47QFCA20F0066-P00094_Justification for Exception to Fair Opportunity_2025-12-17.pdf

Version 02/28/2025 Page 1

JUSTIFICATION FOR AN EXCEPTION

TO FAIR OPPORTUNITY

UNDER INDEFINITE

DELIVERY/INDEFINITE QUANTITY

(IDIQ) CONTRACTS

Task Order 47QFCA20F0066

Enterprise Services Integration and

Modernization (ESIM) in support of:

United States Army Pacific (USARPAC) G6

United States (U.S.) General Services Administration (GSA)

Federal Acquisition Service (FAS)

Assisted Acquisition Services (AAS) Defense

Interagency Agreement Number 47QFCA19S0012

Docusign Envelope ID: 090B50F5-8EFF-44D0-9CF2-642F5104FF6D

Version 02/28/2025 Page 2

The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this

Justification for the issuance of an Exception to Fair Opportunity order pursuant to Federal

Acquisition Regulation (FAR) FAR 16.505(b)(2)(i)(C).

a. Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of United States Army Pacific (USARPAC)

Contracting Activity:

GSA AAS Contracting Office (QFXX)

1800 F Street, NW

Washington, D.C. 20405

b. Nature and/or Description of Action Being Approved:

The Government intends to modify task order 47QFCA20F0066 to include two additional 6-month FAR 52.217-9 options. As a result of this modification, the task order period of performance (i.e., the Base Period and all FAR 52.217-9 options) will change from September 27, 2020 – January 3, 2026 to September 27, 2020 – January 3, 2027.

The total task order ceiling will remain unchanged; unused ceiling totaling $60,873,230 from prior periods will be realigned to the two new 6-month FAR 52.217-9 options. The

Contract Line Item Number (CLIN) contract types will remain the same (e.g., labor

CLINs will remain cost plus award fee).

c. Description of Supplies/Services and Estimated Value:

The scope of the ESIM task order is to provide a quality-focused process and capability that enables effective sustainment and modernization of Command, Control, Communications, Computers (C4) and Information Technology (IT) systems in support of USARPAC G6 and its strategic and operational partners. These services include site surveys, engineering, design, procurement, logistics, implementation, Operations and

Maintenance (O&M), Knowledge Management (KM), and training support of new and existing C4 systems. The primary place of performance is Fort Shafter, HI. Examples of other places of performance include Outside of the Contiguous U.S. (OCONUS) locations in Alaska (AK), Guam, Japan, Okinawa, and South Korea.

Set forth below is a summary of the ESIM tasks from the Performance Work Statement, each of which would be continued in the new FAR 52.217-9 option periods:

Task 1 – Provide Program Management: The contractor shall provide program management support including the cost, schedule, and technical management and oversight of all activities performed by contractor personnel, including subcontractors, to satisfy client needs. Inclusive of this support is contract/subcontractor management, facility management, asset management, risk management, quality control, invoice support, and management of TO funding from multiple agency sources in accordance with USARPAC G6 best practices.

Task 2 – Provide Engineering and Design: The contractor shall provide engineering and design services to facilitate the upgrade, installation, integration, and turnover of C4

Version 02/28/2025 Page 3 and IT systems. Engineering and design activities include periodic design reviews of implementation plans, bill of materials, and test plans.

Task 3 – Provide Procurement and Logistics: The contractor shall provide procurement and logistics services to identify equipment requirements for integration, procure incidental material and hardware, track procurement status and equipment disposition, and report such provisioning actions.

Task 4 – Provide Implementation: The contractor shall provide implementation services to accomplish modernization projects/efforts for strategic and operational partners’ C4 and IT systems across the INDOPACOM AOR. Implementation encompasses the full installation, integration, secure, harden, test, and as-built documentation of the planned C4 and IT system projects.

Task 5 – Provide Operations and Maintenance (O&M): The contractor shall provide operations and maintenance support services to existing and modernized C4 and IT systems. Operations and Maintenance activities include break/fix actions, development of life cycle sustainment plans, and cybersecurity/IA implementation.

