CUI//SP-SSEL

Sole Source Justification

(SSJ)

FAR 52.217-8 Option to Extend Services

Solicitation ID: 47QFEA25Q0009

Operations and Maintenance Support

Halley’s COMET Bridge

Follow-on in support of:

GSA Office of the Acquisition IT Services

United States (U.S.) General Services Administration (GSA) Federal Acquisition Service (FAS)

Assisted Acquisition Services (AAS) Civilian

Interagency Agreement Number 47QFEA24S0006

Controlled by AAS Contracting Officer Tiffany Johnson: Tiffany.Johnson@gsa.gov

Version 02/28/2025

Docusign Envelope ID: 859BEF28-D93E-40C2-8A55-6C79274EDF29

The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this Sole Source Justification (SSJ) for orders pursuant to General Services Acquisition Manual / Regulation GSAR 538.7104-3 (GSA Class Deviation RFO-2025-FSS-GSAR 538).

i.) Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of the GSA Office of the Acquisition IT Services.

Contracting Activity:

GSA AAS Contracting Office AAS Civilian, Sector 1 ii.) Nature and/or Description of Action Being Approved:

The Government intends to exercise a six-month extension period, in accordance with FAR 52.217-8, to the existing sole-source Operations and Maintenance (O&M) Support Halley’s COMET Bridge Task Order (TO) 47QFEA25F0004 while the Government contemplates its new key focus areas and requirements. Exercising the FAR 52.217-8 clause will incorporate six months of performance from March 27, 2026, through September 26, 2026. This current Task Order was awarded under the International Business Machines Corporation (IBM) GSA Multiple Award Schedule (MAS) contract GS-35F-110DA.

FAR 52.217-8, Option to Extend Services was incorporated into the Task Order but was not evaluated in accordance with FAR 17.202 (a) which states, “prior to awarding the basic contract, the contracting officers must evaluate offers for option quantities or periods included in the solicitation”. As a result this Sole Source Justification provides evidence that the six month option incorporated into the task order award is in the best interest of the Government.

The historical background of this sole-source action is detailed as follows:

● The previous Task Order 47QDCB19F0005 was competitively awarded under Multiple Award Schedule (MAS) Blanket Purchase Agreement (BPA) 47QDCB19A0008 on September 27, 2019 through September 26, 2024, to Sevatec, Inc. (hereafter referred to as IBM), for one year base period and four one year option periods and subsequently extended from September 27, 2024, through March 26, 2025 in accordance with FAR 52.217-8 Option to Extend Services.

● The recompete of Task Order 47QDCB19F0005 was originally solicited as a seed order against COMET 2 BPA solicitation on January 23, 2025, RFQ ID: RFQ1740143, CIO Modernization and Enterprise Transformation (COMET) II BPA reference # / uPIID

47QFEA25Q0005.

● In order to prevent a break in service, due to unforeseen delays with the release of the COMET 2 solicitation, a bridge contract was awarded to IBM utilizing FAR 8.405-6(a)(1)(i)(A)—Urgent and Compelling Need authority1. This one year task order

1 On February 13, 2026, an amendment to the limited source justification was signed and posted to SAM.gov. The amendment incorporated the FAR 52.217-8, Option to Extend Services to the provided for the continuance of routine maintenance, security patching, and enhancements of applications. The justification for the sole-source award was due to the complexities and necessity for continuity of services following the expiration of the previous contract vehicle, the criticality of system continuity, insufficient time to conduct a full competition before the services were required, and the inherent risk of service interruption.

● During the performance of the bridge contract a major shift in priorities ushered by the change in Administration in January 2025. As a result GSA IT’s priorities and focus areas changed significantly. As a result the COMET 2 BPA no longer met the needs of GSA IT and the solicitation was canceled on July 11, 2025, six months after it was issued and four months into the bridge’s period of performance.

