A02_JEFO 24-060_Section 508 Final_Redacted_v1.pdf

CUI/Source Selection Information (See Far 2.101 and 3.104)

Control No: 24-060 Contractor: SOS International LLC

Service: Section 508 Compliance Support/Cloud Migration Support Est Dollar Value:

JUSTIFICATION REVIEW DOCUMENT

FOR EXCEPTION TO FAIR OPPORTUNITY

Supply/Service: Section 508 Compliance Support/Cloud Migration Support

Authority: Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(C)

Prepared by: Jennifer Prior DSN: (520) 693-0020 Contract Specialist Email: jennifer.a.prior.civ@army.mil

Contracting Officer: Irene Kremer-Palmer DSN: (520) 693-1191 Contracting Officer Email: irene.m.kremer-palmer.civ@army.mil

Reviews: I have reviewed this justification and find it adequate to support an exception to fair opportunity.

Controlled by: Army Controlled by: HQDA OCIO ESA CUI Category: Source Selection Limited Dissemination Control: FED ONLY

Contractor: SOS International LLC

Department of the Army Justification for Exception to Fair Opportunity

Under Multiple Award Indefinite Delivery Contracts

1. Contracting Activity: U.S. Army Contracting Command – Rock Island (ACC-RI), Rock Island Arsenal, Rock Island, IL 61299-8000.

2. Description of Action: Headquarters Department of the Army (HQDA) Office of the Chief Information Officer (OCIO), U.S. Army Enterprise Services Agency (ESA), Information Technology and Compliance Directorate (ITCD) requests a firm-fixed-price modification to task order W519TC24F0114 with SOS International LLC (SOSi). ACC-RI will execute this action against the Computer Hardware Enterprise Software and Solutions (CHESS) Information Technology Enterprise Support – 3 Services (ITES-3S) Indefinite Delivery Indefinite Quality contract W52P1J-18-D-A042. ACC-RI projects award for and will obligate fiscal year , Operations and Maintenance, Army, and Research Development and Test Evaluation funds. An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d)(i)(B). Additionally, this acquisition is covered under the ITES-3S program level acquisition plan.

3. Description of Supplies/Services: SOSi was awarded task order W519TC24F0114 in to provide ESA IT Applications Management and Support Services.

The scope of this task order encompasses technical, analytical, system/network/Local Area Network database, administration, application programming, information security, documentation analysis, data entry, digitization, and infrastructure sustainment support for execution of the Army Records Information Management System (ARIMS). This includes the planning, creation, implementation and maintenance of ARIMS databases and report generation. The scope also entails the interoperability and maintenance of ARIMS Family of Operations records management and information technology systems.

HQDA OCIO ESA ITCD has a requirement to add Cloud Migration Support to support the cloud migration initiatives, as well as Section 508 Compliance Support to support the Army-wide Section 508 program initiatives that were not originally included on W519TC24F0114 (and subsequently not staffed by SOSi) but are required to comply with Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d).

The Government anticipates that to achieve these increased tasks, SOSi will require additional positions for Cloud Migration Support, likely comprised of SharePoint Developer and Customer Support IT Specialist, to support the cloud migration

Contractor: SOS International LLC initiatives, which includes migration of the ARMIS system and its associated child systems to a cloud environment. This increase in scope will enable the timely decommissioning of the current data center within the next , in alignment with HQDA OCIO ESA’s strategic goals, as well as ensure adequate coverage for maintenance and any cloud environment

In HQDA OCIO ESA ITCD was assigned the Section 508 Compliance mission for the Army-wide Section 508 program and requested funding after the scope/requirements for the program were determined. Funding became available for increased scope of Section 508 support in . It is anticipated that the contractor will require Trusted Tester, Analyst, and Curriculum Developer, to support the Army’s Section 508 program; those responsibilities are defined below. The contractor will be responsible for testing Information and Communication Technology components, providing analysis on compliance, and developing training curricula to ensure that all systems and documents meet the required accessibility standards to comply with Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d.).

