JOFOC- GSA AAS ARCWERX 47QFSA24R0005_Redacted.pdf

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

One Acquisition Solution for Integrated Services (OASIS) Small Business (SB) Pool 6 Contracts:GS00Q14OADS739, GS00Q14OADS713, 47QRAD19D7002,47QRAD20D7002, and GS00Q14OADS721 Federal Acquisition Regulation (FAR) 6.302-2, Unusual and Compelling Urgency

1. BACKGROUND

The Office of Professional Services and Human Capital (PSHC) manages the multiple award, multi-agency, complex professional services program known as the One Acquisition Solution for Integrated Services (OASIS) contract program, including all contract administration and program oversight. The OASIS Small Business (SB) master contracts were competed as a 100% total small business set-asides in 2013 under competitive procedures, and the contracts’ ordering period expires on December 19, 2024. While the contracts have a set ordering and performance completion period, the contracts do not have a maximum ceiling value.1

The purpose of the Competition in Contracting Act (CICA) is to encourage competition for government contracts with policy goals of increasing the number of competitors, reducing costs, and increasing small business opportunity. The OASIS contract program has been highly successful in achieving these goals. The customer agency procurement that is the subject of this justification and approval (J&A) achieved the competition the law seeks, but the ordering agency is taking longer to evaluate than anticipated. As such, the competitive process will extend beyond the OASIS SB deadline for placement of orders.

Allowing for task order completion by utilizing a statutory exception to full and open competition, the General Services Administration (GSA) can:

● Ensure the government carries out the statutory intent and policy objectives of CICA.

● Allow enough time for the competitive process to play out.

● Achieve better pricing because adequate competition has been received amongst several small businesses.

On the other hand, if GSA does not allow for task order completion, the ordering agency will be forced to:

● Award long sole source extensions, likely at higher prices.

● Waste the investments of small businesses who pursued this opportunity, making them less likely to compete in future government contracts.

1 Two deviations were signed prior to the release of the OASIS solicitations. Both were class deviations signed 07/24/2013 by GSA’s Senior Procurement Executive (SPE), and allow the performance period to exceed five years, and to allow “no-maximum ceiling value” for the life of the contracts.

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● Waste the investments the agency has made to procure this requirement.

This scenario leaves GSA with an unusual paradox. By invoking an exception to competition, the Government achieves competition; but, if GSA doesn't invoke the exception to competition, it ends up forcing the procuring agency into a sole source environment, the very thing CICA was striving to limit.

Given the goal of CICA, and the fact pattern explained herein,GSA has determined individual contract extensions to support the completion of the task order award is in the best interest of the government. Competition is achieved, the agency’s mission can be met, and the time and money spent on task order acquisition planning, market research, coordination, approvals, solicitation development, evaluation and award, will not be lost.

The OASIS contract extensions contemplated herein will ensure that the GSA Office of Assisted Acquisition Services (AAS) will have the time needed to complete their ARCWERX Research, Test, Evaluation, Modernization, and Innovation Support (ARTEMIS) task order procurement in support of the mission of the Air National Guard Readiness Center Innovation Office (ARCWERX). The GSA AAS contracting officer and program manager have documented their efforts to complete the procurement prior to the end of the current OASIS SB (Pool 6) ordering period.

The ordering activity provided written documentation to support their request to extend the ordering period for the OASIS SB contracts listed in this justification. The documentation in this justification explains why the requested extension to the ordering period for those OASIS SB contracts is critical to the ARCWERX’s mission, whichis to rapidly and efficiently research, develop, prototype, test, evaluate, procure, transition and field critical enabling technologies and capabilities that address immediate, near-term and mid-term threats to our national defense. As such, failure to approve the contract extensions for the OASIS SB contractors who responded to the ordering activity’s task order request for proposal (TORFP), will result in significant negative mission impact in the form of (1) a lapse of procured services resulting in the inability of the requiring activity to fully support their national defense mission, and (2) financial loss to ARCWERX.In summary, this justification documents the severe negative mission impacts that will be suffered by the Government if the extensions are not approved, forcing the work on the task order procurement to be abandoned.

