47QMCB25Q0010_DTA6_LSJ_Redacted_2025-06-03.pdf

Federal Acquisition Service

U.S. General Services Administration 1800 F Street NW Washington, DC 20405 www.gsa.gov

Limited Sources Justification

FAR 8.405-6

1. Identification of the agency and the contracting activity.

This requirement is an assisted acquisition conducted by the General Services Administration (GSA) for procurement of Travel Management Center (TMC) services in support of the Department of Defense (DoD) Defense Travel Management Office (DTMO).

Contracting Activity: General Services Administration (GSA) Federal Acquisition Service (FAS) Travel Acquisition Support Branch (QMACB) 1800 F Street, NW Washington, D.C. 20405

2. Nature and/or description of the action being approved.

The purpose of this limited sources justification is to support the award of a sole source task order to CW Government Travel, Inc. (CWT) for continued support in providing official TMC services for the United States Marine Corps (USMC), Defense Travel Area 6 (DTA 6). The Department of Human Health Services (HHS) Program Support Center (PSC) originally awarded contract HHSP233201700023I on May 31, 2017, to CWT for a period of performance from June 1, 2017, to May 31, 2020, to provide TMC services for DTA 6 USMC.

On June 14, 2019, HHS/PSC officially notified the DTMO by memorandum and email that it would be terminating its assisted acquisition program for non-HHS agencies. As a result, effective September 30, 2019, HHS PSC executed its termination of contract HHSP233201700023I. On October 1, 2019, GSA executed a bridge task order 47QMCB19F000A that continued services for DTA-6 USMC from October 1, 2019, to March 30, 2021.

On March 30, 2021, GSA awarded a new sole source task order, 47QMCB21F000C, to CWT to ensure a continuation of support services between old and new task order award. The sole source task order was awarded with a five (5) month base period and six (6) 1-month option periods and expired on September 7, 2022. This sole source task order was awarded to cover performance while a competitive procurement was solicited and awarded. The competitive re-procurement was delayed based on multiple protests at both the Government Accountability Office (GAO) and U.S. Court of Federal Claims (CofC) on a related acquisition, Army CONUS TMC services. In total, four (4) GAO pre-award protests were submitted on the re-solicitation of the Army CONUS acquisition. Additionally, there have been eleven (11) GAO protests on the DoD TMC Services acquisitions and one (1) protest to the U.S. Court of Federal Claims. These protests have caused significant delays and made it necessary to issue another limited sources task order for this requirement.

United States Marine Corps DTA-6 Limited Sources Justification

On September 8, 2022, GSA awarded a sole source task order 47QMCB22F000M to CWT to ensure a continuation of support services between old and new task order awards. The sole source task order was awarded with a seven (7) month base and two (2) 2-month options periods and expired on February 7, 2024.

During review of all DTMO TMC Task order security requirements in May 2023, the DoD Defense Human Resources Activity (DHRA) Security Office identified significant issues with current security language that was no longer in compliance with current policy. To ensure increased protection of Controlled Unclassified Information (CUI) with respect to the aggregation of military Personally Identifiable Information (PII), the DHRA Security Office requested significant changes to the security language for personnel and cybersecurity. These changes were in process for DTMO for approximately six months which required an additional sole source task order for DTA 6. This sole source task order, 47QMCB24F0005, was awarded on January 19, 2024, with an eight (8) month base and one (1) 2-month option period and will expire on June 7, 2025.

An additional protest was filed for the current full and open competition solicitation for the follow-on task order for this requirement. Because this has significantly delayed the award of the follow-on task order, an additional sole source task order is being requested.

The current limited source contracting action is pursuing a waiver from placing an order on a competitive basis pursuant to FAR 8.405-6(a)(1)(i)(A) which states that an urgent and compelling need exists, and following the procedures would result in unacceptable delays.

There is no alternative source that can meet the need for immediate uninterrupted travel services and mission readiness.

The requirement is above the simplified acquisition threshold and the estimated value is . The period of performance for this sole source effort will be for a total of three

(3) months, from June 8, 2025, to September 7, 2025. The purpose of this task order is to maintain continuity and provide official TMC services for DTA-6 while the Government finalizes the award of the competitive acquisition in support of this requirement. There is no alternative source that can facilitate the need for immediate uninterrupted travel services and mission readiness.

3. A complete description of the supplies and/or services required to meet the

The required TMC services are highly specialized and require familiarity with specific travel regulations and laws, including the Joint Travel Regulations (JTR), the Defense Transportation Regulations (DTR), and local Business Rules developed by each site, as well as interfacing

-to-end travel. Therefore, the TMC must have immediate capability to provide the required services as well as detailed knowledge of travel regulations and business rules to ensure traveler reservations are accurate, timely, and IAW with numerous policies and regulations. This requirement does not lend itself to a quick transition for a new contractor. The transition period, including implementation for a new contractor, is 90 days for OCONUS locations applicable to this requirement. The current task order expires on June 7, 2025. The award decision for the competitive acquisition is currently being finalized and award is anticipated by May 30, 2025, leaving insufficient time for the required implementation period.

