47QFDA21F0051_T04_06_Statutory Exception_Justification for an Exception SAM.Gov.pdf

Version 06/23/2020

General Services Administration (GSA) Federal Acquisition Service (FAS)

National Capital Region (NCR)

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

UNDER IDIQ CONTRACTS

SOLICITATION ID: 47QFDA21K0036

The General Services Administration (GSA) makes this Justification for the issuance of an Exception to Fair Opportunity order pursuant to Federal Acquisition Regulation (FAR) 16.5.

a. Identification of Agency and Contracting Activity:

Agency:

General Services Administration National Capital Region Acting in support of Army National Guard (ARNG)

Contracting Activity:

GSA NCR Assisted Acquisitions Service (AAS) 1800 F Street, NW Washington, D.C. 20405

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

NCR AAS, in support of U.S. Army National Guard (ARNG), proposes to award a sole source Labor-Hour Task Order (TO) to Science Applications International Corp (SAIC), using the U.S. Army’s Computer Hardware, Enterprise Software and Solutions (CHESS) IDIQ. The purpose of the Bridge Initiative (henceforth referred to as “Bridge”) action is to support operations and maintenance of two mission-critical ARNG personnel systems;

(1) the Reserve Component Manpower System – Guard (RCMS-G) and (2) the Strength Maintenance Management System (SMMS), to maintain its cyber security compliance and to perform critical data operations in order to facilitate competition for a future support requirements.

The proposed period of performance for the Bridge is a 12-month period from July 1, 2021 – June 30, 2022, with an estimated total value of $16.4 million.

c. Description of Supplies/Services and Estimated Value:

The overall objective of the Bridge is to provide critical operations and maintenance to two mission-critical ARNG personnel systems, RCMS-G and SMMS. The ARNG G1 is responsible for creating, managing, and executing all manpower and personnel plans, programs, and policies across all the ARNG Directorates, and these two systems are used to support and enhance the ARNG G1 decision-making process. Most data input to these systems are raw data that indicate the status of Reserve Component personnel and the

DocuSign Envelope ID: 13F221D5-F5C7-44BB-9B6C-54EEE5443F22DocuSign Envelope ID: A40A3F7C-D228-412B-B070-ACA048EDD531DocuSign Envelope ID: 1E1D92F1-A532-41C4-B162-70EE779CB54E changes that have occurred to the force during the current reporting period. SMMS and RCMS-G process these data and convert them into useful information for the users.

The services required to maintain RCMS-G and SMMS can be grouped into three categories of program management, operations and maintenance, and data operations.

Program management includes the management and oversight of all activities performed by contractor personnel to satisfy the requirements identified in the statement of work.

Operations and maintenance includes tasks related to system, database, and web server maintenance, service desk, cyber security monitoring, defect identification, tracking, and resolution, change and configuration management support, continuity of operations, and disaster recovery. Data operations includes tasks related to data processing, data reprocessing, mainframe operations, and maintenance of system interfaces with approximately 40 external systems.

A new and expanded services contract to support RCMS-G and SMMS recompete action is actively in process with anticipated award during FY22. The primary goal of the Bridge is to improve the systems in place to better posture the ARNG G1 for future transitions to be included in this future recompete. As the Bridge solution updates the existing Adobe Flash content to meet cyber security compliance standards, RCMS-G and SMMS will be able to maintain their accreditation and remain accessible to its end users.

During the execution of this Bridge, there are two significant requirements that are essential to maintaining the RCMS-G and SMMS as enduring resources for the ARNG.

These include:

● Ensure Cyber Security Compliance. The RCMS-G and SMMS systems use an obsolete software development kit (Adobe Flex) which uses Adobe Flash to make browser-based software perform similar to desktop software. Adobe Flash reached end of life on 31 December 2020 but the ARNG was not successful in updating and removing existing Adobe Flash content in RCMS-G and SMMS.