To support this Justification and Approval (J&A) document, the ordering office provided documentation explaining why they may not have been able to award their TO before the current OASIS SB Pool 6 ordering period end date, and this information was specifically relied on in preparing this justification document. The action to extend individual OASIS master contractsdoes not allowcontractors impacted by thisaction to acceptany other OASIS SB ordersbeyond December 19, 2024, except the orderthat will result from the TORFP specifically identified in this document. As documented herein, the TORFP was competed among all 45 OASIS SB Pool 6 contractors who are in the applicable pool and the solicitation was issued during the original order period of the OASIS contracts, and closed prior to the end date of the OASIS SB original ordering period (December 19, 2024). All contractors who responded to the TORFP are all subjects of the individual extensions documented herein.

The specific action being supported in this justification will be to extend the ordering period on individual contracts held by contractors that responded to TORFP, which closed prior to the end date of the original ordering period. This action will only allow an order to be placed after

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December 19, 2024 under the specific TORFP issued by the agency identified herein. This action extends the individual contracts for those OASIS SB Pool 6 master contract holders, who responded to the TORFP and are still under consideration for award of the TO. The GSA OASIS SB Pool 6 master contracts were competed as a 100% total small business set-aside, and posted on Sam.gov (FedBizOps), in 2013 under competitive procedures.

The TO identified in this justification was competed under the applicable pool of contracts, and all 45 contractors in the OASIS SB Pool 6 were given fair opportunity to respond to the TORFP.

2. IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY

This justification supports the extension of certain (listed below) OASIS Pool 6 SB master Indefinite Delivery Indefinite Quantity (IDIQ) contracts on an individual basis. The Contracting Activity for the extensions of the OASIS SB Pool 6 master contracts is GSA’s PSHC Contracting Office, Division C. The highly complex, professional services TO is being issued by GSA AAS on behalf of the requiring agencyARCWERX. The TOis not being issued by PSHC’s Contracting Office, as such the dollar value of the TO is not a deciding factor in the approval of this justification.

The following are the OASIS SB Pool 6 master contract holders that responded to the fair opportunity TORFP solicitation issued by GSA’s AAS office on behalf of the ARCWERX customer by the solicitation closing date of July 15, 2024, and therefore these are the only interest parties/contracts/contractors whose masters contracts are impacted by the individual extensions supported by this justification and approval:

Contract Number Contractor Name UEI Code

These contractors submitted proposals on TORFP number 47QFSA24R0005 in support of GSA AAS, Acquisition Office for Air Force/Navy/Space Force Business Unit, Sector 1, Div 1, Branch C (ordering activity) requirement fromARCWERX locatedin Tucson, AZ and the mission partners listedbelow:

1. ARCWERX

2. Air National Guard Air Force Reserve Command Test Center (AATC)

3. Air Force Innovation Center (AFWERX)

4. Air Force Life Cycle Management Center (AFLCMC)

5. Air Force Research Laboratory (AFRL)

6. US Space Force (USSF) Space Systems Center (SSC)

7. Program Executive Office (PEO) Space Domain Awareness & Combat Power

(SDA/CP)

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8. PEO Battle Management Command, Control & Communications (BMC3)

9. Air Force Special Operations Command (AFSOC)

10. Air Force 361st Intelligence, Surveillance and Reconnaissance Group (ISRG)

11. National Guard Bureau

12. Navy Innovation Center (NAVAL-X)

13. Naval Surface Warfare Command (NSWC)

14. Office of the Secretary of Defense (OSD)

15. Air Force Nuclear Weapons Center (AFNWC) (Test & Evaluation Division)

16. Army Futures Command

17. Defense Innovation Unit (DIU)

All of the above organizations are impacted by the outcome of this justification.

This action authorizes the extension of individual contracts for those OASIS SB master contract holders who responded to the TORFP2, and remain under consideration for award of the task order.