Task 6 – Knowledge Management (KM) Services: The contractor shall provide KM services in support of ESIM projects/efforts, including expertise in SharePoint as well as the development of standard operating procedures to develop and retain knowledge.

Task 7 – Provide Cybersecurity/Information Assurance (IA) Services: The contractor shall provide cybersecurity/IA services to strengthen the posture of USARPAC G6.

Task 8 – Provide Training: The contractor shall provide quarterly training services for identified C4 and IT systems at the customer site, including developing user-based training material, providing user-operations training on C4 and IT systems, developing and providing capabilities training, and developing, sustaining, and updating a training library of products to ensure that all training is applicable to the current production environment.

Task 9 – Surge/Special Projects (Optional): Provide surge support for Tasks 1-8 for

USARPAC and its strategic and operational partners, including out-of-cycle system upgrades, supported system failures, supported software/application failure, and training.

Estimated Value: The total task order ceiling will remain unchanged, however this justification reflects the total value of the $60,873,320 that will be realigned to the two new 6-month FAR 52.217-9 options.

d. Identification of the Exception to Fair Opportunity and Rationale:

This task order Justification is being prepared as required by FAR 16.505(b)(2)

(Exceptions to the Fair Opportunity Process).

The rationale is that 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 (FAR 16.505(b)(2)(i)(C)).

A fair opportunity to compete was given under the original award of Task Order

47QFCA20F0066 for this requirement under the multiple award contract when proposals

Version 02/28/2025 Page 4 were solicited from seventy contractors, and seven proposals were received and evaluated on a best value basis. The relationship between the original competed order and this follow-on is logical because, apart from the period of performance, the scope of the Task

Order remains unchanged; for instance, the PWS tasks and in-scope performance locations will remain the same. The total ceiling value and contract type of the Task

Order will remain unchanged.

This exception to fair opportunity is necessary and in the interest of economy and efficiency, because the Government’s post-ESIM procurement solution, which will provide the services currently being provided by ESIM after the conclusion of ESIM, has encountered significant, unforeseen delays. Additional time is required to promote competition from the best sources and ensure compliance with Executive Order (EO)

14271 (Ensuring Commercial, Cost Effective Solutions in Federal Contracts) and other recent changes to acquisition policy.

There is an immediate need for USARPAC and its mission partners to continue to receive contractor support services. In-scope ESIM services include cybersecurity, sustainment of systems and networks in command and control facilities, and maintaining 24/7 emergency action center operability. These services are critical to United States national security and war readiness and prevention. The ESIM contractor provides essential operation and sustainment support of secure audio visual / video teleconferencing

(AV/VTC) systems for USARPAC General Officers and Flag Officers. Additionally, the

ESIM contractor provides sustainment support for Satellite Communications (SATCOM) in the USARPAC Emergency Action Center within the Joint Operations Center. This command and control center is responsible for responding to emergencies and conducting operations in the Pacific region. Its functions include maintaining 24/7 situational awareness of natural and geopolitical crises that may disrupt regional stability, coordinating responses, and sharing information with partners. A break in contractor support would create technical hardships for USARPAC, the Army command responsible for Army forces in the Indo-Pacific region. Failure of IT or communications systems, whether a break/fix issue or compromised cybersecurity, would be a critical problem in a dangerous strategic environment where the Department of War is focused on maintaining and extending our military advantage and deterring threats.

The period of performance of ESIM’s final FAR 52.217-9 option ends on January 3, 2026; without continuity of service support by the current ESIM contractor, IMC, the

Government risks mission failure for USARPAC. This modification to add two 6-month

FAR 52.217-9 options to ESIM will ensure that there is no gap in service or mission failure for USARPAC. This will also provide adequate time for transition between ESIM and the post-ESIM solution, relieving any pressure for an artificially short transition-in period for the post-ESIM procurement, which could limit competition on the post-ESIM procurement.

