47QFWA25Q0005_NAVFAC Bridge JETFO Fully Signed Redacted_2025-04-29.pdf

CUI//SP-SSEL

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JUSTIFICATION FOR AN EXCEPTION

TO FAIR OPPORTUNITY UNDER

INDEFINITE DELIVERY/INDEFINITE

QUANTITY (IDIQ) CONTRACTS

Solicitation 47QFWA25Q0005

Digital Transformation Services

(NAVFAC CIO DT) – Follow-On in support of:

The Naval Facilities Engineering Command (NAVFAC)

Command Information Office (CIO)

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

Federal Acquisition Service

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

Interagency Agreement Number 47QFMA20S0008

Controlled by AAS Contracting Officer

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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 NAVFAC, CIO

Contracting Activity:

General Services Administration, Federal Acquisition Service AAS Air Force / Navy / Space Force, Sector 3, Division 1 Branch C 819 Taylor Street Fort Worth, TX 76102

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

This requirement will result in a new interim Task Order in support of NAVFAC CIO. To better align with Federal, Department of Defense (DoD), and Department of Navy (DON) cybersecurity guidelines and mandates, and as part of NAVFAC’s overall digital transformation strategy, NAVFAC HQ seeks business system modernization and business intelligence support. The resultant Task Order will provide services to help evaluate the existing data management practices and Information Technology (IT)/Operational Technology (OT) infrastructure and establish a more robust infrastructure that includes data management, data analytics, IT/OT modernization support, and innovation to help with improved decision-making, more predictive analysis and risk management, and the establishment and sustainment of a common data governance model across the organization. Upon approval to use the exception to fair opportunity procedures of FAR 16.505(b)(2)(i)(C), GSA intends to award an interim Task Order for a 6-month base period with one 6-month option period (via FAR 52.217-8) under Alliant 2 Government-Wide Acquisition Contract (GWAC) 47QTCK18D0029 to Deloitte Consulting LLP, Cage Code1TTG5, 1919 North Lynn Street Arlington, VA, 22209-1742.

c. Description of Supplies/Services and Estimated Value:

The severable services Task Order will be awarded on a Time and Materials (T&M) basis with a Direct Reimbursable CLIN for Travel and a Direct Reimbursable CLIN for the Contract Access Fee (CAF). The GSA’s Alliant 2 GWAC will be utilized. NAVFAC necessitates a common data management framework that includes reach back to current stand-alone, sensitive, and authoritative data sources. As part of this initiative, NAVFAC requires support to perform tasks such as governance and policy; data modeling, simulation and management, and the use of data analytic techniques using common reporting tools; data mining and data reporting; and data integration. This initiative will

Version 02/28/2025 Page 3 assist NAVFAC in leveraging both existing and emerging Information Technology platforms to manage complex and disparate datasets and present data in dynamic and innovative fashion.

Federal, DOD, and DON Cyber security mandates and guidelines that include DoDI 8510.01 and SECNAVINST 5239.3B to transform and enhance NAVFAC’s data analytics approach must be followed.

The Independent Government Cost Estimate (IGCE) for this requirement is $26,452,787.34 (inclusive of CAF and GSA fee). The performance period is anticipated to consist of a 6-month base period and (6) six-month option period (via FAR 52.217-8), estimated to begin on or around May 29, 2025. This requirement will provide for an interim Task Order for up to a year to allow GSA to solicit and award a longer term (5 year) new Task Order.

Period Period of Performance Value

Base Period 5/29/2025 - 11/28/2025 $13,226,393.67

Option Period 1 (FAR 52.217-8) 11/29/2025 - 05/28/2026 $13,226,393.67

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

This Task Order (TO) Justification is being prepared as required by FAR 16.505, Exception to Fair Opportunity Process.

The rationale is:

The order must be issued on a sole-source basis in the interest of economy and efficiency as a logical follow-on to an order already issued under the contract, provided that all the contractors were given fair opportunity to be considered for the original order (FAR 16.505(b)(2)(i)(C)).

Background GSA Federal Acquisition Service (FAS) legacy Mid-Atlantic Region 3 initially established the current Task Order (47QFMA20F0038) for a 5-year period originally expiring September 29, 2025. This was later revised (via Modification P0040, signed 16 Sept 2024) to a conclusion date of May 28, 2025, due to significant ceiling increase (in excess of doubling the original ceiling). There were two modifications issued under the current task administered by Region 3 that significantly increased the ceiling of the task as noted below:

Modification P00029 (executed 9/23/2003), increased the ceiling $19,822,651.92.

