms a basis for this justification ai·e complete and accurate.

I OIi,., i,. <,; 1,. 1 r, ContJ.·acting Officer Representative

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10. WRITTEN DETERMINATION OF THE APPROVING OFFICIAL IDENTIFYING

THE CIRCUMSTANCE THAT APPLIES TO THE ORDER.

Based on the above cited justification, I hereby detennine the circumstance in FAR 16.507- 6(b )(3) applies to this justification for an exception to fair opportunity.

Acting Competition Advocate

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