The current bridge is expiring, and GSA plans to restructure this requirement as part of broader IT strategy changes. Both GSA and the federal Government have undergone significant changes that require it to reassess its needs. As previously stated, the cancellation of COMET II BPA during the bridge’s period of performance caused a redirection of the recompeted requirements which is now in the market research phase with an expected award date of August 2026.

Therefore, a six month option extension would provide sufficient procurement lead time for the new requirement. While the Government determines the best path forward, this six-month extension will ensure IBM continues providing uninterrupted services under the existing requirements. Once the extension ends, this requirement may be discontinued or incorporated into a different contract vehicle.

iii.) A Complete Description of Supplies/Services Required to Meet Agency’s Need (Including the Estimated Value):

The stand-alone, one year sole source Task Order 47QFEA25F0004 is Time and Materials (T&M with a not to exceed (NTE) of $17,560,022.90 from March 27, 2026 – September 26, 2026. The FAR 52.217-8 clause will increase the Task Order not-to-exceed value from $35,120,045.81 to $52,680,068.71.

The purpose of this requirement is to provide the GSA Office of Acquisition IT Services with continued Operations and Maintenance (O&M) support, enhancements, and technical services needed to sustain GSA IT systems, as well as moderate new features, and improvements without changing the direction or scope of the system. These services ensure uninterrupted support for mission-critical applications supporting acquisition, e-commerce, lifecycle management, and digital experience functions. The importance of these applications cannot be overstated, as they are central to the operational continuity and effectiveness of federal procurement activities. A failure or significant disruption within these systems would have negative impacts which are described in section IV of this SSJ.

period of performance of the bridge contract. Please refer to the amendment titled "Amendment to Limited Source Justification 2-10-26” for more information regarding the inclusion of FAR 52.217-8.

The applications developed and maintained by the Acquisition IT Services organization are used by business portfolios within GSA, customer agencies, the vendor community, and the general public. Therefore, the stability, security, and continuous operation of these applications are paramount to ensuring the continuity and integrity of acquisition processes across all federal agencies. A lapse in funding creates a significant risk of halting essential IT services, which would negatively impact the mission of all supported programs and their daily operations.

Continued funding ensures compliance with IT-specific mandates and preserves mission-critical capabilities.

The primary technical objectives of this requirement are as follows:

Objective 1 – Task Order Management.

The contractor shall provide program management support under this TO. This includes the management and oversight of all activities performed by contractor personnel, including subcontractors, to satisfy the requirements identified in this Performance Work Statement (PWS).

Objective 2 – Transition Management Services.

The Contractor shall provide a Transition-Out Plan NLT 90 calendar days prior to expiration of the Task Order. The Contractor shall identify how they will coordinate with the incoming Contractor and/or Government personnel to transfer knowledge specified in the PWS. They shall establish and maintain effective communication with the incoming Contractor and Government personnel for the transition period as required.

The Transition-Out Plan shall facilitate the accomplishment of a seamless transition from the incumbent to incoming Contractor personnel at the expiration of the Task Order. During the transition in, the contractor shall ensure that there will be minimal service disruption to GSA applications and no service interruptions to mission critical IT systems.

Objective 3 – Application Operations and Maintenance (O&M).

The contractor shall provide application lifecycle management for supported applications during the TO period of performance. GSA is responsible for the implementation, support, management and operation of GSA’s applications by providing resilient, flexible, and secure technologies and services including DevOps, Database management, Operating Systems (OS) and system integration for the support of 50 applications on over 800 virtual servers spread across Red Hat Enterprise Linux, Windows, and Solaris physical servers, in addition to systems deployed on FAS Cloud Services. For the purpose of this TO, O&M is defined as activities and functions carried out to ensure existing applications perform as intended or for minor development, maintenance or enhancements.

iv.) The Authority and Supporting Rationale:

This action is conducted under the authority of the Multiple Award Schedule (MAS) Program.

