25D5001-5003_JA_Redacted.pdf

UNITED STATES MARINE CORPS

MARINE CORPS INSTALLATI ONS COMMAND

3000 MARINE CORPS PENTAGON

WASHINGTON, DC 20350-3000

N REPLY REFER TO:

MCICOM-JA-26-006

ANNEX 1- CLASS JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

TI1e Contracting Activity is the Marine Corps Installations Command (MCICOM) Headqua11ers (HQ) Contracting located in Arlington, VA.

2. Description of the Action Being Approved.

TI1e actions being approved are for the non-competitive award of modifications to three of the MCI COM Professional Services Support (PSS) Multiple Award Indefinite-Delivery/Indefinite-Quantity (IDIQ) contracts to increase the total shared maximum ordering ceiling for Lot 1 (Unrestricted). TI1ese actions are being approved on a sole source basis m1der the authority of 10 U.S.C. § 3204(a)(l), only a limited number of responsible sources. Authority to act m1der this class justification expires on 31 January 2028 or whenever the shared maximum ordering ceiling for Lot 1 is exhausted.

3. Description of the Se1vices.

TI1e MCICOM PSS vehicle is a pa11ial small business set-aside Multiple Award Contract (MAC) for the acquisition of various professional services. TI1e base IDIQ contracts were competitively awarded with a five-year ordering period from 6 November 2024 through 5 November 2029. TI1e vehicle is comprised of two lots that divide specific task areas between three large businesses (Lot 1 Unrestricted Tasks) and seven small businesses (Lot 2 Set-Aside Tasks), as shown below.

LOT TaskArt'a PWS

LOTl

Unresnicted Tasks

LOT2

Set-Aside Tasks

Task Area 2 - Installations Communications Prol!ram Suooort 4.2 Task Area 3 - Operations Support 4.3 Task Area 7 - Facilities Support 4.7 Task Area 8 - Infonuation and Task Management Sunnort 4.8 Task Area 1 - Logistics Suooort 4.1 Task Area 4 - MCI COM Defense Program Review Initiative (DPRI) Suooort 4.4 Task Area 5 - Planning Suppo11 Task Area 6 - Government and External Affairs Support

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4.5 4.6

Controlled by: DON, USMC, I&L HCA

Controlled by: MCICOM HQ Contl'acting CUI Category(ies): PROCURE Limited Dissemination Control: DL ONLY

POC:

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Navy Marine Corps Acquisition Regulation Supplement

MARCH 2026 (Change 26-03)

LOT Contract 1D10 Contract Holder M9549425D5001 Booz Allen Hamilton Inc

LOTl M9549425D5002 Concunent Technologies Corp Large Business

M9549425D5003 KPMGLLP

M9549425D6001 Bowerv Solutions M9549425D6002 KSA Inte!!ration

LOT2

M9549425D6003 Peridot Solutions M9549425D6004 Professional Solutions Delivered

Small Business M9549425D6005 Si!!Ilificance M9549425D6006 Starlo Innovation M9549425D6007 Vect:rona-ITA Solutions II

This class Justification and Approval pertains only to Lot 1 (Unrestricted Tasks).

During performance, MCICOM identified a critical need for additional ceiling capacity within Lot 1 due to an unanticipated surge in high-priority requirements. Specifically, significant shifts in the U.S. Marine Corps operating environment and new Department of War· (DoW) priorities-namely the enterprise-wide focus on Facility-Related Control Systems (FRCS), the 2030 Barncks Initiative, and the allocation of a surge of funding anticipated in fiscal year· (FY) 2027 and beyond to support Future Years Defense Programs (FYDP}--have accelerated the consumption of the existing Lot 1 ceiling. The magnitude and timing of these initiatives, which now account for over 55% of the cunent ceiling, were impossible to predict when the original Independent Government Estimate (IGE) was established. Initial projections based on historical data estimated an annual burn rate of approximately $32M across both Lot 1 and Lot

2. However, new DoW-level directives have resulted in an actual bum rate of over $96.SM in the first 18 months-a 202% increase over planned estimates.

The proposed modifications do not extend the time period of the contracts. The ceiling increase will apply only to the remaining IDIQ ordering period, which concludes on 5 November 2029.