It is in the Government’s best interests for IMC to continue to provide these services for the up-to-one-year extension, instead of awarding the work to a different contractor.

IMC has employees already in place in theater that possess the requisite skills and institutional knowledge that are required to seamlessly continue the required support.

Continued performance from the current contractor ensures no break in, or degradation of, support services while the post-ESIM procurement solution is put in place, and is the

Version 02/28/2025 Page 5 most timely and economical path forward. IMC has been successfully providing these services for five years, thereby demonstrating adequate staffing and corporate capability to maintain continuity of support with these new FAR 52.217-9 options. Continuing these services with IMC will avoid costly transitions to a new contractor (e.g., recalling contractor staff stationed in foreign countries thus incurring costly relocations expenses for both an incoming and a new outgoing contractor, navigating host nation agreements/Status of Forces Agreements for countries such as Korea and Japan, changes in facility and badge access, and transition-out/-in overlap between contractors in short order upon the award of the post-ESIM procurement). In addition to being costly, such a transition would not be feasible in the timeframe remaining. A new contractor would require significant time to transition in given the geographic footprint of ESIM, and the time to compete and award a bridge contract is not feasible given the upcoming expiration of January 3, 2026. Finally, attempting to solicit and award this up-to-one-year period on a competitive basis would be duplicative of the efforts already underway to solicit and award the post-ESIM procurement, thus incurring additional costs and an undue administrative burden.

Adding two 6-month FAR 52.217-9 options to ESIM is the most efficient solution, because the framework is already in place for ESIM and would not require any administrative duplication. The terms and conditions of the existing ESIM task order meet the Government’s requirements, and services would successfully continue uninterrupted.

e. Determination That the Anticipated Cost is Fair and Reasonable:

The anticipated costs associated with this additional performance have been found fair and reasonable, as required by FAR 16.505(b)(2)(ii)(B)(5). In accordance with TO

Section B.5.2, the contractor will use labor categories that are mapped to existing VETS

2 contract labor categories. In accordance with TO Section B.5.1, the contractor’s indirect burdening will be limited to the ceiling rates established when ESIM was awarded. In accordance with TO Section H.11.2 and H.12, the contractor will be required to obtain

Government review and approval of proposed non-labor costs via the Travel

Authorization and Consent to Purchase Requests. The Award Fee Determination Plan

(AFDP) includes criteria addressing the contractor’s management of costs. These oversight mechanisms will work in concert to ensure that costs remain fair and reasonable throughout execution.

f. Other Facts Supporting the Justification:

All supporting factors are identified above.

g. Statement of Actions:

As discussed above, this action is contemplated to improve competition for the upcoming post-ESIM procurement solution. That acquisition is well underway. Planning began in

2024, and a Request for Information (RFI) was issued to VETS 2 Government-Wide

Acquisition Contract (GWAC) contractors in April 2025. Market Assessment

Discussions (MAD) with industry partners began in May 2025 and continued in October

2025. An electronic Reading Room (eRR) was opened in June 2025. Solicitation release

Version 02/28/2025 Page 6 is anticipated in Quarter 2 (Q2) of Fiscal Year 2026 (FY26), offeror oral presentations are anticipated to be conducted in Q3 of FY6, and task order award is anticipated in Q3 or

Q4 of FY26.

h. Certification by Technical or Requirements Personnel:

I hereby certify that the supporting data is accurate and complete.

Contracting Officer’s Representative:

Jamie Humphrey Date

Program Manager, AAS Defense

Assisted Acquisition Services

i. Signature of Authorized Officials:

I hereby certify that the Justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that the exception to fair opportunity is in accordance with the requirements and is in the best interest of the Government.

Contracting Officer:

Steve Madsen Date

Contracting Officer, AAS Defense

Assisted Acquisition Services

Client Executive:

Corey Nickens Date

Client Executive, AAS Defense

Assisted Acquisition Service

Docusign Envelope ID: 090B50F5-8EFF-44D0-9CF2-642F5104FF6D

10/22/2025

10/22/2025

10/23/2025