This document serves as a justification for other than full and open competition in accordance with FAR 6.302-2, “Unusual and Compelling Urgency”;justified and approved in accordance with FAR 6.303 and 6.304.

3. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

The action being approved will extend the OASIS SB contracts listed in paragraph 2 by 30 days from their current ordering period, which expires on December 19, 2024, to a new ordering period end date of January 18, 2025. This extension will allow for TORFP evaluations to conclude and placement of the task order identified in this justification to be finalized. An additional 180-day ordering period “contingency option” will be included in the extension to accommodate protest resolution should a protest be filed against the task order. If a protest is filed and the outcome requires the issuance of a new solicitation (not an amended TORFP), the ordering contracting officer will not be able to utilize OASIS SB for the recompete. The 180-day contingency option period may be exercised, if needed, only to allow ample time for the protest and any corrective action to be resolved.

The date for completing performance of any resultant task order is December 19, 2029, which comports with the master contracts’ terms and conditions and authorized period of performance.

Prior to the award of the OASIS contracts, the GSA Senior Procurement Executive (SPE) approved a deviation to FAR 16.505 authorizing no maximum ceiling value for the contract and, therefore, there is adequate ceiling value to support any resultant task order award.

Furthermore, an unlimited number of task orders may be placed during the term of the master contracts.

The following is the AAS CO’s plan of execution will allow the following schedule to be carried out within the ordering period, if the ordering period is extended:

12/17/2024 - Award andUnsuccessful Notification Letter and Evaluation Statement (NLES) at the time of award

2 The subject task order was competed under the master Indefinite Delivery, Indefinite Quantity (IDIQ) OASIS SB’s Pool 6 contracts.

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12/20/2024 - Deadline to Receive Oral Feedback Meeting Request from Offerors (three Business Days)

12/27/2024 - Conduct Oral Feedback (within five days of receipt of the request)

12/31/2024 - Offeror Must Submit Additional Questions within Two Business Days from the Oral Feedback Meeting

01/03/2025 - Obtain Legal Review and Concurrence of Responses

01/06/2025 - Provide Written Responses to Follow Up Questions After an Oral Feedback Meeting, if Required, FAR Debriefing and Explanation Process has Concluded.

01/16/2025 - 10 Days After Debriefing Date (Timely Protest Period)

By January 16, 2025, AAS will know if a timely protest has been filed and if the contingency optional period is needed or not. At that time, the OASIS CO will be able to either exercise the option period modification to extend the ordering period, or the ordering period will end as of January 18, 2025.

GSA AAS, issued a TORFP in support of the work to be accomplished for the ARCWERX customer agency located in Tucson, AZ and its mission partners on June 3, 2024 with a closing date of July 15, 2024. The ordering activity made the award on December 16, 2024. Over the last several months, the AAS acquisition team has taken preventative measures to mitigate schedule risks to the maximum extent practicable; however, they are requesting an extension to the ordering period of the aforementioned contracts to facilitate complete evaluation, award, and resolution of protests, if applicable. While the GSA AAS office successfully awarded their TO within the current ordering period, it is important to note any potential protest will likely be filed after no new orders can be placed against the OASIS SB Pool 6 contracts. The risk of protest is heightened due to the substantial dollar value and high visibility of the requirement and the GSA AAS team is anticipating the order will be protested.3

4. DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS

The OASIS SB Pool 6 master contract scope is Research and Development, under NAICS 541715, Exception A (specific to Aircraft, Aircraft Engine and Engine Parts). The scope of the ARCWERX TORFP requirement is specifically for the acquisition of professional services that include program management, innovative research and development (R&D), subject matter expertise, software development and testing, digital engineering, aircraft and aerospace systems integration and testing, mission concepts of operation, training, and related special studies to demonstrate and assess aerospace and ground capabilities and techniques.

