Justification for Other Than Full and Open Competition RFO 6.104-1 and GSAR 538.7104-3

RFQ 47QMCB26Q0024

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 Company (TMC)/Travel Agent Services in support of the Department of State (DOS).

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

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

The purpose of this sole source justification is to support the award of a sole source task order to CW Government Travel (CWT), Inc., in providing official TMC/Travel Agent Services for DOS.

Based on the Market Research conducted to support DOS and their complex requirements, there are no other qualified and capable sources to provide TMC/Travel Agent Services. The Department of State needs TMC services in over countries;

providing in-country support requires specialized knowledge, local legal compliance, and to book travel legally. It also requires the ability to provide immediate support for health issues, lost documents, or urgent rebookings that require the use of local networks to resolve issues. Local support has visibility into local conditions, provides reliable, authorized operators, understands the local language, and manages currency differences. It also requires on-the-ground coordination for local transportation bookings and problems that may arise. Many countries have differing

, depending on the country to include requirements, . Based on the market research, there is only one (1) supplier on the MAS who currently has the ability to provide TMC services in over countries for DOS. As the current service provider, CWT is well-positioned, with the necessary resources and agreements (either directly or through other TMCs) already in place, to continue providing these services immediately. International requirements account for of the contract value for DOS. We estimate, based on commercial practices, that establishing a network to support on-site services in over countries would take at least a year, and with GO.gov go-live to be November 2026 for DOS this timing is not feasible.

The TMC PMO will be working with additional MAS contractors in the coming year to ensure there are other providers with the capabilities to perform in-country around the world, including having the necessary networks and access to qualified and trained travel agents or the ability to rapidly establish the required access and networks.

However, given the requirement for DOS to go-live with GO.gov in November 2026, market research shows there are no other companies with the required capabilities and there is not enough time for another vendor to put the necessary arrangements in place to do a full competitive bid. Since this task order is a one year base period, with four option periods, we have an opportunity to competitively bid this contract down the road once there is competition.

The anticipated period of performance (POP) for this task order is expected to be July 6, 2026 through July 5, 2031.

3. A description of the supplies or services required to meet the agency’s needs (including an estimated value).

The total value of the proposed Task Order is (this includes the costs for cost constructed travel under CLINs 311 and 311A, which are actually paid by the traveler). The required TMC services are highly specialized and require familiarity with specific travel regulations, local customs/language, and laws, including the Federal Travel Regulation (FTR) and the Foreign Affairs Manual (FAM), and unique Business Rules developed by DOS. DOS has specific requirements for international-based services in support of their embassies and posts around the world. They also require dedicated support for their complex and unique travel types specific to DOS, including in-country TMC support using in over countries, Permanent Change of Station (PCS), , etc. Finally, DOS requires Central Bill Accounts (CBA) reconciliation support for both CONUS and OCONUS, with the OCONUS CBA reconciliation process being uniquely defined for DOS. They require dedicated onsite VIP support, with roll-over capabilities to an offsite VIP group. Finally, they have a significant amount of international and cost constructed travel which requires seasoned agents to perform.

Therefore, immediately during contract implementation, and in support of the GO.gov implementation, the TMC must have detailed knowledge of DOS unique needs and travel regulations and business rules to ensure traveler reservations are accurate, timely, and in accordance with numerous policies and regulations and that the travel agent is authorized in country to perform such services.

4. An identification of the statutory authority permitting other than full and open competition.

RFO 6.104-1 (DEVIATION RFO-2025-06 June 2025) and GSAR 538.7104-3 (b)(ii) (DEVIATION RFO-2025-FSS-GSAR 538 Nov. 2025)- Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized as outlined above.

5. A demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires using the authority cited.

Due to the circumstances noted above, it is imperative that TMC services are contracted to CW Government Travel, Inc, as they are the only contractor capable of performing State department requirements for in-country support and proven experience in providing such services. DOS require dedicated support for their complex and unique travel types. CWT is also the incumbent contractor under the ETS 2 business model. CWT has provided support in this area with immediate response and the ability to continue services to all activities under the order. This further validates that they have the local resources and expertise needed to provide these services.

Therefore, in accordance with GSAR 538.7104-3(b)(ii) (DEVIATION RFO-2025-FSS- GSAR 538 Nov. 2025), only one source is capable of providing the products, services or solution.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as possible, including whether a notice was or will be publicized as required by part 5 and, if not, which exception under part 5 applies.

