31310023D0003 JOFOC FAIMIS.pdf

NRC JUSTIFICATION AND APPROVAL

Version Control Date: March 2026: – FAR references per RFO

Justification and Approval (J&A) For All Commercial/Non-Commercial Contract Actions U.S. Nuclear Regulatory Commission

☒FAR 6.103 Justification for Other Than Full and Open Competition (JOFOC)

Contracting Officer's Representative (COR) Name and Email John Howerton, John howerton@nrc.gov Title Program Office / Division Product or Service System Analyst OCFO/DOC Service

Requisition Number Award Date Delivery Date (Supplies)

Name and Address of Proposed Contractor

CGI Federal Inc 12601 Fair Lakes Circle GWAC Solutions Center Fairfax, VA 22022

Current Period of Performance Start Date

Current Period of Performance End Date

Total Estimated Contract Value (enter ONLY numbers, i.e., 12346) $52,000,000.00 02/01/2023 01/31/2028

Period of Performance Extension Start Date (If applicable)

Period of Performance Extension End Date (if applicable)

Proposed Funding Increase amount (if applicable)

$7,000,000.00

1. Nature and/or description of the action being approved.

Type of Action: ☐ New Award ☐ Follow-on Award ☒Ceiling Price Increase ☐ Extension

Type of Contract Vehicle:

☐Purchase Order ☐BPA, BPA Call against a FSS Contract/GSA Schedule ☐Task Order/Delivery Order against an NRC Contract or GWAC ☒Other __Indefinite Delivery indefinite Quantity (IDIQ) https://www.acquisition.gov/far/subpart-6.3

Description of Action:

The Nuclear Regulatory Commission (NRC) Office of Chief Financial Officer (OCFO) requires a noncompetitive modification to Indefinite Delivery Indefinite Quantity (IDIQ) Contract No. 31310023D0003 with CGI Federal Inc. This contract provides the Nuclear Regulatory Commission (NRC) with Financial Accounting and Integrated Management Information System (FAIMIS) Support Services.

This Justification for Other Than Full and Open Competition (JOFOC) supports the issuance of a noncompetitive modification to increase the IDIQ maximum value from $45,000,000 by $7,000,000 to $52,000,000.

2. Contract Type:

☒ F i x e d - P r i c e ( F P )

☐ Cost-Reimbursement (CR)

☐Time-and-Materials (T&M)

☐ Labor-Hour (LH)

☒ Hybrid

Sole Source ☒ Yes ☐ No

Brand Name ☐ Yes ☒ No

3. Period of Performance & Total Estimated Value of Contract

Start Date End Date Option Period Value (Ceiling)

Base Period 02/01/2023 01/31/2028 $52,000,000.00

Option Period 1

Option Period 2

Option Period 3

Option Period 4

Option Period 5

Option Period 6

Option Period 7

Option Period 8

Option Period 9

Total Contract Value $52,000,000.00

4. Provide a background and description of the supplies or services required to meet the agency's needs, including the rationale for the estimated value change (if applicable).

The additional ceiling will allow NRC to increase the ceiling on two existing task orders and issue a new task order so that the Contractor can perform the critical requirements for continued system support, regulatory fee billing operations, and required modernization of FAIMIS-related environments. These requirements are as follows:

1) A new follow-on Fee Billing Operations and Maintenance (O&M) task order upon the completion of the initial implementation of the Fee Billing application on August 31, 2026.

2) A new CLIN to support Go.gov implementation within the existing FAIMIS O&M Task Order.

3) Upgrade of the FAIMIS-STAQS System Integration and Test (SIT) Environment under the SIT task order.

5. Authority:

☒ FAR 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements.

6. Supporting Rationale:

The following rationale supports the use of the authority cited in Section 5 of this document. See brand name description1 if applicable.

☒ FAR 6.103 Rationale

This modification being issued under the authority of FAR 6.103-1 “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements,” Continued operations, maintenance, and modernization support are required for the NRC’s highly customized FAIMIS Momentum® ERP system. CGI Federal Inc. (CGI) is the only responsible source capable of providing this support without introducing significant risk to the agency’s financial management operations.

The NRC’s FAIMIS environment includes extensive proprietary customizations—most notably the license fee billing capabilities that support complex, mission-critical billing functions. CGI is the original developer and implementer of these customizations and has continuously supported FAIMIS and the NRC’s eBilling solution since 2012.

Due to the high utilization of the current IDIQ contract ceiling, the NRC is conducting market research with the intent to solicit and award a new contract for future FAIMIS support. However, the existing task orders and newly identified requirements are tightly integrated with the NRC’s customized FAIMIS environment and cannot be transitioned to another vendor without significant time and a major system overhaul. Any transition would likely require replacing the NRC’s financial management system and recreating all NRC‑specific customizations and interfaces, resulting in substantial duplication of cost, unacceptable delays, and considerable operational risk.

Because the agency cannot complete a new procurement before the follow‑on work must begin, a ceiling increase is necessary to maintain continuity of operations and ensure that critical new requirements can be supported without disruption. The work requiring the ceiling increase consists of customized enhancements, continued O&M, modernization activities, and extensions of existing FAIMIS modules, all of which build directly on CGI’s prior tasks. These efforts constitute a follow-on to services already performed under the existing contract and cannot be performed by any other source without substantial disruption. The proprietary nature of the Momentum® ERP platform further requires that such updates be performed by CGI, the system developer, and the only entity with access to the proprietary components, architecture, and NRC-specific customizations.