Additionally, the TO scope provides support to our nation’s defense systems by providing specialized R&D, technical, and programmatic support related to innovative technology enablers for aircraft and aerospace related military, intelligence, and counterintelligence missions to support the ARCWERX mission. ARCWERX mission also supports a vast number of other customers to include other Department of Defense (DoD) components as stated in Section 1.

3 An order of this magnitude (est. $636 million) presentsa significant opportunity for the competing OASIS SB contractors, increasing the likelihood award protests.

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ARCWERX is the Air National Guard and Air Force Reserve’s innovation hub. Initially established to manage innovation funding and related project tracking, it has expanded to provide innovation connection, education, and acceleration as well as organic software development. ARCWERX is uniquely positioned within the Air National Guard Air Force Reserve Command Test Center. This makes it the only innovation hub in the Air Force with direct access to developmental and operational test and evaluation assets and expertise as well as co-location with the only maintenance test flight in the Air Force.

This is a new requirement and there is no specific contractual history for this effort. Historically and presently (prior to redefining the requirements), the ARCWERX organization, and their current mission partners, aiming to utilize this ARCWERX acquisition, have used contract vehicles with focus areas including Test and Evaluation; Intelligence, Surveillance, and Reconnaissance (ISR); and a variety of other contracting actions, both organic and assisted acquisition, to execute their mission.

The ARTEMIS TO provides program management, innovative research and development, subject matter expertise, software development and testing, digital engineering, aircraft and aerospace systems integration and testing, mission concepts of operation, training, prototype test article development and limited procurement and related special studies to demonstrate and assess aerospace and ground capabilities and techniques. The scope includes providing specialized R&D, technical, and programmatic support related to innovative technology enablers for aircraft and aerospace related military, intelligence, and counterintelligence missions.

The TO shall provide ARCWERX and its mission partners with professional services technical deliverables to support crucial aircraft and aerospace collection system research, development, integration, and test; aircraft and related test platform leasing and logistics, subject matter expertise in tactics, techniques, and procedures (TTP), software performance evaluations and advanced technology scouting and assessments. Specific tasks under the ARTEMIS TO include:

● Program Management

● Systems Engineering, Digital Engineering and Technical Services

● Hardware and Software Rapid Prototyping, Testing, Integration and Evaluation

● Modeling and Simulation, and Performance Assessments

● Advanced Special Studies

● Education, Training, System Maintenance, and Tactics, Techniques, and Procedures (TTP) Development

The customer agency’s TO is estimated to be valued at approximately $636.6M. This dollar value is applicable to the TO only. This dollar value does not impact the review and approval requirements of this justification and approval document. This action covered under this justification is applicable to the master contract level only.

5. IDENTIFICATION OF THE STATUTORY AUTHORITY PERMITTING OTHER THAN FULL

AND OPEN COMPETITION

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The statutory exception to full and open competition is issued under 41 U.S.C. 3304(a)(2) as implemented by FAR 6.302-2, “Unusual and Compelling Urgency”.

6. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’SUNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF

AUTHORITY CITED

6.a.Market research efforts signified OASIS SB wasthe best method for satisfying this requirement.

The GSA AAS office performed a market survey and commerciality determination. As a result, it was determined that commercial services are not suitable to meet the highly complex ARCWERX ARTEMIS professional services requirements. When performing its survey of the market, the AAS acquisition determined that specialized technical services (custom application integration, system enhancements, and associated maintenance) which are required to meet the ARCWERX ARTEMIS requirements were not available in the commercial marketplace.

The ordering activity surveyed the Acquisition Gateway, GSA’s Multiple Award Schedule (MAS) Professional Services Schedule (PSS), GSA’s Best in Class (BIC) multiple award (MA) Indefinite Delivery Indefinite Quantity (IDIQ) ASTRO contract vehicle, and GSA’s BIC MA-IDIQ OASIS contract vehicle. After careful consideration of the ARCWERX requirements, its complexities, and review of the marketplace, the OASIS Small Business (SB) contract vehicle Pool 6 was selected as the best alternative to meet the Government’s needs.