Consideration of schedule contractors will be restricted in accordance with:

● GSAR 538.7104-3(b)(1)(ii)(GSA Class Deviation RFO-2025-FSS-GSAR 538) —Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized;

This Sole Source Justification (SSJ) supports the Government’s exercise of FAR 52.217-8, Option to Extend Services, under the current Task Order to ensure uninterrupted delivery of mission-critical IT operations across GSA. This extension provides the Government sufficient time to complete the competitive recompete acquisition, which is currently scheduled for award in August 2026.

As the Task Order approaches expiration, the Government intends to exercise FAR 52.217-8 to continue these requirements at the existing contract rates and within the current scope. The FAR 52.217-8 extension was incorporated into the contract's terms and conditions at award.

Consequently, this contractor is the sole vendor eligible to perform the six month option to extend. This approach ensures continuity of services.

The current Task Order provides GSA with Operations and Maintenance (O&M) personnel to support GSA environments, including routine maintenance, security patching, and minor application enhancements. A break in contract support would disrupt more than fifty (50) applications that require this continuous maintenance, security patching, and enhancements to support the Government procurement process. These systems support the Federal Acquisition Service (FAS) and also provide services to Administration Headquarters, the Office of Governmentwide Policy, and the Public Buildings Service. Any lapse in support or change in vendor would be detrimental to the mission of maintaining a focused portfolio of applications that enable GSA to support Government-wide acquisition activities.

Leveraging six years of experience with this requirement, the contractor has developed project management and technical expertise that positions itself as the only source capable of fulfilling the requirements at this time. Furthermore, switching the current vendor would lead to the loss of significant institutional knowledge and accumulated expertise developed over the years of managing the systems. A new vendor would require an unacceptably long time to on-ramp, jeopardizing the delivery of uninterrupted support to GSA IT and the system owners/users.

Without the time for a proper transition, as stated in the PWS timeline, switching vendors at this time would introduce new security vulnerabilities due to a lack of familiarity with the systems’ security architecture and potential misconfigurations. This could increase the risk of data breaches, unauthorized access, and compliance violations. A new vendor may not be able to immediately optimize the system for performance, leading to slower response times, increased processing times, and reduced overall efficiency. This could negatively impact user productivity and the agency's ability to meet its performance goals.

IBM is uniquely qualified to continue performing the required services due to its institutional knowledge and long-standing involvement supporting Halley's COMET systems. IBM has gained a deep understanding of the architecture, integrations, configuration, operational dependencies, and security requirements associated with more than fifty interconnected applications under this requirement. IBM has also cultivated robust working relationships with essential GSA IT and FAS system owner personnel, promoting a collaborative atmosphere conducive to swift problem resolution and proactive maintenance. This proficiency encompasses a detailed understanding of GSA's internal procedures, security protocols, and reporting requirements. IBM maintains a comprehensive repository of historical data, documentation, and troubleshooting procedures specific to each application’s environment. This knowledge base is essential for the timely and efficient diagnosis and resolution of issues. No other contractor could assume responsibility for these systems within the limited timeframe of the extension period without introducing a significant risk of service disruption.

IBM provides these services to the following applications that cannot be interrupted and would be negatively impacted by a vendor transition:

● The GSA Advantage suite of systems, which provides ordering capability for more than one million GSA-supplied items and more than 65 million GSA and VA Schedule products and services from approximately 16,000 vendors and has processed more than ten million orders totaling more than $8 billion.

● The Sales Reporting Portal (SRP), which is used by FAS vendors to report transactional sales data and to pay their Industrial Funding Fee (IFF) and Contractor Access Fee (CAF). SRP integrates with GSA Pegasys and the Department of the Treasury’s Pay.gov system to accept and reconcile financial transactions related to the IFF and CAF. These include the migration of Contract Payment Reporting Module (CPRM) data to the Sales Reporting Portal (SRP).