Operation & Maintenance (O&M) funds will be used for these requirements. The estimated value of the ceiling increase for Lot 1 is $96,718,238.12. This modification will increase the total shar·ed maximum ordering ceiling for Lot 1 from $101,427,376.71 to $198,145,614.83. The ceiling for Lot 2 remains unchanged.

The proposed ceiling increase is based on the revised IGE, which reflects known requirements and projected future needs over the remaining ordering period. The estimate is supported by the calculations outlined below.

Historical Context:

Over the past 18 months of the Lot 1 PSS contract, the following task orders have been executed or ar·e cunently in progress:

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Task Order

M9549425F5004 M9549425F5005 M9549425F5006 M9549425F5007 M9549425F5008

Total Contract Vallll'

$ 11.302, 717.35 $ 15,790,242.00 $ 7.173,890.60

$ 7,504,019.64

*Denotes a requirement that is cwTently "in work" (fask Order). TI1is pending task order will not be awarded, unless the offerors value is below tlie IDIQ ceiling or the ceiling increase modification is fonnally approved and executed.

Independent Government Estimate (IGE) and Ceiling Calculation Methodology

TI1e Government requests a modification to increase the total ceiling of the Lot 1 PSS IDIQ contract from $101,427,376.71 to $198,145,614.83.

To calculate a realistic, fact-based ceiling expansion that ensures continuous mission suppo11 while preserving the statutory p eference for con etifo the ovenuuent utilized esf nates from MCICOM's :Ill• • � • inunediate exhaustion of the cunent ceiling and incorporates the unforeseen FYDP requirement. TI1is expansion also provides the necessary l 2-to-18-month administrative rnnway to conduct a full and open competition for a follow-on PSS IDIQ for FY29 and beyond.

TI1e IGE is built upon tluee distinct elements:

(1) Cunent Execution Baseline (Ceiling Exhaustion)

Since its award approximately 18 months ago, the Lot 1 PSS contract has experienced a 100% award-to-pr i tic al mission requirements. A warded and cunently "in-work" task orders total As a result, the cmTent $101M ceiling has been entirely exhausted, creating an immediate deficit that precludes the award of pending requirements.

(2) Discrete Fut1ue Requirements (FYDP-Aligned)

Tiie Government has identified major, out-of-cycle programmatic requirements that significantly exceed historical averages. Most notably, the ate (GF) requires

P-

Because these are specific, multi-year programmatic surges, they are estimated precisely based on programmed ftmding rather than historical averages.

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Vear Value

Total Cfilill IDCl'faSf $ 96 718 238.12

*While the fonnal lDIQ ordering period conch1des on 5 November 2029, the period of perfonnance for task orders executed prior to the ordering period's expiration may extend th rough FY3 l.

TI1ese critical task orders will be placed within the next 3-12 months. TI1e period of pe1fonnance for these orders is expected to exceed the 12-18 months required to award the replacement PSS IDIQ contract. Thisextended duration is necessary to enstu·e continuity of operations; transitioning to a new contractor mid project would cause severe dismptions and unacceptable delays to project completion. Any unanticipatedrequirements outside of this defined scope will be defened until the new PSS contract is awarded.

4. StaUJtocy Authoritr Penniuin� Other Uian full and oVen competition

10 U.S.C. § 3204(a)(l), Only one responsible source and no other supplies or services will satisfy agencyrequirements. TI1is authority extends, for DoD, to situations where only a limited number of responsible sources can satisfy agency requirements. Specifically, this action limits competition for the required services to the existing, qualified pool of awardees tmder the multiple-award Lot 1 PSS IDIQ contract, asonly these sources can meet Do W's urgent mission timelines for the continued provision of these highly specialized services without resulting in unacceptable delays and substantial duplication of cost.

5. Rationale Justifying Use of Cited Stanitory Authority.

TI1e statuto1y autho1ity applies because awarding a follow-on contract for the continued provision of highly specialized services would result in substantial dupliaction of cost to the Government that is notexpected to be recovered through competition and tmacceptable delays in fulfiJling the agency's requirement.While the Government acknowledges the substantial quantitative increase to the IDIQceiling, the nature of the professional suppo11 services remains stlictly within the competitively awarded scope of the Lot 1 Perfo1mance Work Statement (PWS).

