37111-14_HC1028-12-D-0029-0029_J A_Redacted.pdf

JUSTIFICATION & APPROVAL (J&A) FOR FEDERAL ACQUISITION

REGULATION (FAR) SUBPART 16.5 ACQUISITIONS

EXCEPTION TO FAIR OPPORTUNITY

Multiple Award Schedule (MAS)/ Multiple Award Contract (MAC)

Orders under MAC/ Fair Opportunity – FAR 16.505, Department of Defense FAR Supplement (DFARS) 216.505-70, Procedures, Guidance and Information (PGI) 216.505-70

Purchase Request Number: 37111-14 Contract Number: HC1028-12-D-0029 Task/Delivery Order Number: 0029 Procurement Title: Defense Readiness Reporting System - Strategic (DRRS-S) Contracting Office: Defense Information System Agency (DISA)/Defense Information Technology Contracting Officer (DITCO)/Joint Interoperability Test Command (JITC) Mission Support Section (PL8315) Estimated Value:

Authority: FAR 16.505(b)(2)(i)(C)

(I.) JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

Number: Not applicable.

Upon the basis of the following justification, I, as the Contracting Officer, hereby approve this exception to fair opportunity pursuant to the authority of FAR 16.505(b)(2)(i)(C).

1. REQUIRING AGENCY AND CONTRACTING OFFICE:

(a) Requiring Agency:

DISA/Joint Interoperability Test and Command (JITC) 2001 Brainard Road, Building 57305 Fort Huachuca, Arizona, 85670

(b) Contracting Office:

DISA/DITCO/PL8315

2300 East Drive, Building 3600 Scott Air Force Base, Illinois, 62225

2. NATURE/DESCRIPTION OF ACTION(S): The nature of this action is to ensure the fixes implemented by the developer corrected the issues in the DRRS-S system identified during the Initial Operational Test and Evaluation (IOT&E) conducted in June 2015. The verification of fixes will occur by conducting a retest of the data collection and analyzation portion of DRRS-S IOT&E by modifying the current cost-plus-fixed-fee (CPFF) DRRS-S task order against the Testing and Evaluation (T&E) Mission Support Services (MSS) indefinite-delivery/indefinite-quantity (ID/IQ)contract, held by Oberon Associates, Inc. This modification, funded with Research, Development, Test & Evaluation funds, is anticipated to add a total of hours to the over the remainder of the base year and option year 1.

Reference Number: HC1028-12-D-0029-0029 Title of Effort: DRRS-S

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3. DESCRIPTION OF SUPPLIES/SERVICES: In order to determine Operational Effectiveness of the system, JITC needs to conduct a data collection and analysis retest of the DRRS-S system and revise the IOT&E Report that has been previously delivered to reflect the results from this retest. Data will be collected from the Service Defense Readiness Reporting System (DRRS), Global Status of Resources and Training Systems (GSORTS) and Enterprise Messaging 4 (EM4) systems. The data is published from each Service at least once a month.

JITC will collect all data submissions for the month and compare it to the data that resides in DRRS-S for accuracy and completeness. The results will be documented by revising the IOT&E Report or providing a memorandum documenting the results of the retest.

(a) The purpose of this modification is to adjust JITC’s contractor labor on the existing task order, to retest and revise the IOT&E Report, in order to continue providing T&E support covered under this task order. Though the actual activities performed are essentially the same, the testing events will include more data analysis than previously anticipated. The testing remains in support of the same customer, programs, and systems as those already covered under this task order. Due to the cumulative increase in scope resulting from this change, the work could not have been reasonably anticipated at time of award and a justification for sole source action is now required.

This task order was originally awarded for and has had one previous modification that altered the contract value prior to this modification. The table below details the modifications and the cumulative changes to the contract value and includes the presently planned modification referenced in this justification.

(b) The period of performance remains unchanged:

- Base: January 20, 2015 – January 19, 2016

- Option 1: January 20, 2016 – January 19, 2017

- Option 2: January 20, 2017 – January 19, 2018

4. SUPPORTING RATIONALE, INCLUDING A DEMONSTRATION THAT THE

PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR THE NATURE OF THE

ACQUISITION REQUIRES USE OF AN EXCEPTION TO FAIR OPPORTUNITY:

(a) Exception to Fair Opportunity. In accordance with FAR 16.505(b)(2)(i)(C): The order must be issued on a sole-source basis in the interest of the economy and efficiency

Page 3 of 7 Pages because it is a logical follow-on to an order already issued under the contract. All awardees were given a fair opportunity to be considered for the original order.