Section 508 Trusted Tester: Section 508 Trusted Tester is responsible for evaluating IT products and services to ensure compliance with Section 508 of the Rehabilitation Act. This position requires a minimum of three years of experience in accessibility testing. This position conducts manual and automated Section 508 compliance testing on Army-wide IT systems, applications, and content that are overseen by the current task order. Section 508 Trusted Tester ensures compliance with all applicable standards such as Web Content Accessibility Guidelines which has 2.0, 2.1, and 2.2 versions, and Portable Document Format Universal Accessibility; and develops and documents detailed test plans and procedures for accessibility evaluation, ensuring alignment with Army and federal guidelines. Section 508 Trusted Tester prepares and submits comprehensive test reports that include detailed findings, remediation recommendations, and verification of fixes for non-compliant issues. Section 508 Trusted Tester works closely with the other contracted developers, designers, and ESA program managers to guide on remediating accessibility issues, including offering expert advice on best practices for accessible design and development. Section 508 Trusted Tester is required to submit a monthly report detailing the number of tests conducted, compliance status, issues identified, and remediation progress.

Section 508 Analyst: The Section 508 Analyst is responsible for analyzing, reviewing, and providing expert guidance on IT products and services to

Contractor: SOS International LLC ensure compliance with Section 508 standards. This position requires at least two years of experience in Section 508 analysis. This position will be required to evaluate IT products and services to determine their compliance with Section 508 standards; and provide expert analysis on the accessibility of software, hardware, and digital content. Section 508 Analyst creates and maintains detailed records of the accessibility evaluations, including compliance status, areas of concern, and recommended actions. Also provides input for accessibility audits and assessments when required.

Section 508 Analyst assists the ESA Section 508 Program Manager in developing and reviewing Section 508-related policies, guidelines, and procedures; and ensures all documentation is up-to-date and aligned with current federal regulations. This position may have to act as a liaison between the Army-wide Section 508 program and other departments, providing advice and guidance on accessibility issues. ESA Section 508 Analyst collaborates with IT teams to establish a method to address and prioritize accessibility barriers, offering guidance on remediation strategies and verifying implementation. ESA Section 508 Analyst provides a monthly report that summarizes analysis activities, the compliance status of the reviewed products, the issues that were identified, and resolutions or recommendations provided.

ESA Curriculum Developer: ESA Curriculum Developer is responsible for developing and maintaining training materials for Section 508 compliance and other IT systems/programs. This position requires two to three years of experience in curriculum development. ESA Curriculum Developer designs and develops training curricula for the Section 508 program and compliance, tailored to the needs of various Army-wide stakeholders, including developers, testers, and project managers. ESA Curriculum Developer creates instructional materials such as manuals, guides, e-learning modules, and presentation decks that are clear, concise, and engaging; and ensures that the content is aligned with Section 508 standards and best practices. ESA Curriculum Developer conducts an assessment to identify training needs across the organization and adapt the curriculum accordingly to ensure all relevant personnel are proficient in Section 508 compliance. ESA Curriculum Developer regularly updates training materials to reflect any changes in Section 508 guidelines, new tools, and best practices, which will ensure that materials remain relevant and effective. ESA Curriculum Developer supports the delivery of the training programs, along with the program managers, which could include coordinating with instructors, preparing training sessions, and ensuring the effective transfer of knowledge. ESA Curriculum Developer

Contractor: SOS International LLC

Service: Section 508 Compliance Support/Cloud Migration Support Est Dollar Value:

regularly collects and analyzes feedback from training participants to continuously improve the curriculum and delivery methods; and submits a monthly report that outlines the training materials developed or updated, the number of training sessions conducted, participant feedback, and proposed curriculum improvements.

The period of performance (PoP) for task order W519TC24F0114

HQDA OCIO ESA ITCD requires a modification to the task order so the Section 508 Compliance Support/Cloud Migration Support starts in of the base year; additionally, HQDA OCIO ESA ITCD requires Section 508

Compliance Support throughout the remainder of the task order while Cloud Migration Support . This proposed action does not extend the PoP and does not include any additional option provisions. For the Section 508 Compliance Support, HQDA OCIO ESA ITCD estimates a value of , based on the Independent Government Estimate (IGE), for the additional support as shown in the table below.

