Amendment to Limited Sources Justification 2-10-26 (1).pdf

CUI//SP-SSEL

AMENDMENT TO LIMITED SOURCES

JUSTIFICATION (LSJ)

Logical Follow-On-Federal Supply Schedule (FSS) Order

IAW FAR 8.405-6(a)(1)(i)(A) Urgent & Compelling Need

Solicitation 47QFEA25Q0009

Sole Source Halleys IT Systems O&M in support of:

GSA Office of the Acquisition IT Services Office of the Chief Information Officer (CIO)

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 Amanda Ayers: amanda.ayers@gsa.gov

Version 11/25/2024

Docusign Envelope ID: 0449786A-0FF9-4C87-92B3-BFAE51DA0203 https://assist.gsa.gov/assist2-web/engagement/ia/package/47QFEA24S0006/overview mailto:amanda.ayers@gsa.gov

The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this Limited Sources Justification (LSJ) for orders pursuant to Federal Acquisition Regulation (FAR) 8.405-6.

i.) Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of the GSA Office of the Acquisition IT Services Office of the Chief Information Officer (CIO)

Contracting Activity:

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

The previous Operations and Maintenance Support Halleys’ COMET task order, 47QDCB19F0005, was a competitive action that was competitively solicited and awarded under MAS BPA 47QDCB19A0008. MAS BPA 47QDB19A0008 expired in July 2024. It was originally awarded to Sevatec on 27 September 2019, for a base and four option years. The task order was exercised in accordance with FAR 52.217-8 Option to Extend Services to extend the period of performance from 27 September 2024 through 26 March 2025.

In December 2022 2020, IBM acquired Sevatec, Inc. through its subsidiary, Octo Consulting Group. Sevatec’s current MAS contract expired in July of 2024. A task order along with a six month extension was issued off of the Sevatec MAS. The Bridge for this work was issued off of Sevatec’s parent company, IBM’s MAS contract GS-35F-110DA.

The current task order is a non-competitive bridge task order that was awarded under the authority of FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays. The original bridge contract was meant to be a one-year contract from 27 March 2025 to 26 March 2026. GSA had intended to recompete the Blanket Purchase Agreement for COMET with a COMET II BPA and had expected the new BPA to be awarded in or around the 4th quarter of 2025. However, due to new priorities in the Administration, the COMET II BPA was cancelled, causing the client and the procurement strategy to pivot. Our solution now is to extend a FAR 52.217-8, six month extension to the current bridge contract. In the meantime, a new competitive contract is currently in the market research phase with an expected award date of August 2026.

This Amendment for Limited-Sources Justification for other than full and open competition is being requested to incorporate an extension of the current Halley’s IT System Operations and Maintenance Support Bridge task order per the provisions of the clause entitled: Option to Extend Services (Nov 1999) (FAR 52.217-8) which has already been incorporated in the task order. While the clause was included, the pricing for the six-month extension was not included in the original bridge task order justification and approval. This amendment seeks to include the additional six-month extension to the one-year bridge contract. This is a Labor Hour type task order. The estimated ceiling price of this six-month extension is $17,560,022.90. Monthly labor rates of this extension are those quoted for the original one-year base of the task order and these rates were determined to be fair and reasonable at the time of the original task order award.

Version 11/25/2024

Docusign Envelope ID: 0449786A-0FF9-4C87-92B3-BFAE51DA0203 iii.) A Complete Description of Supplies/Services Required to Meet Agency’s Need (Including the Estimated Value):

The scope of this effort is to provide the GSA OCIO Acquisition IT Services organization with services that support the operation, maintenance, minor enhancements, moderate new functionality features and improvements without changing the direction/scope of the system.

The primary technical objectives of this requirement are as follows:

Objective 1 - Task Order Management Objective 1 Task 1 – Participate in a Program Kick-Off Meeting

Objective 1 Task 2 - Prepare a Monthly Status Report (MSR)

Objective 1 Task 3 - Create and Maintain Management Portal

Objective 2 – Transition Management Services Objective 2 Task 1 - Transition In and Operational Readiness

Objective 2 Task 2 - Transition Out

Objective 3 - Application Operations and Maintenance (O&M) Objective 3 Task 1 - Current Operations and Change Management

Objective 3 Task 2 - Environment(s)

Objective 3 Task 3 - Change Management

Objective 3 Task 4 - System Documentation

Objective 3 Task 5 - Release Management

Objective 3 Task 6 - Data and Database Management

Objective 3 Task 7 - AWS FAS Cloud Services Platform Management

Objective 3 Task 8 - Problem Management and Defect Resolution

Objective 3 Task 9 - User Training (As Needed)

Objective 3 Task 10 - Application Decommissioning (As Needed)

Objective 3 Task 11 - Regulatory and Minor Enhancements

Objective 3 Task 12 - Daily Operations

Objective 3 Task 13 - Information Assurance

Objective 3 Task 14 - Service Level Agreements (SLA)

Objective 3 Task 15 - Tools

The FAR 52.217-8 extension will add $17,560,022.90 for the six-month extension period, increasing the Task Order not-to-exceed value from $35,120,045.81 to $52,680,068.71.

iv.) The Authority and Supporting Rationale:

The acquisition is conducted under the authority of the Multiple-Award Schedule (MAS) Program. Consideration of schedule contractors will be restricted in accordance with:

a. FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays

Originally, a new BPA was underway with an anticipated award date of FY25 Q4. There would have been plenty of time to award a task order off of the BPA before the end of the one year bridge. FAS IT originally intended to immediately issue two task orders against the new COMET II BPA and replace the existing Halley’s task order.

