47QFLA25F0017_JEFO_SIGNED_20250114_Redacted.pdf

CUI//SP-SSEL

Version 11/25/2024 Page 1

JUSTIFICATION FOR AN EXCEPTION

TO FAIR OPPORTUNITY

UNDER INDEFINITE

DELIVERY/INDEFINITE QUANTITY

(IDIQ) CONTRACTS

Solicitation 47QFLA25Q0003

USAF SAF/FM ELFF Support – Bridge Task

Order in support of:

United States Air Force – Financial Systems

Operations

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

Federal Acquisition Service (FAS)

Assisted Acquisition Services (AAS) Air Force/Navy/Space Force

Interagency Agreement Number 47QFLA11S0006

Controlled by: Jason.Miller@gsa.gov

Version 09/24/2024 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) 16.5.

a. Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of United States Air Force – Financial Systems Operations

Contracting Activity:

GSA AAS Contracting Office (QFBACC) 1800 F Street, NW Washington, D.C. 20405

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

The General Services Administration (GSA), Federal Acquisition Service (FAS), Assisted Acquisition Services (AAS) received a requirement from Secretary of the Air Force, Financial Operations SAF/FMF, Air Force Financial Systems Operations (AFFSO) Wright-Patterson Air Force Base (WPAFB), OH. This requirement will acquire non-personal technical support services that will function as a single focal point to the Government for the maintenance, sustainment, and enhancement activities for eFINANCE, LeaveWeb, FMSuite, and FMDQS (ELFF).

This procurement is to establish a 12-month bridge contract (one 6-month base period + one 6-month option period) to support the timely financial operations and facilitate greater performance and availability of the current ELFF systems that supports nearly 500,000 users. Task order 47QFLA24F0019 was awarded on 2 January 2024 to provide support for five years (base + 4 option periods), but due to an ongoing protest, this bridge contract will continue support services until the protest is completed. On 12 January 2024, a protest was submitted by Octo Consulting Group LLC to the Government Accountability Office (GAO). Octo Consulting Group LLC claimed the Government improperly awarded the task order to CAN SoftTech, Inc. via a flawed evaluation of both offerors' quotations. Upon receipt of the GAO protest, the GSA Contracting Officer concluded that a corrective action will be required to re-evaluate the offerors quotes. The GAO notified GSA it had formally dismissed the Octo GAO protest in response to the GSA corrective action on 31 January 2024.

On 1 February 2024 - 4 April 2024, the GSA Contracting Officer and the client, Air Force Financial Services Office (AFFSO), conducted a re-evaluation of the quotes.

During the re-evaluation, questions regarding the PWS and RFQ were discussed and it was determined that revisions would need to be made to both the PWS and RFQ.

Therefore, due to the revisions needed within the PWS and RFQ, the GSA CO determined that a termination for convenience would be in the Government's best interest. The GSA Contracting Officer issued the termination for convenience letter (task order 47QFLA24F0019) to CAN SoftTech, Inc. on 25 June

Version 11/25/2024 Page 3

2024. On 1 July 2024, shortly after receipt of the termination for convenience letter, CAN SoftTech, Inc. filed a protest in the U.S. Court of Federal Claims (COFC).

To date, no final ruling by the COFC regarding CAN SoftTech, Inc.'s protest has been made. As of this writing, discovery issues are ongoing and a final decision is not expected for months. The issuance of a 12-month bridge contract (one 6-month base period + one 6-month option period) allows time for a final decision from COFC as well as time for the issuance and award of a competitive action. Once the COFC decision is made, the CO will proceed with the competitive solicitation.

Until the CO can proceed with the competitive solicitation, the approval of an exception to fair opportunity and award to the current contractor, Octo Consulting Group LLC is required.

Contractor Information

Octo Consulting Group LLC 10780 Parkridge Blvd FL 4 Reston, VA 20191-4373

UEID: X5V6UB9HVCD8

It is noted that as of December 2022, Octo Consulting Group LLC was acquired by International Business Machines Corporation (IBM - UEI: VV9KH3L99VE3) via a novation. In August 2024, all contracts awarded to Octo Consulting Group LLC being novated to IBM were submitted to the Defense Contract Management Agency (DCMA).