Expanding the current ceiling to $198,145,614.83 is the only viable proctu·ement strategy to preventcritical mission failure. �)��� will prov� the near-term mission critical requirements to support ·rectorate ·�ision, and the Services Branch. This suppo11 is essential for responsibly allocating and monito1ing progress forMCI COM portion of the $1.5 trillion general investment nm.vs://www.war.gov/News/Releases/Release/Article/4466038/department-of-war-releases-the presidents-fiscal-year-202 7-bud getQ.

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This situation is ftmdamentally driven by an lmanticipated smge in the volume and operational tempo of requirements. This accelerated consmnption of the ceiling has manifested through three primary factors:

• Emergent, High-Value Requirements: New DoW p1i01ities have resulted in large-scale, urgent task orders that were impossible to fully predict when the original IGE was established. For example, two task order Information Officer's (CIO) initiative for FRCS accOlmt for a combined of the ce�). Additionally.projects aligned to Banacks 2030 have resulted in a substantial need from. totaling-not including the requirement for the Funu·e Years Defense Budget).

• Structural Ceiling Misallocation: Toe initial ceiling allocation between Lot 1 (Large Business) and Lot 2 (Small Business) was based on an analysis of small business capabilities in certain task areas, rather than the projected dollar value of the work that would align to each Lot.

Furthermore, the removal of Task Area 1 (Program Management) from the scope dming the draft RFP process eliminated approximately $8M of ceiling that was originally planned for Lot 1. Toe combination of these factors resulted in a Lot 1 ceiling that was insufficient for the high-value, ente1p1ise-level tasks it was designed to support.

• Civilian Workforce Deficits: Secondary to the FYDP needs, the Defened Resignation Program (DRP) has resulted in a significant loss of Government employee support in muuerous MCICOM directorates. These positions cannot be backfilled due to billets elimination. While there are some efforts to fill vacancies, the lead time necessa1y to secure exemptions to the hiring freeze, onboard a federal employee, and overcome the learning curve of a new position requires 12 to 18 months. Therefore, contractor suppo1t is the only viable means of sustaining mission requirements.

Given this context, the following justifications apply:

Unacceptable Delays in Fulfilling the Agency's Requirements (FAR 6.103-l(c)(2)(ii))

If the Government were to execute a new, foll and open competition for a parallel IDIQ vehicle to cover this $96. 7M requirement, the estimated length of delay is approximately 12 to 18 months. This estimate is de1ived from standard Procmement Administrative Lead Time (PAL T) timelines for establishing a new $100M+ Multiple Award Contract (MAC), which includes requirements development, market research, solicitation, evaluation of complex technical proposals, and potential protest periods.

A delay of this length is prohibitive and lmacceptable. Toe current ceiling is nearly exhausted, and waiting approximately 18 months for a new vehicle would severely disrupt the execution of filnu-e needs and de�rade onoojnf operations at MCICOM HQ, resulting in mission failure. The emergent r

FYDP requirement represents a non-discretionary, immediate-need Inission expansion. Attempting to sever this requirement and compete it on a new standalone IDIQ dming the immediate FY27 smge would result in lmacceptable delays of 12 to 18 months, stalling DoW facility modernization effo1ts.

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Navy Marine Cor ps Acquisition Regulation Supplement

The incumbent contractors currently possess the established cleared personnel, facility clearances, and integrated administrative infrastructure required to absorb the FY27 programmatic surge. Intem1pting these c1itical processes while a new contract is solicited is not viable.

Subs tantial Duplication of Cost (FAR 6.103-l(c)(2)(i))

Competing a new vehicle to supp011 the remaining scope would duplicate significant administrative costs, and resources already expended by the Government to establish the ctment MAC. The existing pool of three Lot 1 contractors is already vetted, possesses the required facility clearances, and hold the instinitional knowledge necessary to seamlessly execute these requirements.

Transitioning the immediate requirements to a new vendor pool would result in an estimated $2.85M in duplicated costs. This represents a 60-day phase-in/phase-out transition overlap ($2.SM), the cost and schedule impact of re-processing personnel and facility clearances ($1 SOK), and an estimated 2,500 Government labor hours ($200K) required to develop a new requirements package, a new solicitation, conduct source selection, and award a new IDIQ over an 18-month PALT.

TI1is substantial cost is not expected to be recouped through a new competition, as the ClllTent ceiling rates were established through foll and open competition and deemed fair and reasonable. Expanding the existing vehicle is necessary to support the immediate FY26/FY27 surge while simultaneously providing the administrative timeline required to develop and compete a comprehensive follow-on acquisition over the next 12 to 18 months.