A notice was not publicized per exception RFO 5.101(b)(1)(iv) (DEVIATION RFO- 2025-05 Supp. 1 Nov. 2025) Is an order issued under a requirements contract, task order contract, or a delivery order contract. This requirement is being procured on a sole source basis as an order placed against the FSS) program. In February of 2025 DOS conducted a Request For Information (RFI) to determine interest in this acquisition, as well as in May 2023 GSA posted an RFI on SAM.gov to determine interest in Travel Management Services. The CO also evaluated the option to do a full and open competition, however, given the short timeline for when an award needs to be made to support the November 2026, go-live date, this was determined to be not feasible.

The TMC PMO regularly engages with the travel agency industry to keep abreast of market research and will encourage travel management companies to develop expertise and capability in providing international in-country support at scale necessary to support DOS. Several federal agencies have international presence ( ., ) and could benefit from competition for international support. The TMC PMO will continue its efforts to encourage industry to fill this need and to understand (and overcome) industry barriers to participation.

7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The CO has determined that the expected outcome of this acquisition, in the Government’s estimation, provides the greatest overall benefit in response to the requirement and therefore the best value to the Government, based on all factors considered above.

GSAR 538.7102-2(d) (DEVIATION RFO-2025-FSS-GSAR 538 Nov. 2025) GSA has already determined that prices are fair and reasonable. “Ordering activities are not required to make a fair and reasonable price determination for FSS products, services, or solutions at the order level or BPA level as FSS contract pricing has been determined fair and reasonable.” In addition, the Contracting Officer will seek additional discounts for this contract action.

8. The market research conducted (see part 10) and the results or a statement of the reason market research was not conducted.

There are a total of 20 Vendors on the SIN 561510 on MAS for TMC services. Of these, there are 12 who have updated their price lists for transactions fees to support the GO.gov implementation and are actively working on the security requirements that will allow them to support agencies transitioning to GO.gov. These TMCs will also need to demonstrate they have the capability to perform the State Department’s complex requirements as well. CW Government Travel, Inc., is not the only company capable of providing TMC Services under GSA Multiple Award Schedule (MAS), Travel Agent Services Category 561510. However, market research confirms that they are the only source with the required capabilities to perform State Department requirements in time for a November 2026 go-live.

9. Any other facts supporting using other than full and open competition.

CWT is DOS’s current TMC under ETS2 and has the experience and capability needed to continue performance.

10. A listing of the sources, if any, that expressed an interest in the acquisition in writing.

In February of 2025 DOS conducted an RFI to determine interest in acquisition. They had 3 responses, which included 4 Suppliers. Those suppliers were:

responded together as a teaming arrangement, but have since dissolved the relationship and indicated if there was an acquisition they would bid separately. However, none of these suppliers who expressed interest have demonstrated their capability to perform in-country in over countries as DOS requires.

11. A statement of the 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.

GSA will work with other TMC suppliers on the MAS to encourage suppliers develop the capability to provide international TMC support in-country on a worldwide basis in order to allow for all vendors to bid on similar procurements in the future. On behalf of DOS (or other federal agencies), GSA will then be able to solicit TMC services utilizing full and open competition procedures under the GSA MAS Program, Travel Category 561510: Travel Agent Services, on future procurements.

GSA will also review the marketplace every year to determine if exercising the next option period and continuing services as a sole source award is still the best value for the government, to include reviewing MAS vendors' capabilities to perform in-country around the world. The period of performance (POP) for the TMC task order will be a 1-year base and 4 1-year option periods for a total period of 5 years, not including the 6 month period per FAR/RFO Clause 52.217-8. If it is found that competition is possible and exercise of the option is not the most advantageous method of fulfilling the Government’s need, price and other factors considered, then the government will re-procure these services competitively and not exercise remaining option periods.

12. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer's knowledge and belief.

Requisitioner:

I hereby certify and accept the responsibility that any and all supporting data provided above or used to justify the above requested sole source procurement (e.g., verifying the Government’s minimum needs, schedule requirements, and/or other rationale for other than full and open competition) is accurate and complete to the best of my personal knowledge and belief.

Michael Salter Date Program Analyst Travel and Expense Services Division

Contracting Officer:

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

Carolina McFaul Date Contracting Officer Travel Acquisition Division

Office of Contracting Operations:

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).

Rebecca Koses Date Acting Director Office of Contracting Operations

Competition Advocate:

Upon the basis of the following justification, I hereby approve the use of other than full

Janet Schweer Date Competition Advocate Contract Accountability Service Center

Head of the Contracting Activity:

Upon the basis of the following justification, I hereby approve the use of other than full

Jeffrey Lau Date Head of the Contracting Activity Office of Shared Services Delivery