The Authorizing Official for the ARNG has accepted the risk to allow the continued use of Adobe Flash beyond the end-of-life support with the implementation of a number of risk mitigation steps. However, this exception is only extended through August 2021 and requires conversion and/or removal of all remaining Adobe Flash content to be completed by this deadline. This is the primary objective for the Bridge as it ensures that both systems will maintain their accreditation throughout the period of the re-competition.

● Maintenance of External Data Interfaces. RCMS-G and SMMS process data via inbound and outbound interfaces with approximately 40 external systems, with the primary source of data being the Total Army Personnel Database – Guard (TAPDB-G). TAPDB-G is scheduled to be subsumed by the Integrated Personnel and Pay System – Army (IPPS-A) Release 3 in December 2021.

Significant changes are expected in the inbound data from IPPS-A’s Release 3, likely requiring a substantial retooling of procedures designed to process the data into the G1 Data Store. Without the proper background and understanding of the

DocuSign Envelope ID: 13F221D5-F5C7-44BB-9B6C-54EEE5443F22DocuSign Envelope ID: A40A3F7C-D228-412B-B070-ACA048EDD531DocuSign Envelope ID: 1E1D92F1-A532-41C4-B162-70EE779CB54E interconnectivity of this data, this change has the potential of breaking the primary data connection for RCMS-G and SMMS or any of its subsequent connections to downstream data partners. The second critical objective for the Bridge is to ensure that all external data interfaces are maintained throughout this critical transition to IPPS-A’s Release 3.

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

This Justification is being prepared as required by FAR 16.505(b)(2), Exception to Fair Opportunity Process.

The rationale is the agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays IAW FAR 16.505(b)(2)(i)(A).

The urgency of not meeting the August deadline would be catastrophic to ARNG human resources and strength maintenance operations, which in turn affect national security. The ARNG would lose critical decision support tools designed to assist analysis and reporting and automated processes that streamline key HR functions. If key components of RCMS-G and SMMS are not available after the August deadline, the ARNG would need to revert to costly manual, labor-intensive processes that that could negatively impact strength maintenance due to accuracy or timeliness of data or processes related to vacancy management, retention management, or incentive management. This is compounded for ARNG units deployed to OCONUS theaters without access to ARNG-managed equipment and must work through CONUS-based detachments to access the tools in RCMS-G and SMMS. By meeting the August deadline, the ARNG ensures proactive and informed personnel management.

The ARNG faced a number of challenges during the 3-year period following the 2017 Adobe announcement to discontinue Flash and has failed to complete the conversion of outdated software for RCMS-G and SMMS. In October 2018, SMMS experienced a catastrophic failure at the Pentagon JSP and required nearly six months to rebuild servers and processes to recover the system. During a majority of this period, SMMS was not available to end users and the subsequent recovery resulted in a number of servers, processes, and components never being restored.

In September 2019, the support contract for SMMS and RCMS-G was awarded to another vendor with an abbreviated transition period. This next vendor was required to complete a relatively short-notice migration of SMMS from the Pentagon JSP to the ARNG Installation Processing Node to once again co-locate with RCMS-G. As this occurred in Spring 2020, RCMS-G was already within the last year of support for Adobe Flash, with no significant progress ahead of the 31 December 2020 deadline.

As the ARNG continues to have a need for RCMS-G and SMMS, GSA is working with the ARNG to award a new and expanded services contract later in calendar year 2022 to support RCMS-G and SMMS. Due to the RCMS-G and SMMS missing its initial 31 December 2020 deadline to deprecate Adobe Flash; and a critical pending deadline of August 2021 for its extension for compliance, significant development must be completed in order for the systems to maintain their security compliance to even reach a

DocuSign Envelope ID: 13F221D5-F5C7-44BB-9B6C-54EEE5443F22DocuSign Envelope ID: A40A3F7C-D228-412B-B070-ACA048EDD531DocuSign Envelope ID: 1E1D92F1-A532-41C4-B162-70EE779CB54E new contract award. It is critical for this Bridge that the contractor has a deep understanding of the software, its data, and the interconnected nature of the systems, their modules, and their shared components.