This action was justified via an Exception to Fair Opportunity (ETFO), supporting the modification, which also incorporated a revised PWS and extended the task for 12 months (09/29/2023 through 09/28/2024). This action supported the then-current needs of the NAVFAC Program. The rationale for this modification was a change in

Version 02/28/2025 Page 4 the Navy’s organizational responsibilities (Navy Bulk Fuel Program), which were being transferred to NAVFAC CIO. The ETFO states:

“The Government requires an extension due to a memorandum of action that was released by the Chief of Naval Operations (CNO) in April 2023, (“Action

Memorandum”). The memorandum identifies duties that were traditionally held by various Navy organizations that are now being transferred to NAVFAC.

The memorandum triggered a halt to requirements development as the unexpected change will result in a substantial undertaking to research, collaborate, and develop the final scope of the recompete action. The determination of mission tasks will have a significant impact on the Performance Work Statement activities for the recompete acquisition. The extension will allow NAVFAC to continue to support its current mission while it defines newly assigned duties.

The extension will provide the Government with a year to develop final iteration of the solicitation documents and award the recompete. The final solicitation package will encompass fundamental organizational operating model changes that are outlined in the Action Memorandum, and the systems and processes that support current and future operating models command and control structure.

Modification P00040 (executed 9/16/2004), accepted Deloitte's “Revised Proposal”, dated 17 June 2024, for a revised, 8-month Period of Performance (09/29/2024 - 05/28/2025) in the amount of an additional $13,500,893.29. The supporting documentation for this extension is filed in the electronic contract file under Modification P00041. The following is an excerpt from the justifying ETFO under Tab 40 filed under Modification P00041:

“The Government intends to issue a modification to extend GSA Alliant 2

Contract No.: 47QTCK18D0029, Task Order No.: 47QFMA20F0038 with

Deloitte Consulting LLP by 8 months (29 SEP 2024 through 28 MAY 2025) to support the current needs of the NAVFAC Program. The purpose of subject extension is to prevent a break in service while providing the Government the necessary time to award the follow- on competitive task order. The total 8-monthestimate of the modification extension is $13,000,000.00, which is estimated to increase the potential ceiling from $50,228,281.75 by $13,000,000.00 to

$63,228,281.75.”

These modifications created ceiling limitations which would prevent work being performed throughout the entire duration of existent PoP.

Bridge Award The subject award will be a Bridge between the current Task Order, and a full, 5-year follow-on award. The justification for the subject Task Order being a bridge is that the government cannot experience a lapse in service, which would leave the NAVFAC CIO without essential IT, Cybersecurity, and regulation-required revisions

Version 02/28/2025 Page 5 to current operating practices. This delay would result from (1) the full-recompete process taking time (due to the shortened current Task Order’s PoP) and (2) the inability for the client organization to finalize and crystalize program requirements (resulting from said regulation-required revisions within the remaining award ceiling or PoP. Accordingly, a lapse in service would seriously compromise NAVFAC’s ability to fulfill their mission requirements of “… Geo-spatial Information & Services

(GI&S) support Encroachment Management, Air & Range Installation Compatible

Use Zone planning, Planning and facilities management services to Regional and

Installation Commanders, Integrated Product Support (IPS) for current and future war fighting systems, Facility Asset Data management.”

(NAVFAC Mission Statement)

Currently the NAVFAC is internally pursuing mission-fulfillment options; including finalization of the organizational changes referenced above. While NAVFAC was initially under agreement with GSA to compete and award the follow-on requirement, recent Executive Orders and pauses on certain efforts have required the effort to be brought in-house by the Navy. Accordingly, the follow-on effort is currently the responsibility of the client.

Sole-Source Justification, in accordance with FAR 16.505(b)(2)(i)(C) The subject Task Order must be “… issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.”

Per this rationale, the subject Task Order must be in the interest of (1) Economy, (2) Efficiency and, (3) all awardees must have been given fair opportunity to be considered for the original / current Task Order.

Economy, Efficiency, and Logical Follow-On Over the course of the current Task Order the original awarded value has increased from $30,405,747.11 to $63,729,175.04, an increase of $33,323,427.93; or more than double the original awarded amount.

This is primarily due to a dramatic expansion of requirement scope, executed in Modification P00029 (above), and further described in an MTF for Modification 40 of the current Task Order:

“Modification 29 was issued on 13 September 2023 to extend the duration of the contract to allow more time for NAVFAC to respond to emergent requirements from the Action Memorandum of the Chief of Naval Operations (CNO) dated

April 2023.