○ The SRP will add functionality to meet the sales reporting and payment of Contract Access Fees (CAF) needs of active Multi-Agency Contracts (MAC) and Government-Wide Acquisition Contract (GWACs) contracts currently in ASSIST’s CPRM. This will enable (CPRM) to be shut down and FAS’s industry partners will have a single system to report sales across FAS contracts. IBM is building out functionality in SRP to allow the active contracts and orders to be migrated from CPRM into SRP. This is work that cannot be interrupted at this time.

● eOffer, a web-based application that allows vendors to prepare and submit their GSA Schedule offers and contract modification requests electronically.

● The Digital Experience suite of applications, which provides tools and resources for the Federal acquisition community to conduct market research and identify suitable contracts.

● CALC+ is where prices paid data is made available to the acquisition workforce, program managers, and industry to support fair and reasonable price determinations, IGCE development, and competitive Task Order pricing intelligence. To gain the efficiencies of mapped MAS labor categories to BLS standards, market thresholds must be made available to the AWF in CALC+ along with the associated enriched prices paid data.

Both of these capabilities enable access to TDR data and a significantly more efficient process of determining labor hour pricing fair and reasonable. This work has only recently begun and also cannot be interrupted.

The complexity and interconnected nature of these applications means that service disruptions would cascade beyond technical issues, creating a Government wide service disruption. Since the GSA IT system hosts essential acquisition applications utilized by various agencies, any downtime would directly impede or halt the ability of federal departments to obtain goods and services to meet their organizations' needs, potentially leading to stop work conditions and potential breaks in service. This disruption could delay necessary purchases, impact contracts, slow down mission-essential Government programs, and ultimately undermine the efficient functioning of the federal government's contracting mechanisms.

The incumbent contractor is essential for ensuring the uninterrupted operation of Government-wide acquisition systems. The required services are specialized, and only the incumbent contractor possesses the capabilities and system knowledge necessary to perform them with the quality and continuity required to sustain the Federal Government’s online procurement systems. The six-month extension is also necessary while the Government completes its consolidated and revamped Request for Quotation (RFQ) in August 2026.

v.) Determination by the Ordering Activity Contracting Officer that the Order Represents the Best Value Consistent with GSAR 538.7102-2(b)(4) (GSA Class Deviation

RFO-2025-FSS-GSAR 538):

In order to determine that the order represents the best value consistent with GSAR 538.7102-2(b)(4) (GSA Class Deviation RFO-2025-FSS-GSAR 538), the Contracting Officer will review the contractor's proposed labor categories, labor rates, and labor hours to ensure that pricing is consistent with the established rates under MAS contract GS-35F-110DA and remains fair and reasonable. The Contracting Officer will evaluate IBM's proposed pricing against the previously awarded Task Order rates, historical pricing for the Halley's COMET requirement, and any available market information for comparable MAS labor categories to ensure compliance with the requirement that ordering activities consider price reasonableness at the order level.

The Integrated Project Team (IPT) responsible for managing the current Task Order has successfully negotiated significant cost savings with the incumbent contractor, IBM. Specifically, the IPT was able to secure a labor rate reduction that will be applied to the Task Order. This crucial negotiation culminated in a formal commitment from IBM on June 26, 2025, where the company confirmed its willingness to extend a 3.5% rate reduction to the Task Order. This concession was made in direct response to recommendations put forth by the General Services Administration’s (GSA’s) Federal Acquisition Service (FAS) Commissioner. The primary objective of securing this labor rate reduction was to realize substantial cost savings for the Government without necessitating any reduction or alteration to the established scope of work under the existing contract. This achievement underscores the IPT's effectiveness in contract management and negotiation, ensuring continued service delivery while simultaneously optimizing taxpayer expenditure.