Further, numerous, documented performance issues with the incumbent contractor have led to the urgency of this contract action. ARNG has proactively managed these issues and is in a position where letting the current order continue would subject the Government to a host of unnecessary risks. The decision to proceed under a sole source award was made after careful consideration and after ARNG explored every avenue to ensure mission accomplishment.

A full and open competition cannot be conducted while still meeting the August deadline, further necessitating the need of this bridge contract action.

Ultimately, failing to meet the August deadline will lead to immeasurable financial costs, as the down time and loss of authority to operate would be prohibitively expensive to the ARNG during the arduous process of re-establishment. Further, this poses immense opportunity cost, as loss of these would affect numerous personnel, resources and business processes; and the ultimate costly uncertainty that potentially starting over would inflict across ARNG.

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

To ensure the anticipated costs to the Government will be fair and reasonable, the Contracting Officer will compare SAIC’s proposed labor hours and labor rates for the sole source TO with SAIC’s CHESS contract pricing and the labor hours and labor rates currently being incurred under the existing requirement for the proposed services.

f. Other Facts Supporting the Justification:

The Government conducted detailed market research to support this approach. This was conducted by reviewing the contractual history of this requirement, careful evaluation of all commercial sources of supply and consultation with highly-experienced Subject Matter Experts (SMEs). While these types of services are available on a variety of established Government contracting vehicles, it was ultimately determined that the sole source bridge task order issued under Army CHESS is the best approach.

Notably, Army CHESS is the required contracting vehicle for these services, per the December 1, 2020 Directive from The Deputy Assistant Secretary of the Army (Procurement) DASA (P)) and formally incorporated into AFARS as follows:

AFARS Part 5139 . The Army Office of the Chief Information Officer will Incorporate the relevant provisions of this directive into Army Regulation (AR) 25-1.

Notably, SAIC and its integrated business partners developed RCMS-G to support the ARNG mission as the Global War on Terrorism increased the training and readiness

DocuSign Envelope ID: 13F221D5-F5C7-44BB-9B6C-54EEE5443F22DocuSign Envelope ID: A40A3F7C-D228-412B-B070-ACA048EDD531DocuSign Envelope ID: 1E1D92F1-A532-41C4-B162-70EE779CB54E requirements for the ARNG following the events of 9/11. During this period, decision support tools were quickly implemented and adapted to support the increasing manpower demands placed on the ARNG in order to support the ARNG mission, both domestic and abroad. Among the most critical of these tools are the Director’s Personnel Readiness Overview (DPRO), the Guard Incentive Management System (GIMS), the Automated Unit Vacancy System (AUVS), and the Retention Management System (RMS). These tools took advantage of raw data compiled and processed from dozens of external sources to support and enhance the ARNG G1 decision-making process. Eventually, specific strength maintenance functions were migrated away from RCMS-G to SMMS, which supported the ARNG from the Pentagon Joint Service Provider (JSP) resources.

In 2015, when the support contract for RCMS-G and SMMS transitioned to another vendor in an open competition, SAIC and their integrated business partners continued to maintain a separate system for the United States Army Reserve (USAR) with the same original codebase. This sister system is the Reserve Component Manpower System (RCMS or sometimes referred to as RCMS-R).

In 2017, when Adobe first announced that Adobe Flash would be discontinued, SAIC and their integrated business partners began conversion of the Adobe Flex/Flash components as part of their operations and maintenance of the RCMS system for the USAR and completed converting the code to HTML5 over the course of the next three years to maintain cyber security compliance.

It is prudent that this Bridge task order be awarded to the same contractor who has successfully maintained this system and who has successfully completed a very similar conversion of code for a system that shares the same codebase for the USAR. This contractor is in a unique position of understanding the complexities of the structure and interactions of RCMS-G and SMMS, while also having successfully undergone a recent modernization effort. This Contractor is the only contractor that knows and understands the data complexities, anomalies, issues, and risks and how to employ the best methods of data integration and processing to ensure consistency of data provided through the future RCMS-G and SMMS Requirement.