There is no incumbent that has been performing this requirement; this is a new requirement.

6.b. Five contractors submitted proposals for this highly specialized and complex services requirement.

The contractors listed in paragraph 1 of this document are the only contractors who are eligible to provide the services identified in TORFP number 47QFSA24R0005 ARCWERX Research, Test, Evaluation, Modernization, and Innovation Support (ARTEMIS) TO, because they were the only contractors who responded timely to the solicitation when it was issued under the auspices of fair opportunity to all those who hold contracts in OASIS SB Pool 6. This extension of the ordering period for the specified individual contracts is necessary to provide enough time for the physical completion of the evaluation and protest resolution process for the award of ARTEMIS

TO.

While there are other contractors who provide these types of services on OASIS Pool 6, only the contractors who responded to the competitive solicitation through the OASIS SB Pool 6 fair opportunity process are in line for award under GSA AAS, Acquisition Office TORFP number 47QFSA24R0005. ALL OASIS SB Pool 6 contractors were given the opportunity to propose on the TORFP. No other contractors on OASIS SB Pool 6 expressed interest in competing for this requirement prior to the closing date of the TORFP.

6.c. Impact of not extending, and forcing user agencies to recompete the services.

The unusual and compelling urgency to extend the OASIS SB Pool 6 contracts named in this document stems from the OASIS SB ordering end date fast approaching (December 19, 2024), and the GSA AAS team needing additional time to complete their procurement, and move

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This action is justified because the agency appropriately spent over twelve (12) months conducting extensive market research and acquisition planning to solicit their requirements under OASIS SB Pool 6. The agency’s milestone plan and procurement activities document that the need to extend the OASIS SB contracts is not due to a lack of planning, but as explained herein, was due to circumstances beyond their control that became known after proposals were received. The extension ensures the contract ordering periods remain open on each of the contractor’s contracts (who respond to the TORFP) while the agency works through the protest process (if needed).

Failure to provide an extension to GSA OASIS contract ordering period will lead to mission failure for both GSA AAS and ARCWERX. The mission of GSA AAS is to award a TO, on behalf of the customer agency ARCWERX, for the specific complex services identified in the Scope of Work contained in the TORFP. Re-solicitation under a different contract vehicle at this time, after GSA AAS has spent 12 months being paid to work with the customer agency to conduct market research, develop the requirement and TORFP, and issue that TORFP, receive proposals and evaluate the proposals received in response to the solicitation, is unacceptable.

Abandoning the procurement will be damaging to ARCWERX because their requirements encompass services necessary to fully support their mission, and our Nation’s defense systems will be severely compromised, the full extent of which cannot be monetized.

In addition to time and resource impacts,one of theTechnical Direction Letters (TDL) in the queue for execution when the ARTEMIS TO is awarded is for AFWERX Prime. A TDL is a task that will be performed under the task order following award. AFWERX Prime manages research and development for advanced programs (Agility Prime, Autonomy Prime, and Integration Prime), focusing on automation and integration. These efforts are directly tied to such operational imperatives as tactical air dominance, global strike, readiness to deploy and fight, operational focused Air Battle Management Systems (ABMS), and moving target engagement.

Delay in award caused by not being able to extend the related OASIS SB Pool 6 contracts and having to re-solicit the requirement will result in a 70% loss of manning at AFWERX Prime causing stop work on the majority of these initiatives and significant delays in the fielding of critical advanced technologies.

Another TDL in the queue for execution when the ARTEMIS TO is awarded is for the 361st

Intelligence, Surveillance, and Reconnaissance Group (ISRG). The ISRG is responsible for development and deployment of advanced sensors responsible for intelligence collection for special operations. These efforts are directly tied to ongoing operational missions affecting both combat operations in various international theaters. The operational imperatives their efforts are directly tied to are moving target engagement, resilient basing, global strike, and readiness to deploy and fight. Delay in award will result in them losing 100% of their development team, resulting in a stop work, and will prevent on time fielding of critical sensors in aircraft such as the MC-12 and AC-130.

