47QFEA25Q0009 Limited Sources Justification 2025-02-26.docx (1) (2) (1).pdf

CUI//SP-SSEL

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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

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

Docusign Envelope ID: 3FDB085B-C59A-44D1-AF05-3393F1D459B0 https://assist.gsa.gov/assist2-web/engagement/ia/package/47QFEA24S0006/overview mailto:amanda.ayers@gsa.gov

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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

Contracting Activity:

GSA AAS Contracting Office

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

This Limited-Sources Justification for other than full and open competition is being requested to implement a bridge contract from 27 March 2025 to 26 March 2026, for the Operations and

Maintenance Support Halleys’ COMET task order. The current task order, 47QDCB19F0005, is 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. This is a Labor Hour type task order. The estimated ceiling price of this extension is $33,952,946.00.

In December 2022, 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 will need to be issued off of IBM’s MAS contract GS-35F-110DA. IBM MAS contract GS-35F-110DA provides identical services and all of the Sevatec employees have signed employment agreements with IBM for this

IT work. While GSA intends to recompete the MAS BPA Comet as Comet II, because of its complexities and to ensure services are not interrupted, GSA will be issuing a bridge to IBM until the new MAS BPA Comet II competition has been issued and awarded, on or around 4th quarter of 2025. Accordingly, GSA must use the IBM MAS contract for the bridge for the O&M

Support for Halley’s COMET task order.

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 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

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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 estimated value of this acquisition is $33,952,946.00 with a one-year base period (27

March 2025 through 26 March 2026).

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

The establishment of a new MAS BPA is underway but due to the complexity, volume, and dollar associated with it, the anticipated award date is Q4 of 2025 with time to ramp on before the end of the one year bridge. FAS IT intends to immediately issue a task order against the new COMET BPA to replace the existing Halley’s task order.

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Due to the timeline of this new acquisition, FAS IT is requesting a one-year bridge be put in place to ensure the continuity of services provided by the incumbent contractor. IBM is currently supporting over 50 applications, both internally and externally facing, that require routine maintenance, security patching, and enhancements. A break in contract support could cause disruption to any/all of these applications, which would be detrimental to the mission of all supported programs and their daily operations, for example:

● The GSA Advantage suite of systems, which currently provides ordering capability for more than 1 million GSA supplied items and more than 65 million GSA and VA

Schedule products and services from 16,000 vendors, has processed more than 10 million orders for more than $8 Billion to date.

● The Sales Reporting Portal (SRP) is used by FAS vendors to report transactional sales data from their contracts and to pay their Industrial Funding Fee (IFF) and Contractor

Access Fee (CAF). SRP integrates with GSA Pegasys and the Dept. of Treasury’s

Pay.gov system to accept and reconcile financial transactions related to the IFF and CAF.

● eOffer is a web based application that allows vendors to prepare and submit their GSA

Schedule offers and GSA Schedule contract modification requests electronically 24/7.

● The Digital Experience suite of applications provides tools and resources for the entire federal acquisition community, making it easier to conduct market research and identify suitable contracts.

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 task order by a one-year bridge, which also allows ample time for transition once new task orders have been awarded.

Since the dollar value of this action is $33,952,946.00 this justification will require the approval of the Head of the Procuring Activity or designee, as prescribed in FAR 8.405-

6(d)(3) “For a proposed order or BPA with an estimated value exceeding $15 million, but not exceeding $75 million … the justification must be approved by (i) The head of the procuring activity, or (ii)(B) if a civilian is serving in a position in a grade above GS-15 under the

General Schedule”. Funds are available to incrementally fund this bridge until transition is complete.

v.) Determination by the Ordering Activity Contracting Officer that the Order

Represents the Best Value Consistent with FAR 8.404(d):

● The Bridge will be awarded using IBM’s GSA MAS schedule contract number GS-35F-

110DA, effective December 21, 2020 through December 20, 2025. 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

Version 11/25/2024 schedule contract, however, ordering activities may seek additional discounts before placing an order.

● A price comparison will be performed against both an Independent Government Estimate as well as the posted MAS SIN 54151S rates from IBM and other SIN 54151S competitors. 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.

vi.) 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 FAR 8.405-6(a)(1)(i)(A) Urgent and

Compelling. IBM has gained institutional knowledge of GSA IT systems through their work on the Halley’s COMET task order. The IBM bridge 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 GSA IT 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.

vii.) Any Other Facts Supporting the Justification:

(a) Procurement History.

(1) Sevatec’s and 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 task order was competitively awarded, following receipt and evaluation of six competing offerors, with a base year and four option years.

(b) Current Situation - Reason for the bridge contract: The client has requested the use of a bridge contract. Both the task order and parent MAS BPA (“COMET”) have expired as of

September 26, 2024. The Option to Extend Services clause 52.217-8 extended the task order until March 26, 2025. The establishment of a new MAS BPA is underway but due to the complexity, volume, and dollar value associated with it, the anticipated award date has been delayed and is not expected to be awarded until the 4th Quarter of 2025. After this award is made, FAS IT intends to immediately issue two task orders against the new COMET MAS BPA to replace the existing Halley’s task order. Due to the timeline of this new acquisition, FAS IT has requested that FAR 8.405-6(a)(1)(i)(A) – be implemented as any disruption in services would be detrimental to the mission of all supported programs and daily operations.

Version 11/25/2024 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 subsequent competitive acquisition is currently being developed and prepared with an anticipated award date in 4th quarter of 2025 in support of GSA Acquisition IT Services support.

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.

Amanda Ayers Date

Contracting Officer, AAS Civilian

Assisted Acquisition Services x.) Written Determination by Approving Official Identifying the Circumstance that

Applies:

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

Program Manager

Office of GSA IT xi.) 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.

Eben Greybourne Date

Supervisory Contracting Officer, AAS Civilian

Assisted Acquisition Services

3/5/2025

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Lawrence Unger Date

AAS Civilian Sector 1, Division 1 Contracting Director

Mark Johnson Date

AAS Civilian Sector 1 Director

Ann Edmonds Date

GSA Office of General Counsel

Jacqueline Sullo Date

Deputy Client Executive, AAS Civilian

Darrick Early Date

Client Executive, QFC AAS Civilian

3/5/2025

3/5/2025