47QSCC27A0001_Sole Source Justification_USMC Bridge_2026-10-20_Redacted.pdf

FSS Sole Source Justification

47QSCC-27-A-0001

47QSCC-27-A-0002

47QSCC-27-A-0003

For the Establishment of 4th Party Logistics (4PL) Blanket Purchase Agreement (BPA)

Logical Follow-on (Bridge)

To Support U.S. General Services Administration (GSA) Customer Supply Center

Division (CSC) for various U.S. Marine Corps Locations

Under

Conducted under RFO FAR Subpart 8.4 – Ordering Under the Federal Supply Schedule

Issued by

GSA, Federal Acquisition Service Office of Shared Services Delivery Office of Contracting Operations

Special Contracting Service Center, Division 1

ISSUE DATE: OCTOBER 20, 2026

Docusign Envelope ID:

I. PURPOSE

The purpose of this FSS Sole Source Justification is to document the rationale for issuing a 3-month (with one 3-month option period) BPA on a sole source basis, with an estimated total value of $92,644,112.

This action bridges the current 4PL NextGen I BPAs (47QSCC21A0004/0005/0006) supporting various United States Marine Corps (“USMC”) locations both on the U.S. mainland within the contiguous United States (“CONUS”), and USMC location in Hawaii and Japan outside the contiguous United States (“OCONUS”), during the acquisition phase of GSA’s current USMC NextGen II solicitation, Request for Quotation (“RFQ”) (47QSCC26Q5001).

RFQ 47QSCC26Q5001 seeks to establish a new USMC BPA award competed under FAR Subpart 8.4 (GSA Class Deviation RFO-2025-08) procedures and this bridge is required in the interim.

II. AUTHORITY

FAR Subpart 8.4, (GSA Class Deviation RFO-2025-08), additionally IAW, GSAR 538.7104-3(b)(1)(iii) (GSA Class Deviation RFO-2025-FSS-GSAR 538), the order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.

III. BACKGROUND

a. 4PL Program History The USMC requires the GSA’s 4PL supply chain solution to meet its mission requirements. The GSA Customer Supply Center (“CSC”), with its acquisition team (Special Contracting Service Center, Division 1 ), manages the 4PL Program, under which CSC is responsible for managing the resources, capabilities, and technology of its own organization, with support from its service providers, to deliver a comprehensive end-to-end supply chain solution to its customers. For this acquisition, the CSC acquisition team issued RFQ 47QSCC26Q5001 on June 15, 2026 to establish a single-award BPA with a contractor holding the GSA Multiple Award Schedule (“MAS”) Special Item Number (“SIN”): Fourth-Party Logistics (“4PL”) Supplies and Services (“4PL SIN”). The purpose of the single-award BPA is to acquire 4PL products and services to be requisitioned to the USMC.

b. Contractual History

As part of its comprehensive approach to managing evolving 4PL program requirements, GSA established the 4PL SIN under the GSA MAS program in June 2020. The initial round of solicitations and contractual agreements under the 4PL SIN were branded by GSA as the 4PL Next Generation (“NextGen”) solution. The current USMC NextGen I BPAs were awarded to a Contractor Team Arrangement (“CTA”) listed below:

BPA Number: 47QSCC21A0004/0005/0006 - three BPAs issued under one requirement as a CTA.

Awardees: CTA - MSC Industrial Direct CO., Inc. (“MSC”); L C Industries, Inc. (“LCI”);

and OSC Solutions, Inc. (“OSC”).

Type of Award: Single Award.

Dollar Value: $950,356,271.00 Period of Performance: 07/26/2021 - 07/25/2026 (Base +4) with a (6) month option extension incorporated (extension ending 01/25/2027).

Issuing/Contracting Office: Special Contracting Service Center, Division 1 (formerly “Retail Operations’ Acquisition Branch”).

Customer: USMC Scope: 4PL Products and Services (all products and services available through each CTA member’s 4PL SIN catalog).

Competition: Full and Open Competition.

Contract Type: Firm-Fixed-Price (FFP).

Supply or Service or Both: Both.MSC, LCI, and OSC provide retail services to facilitate the management/delivery of the 4PL products.

IV. RATIONALE

During the re-compete acquisition phase of the USMC NextGen II solicitation, the Contracting Officer (“CO”) in coordination with the CSC Program Office determined the current acquisition milestones pose a significant risk in continuity of operations due to several factors, and as such, immediate mitigation efforts should be conducted to ensure there is no lapse in 4PL products and services to USMC customers.

a. Interdependency of the 4PL Program Although every acquisition within the 4PL Program is a stand-alone acquisition, the USMC NextGen II BPA is interdependent upon other 4PL actions. A predecessor acquisition supporting the U.S. Navy (“Navy”) 4PL NextGen II BPA (47QSCC26A0001) which was recently awarded on March 26, 2026 helped forge the current NextGen II acquisition model, upon which future 4PL NextGen II BPAs will be structured. During this acquisition, the 4PL Program experienced several delays, such as significant changes to the acquisition approach, evaluation factors, Agency-level and Government Accountability Office (“GAO”) level pre-award protests that were filed. As a result, the Acquisition Team made several strategic pauses on the USMC and United States Coast Guard (“USCG”) NextGen II acquisitions to perform additional Market Research, address concerns, mitigate risks, and better formulate the 4PL Program-wide acquisition approach. These acquisition improvements were first implemented in the Navy NextGen II BPA, but ultimately would flow down to USCG, and USMC NextGen II acquisitions.