For the Cloud Migration Support, the additional support will be used in the base and option year one. HQDA OCIO ESA ITCD estimates a dollar value of based on the IGE, for the additional support as shown in the table below.

Contractor: SOS International LLC

The grand total increases for the base and options are shown in the table below.

4. Authority Cited:. FAR 16.505(b)(2)(i)(C). The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

5. Reason for Authority Cited:

Task order W519TC24F0144 was awarded on to SOSi on a competitive basis under CHESS ITES-3S. On , a request for proposal was issued to all CHESS ITES-3S contract holders. All were given a fair opportunity to be considered for the original award. This is the first use of this exception under the existing task order. The relationship between the initial order and the integration of Section 508 Compliance Support/Cloud Migration Support is a logical extension of the existing contract, as the initial task order includes the oversight and management of the ARMIS and its child systems. Section 508 Compliance Support is directly related to the existing scope of the initial task order as it enhances the current services by ensuring that all the information and communication technology components, systems, and documents managed under ARIMS meet federal accessibility standards. Cloud Migration

Contractor: SOS International LLC

Support is a workload increase on existing scope of the initial task order. Therefore, it is in the Government’s best interest for SOSi to provide the additional support required.

, HQDA ESA ITCD notified ACC-RI of potential requirements for Section 508 Compliance Support/Cloud Migration Support. ACC-RI directed HQDA ESA ITCD to begin market research at that time to determine the most appropriate acquisition strategy. , HQDA ESA ITCD provided funding and confirmed the official requirements. In the interest of economy and efficiency, SOSi, the current contractor on the ESA IT Applications Management and Support Services task order, must provide the additional support identified in paragraph 3 because SOSi is already familiar with the technical environment and requirements for the project, having provided related services (maintenance and support for all the systems that support ARIMS). By allowing SOSi to expand the Section 508 resources, there will be a more efficient process for training and supporting end users and other team members as SOSi can develop a tailored curriculum that aligns with both Section 508 standards and the existing system architecture. Additionally, layer of complexity; having SOSi provide additional resources helps ensure the transition to cloud-based systems is aligned with Section 508 compliance from the outset as SOSi would be able to manage both processes concurrently, preventing costly and time-consuming retrofitting after cloud migration is complete. The seamless integration of these services under SOSi will allow the Army to meet its Section 508 obligations without any delay in service and meet the data center migration schedule.

Attempting to award the additional support to a separate contractor would not be economical or efficient. If the Section 508 Compliance Support/Cloud Migration Support cannot be acquired under the existing task order, a separate task order would have to be solicited.

Contractor: SOS International LLC

6. Market Research:

In , HQDA OCIO ESA ITCD analyzed the contract holders on CHESS ITES-3S including the that provided proposals for the initial order. In addition, a request for information was posted on CHESS ITES-3S on for days to gather information on contractors, in addition to SOSi, capable of providing the required additional support.

expressed interest in the requirement. An analysis of the ITES-3S contractor responses revealed that had the services, capabilities, and experience necessary to meet the requirement; additionally, other contractors could potentially meet the requirement. While there are contractors other than SOSi who can perform the required services, as discussed in paragraph 5, SOSi is the only contractor capable of providing the Section 508 Compliance Support/Cloud Migration Support in the interest of economy and efficiency.

7. Actions to Increase Competition: No specific actions to increase competition are planned for the remainder of the current task order. However, the Government will continue to conduct market research for any follow-on acquisitions to allow for competition to the maximum extent practicable.

8. Other Facts:

a. Procurement History

Contractor: SOS International LLC

Contract: W52P1J-18-D-A042, Order W519TC24F0114 Contractor: SOSi Award Date:

Competitive Status: Competed on CHESS ITES-3S

Contract Number: GS35F0011K, Order W15QKN-16-F-0084 Contractor:

Award Date:

Competitive Status: Competed on General Services Administration Federal Supply Schedule