(b) Description of the Justification. The DRRS-S requirement was awarded as a CPFF task order to Oberon on January 15, 2015 following a fair opportunity competition using the JITC T&E MSS ID/IQ contracts. The IOT&E of the DRRS-S system identified several issues that resulted in a finding of the DRRS-S system Not Operationally Effective.

During the June testing, JITC identified a data loss from one of the data sources.

This loss attributed to a Not Operationally Effective determination. DRRS Implementation Office (DIO) has identified the source of the loss and is implementing a fix. This fix will need to be successfully evaluated before the determination could change.

The DIO identified several fixes and has asked JITC to re-execute portions of the test and to validate each fix. The contractor that conducted the IOT&E last month is fully trained on the system and has a strong understanding of the data. It would not be cost effective to train another contractor to step in and take over the work. Because the additional labor is in support of an existing customer already receiving DRRS related test support under this task order, the change of scope to include the retesting of the DRRS-S system, data collection, and data analyzation support is a logical extension of the task order. Soliciting for a new contractor will result in a significant amount of duplicative effort and associated cost. This is due to the discrepancies found between the data contained in the DRRS-S system in comparison to the data in the Service DRRS and GSORTS systems. It would take additional time for a new contractor to sufficiently understand the capabilities to be tested, conduct the required coordination, and validate assessment methodologies. As such, the logical modification to an order already issued under the current contract.

(c) Justification.

(1) Minimum Government requirements. The Government requires immediate and highly specialized knowledge of the DRRS-S test that was completed in June 2015 to collect and analyze data in order to verify data mapping fixes.

(2) Proposed sole source contractor. The current contractor, Oberon, is the only contractor that can perform the work without adding excessive duplicative costs to the Government and still meet the testing schedule. This is due to the amount of time already invested in the ongoing testing efforts, resulting in their extensive knowledge of the data and the issues that were identified during the test. To date, the contractor has invested a significant amount of labor hours to learning the system, understanding the data schema and how the data flows through the system. They have intimate knowledge of all the issues identified during the latest test and understand the points of failure in the data flow. Even if there was sufficient time for a new contractor to obtain the requisite knowledge to prepare for and execute these events, the additional cost to the Government is expected to be approximately . This comprehensive figure includes the total cost to the Government for the duplicative familiarization of a new contractor, as well as the unavoidable duplicative coordination among stakeholders engaged in preparing for and conducting multiple, complex, and in some cases concurrent detailed assessment activities (i.e., in addition to the additional cost

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JITC would incur for direct T&E MSS contract labor, it also includes the required labor for DRRS Implementation Office personnel and operational users to sufficiently support this effort).

(3) Discussion regarding cause of the sole source situation. The reason for this sole source submittal is due to the DRRS-S system needing to be retested because it was found not operationally effective. DRRS-S is scheduled to replace GSORTS as the system of record in October 2015. The not operational effective determination prevents GSORTS from sunsetting. This retest is required to demonstrate operational effectiveness prior to DRRS-S taking over the GSORTS system. Given the DRRS Implementation Office’s robust fielding schedule and the extremely high cost of replacing the current contractor, not only is there insufficient time to solicit for this requirement, it is unlikely that other stakeholders will be able to expend the required time, effort, and cost to facilitate a successful transition without jeopardizing mission.

Due to the current investment and robust test and evaluation schedule, modifying the current task order enables JITC to extend existing resources and meet the DIO’s requirements.

(4) Demonstration of unique source. Oberon is the only qualified contractor capable of providing these services within the time required by JITC and without incurring significant additional duplicative costs. Oberon is currently in place, located at JITC- Fort Huachuca, Arizona, with the proper clearances, and capable of supporting this task without interruption. No phase-in or ramp-up will be required to expand this support. Therefore, it is not in the best interest of the Government to compete this task at the present time.