6. Desc1iption of Eff011s Made to Solicit Offers from as Many Offerors as Practicable.

Market Research: Extensive market research, including a Request for Info1mation (RFI) and Sources Sought Notice (SSN), was conducted p1ior to the award of the base IDIQ contracts, which resulted in a competitive award to the three Lot 1 prime contractors.

DFARS PGI 206.103-170(d) requires the Contracting Officer to post an RFI or SSN when utilizing the authority at FAR 6.103-1 . However, this requirement may be waived by the Head of the Contracting Activity (HCA) or a designated General/Flag Officer or Senior Executive Se1vice (SES) member. A waiver for this requirement is included in the contract file.

Market capabilities for this scope of work are already well-documented and tmderstood based on the recent competitive award of the base IDIQ. It is fonnally acknowledged that industry possesses a robust capability and capacity to perfo1m these professional suppo11 seivices in the targeted areas, specifically:

Task Area 2 Installations Communications Program Suppo11

Task Area 3 Operations Support

Task Area 7 Facilities Support

Task Area 8 Info1mation and Task Management Support

Issuing a new RFI or SSN at this time will not yield any new market intelligence that alters the justification for this acquisition. As detailed in Paragraph 5, seeking alternative sources now would result in tmacceptable delays and a substantial duplication of costs. Consequently, conducting ftuther

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market research would only stall the procurement process and risk a break in mission-critical services for MCICOM.

The Government considered the use of other existing Government-Wide Acquisition Contract (GWAC) and agency-specific vehicles that could potentially meet MCICOM’s customer base. The following alternatives were deemed not viable:

General Services Administration One Acquisition Solution for Integrated Services (OASIS +).

While this vehicle contains both the vendor base and applicable NAICS codes, the associated procurement lead time is approximately 365 days per MCICOMBul 4200. This lead time does not include the time required to develop a procurement ready package (e.g., acquisition strategy, source selection, DD2579). As these urgent requirements must be awarded in time to support late FY26 planning, this delay is unacceptable.

Navy SeaPort-NxG. This vehicle was also considered; however, due to the commercial nature of these professional services and the associated lead time for order placement, it was not a viable alternative for meeting this urgent need.

Leveraging these alternate contact vehicles would introduce substantial administrative delays, preventing the timely execution critical services.

As detailed in Paragraph 5 above and the associated waiver, it is not practicable for any company other than the existing Lot 1 MAC holders to absorb this immediate surge in requirements. Onboarding a new vendor pool would result in unacceptable mission delays regarding the planned acquisitions and substantial duplication of administrative costs.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined the anticipated cost to the Government of the services covered by this J&A will be fair and reasonable. This determination is based on the fact the underlying IDIQ contract rates were previously established through full and open competition and determined to be fair and reasonable at the time of award. These rates establish ceiling labor rates for all future task orders issued under this increased ceiling. Further, all future task orders will be competed among the three Lot 1 prime contract holders. This continuous competition will ensure downward pressure on pricing, as offerors will be incentivized to propose rates below the established ceiling rates to win each task.

8. Actions to Remove Barriers to Future Competition.

To remove barriers for future acquisitions of these services, the Government plans to re-compete the entire MCICOM Professional Services Support requirement prior to the expiration of the current contract's ordering period on 5 November 2029. The Government will incorporate the lessons learned from the unanticipated surge in requirements, such as the 2030 Barracks Initiative and FRCS support, to develop a more comprehensive PWS and IGE for the follow-on competition. This will ensure the subsequent contract vehicle is sized appropriately to support the full scope of anticipated mission needs.

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MCICOM-JA-26-006

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

Technical Cognizance and Requirements Cognizance:

te

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

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

DIRECTOR OF CONTRACTS APPROVAL

Upon the basis of the above justification, I hereby approve, as the Director of Contracts, the solicitation of the proposed procurement(s) described herein using other than full and open competition, pursuant to the authority of 10 U.S.C. 3204(a)(x)(provide appropriate citation).

Distribution List for DL ONLY Limited Dissemination Control

• MCICOM HQ Contrncting Personnel

• LB Personnel

• Procurement Team Personnel (to include but not limited to: Legal, Customers/Requirements Owners, Source Selection Personnel, Small Business Representatives)

• Any other individual designated by the KO

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