The NRC has made a significant long-term investment in developing, customizing, and maintaining its FAIMIS environment. Based on system dependencies, proprietary architecture, and the risk and cost associated with transitioning to a new vendor, CGI remains the only responsible source capable of meeting the agency’s immediate operational and modernization needs. Accordingly, proceeding with this action under FAR 6.103-1 is in the best interest of the Government, ensuring economy, efficiency, and uninterrupted mission-critical financial management operations.

7. Market Research (MUST BE COMPLETED):

Market research was not conducted for the ceiling increase but the NRC is in the early stages of market research to develop an acquisition strategy to replace the current FAIMIS IDIQ contract.

However, the agency does not have sufficient time to solicit requirements, conduct transition activities, and onboard a new contractor before the immediate follow-on FAIMIS requirements must be performed.

The NRC has determined that no other source is capable of assuming, transitioning, and successfully performing these highly customized and mission-critical FAIMIS services before the ceiling is required for the new critical requirements. Technical experts in OCFO determined that due to the proprietary nature of the system, other vendors cannot perform these functions without substantial duplication of cost, prolonged transition time, and unacceptable operational risk to financial management operations.

Accordingly, a sole-source modification is necessary to maintain continuity of operations while the NRC completes a competitive acquisition. Proceeding with a ceiling increase modification ensures uninterrupted financial system performance and mitigates the significant risks associated with attempting to transition to a new vendor before the competitive procurement is finalized.

8. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under

5.202 applies.

In accordance with FAR 6.103-1, this action is being conducted on a sole-source basis. As a result, offers were not solicited from multiple sources because the NRC has determined that only one responsible source, CGI Federal Inc. (CGI), is capable of performing the required FAIMIS services without unacceptable delay, substantial duplication of cost, or significant operational risk. A pre-solicitation notice for this ceiling -increase modification will be posted to the Governmentwide Point Entry (GPE) in accordance with FAR 5.101(a).

The NRC is currently developing a full and open competitive acquisition for future FAIMIS support services. However, due to the immediate need to maintain continuity of operations during this interim period and the proprietary nature of the FAIMIS Momentum® ERP environment, it is not practicable to solicit competition for this action. Competition will be pursued to the maximum extent practicable under the forthcoming competitive procurement.

9. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will determine that the anticipated cost of this modification is fair and reasonable prior to award, consistent with the requirements of FAR 15.404. This determination will be based on evaluation of the contractor’s proposed pricing, including an assessment of labor categories, labor mix, hours, and level of effort for each requirement.

The Contracting Officer will consult with the Contracting Officer’s Representative (COR) to confirm the technical validity and reasonableness of the proposed level of effort to ensure that it accurately reflects the work necessary to meet the NRC’s requirements.

To establish price reasonableness, the Contracting Officer will compare CGI’s proposed pricing with:

• existing contractual rates under the FAIMIS IDIQ,

• historical pricing for similar FAIMIS support services, and

• the complexity and scope of the tasks associated with the ceiling increase.

Upon completion of this review, the Contracting Officer will document the determination that the pricing for this modification is fair and reasonable and represents the best value to the Government.

10. Any other facts to support justification.

6.104-1(a)9 Justification content.

(i) When 6.103-1 is cited for follow-on acquisitions as described in 6.103-1(c)(2), an estimate of the cost to the Government that would be duplicated and how the estimate was derived.

(ii) When 6.103-2 is cited, data, estimated cost, or other rationale as to whether and how much the Government would be harmed.

If the NRC were to transition the FAIMIS requirements to a new contractor at this time, the Government would incur substantial duplication of cost due to the proprietary Momentum ERP architecture and the extensive NRC specific customizations developed and maintained by CGI Federal since 2012. A new contractor would be required to:

• conduct a full system discovery

• recreate or redevelop NRC specific configurations, interfaces, and fee-billing logic; and

• revalidate all financial system integrations to ensure compliance with Federal financial management requirements.

Based on prior modernization efforts, historical FAIMIS implementation costs, and estimated labor hours required to redevelop the NRC’s custom Momentum environment, the NRC estimates that transitioning to a new contractor at this stage would result in an estimated $20 million in duplicated costs. This estimate reflects expected costs for system analysis, redevelopment, data mapping, interface reconstruction, integration testing, and recertification activities. These costs would be incurred before any new contractor could begin performing the follow-on work required under this action.

Because these duplicated costs would not contribute to any new capability and would significantly exceed the cost of continuing performance under the current contract, a competitive transition at this time would not be in the best interest of the Government.

☒508 Compliant

11. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

N/A

12. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The NRC recognizes the importance of promoting competition for future acquisitions. The primary barrier to competition for the current requirement is the highly customized and proprietary nature of the NRC’s FAIMIS implementation within the CGI Momentum® ERP environment. These system characteristics limit the ability of other vendors to assume support without significant transition time, cost duplication, or operational risk.

To remove or reduce these barriers for subsequent acquisitions, the NRC is actively preparing to conduct a full and open competitive procurement for future FAIMIS support services. As part of this effort, the agency will evaluate opportunities to enhance documentation, standardize interfaces, assess alternative solutions, and identify potential strategies to increase the number of vendors capable of performing the work. The NRC will also develop a comprehensive acquisition strategy and timeline to ensure adequate time for competition.

This limited-source modification is necessary only to maintain continuity of operations while the agency completes the planning and development activities required for the upcoming competitive procurement. The NRC is committed to restoring full competition as soon as practicable.

13. Publicizing Contract Actions:

A pre-solicitation notice for this ceiling -increase modification will be posted to the Governmentwide Point Entry (GPE) in accordance with FAR 5.101(a).

The NRC will comply with the post-award notice requirements applicable to other than full and open competition actions. A notice of the award will be posted to SAM.gov within the required timeframe following execution of the modification.

In accordance with 6.301 this contract action

☒will be publicized on System Award Management