Based on this evaluation, the Contracting Officer will determine that the extension provides the best value to the Government, considering the need for continuity of services, avoidance of transition risk, and consistency with the rates established under the contractor’s MAS schedule.

vi.) Description of the Market Research Conducted Among Schedule Holders and the Results of the Research:

Market research determined that while multiple GSA MAS Schedule contractors are capable of providing general IT operations and application support services, none currently possess the incumbent’s institutional knowledge and system-specific experience with the Halley’s COMET environment. The Halley’s COMET environment supports more than fifty interconnected Acquisition IT applications that are actively used by GSA, customer agencies, vendors, and the public. These applications require continuous operations, maintenance, security patching, and minor enhancements to remain functional and available.

The incumbent contractor has performed these services over an extended period and has developed detailed familiarity with the applications, their technical architecture, and their operational interdependencies. This knowledge is critical to sustaining uninterrupted service delivery. Given the complexity of the environment and the limited time remaining prior to the expiration of the current Task Order, another contractor could not reasonably assume responsibility for these systems without a substantial transition period that would risk disruption to ongoing operations.

Accordingly, market research supports the conclusion that only the incumbent contractor is capable of maintaining uninterrupted Operations and Maintenance support for the Halley’s COMET systems during the FAR 52.217-8 extension period.

vii.) Any Other Facts Supporting the Justification:

The Performance Work Statement requires the contractor to submit a transition-out plan no later than ninety (90) days prior to Task Order expiration and to begin executing that plan no later than sixty (60) days before the end of performance. There is insufficient time to conduct a full and open competition, make an award, and complete a compliant transition in accordance with the PWS schedule before the current Task Order expires.

This constraint is further compounded by the fact that the Halley Task Order is undergoing a comprehensive revamp and may not be recompeted in its current form. Instead, it is being aligned with other GSA IT operations and maintenance requirements to increase competition.

The client plans to conduct market research activities, including industry days, to support the development of this new acquisition. It is anticipated that the recompete will be awarded in August 2026, with a possible start date in September 2026, to accommodate the required transition and any applicable protest periods.

Initiating a separate, short-term recompete solely for the interim period would be inefficient and counterproductive given that the full and open recompete is already underway. Accordingly, there is insufficient time for the current Task Order to transition to a new contractor while Halley’s revamp and integration efforts are being executed.

viii.) Statement of the Actions, if Any, the Agency May Take to Remove or Overcome any Barriers that Led to the Restricted Consideration Before Any Subsequent Acquisition for the Supplies or Services is Made:

A competitive acquisition for GSA Acquisition IT Services is currently under development, with an anticipated award in August 2026 and a planned start date in September 2026.

ix.) Contracting Officer Certification that the Justification is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

I hereby certify that this Justification is accurate and complete to the best of my knowledge, and I determine on the basis of the findings above that the limited sources approach is in accordance with the requirements and is in the best interest of the Government.

Tiffany Johnson Date Contracting Officer, AAS Civilian Assisted Acquisition Services x.) Evidence that any Supporting Data that is the Responsibility of Technical or Requirements Personnel and Which Form a Basis for the Justification Have Been Certified as Complete and Accurate by the Technical and Requirements Personnel:

Kari Namiot Date GSA IT, Office of Acquisition IT Services xi.) Written Determination by Approving Official Identifying the Circumstance that Applies:

I hereby certify that this justification is accurate and complete to the best of my knowledge, and I determine on the basis of the findings above that exercising the six-month option period, as already incorporated in the contract’s terms and conditions under FAR 52.217-8, is in accordance with the requirements and is in the best interest of the Government.

Contracting Officer, AAS Civilian Assisted Acquisition Services (AAS) xii.) Reviews/Approvals I have reviewed this justification and I have determined to the best of my knowledge and belief, based on the information contained herein, that it complies with all applicable policies and regulations.

Reviewed by:

Contracting Officer, AAS Civilian Assisted Acquisition Services (AAS)

Reviewed for Legal Sufficiency:

Ann Edmonds Date Legal Counsel, AAS Civilian Assisted Acquisition Services (AAS)