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If this procurement is abandoned, it will cause a break in service of a highly specialized and knowledgeable workforce which provides support for ARTEMIS and the program management, systems engineering, digital engineering, technical service, hardware and software rapid prototyping, testing, integration, evaluation, modeling, simulation, performance assessments, advanced special studies, education, training, system maintenance, Tactics, Techniques, and Procedures (TTP) development provided by this requirement. The expected outcome of the extension is to allow for retention of the highly skilled workforce and support for ARCWERX and its mission partners listed in paragraph 2 on a continual basis. Presently, there is not sufficient lead time to re-procure the services under the standard “open market” competitive acquisition processes.

If the program were to have to stop the acquisition at this point in time (when the agency is literally weeks from award), it will have the following negative impacts:

● Revising the acquisition strategy could take up to approximately 12 months or more, which will involve:

○ an estimated $3.8M in work hours will be lost4 (this is inclusive of the requiring agency activities, as well as the direct labor and travel charged by GSA’s AAS team, as described later in this document);

○ to develop a new budget package for approval (because the funding that has been approved will have been lost/expired due to non-execution of funding, which is highly unacceptable in the DoD – programs are to execute funds given to them timely, and for the approved requirement), and revise the market research conducted in support of the requirements as described herein;

○ to obtain senior official approval of the new acquisition strategy;

○ to issue a new solicitation and keep it open for 30 or more days;

○ to evaluate offers, which will take approximately 6 to 12 weeks to complete;

○ to obtain final approvals for the award.

The above timeline demonstrates how unacceptable it will be to abandon the current path forward. What is in the very best interest of the Government, in the interest of time, money and ensuring the warfighter is supported as required by the ARCWERX mission, is to extend the OASIS contracts so that the ordering period will remain open and the task order award completed.

7. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED

FROM AS MANY SOURCES AS PRACTICABLE INCLUDING WHETHER A NOTICE WAS

OR WILL BE PUBLICIZED AS REQUIRED BY SUBPART 5.2 AND, IF NOT, WHICH

EXCEPTION UNDER 5.202 APPLIES.

The individual OASIS SB contracts were synopsized in accordance with FAR Part 5.2, competed in accordance with FAR Part 15, and resulted in forty five (45) Pool 6 multiple award IDIQ contracts. This justification does not circumvent competition. There have been two levels of competition: the first, competition when the original OASIS SB contracts were awarded; and

4 Based on GSA’s Assisted Acquisition Services (AAS) office, which is an office that charges a fee for conducting acquisition services on behalf of other government agencies, estimates that it costs 3% of the total value of a task orders value to execute the full lifecycle of an order. In this case, the formula is 3% x 636M (TO estimated value) / 5 year total lifecycle = over $3.8M. Using this calculation, at this time the agency has spent over $3.8M to bring the procurement to the current stage in the life cycle.

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After TORFP number 47QFSA24R0005 was issued, five (5) OASIS SB Pool 6 contractors (identified in Section 2 of this document) submitted proposals.

8. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST TO

THE GOVERNMENT WILL BE FAIR AND REASONABLE

There is no additional direct cost to the government associated with the 30-day master contract extension, or the contingency option for the affected OASIS contracts. Pricing at the master contract level is restricted to sole source labor hour and time and materials type TOs, and is therefore not applicable to the TORFP because the order is competitive. Additionally, administrative costs to the government to maintain the contracts’ ordering periods is di minimis given contract administration for the entire OASIS SB contract program continues through December 19, 2029.

9. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS (see part

10) OR A STATEMENT OF THE REASON MARKET RESEARCH WAS NOT CONDUCTED.

The market research was conducted from August 2023 through February 2024. The following actions were taken which yield information considered during the market research:

● Knowledgeable individuals in Government and industry were contacted

● Government databases were queried for information relevant to procurement’s requirements.