The data operations performed by the Contractor are complex and encompass the following: 6 database servers with over 20 years of historical personnel, financial, and training data in 349 databases with 96,171 tables, and utilizing over 70,000 stored procedures. In a combination of manual and automated processes, data is processed from approximately 40 external data systems in daily, weekly, monthly, quarterly, annually, and other semi-regular cycles in order to populate the G1 Data Store that supports RCMS-G and SMMS. This underlying data supports key reporting requirements to the Department of the Army, the Department of Defense, and to Congress.

Based upon the Contractor’s previous 20+ years of experience working to process the raw data for the ARNG, both for RCMS-G/SMMS and the more rudimentary systems that predated them, the Contractor understands the critical interdependencies of the planned development tasks. The Contractor’s intimate knowledge of the ARNG’s current environment, human resources processes, existing deficiencies, and data limitations

DocuSign Envelope ID: 13F221D5-F5C7-44BB-9B6C-54EEE5443F22DocuSign Envelope ID: A40A3F7C-D228-412B-B070-ACA048EDD531DocuSign Envelope ID: 1E1D92F1-A532-41C4-B162-70EE779CB54E makes it exceedingly likely that it can accomplish the required work in the least amount of time with the least amount of effort.

A new firm would have to spend one to two years learning the ARNG’s unique reporting and accounting environment and understanding the intricate interdependencies of many of the tasks, in order to maintain data operations while performing the required operations and maintenance. Competing this Bridge to another contractor would mean the awardee could spend one to two years learning the business processes and developing a deep knowledge of underlying data before they are able to begin converting the Adobe Flash components or adjusting the Extract, Transform, and Load (ETL) procedures to accommodate the new IPPS-A Release 3 data. There is a high risk that the contractor would not be able to deliver a quality solution because they would still be learning the complex data sets when the future RCMS-G and SMMS Requirement is awarded. A delay in the completion of this Bridge would lead to major negative consequences for the ARNG if RCMS-G and SMMS lose their authority to operate prior to the time of award or if the systems fail to integrate the data associated with IPPS-A Release 3.

As a result, SAIC has been identified as the only vendor that can ensure no gaps in service, under this very limited timeline.

g. Statement of Actions:

Actions are being taken to ensure the removal of barriers that led to the Government using an exception to fair opportunity. Any future O&M, enhancements, upgrades, etc.

performed under the Bridge will be covered under the ARNG’s RCMS-G and SMMS support contract that will be competitively re-competed by GSA later in calendar year 2021.

h. Certification by Technical or Requirements Personnel:

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

May 12, 2021 MAJ Sonny W Louie Date

ARNG-HRZ-S

SMMS/RCMS-G Functional System Owner sonny.w.louie.mil@mail.mil

LOUIE.SONNY.WAESHAL.1016383607

2021.05.12 09:13:20 -04'00'

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i. Signature of Authorized Officials:

The Technical and Requirements Personnel assertion is provided as an Attachment.

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.

Raymond Meraz Date Contracting Officer

NCR/AAS/COD

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

Dennis Harrison Date Deputy Director

NCR/AAS/COD

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

Stacy Williams Date Competition Advocate Director, Acquisition Oversight Division

Houston Taylor Date Head of Contracting Activity

5/12/2021

Digitally signed by RAYMOND MERAZ DN: C=US, O=U.S. Government, OU=General Services Administration, CN=RAYMOND MERAZ +

OID.0.9.2342.19200300.100.1.1=47001003085477

Reason: I am the author of this document Location: your signing location here Date: 2021.05.12 09:41:29-04'00' Foxit PhantomPDF Version: 10.1.3

RAYMOND

MERAZ

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5/14/2021