(5) Procurement discussion. The original task order was competed among all seven T&E

MSS contractors. Four prime contractors participated in this competition, of which Oberon was selected as the lowest price technically acceptable. The increase in scope and cost is necessary to support the additional labor hours required to provide the data collection and analysis to verify the fixes DIO is implementing in order to address the issues identified during testing. While extending the current task order to support the change in scope is a cost effective and timely option to address JITC’s DRRS-S system retest, soliciting for a new contractor will result in a significant amount of duplicative effort and associated cost. This is due to the substantial amount of unplanned activities it would take for a new contractor to sufficiently understand the capabilities to be tested, conduct the required coordination, and validate the test methodologies. Unplanned activities include document reviews, training events, test plan working groups, coordination activities, and methodology validation events.

Modifying the current TO enables JITC to extend existing resources in a cost effective and timely manner to meet JITC’s requirement.

(6) Impact. If Oberon is unable to support this task, we would be unable to conduct this testing in the proposed timeframe. The cost and time it would take to conduct a re-compete of the task would be prohibitive and we would be unable to support the mission. If DITCO were to compete this task, based on historical experience, it could

Page 5 of 7 Pages delay the start of the task up to three months based on the timelines to issue a competitive task and up to nine months, with maximum stakeholder support, to transition to a tester with a full knowledge and understanding of the JITCs data collection and analyzes of the DRRS-S system. Selecting another prime contractor would increase costs due to the estimated time to familiarize the contractor with the associated capabilities well enough to properly support multiple and simultaneous planning activities, develop the required plans, carry out the assessments, reduce and analyze the resulting data, and develop assessment reports. To compete the task;

obtain the required training for the next prime contractor; and ensure a requisite degree of familiarization with system functions, missions, and uses, would not meet the customer’s acquisition.

5. COST/PRICE FAIR AND REASONABLE DETERMINATION: Rates have been established with the basic contract. All rates set forth in the contract, and used on individual task orders, were based on full and open competition and a price analysis was accomplished.

Proposed task order rates and loadings will be compared with the basic contract rates and loadings and verified as fair and reasonable.

6. MARKET RESEARCH:

a. In accordance with FAR Part 10, market research has been conducted for this acquisition.

JITC performed a formal analysis of the market through GSA Advantage, and historical contract costs. The action officer has determined through market research and market analysis that in the future, competition can be obtained for the above requirement using competition amongst T&E MSS contractors. However, the only way to avoid the loss of invested resources and additional costs to the government is to modify the existing task order to accomplish the requirement.

b. This effort requires highly specialized, multi-disciplinary knowledge and the need for staff to be available immediately to continue the development of capability to support testing operations.

These development efforts require the contractor’s staff to have understanding of the DRRS-S IOT&E requirements conducted in June 2015. The use of any other contractor other than the incumbent, Oberon, would result in significant delays in testing efforts and threaten the ability to provide an acceptable level of support. The current contractor has been performing the contracted duties at an acceptable level since January 2015. Staffing is already in place to continue this effort for the duration of the task order without any delay in service. This method represents the best value to the Government, in order to allow for completion of the effort.

7. ANY OTHER SUPPORTING FACTS: None.

8. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME BARRIERS

THAT LED TO THE EXCEPTION TO FAIR OPPORTUNITY:

Procurement History.

Contract Number: HC1028-12-D-0029-0029 Contractor: Oberon Contract Period: January 20, 2015 – January 10, 2016, with two 1-year option periods

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Total Contract Value: (Base + all options) Contract Type: CPFF Objective: The purpose of this tasking is to provide the DRRS-S v4.6.x IOT&E and the Joint Interoperability Test and Certification.

This task order was awarded following a fair opportunity competition using the JITC T&E MSS ID/IQ. All seven T&E MSS contractors were afforded the opportunity to be considered for this task order. Due to the customer’s acquisition changes to get the DRRS-S system operational, more intense support is now required to ensure the DRRS-S is ready to take over the (Status of Resources and Training Systems) SORTS mission.

9. REFERENCE TO THE APPROVED ACQUISITION PLAN (AP): This requirement does not require a written acquisition plan, as one was completed at the base contract level.