As a result, the original USMC NextGen II acquisition milestones shifted, while the CSC Program Office and the Acquisition Team revised the Navy NextGen II evaluation criteria and addressed the Agency and GAO-level protests. Due to the nature of the 4PL program’s interdependency to ensure consistent acquisition approaches and outcomes across the program, the currently established acquisition milestones are no longer reasonable due to several factors which will be outlined below.

b. Status of Forces Agreement (“SOFA”) Timeline The Outside of the Continental United States (“OCONUS”) component of the USMC Next Gen II requirement adds an additional layer of complexity and uncertainty to the current milestones. The SOFA process for each host nation where the USMC operates varies by country, but the process is generally similar in that additional lead-time is required for reviewing SOFA applications, navigating the host nation rules and regulations, and ensuring that GSA attempts to mitigate any additional unforeseen delays when working through the SOFA application and designation process. Specifically for the USMC SOFA process in one of the OCONUS host nations (Japan), the process can be timely from start to finish as several key processes must be completed prior to being granted SOFA status. In these instances GSA is working with OCONUS host nation Governments which can include delays. Generally, the CSC Program Office requires approximately 120 days from the time of award to allow for SOFA certification in Japan.

c. GSA PICS and Catalog Timelines Onboarding the USMC CTA at the USMC locations took several months and consisted of both system and operational onboarding approaches. As part of the systems onboarding process, each CTA member must prepare their catalog and submit their product offering via GSA’s Schedule Input Program (“SIP”) for loading to GSA’s cataloging system (“PICS”) to allow merchandise to be sold within the GSA point of sale systems. At a minimum, the system onboarding process will take 90 days to complete from the time of award due to the size of catalogs required to be loaded to PICS. The current USMC CTA has completed all the onboarding procedures at these locations. The current expiration date timeline of the USMC NextGen I BPAs do not support the minimum timeline necessary to transition catalogs to a new contractor(s) and present a significant risk to CSC’s ability to maintain uninterrupted store operations and fulfill USMC requirements.

d. Additional Reason(s)/Rationale Operational onboarding includes product research and sourcing, installation of equipment, running fiber optic data lines, installing racking and shelving, complying with installation security protocols, complying with installation security access requirements, transporting adequate product to the 4PL locations, and stocking the shelves and staging the inventory. To adequately support these locations, the USMC CTA is required to transport products to OCONUS locations in Japan and Hawaii, with transportation lead times up to 90 days. The transportation lead time is a critical component of the 150 day implementation timeline to transition the Japan locations to a new contractor. The USMC CTA has completed the operational onboarding at these locations, and the use of any other contractor or 4PL SIN Holder is simply not feasible due to the magnitude and timeline required for program implementation. The USMC relies upon the 4PL Servmarts stores to support material requirements in performing their assigned missions. The expiration of the current USMC CTA BPAs do not support the minimum timeline necessary to transition store operations to new contractor(s) and present a significant risk to CSC’s ability to maintain uninterrupted store operations and fulfill USMC requirements.

e. Attempts in Establishing Competition

Under the 4PL Program, the CO makes every effort and attempt to establish and maximize competition, IAW FAR Subpart 8.4 (GSA Class Deviation RFO-2025-08), and GSAR 538.71 (GSA Class Deviation RFO-2025-FSS-GSAR 538). The CO consults with the GSA Small Business Advocate, requires Small Business Participation Plans for large businesses, allows and encourages the use of CTAs, and solicits for Full & Open Competition. The 4PL Program has taken every measure to ensure that 4PL SIN Holders are afforded fair opportunities to compete for 4PL awards. Although GSA originally intended to have competed and awarded a NextGen II BPA to support the USMC, necessary actions were taken as a result of the Navy protests, which delayed the USMC NextGen II acquisition process to a point where the original acquisition milestones are no longer feasible, and efforts for obtaining competition are not possible for a short-term bridge. Without this logical follow-on BPA, there will be a lapse in 4PL operations at the various USMC locations due the transition In/Out process and the SOFA process needed for OCONUS locations.