The revised responsibility of the CIO halted the recompete efforts of GSA’s acquisition team, which had been working towards a release of the solicitation of

Version 02/28/2025 Page 6 the requirements package. The CNO’s changes to the Navy environment would not be realized if the recompete was awarded without incorporating the new requirements. The previous solicitation package addressed the current operating model and did not support the analysis and evaluation of systems and processes outside of the shore environment which were integrated into the shore operating model.”

The current award has seen changes to the PWS (via revised responsibilities such as those identified in Modification P0040). Accordingly, these altered requirements must be carried forward into any resultant Task Order for a short duration, allowing the finalization of these “…emergent requirements…” and “… revised responsibilities…”. Accordingly, the subject, interim, short-term, sole-sourced Task Order comprises a “… logical follow-on…” in that the resultant subject Task Order

PWS is a direct continuation of work changes initiated under the current Task Order.

These are changes which need to be finalized before any resultant Task Order requirement/PWS can be fully stabilized. This will ensure that a subsequent, full 5-year follow-on award can be appropriately, competitively awarded with a crystalized and finalized understanding of these requirements.

As the client has worked through these changes (and continues to work through these changes) with the incumbent awardee, the awarding of a full follow-on at this point would require unacceptable delays to the program through ramping up a new awardee’s capability to assist with this transition.

Additionally, the rapidly changing requirement resulted in the evolution of the current Task Order from a Hybrid, Firm-Fixed Price and T&M type award, towards a model utilizing TDL’s, as described above. This has resulted in undue administrative burden on the government through the issuing and administering of nearly 100 TDL’s. The transition of the administrative model from its current TDL structure to a fully T&M structure, through collaboration with the current awardee, will allow the government to fully solidify its administrative model prior to competitively awarding a full, 5-year follow on Task Order.

Accordingly, the subject, short term Task Order is a “… logical follow on…” which will allow for (1) a finalization of the regulatory environment in which the requirement exists, while (2) also allowing for a transition of program administration away from the usage of TDL’s, while also providing required contractor coverage for a period of time sufficient to allow the establishment of a competitively awarded, 5-year award.

Additionally, this transition via a short-term, interim Task Order, issued to the current awardee represents the most “… economic…” and “… efficient…” means for the government to finalize this transition prior to competitively awarding a full term, 5-year award.

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Fully recompeting a 5-year contract at this time would not be in the best economic interest of the government, as revisions (as identified above) have the potential to result in further requirement revisions, beyond what could be reasonably anticipated vs a more finalized requirement; due to these “…emergent requirements…” and “… revised responsibilities…”

Accordingly, allowing the incumbent awardee to continue working with the client organization for the shortened Period of Performance via the subject award represents the best interests of the government relative to the administrative costs vs allowing this transition period.

Fair opportunity for all awardees in the “…original…” / current order A fair opportunity to compete was given under the original 47QTCK18D0029 / 47QFMA20F0038 for this requirement under this multiple award contract when proposals were solicited from the unrestricted pool of GSA Alliant 2 holders, and 2 proposals were received and evaluated on a Best-Value, Trade-Off basis. The relationship between the original competed order and this follow-on is logical because work to be completed under the subject Task Order will comprise of a continuation of the same work being carried out under the current, above-referenced Task Order, and as described above in Section C.

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

Actions anticipated to ensure fair and reasonableness of the incumbent awardee’s proposal will be in accordance with the procedures and criteria under FAR 15.4, Contract Pricing. Market research, including utilizing current Alliant 2 GWAC pricing tools and historic prices paid on the current order, will be utilized to ensure that the prices awarded under the follow-on are considered fair and reasonable. Also, the Alliant 2 Benchmark (Ceiling/Maximum) Labor Rates will be used to evaluate the proposed price. The market research conducted during the development of the Independent Government Cost Estimate (IGCE) established that the Government's need is best met by structuring this Task Order as a T&M. The Government Estimate was calculated by comparing the approved IDIQ contractual rates from the associated requirement for comparable labor categories/services with the current rates found under Alliant 2. The Government recognizes that although the risk of performance is higher in a non- fixed-price task at both CLIN and overall Task Order level, there will be adequate controls in place, such as a not-to-exceed ceiling price, overall contractor performance monitoring, and surveillance methods to assure quality and control costs. The GSA Contracting Officer anticipates a determination that the final award price will be determined fair and reasonable. The Contracting Officer will exercise reasonable business judgement in making such determination based on knowledge of previous acquisition and market conditions for these commercial items/services.

f. Other Facts Supporting the Justification:

There are no other facts.