All Octo employees and assets were transferred as of January 2024. The anticipated effective date for Octo to officially become IBM is 1 January 2025. This bridge task order will be awarded between 1 January 2025 and 31 January 2025. Therefore, the awardee on the bridge task order will be IBM.The following is IBM contractor information and will be shown as the awardee of this task order:

International Business Machines (IBM) 6710 Rockledge Dr.

Bethesda, MD 20817-1834

UEID: VV9KH3L99VE3

c. Description of Supplies/Services and Estimated Value:

The Contractor shall function as a single focal point to the Government for the maintenance, sustainment, and enhancement activities for EFINANCE, LEAVEWEB and FMSUITE and FMDQS. In addition, the Contractor shall be responsible for supporting any integration activities of EFINANCE, LEAVEWEB, FMSUITE and FMDQS modules with future AF Enterprise resource Planning (ERP) effort, Business Enterprise Architecture (BEA), and Standard Financial Information Structure (SFIS) and cloud computing.

The Contractor shall:

Version 11/25/2024 Page 4

● Design, code, unit test, formal test, and implement BEA/SFIS as required and cloud

Computing EFINANCE, LEAVEWEB and FMSUITE requirements.

● Provide software maintenance, enhancement and sustainment support for EFINANCE, LEAVEWEB and FMSUITE

● Provide training documentation used to develop training materials for EFINANCE, LEAVEWEB and FMSUITE

● Provide second and third tier Help Desk support for the functional and technical user community

● Operate, maintain, and administer systems in a virtual environment, current operating system (OS), database (DB), web server (WS) and utility software

● Not cross utilize personnel between firm fixed prices tasks and labor hour tasks

Estimated Ceiling is as follows:

- Base Period: $2,949,904.41

- Option Period: $2,949,904.41

Total: $5,899,808.82

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

This Task Order (TO) Justification is being prepared as required by GSA-FAS-AAS in accordance with:

- FAR 16.505(a)(4)(i), and in accordance with the format prescribed by FAR 16.505(a)(4)(ii)

- FAR 16.505, Exception to Fair Opportunity Process

- Defense Federal Acquisition Regulation System (DFARS) 216.505-70, Orders Under Multiple Award Contracts

- Procedures, Guidance and Information (PGI) 216.505-70, Orders Under Multiple Award Contracts

- FAR 17.204, Options, Contracts

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

The need-by date of this bridge task order to be awarded is no later than 1 February 2025. The recompete award (47QFLA24F0019) has been terminated as part of the corrective action GSA proposed to take as a result of a protest. If this requirement took the normal competitive acquisition route, 6-8 months would be required and a lot of tax payer dollars spent, the client will be at risk of losing $5.8M of funding without a support contract in place. The client has a budget/estimate that the agency will need $491,651 per month for 12 months for labor totaling $5.8M. If there's no bridge contract in place, then the client cannot obligate the budgeted funds. The funds

Version 11/25/2024 Page 5 would be left unearned and the client would be at risk of losing the budgeted funds to other programs. Additionally, if a lapse in coverage happens due to this bridge task order not being awarded in time, four separate financial systems will be locked out (FMSuite, Leaveweb, EFinance and FMDQS) and all Air Force personnel will be affected. Without these systems, the ability to manage entitlements (pay and leave) for Air Force personnel will be lost.

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

Adequate pricing information is available for the Contracting Officer to determine that the anticipated cost to the Government for the services covered by this bridge contract will be fair and reasonable. The Government estimate is based on the existing labor rates and labor categories on the incumbent (Octo Consulting) task order 47QFRA18F0054.

The GSA Contracting Officer will determine the cost for the bridge period to include labor rates and labor hours as fair and reasonable.

f. Other Facts Supporting the Justification:

In accordance with FAR 10.001(a)(2), which governs that market research appropriate to the circumstances must be conducted. Appropriate market research was performed under task order 47QFLA24F0019 for the exact same services, which showed that numerous companies were interested in performing these services. However, none would have the ability to perform these services without a proper transition to ensure there is no gap in service. Because this market research was documented within the past 18 months at the time of the market research phase of this bridge task order, a new Market Research Report (MRR) was not created and the MRR from 47QFLA24F0019 is being used at the MRR for this requirement. The Contracting Officer has annotated this in a Memorandum For Record (MFR) and it is filed in Tab 4 in the electronic contract file.

g. Statement of Actions:

This bridge contract will allow time for the Court of Federal Claims protest decision and a subsequent competitive solicitation.