However, due to new priorities in the Administration, the COMET II BPA was cancelled, causing the client and the procurement strategy to pivot. Our solution now is to extend a FAR 52.217-8, six-month extension to the current bridge contract. In the meantime, a new competitive contract is currently in the market research phase with an expected award date of August 2026.

Due to the nature and use of these, and other applications supported by this task order, it is in the best interest of the government to extend the bridge task order with an optional six month extension in accordance with FAR 52.217-8, which will also allow time for transition once the new task order has been awarded.

Funds are available to incrementally fund the extension of this bridge order.

v.) Determination by the Ordering Activity Contracting Officer that the Order Represents the Best Value Consistent with FAR 8.404(d):

vi.) The Bridge will be awarded using IBM’s GSA MAS schedule contract number GS-35F-110DA, effective December 21, 2020 through December 20, 2030. That MAS Contract includes ceiling rates and a price list that has already been determined to be fair and reasonable. The price list contains all supplies and services offered by a schedule contractor. The relevant services listed on the schedule are priced at hourly rates for the performance of specific tasks. Because prices in schedule contracts have already been determined by GSA to be fair and reasonable, ordering activities are not required to make a separate determination of fair and reasonable pricing prior to issuing an order against a schedule contract, however, ordering activities may seek additional discounts before placing an order. Additionally, doing a stand-alone, new task order affects execution risk and does not provide any cost savings to the Government. A new task order would be going to the exact same contractor, cause additional contracting work with the creation of new documents, files, and also cause additional burdens on funding streams.

vii.) A price comparison will be performed against both an Independent Government Estimate as well as the posted MAS SIN 54151S rates from IBM. The contracting officer has determined that adequate technical and pricing information is available to compare to the labor hours and rates proposed by IBM for this task order award. The Government will also analyze IBM’s proposed labor rates, labor mix and labor hours against the historical pricing for this work.

viii.)Description of the Market Research Conducted Among Schedule Holders and the Results of the Research: GSA has determined that IBM, Inc. is the only firm in the short term that has the required expertise and tools which are readily available to meet all of the government’s requirements in accordance with FAR 6.302-2. IBM has gained institutional knowledge of CIO systems through their work on the Halley’s COMET task order. The IBM bridge six-month extension is necessary because of the time required for the new competition and to avoid an interruption of services. No other firms have the capability or expertise in CIO systems that IBM possesses, nor could a new firm on-ramp quickly enough to deliver uninterrupted support to GSA prior to the systems transition to a new business platform.

ix.) Any Other Facts Supporting the Justification:

(a) Procurement History.

(1) IBM’s performance has been satisfactory throughout all periods of task order performance. Performance is considered highly acceptable and provides no basis for terminating this effort.

(2) Competitive status of the current contract: The current bridge contract was awarded on a sole source basis in accordance with FAR 8.405-6(a)(1)(i)(A). A new competitively solicited task order is in process with a planned base year and four option years. This award is planned for August 2026.

x.) 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 subsequent competitive acquisition is currently being developed and prepared with an anticipated award date of August 2026 in support of GSA OCIO Acquisition IT Services support services.

xi.) 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.

Amanda Ayers Date Contracting Officer, AAS Civilian Assisted Acquisition Services

Version 11/25/2024

2/11/2026 xii.) 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 an urgent and compelling need exists and is in accordance with the requirements and is in the best interest of the Government.

Kari Namiot Date Program Manager Office of GSA IT xiii.)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.

Wei Lu-Gin Date Supervisory Contracting Officer, AAS Civilian

Assisted Acquisition Services

Lawrence Unger Date AAS Civilian Sector 1, Division 1 Contracting Director

Kim McFall Date

AAS Civilian Sector 1 Program Division Director

Docusign Envelope ID: 0449786A-0FF9-4C87-92B3-BFAE51DA0203

2/12/2026

2/11/2026

2/12/2026

2/13/2026

Mark Johnson Date

AAS Civilian Sector 1 Director

Ann Edmonds Date

GSA Office of General Counsel

Jacqueline Sullo Date

Competition Advocate

Deputy Client Executive, AAS Civilian

Darrick Early Date

Client Executive, QFC AAS Civilian

Docusign Envelope ID: 0449786A-0FF9-4C87-92B3-BFAE51DA0203

2/12/2026

2/13/2026