In addition, DoD travelers often use a centrally billed account (CBA) to pay for travel. The Contractor provides assistance in reconciling these accounts monthly. The procedures for reconciling vary by service and also require knowledge of the procedures in place by the Defense Finance and Accounting Service (DFAS). This is a unique requirement to DoD that is not part of the travel requirements for the rest of the Federal Government. DoD travelers are mandated to use the Defense Travel System (DTS) to book all Temporary Duty (TDY) travel, which also requires familiarity by the Contractor. Further, the Contractor must be prepared to surge requirements. Surge support is somewhat specific to DoD and responds to contingencies including, but not limited to, national emergencies, accident investigations, aircraft recovery teams, evacuations, rescue operations, EXODUS travel, civil disturbances, disasters, military peacetime and wartime contingency operations, exercises, personal emergencies, holiday travel and mass casualties (human remains). The current incumbent contractor, CWT, has provided support in this area with immediate response and the ability to continue consistent services to all activities under the current task order. This further validates that they have the resources needed to maintain continuity of services to both the event at hand and normal day-to-day operations at all sites on this order.

It is imperative that these TMC services be continued with the incumbent contractor. Awarding to any source other than the incumbent contractor will severely jeopardize the continued

-critical services and result in unacceptable services to date, although there have been ongoing performance issues relating to help desk call response times and in person staffing. Plans are currently in place to track and improve support its travel requirements. To ensure that TMC services for the DTA 6 locations are uninterrupted, these services must be obtained from the incumbent contractor until such time as the re-compete utilizing full and open competition is completed. The incumbent contractor is the only vendor that can meet the requirement without significant disruption and delays to

4. The authority and supporting rationale (see FAR 8.405-6 (a)(1)(i)(A) - An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

Due to the circumstances noted above, it is imperative that the TMC services are continued with the incumbent contractor. It is not feasible to complete a transition of services from the incumbent contractor to a successor contractor prior to the expiration of the current task order.

The incumbent has the re JTR, DTR, and other travel related policies; established DTS Passenger Name Record (PNR) validation; established centrally billed accounts and reconciliation processes specific to the customer; and customer centric Global Distribution System (GDS) agreements and profiles for CONUS and OCONUS which require 60 days (CONUS) and 90 days (OCONUS) for implementation. The established profiles afford the incumbent contractor to support each ind established business processes, allows for immediate continuity of services and continued mission capability, and avoids a gap in mission critical services that could impact National Security.

The potential loss or disruption of these services and required time for transition to a new contractor can cause significant harm; thereby severely hamperi order to successfully meet its travel requirements which may directly impact National Security.

Therefore, in accordance with FAR 8.405.6 (a)(1)(i)(A), an urgent and compelling need exists, and delay may result in unacceptable and sequential delays for DoD travelers.

5. A determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d).

While the Government acknowledges CWT has encountered performance issues on this and other related task orders, not having a contractor at all who can provide the required services is has determined that the expected outcome of this acquisition provides the greatest overall benefit in response to the requirement and therefore the best value to the Government consistent with FAR 8.404(d), based on all factors considered above.

IAW FAR 8.404 (d), GSA has already determined that prices are fair and reasonable. In addition, the Contracting Officer will seek additional discounts for this contract action.

6. A description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted.

Schedule (MAS) SIN 561510 for Travel Agent Services. However, market research confirms that they are the only source capable of providing the entire scope of highly-specialized services within the condensed time frames in order to ensure mission-critical quality levels are achieved. GSA has also conducted Requests for Information (RFI) for similar services and received very limited feedback from industry. Based upon the market research results, DoD has determined that no other vendor would be able to start-up and perform the services required by the contract start date of June 8, 2025, without grossly impacting and hampering the DTA-6 travel services.

7. Any other facts supporting the limited source justification.

The cost of losing the incumbent contractor to provide the services at the current time would be detrimental to DTA-6 meeting its mission requirements. In addition, these services are in the process of a full and open competition that has been delayed by new security requirements identified in May 2023 and the revised security language completed in October 2023. The new security requirements also impact several related DTMO TMC services acquisitions which must be staggered to support task order transitions one at a time.

The coordination of incentives and disincentives between December 2023 and May 2024 further delayed issuance of the RFQ. The USMC WW RFQ was issued on August 19, 2024, and quotes were due October 4, 2024. Two protests, one to the agency and one to GAO, took place between November and December 2024. Quote evaluations, exchanges with offerors, and preparation/review of the award decision took place between January 2025 to present.

This short-term task order will provide the necessary continuity of services until the award decision on the current full and open re-competition is officially completed. This is a viable option which will allow DoD to continue its mission while the re-procurement is being finalized.

8. A 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.

On behalf of DTMO, GSA recently re-competed the U.S. Marine Corps requirements for DTA

SIN 561510 for Travel Agent Services. However, the task order has not been awarded due to delays caused by protests described in paragraphs 2 and 7 above.

9. Certifications and Approvals

Requisitioner: (Contractor Employee or Federal Employee)

I hereby certify and accept the responsibility that any and all supporting data provided above or used to justify the above requested limited source procurement (e.g., verifying the full and open competition) is accurate and complete to the best of my personal knowledge and belief.

Signature Date

Contracting Officer:

I certify and approve that the information contained in this Limited Source Justification is accurate and complete to the best of my knowledge and belief.

Competition Advocate:

Upon the basis of the following justification, I, hereby approve the use of other than full and open competition of the proposed contractual action pursuant to the authority of 41 U.S.C.

2304).