● Participated in interactive, online communication among industry, acquisition personnel, and customer agencies. An eBuy Request for Information (RFI) posted on August 10, 2023 (closed on August 24, 2023) resulted in eight responses from OASIS SB Pool 6 contract holders, one response from OASIS Unrestricted Pool 6 and one response from an ASTRO contract holder.

The results of the market research led to a determination by the CO that the Government would receive adequate competition via GSA OASIS Small Business, Pool 6 and there was time to issue the solicitation and make the award timely. At that time, the contracting officer made the determination that this effort be set aside under OASIS SB Pool 6. On October 26, 5 GSA AAS performed extensive market research dating back to December 2023. A draft TORFP was released in Symphony and emailed to all 45 OASIS SB Pool 6 contract holders. On January 4, 2024, the Contracting Officer requested feedback from contract holders about whether or not they intend to propose. A total of seven companies responded that they intend to submit proposals) and one contractor responded that they may submit a proposal. In addition to the draft TORFP, instructions for obtaining optional access to a Virtual Resource Repository (VRR) were provided. The Government received 148 questions in VRR from six different companies in regard to the first draft TORFP. The Government used the questions and recommendations received to assess any adjustments that needed to be made to the requirement documents. On February 6, 2024, the Government provided written answers to all of the questions in both the VRR and Symphony. To date, two Draft TORFPs, and their respective attachments, have been loaded to the VRR, and shared with the 11 OASIS SB contractors that have requested access. All of the same documentation has been posted on Symphony to ensure all 45 potential Pool 6 offerors had access. A virtual industry day was also held on February 29, 2024 to share the latest information with industry participants and gather further feedback. Over 30 individuals attended the event, where the Government presented a mission brief, an acquisition overview, responses to pre-submitted contractor questions, and insights on future expectations.

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2023 the contracting officer posted an announcement to eBuy and Symphony to inform contractors of this decision.

10. OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION

GSA AAS had spent a reasonable amount of time and resources in acquisition planning, market research, and issuance of the solicitation to meet their customer’s urgent and complex requirements in a timely manner. The ordering activity incurred significant administrative costs in preparation for this complex TO. Resolicitation will result in a substantial duplication of cost and effort to compete a contract to support this specific requirement for ARCWERX ARTEMIS.

GSA’s AAS office provided the amount charged out to the federal agency for the labor hours of work performed thus far to put the acquisition strategy together, solicit and evaluate the offers received in response to the solicitation to-date, which is$800,249.00has been spent to date to put their TO in place. A detailed contract formation estimate of $800,249 was calculated by the GSA AAS team, in regards to the fees charged to the client agency for the work performed thus far.. This figure accounts for two full-timeequivalents(FTEs), each contributing 1,500 hours, resulting in a total labor cost of $795,249. A travel estimate of $5,000 was also included for the team to travel to the client for evaluation training.

To address the unexpected delays in evaluations, the contracting team took an additional trip to conduct in-person evaluations, aiming to expedite the process and highlight the importance of the timeline to the client. If the procurement process were to be restarted, the agency will forfeit the entire pre-award effort and associated time, as costs incurred will not be recovered and reprocurement expenses will continue to accumulate and the cost of this procurement will potentially double, significantly increasing the opportunity costs to the ordering agency.

Additionally, the agency has a bona fide need for the services to begin within the next month, and if an alternative approach is taken the mission requirements of the customer (ARCWERX) will not be met in a timely manner, with the delays causing severe consequences.Additionally, there are four mission partner agencies that have $60M allocated to these services that will be procured under the pending TO, which will potentially need to be reallocated if the ARCWERX TO cannot be placed against the OASIS SB Pool 6 contract vehicle. The funding approved for expenditure for this specific program could be lost by the agency, and this presents an unacceptable outcome because the budget approval will have to be defended and approved again. In addition, the agency will not be able to achieve their mission because they are unable to get the mission-required support services on contract, while they start the entire acquisition lifecycle over again. In addition to the mission readiness injury, ARCWERX estimates that failure to execute this order will result in serious loss of effort and financial injury to the Government upwards of $61.8M, which accounts for the rework Required to completely redo this procurement. The absolute need date for this requirement is as soon as it can be awarded considering they are already running behind their original planned schedule as a result of the organic procurement process, but not later than January 2025.

The purpose of this extension is to allow for the Agency to complete their work on the TO procurement. Additionally, it is not feasible - nor possible to consider any other contractor than the five identified herein to compete for, or be awarded a TO in adequate time to support the requirement, because they are the five who were in the OASIS SB Pool 6 and responded to the

TORFP.

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If GSA was to fail to authorize the extensions of the ordering periods for the specific of the impacted contracts, not only will the mission be significantly negatively impacted (there will be no services), but a recompete of the services will have to begin in earnest with other JOFOCs most likely being necessary. In short, other noncompetitive actions will be needed to support this requirement. By extending these contracts, competition, in practice, is maintained/fulfilled.

11. A LISTING OF SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST IN

THE ACQUISITION

The TORFP (47QFSA24R0005) was issued under OASIS SB Pool 6 on June 03, 2024.

The following OASIS contractors responded to the TORFP:

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12. A STATEMENT OF ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR

OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT

ACQUISITION FOR THE SUPPLIES OR SERVICES REQUIRED

The OASIS SB contracts are multiple-award IDIQ contracts, and the OASIS+ SB family of contracts are the follow-on contracts under evaluation at this time. GSA conducted a FAR Part 15 full and open competition to award the OASIS master IDIQ contracts in 2014, and the same process was utilized in soliciting OASIS+ follow on contracts. To date, the OASIS+ SB Contracts have not been awarded and are currently awaiting resolution of multiple protests. OASIS+ SB was projected to be awarded in July-August 2024, which would have allowed federal agencies to utilize the contract vehicle for their procurements. Agencies relied on these contracts being in place prior to the expiration of OASIS SB; however, due to circumstances beyond their control, these agencies had to weigh the risks of issuing their TORFPs under OASIS and completing TO awards prior to December 19, 2024, or waiting for OASIS+ to be awarded.

GSA is not a mandatory source for professional services and agencies have the option to choose the procurement vehicle that best suits their needs. GSA does not have the authority to hold agencies accountable to meet the agencies’ acquisition milestones and deadlines;

however, GSA has no intention of considering further extension of the contracts outside of what is described herein. This extension action is for the Government to finish their evaluation and award work only, and the the performance period for the class of OASIS SB Pool 6 is not being extended and shall end (on all awarded TOs) December 19, 2029.

Lastly, to minimize or eliminate the need for non-competitive extensions in the future, GSA will apply transition lessons learned to all follow-on GSA procurements for these types of services.

13. CERTIFICATIONS AND APPROVALS

TECHNICAL PERSONNEL CERTIFICATION:

I certify supporting data for this Justification for Other than Full and Open Competition, was provided by the responsible requirements owners from GSA AAS, Acquisition Office for Air Force/Navy/Space Force Business Unit, Sector 1, Div 1, Branch C. GSA fully relied on the information provided by the GSA AAS agency, who own the ARCWERX Research, Test, Evaluation, Modernization, and Innovation Support (ARTEMIS) TO requirement. The data which formed the basis for this justification has been certified as complete and accurate by the ordering activity’s technical or requirements personnel who provided the information herein and signed the GSA agency request form on file.

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CONTRACTING OFFICER CERTIFICATION AND APPROVAL:

I certify this Justification for Other than Full and Open Competition, in accordance with FAR 6.302-2, is accurate and complete to the best of my knowledge and belief.

___________________________ Date: _______________________ Daniel Trimboli,GSA Contracting Officer Office of Professional Services and Human Capital

Approvals:

___________________________ Date: _______________________ Kristi Irvin, Competition Advocate Office of Professional Services and Human Capital

___________________________ Date: _______________________ Tiffany T. Hixson, Head of the Contracting Activity Office of Professional Services and Human Capital

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