Further, issuing a separate RFQ for this requirement, which is already included in the ongoing USMC NextGen II acquisition, would be counterproductive and duplicative, creating undue administrative burden and costs that do not align with the Agency’s objectives for enhanced efficiency. Localized individual acquisitions for these supplies are not in the interest of economy and efficiency because of the duplicative nature of soliciting to cover a solicitation. A short-term bridge BPA will allow current 4PL operations to continue, uninterrupted, while also allowing the USMC NextGen II acquisition to advance, allowing for maximum competition. It is neither economically sound nor in the best interest of the Government to competitively establish a new short-term BPA for the 6-month limited period of performance. The duplicative efforts and costs will not be recovered through re-competition. Establishing a new short-term BPA and onboarding another contractor at these locations would require complete duplication of tasks, at additional expense and effort to the Government. With this logical follow-on BPA, GSA will avoid the substantial duplication of efforts, resources, and additional costs. Further, this logical follow-on BPA will allow the Government to continue to receive cost savings associated with the currently established 4PL BPA pricing and discount structure.

The USMC NextGen I BPAs established flat-rate discounts, which apply to all sales, resulting in significant savings from GSA MAS catalog pricing. This logical follow-on BPA will allow GSA to continue to build on those discounts as cumulative sales continue to accrue.

f. Schedule Risks If bridge BPAs are not approved before the CSC operational deadline of October 25, 2026, and established before the end of the current 6-month extension period (date 01/25/2027), GSA runs the risk of not being capable of supporting the USMC customer and cannot maintain continuity of operations. This scenario will create a lapse in mission-critical supplies being delivered to USMC operational commands around the globe. GSA must ensure this outcome is avoided at all costs. Because of the transition-in/transition-out timeline needed to on-board and off-ramp 4PL contractors, the CSC Program Office requires 90 calendar days for CONUS locations, 120 calendar days for Hawaii, and 150 calendar days for Japan. This risk was identified in the USMC NextGen II Acquisition Plan (”AP”), and GSA’s mitigation approach does not change. As was identified in the AP, the CO stated, “The implementation timeline risk will also be mitigated with the use of available PoP extension authorities in the case of unexpected delays. If deemed necessary, The USMC NextGen BPAs include the clause at FAR 52.217-8 which would provide an additional six months of contract coverage, potentially extending the expiration date to 01/25/2027. In extreme situations, where delays extend beyond all foreseeable scenarios, GSA leadership has historically realized the responsibility associated with maintaining continuity, especially in cases where GSA is solely, or primarily, tasked with supplying the logistical support.’’ As was identified in the AP, the 6-month extension has been exercised, and will conclude on 01/25/2027. The schedule risk previously identified has now materialized. GSA has exhausted all available PoP extensions.

g. Protest Risk Given the nature of the 4PL Program, and the scope and magnitude of the opportunity, the CO determines there is a considerable likelihood the USMC NextGen II acquisition will receive an award protest. Any protest will further exaggerate the current milestones and timeline. If a bridge BPA is not in place to maintain operations, then GSA runs the risk of not being able to support the USMC customers. A GAO-level protest can often exceed 100 days, per instance, after a protest is filed, but before a decision is rendered. In the event GSA receives an Award protest, the litigation period could exceed 100 days, adding to an already aggressive timeline. The protest risks were not specifically identified in the AP because these risks are present and inherent in the scope, scale, and magnitude of the 4PL NextGen I and NextGen II acquisitions. The primary reason(s) the 4PL awards are often protested are, 1) 4PL NextGen BPA awards are single award BPAs and have very large estimated dollar values, sometimes upward in the billions of dollars in potential value, and 2) GSA and its military customers provide retail space to 4PL contractors at no additional cost and with minimal risk; there is limited on-base competition for similar products; and GSA can often provide inter-governmental overseas shipping logistics at no additional cost to the contractors. These factors create significant incentives for offerors to challenge 4PL solicitations and awards, but also represent the primary reasons that 4PL contractors can often provide products to military customers below established GSA MAS catalog pricing. Given the very nature of the program and its global reach and impact across the U.S. armed forces, the 4PL Program will likely continue to face protest risks, thus further emphasizing why maintaining operations is critical to our USMC customer. Maintaining 4PL operational stability remains a priority to support customer needs, despite the presence of ongoing protest activities.

h. Lapse of Service Risk Under the authority at FAR 52.217-8, Option to Extend Services (Nov 1999), the option to extend the BPAs final PoP for an additional six month period (July 26, 2026 through January 25, 2027) was exercised in writing by the CO in June 2026 to avoid a lapse in service and allow additional time for the award and transition to the USMC NextGen II BPA. As such, no additional time is available to be added to the current BPAs. Despite the CO’s action to mitigate delay risks, in August 2026, the CSC Program Manager informed the CO of serious concerns regarding a potential lapse in product support and 4PL services due the required transition-in/transition-out timelines (90-days for CONUS, 120-days for Hawaii OCONUS, and 150-days for Japan OCONUS). The CO evaluated the facts, timelines, and likelihood of additional delays and determined that a bridge BPA would be required to mitigate the risk of a lapse in service, and that under the timelines provided by the current BPAs, there would be insufficient time to allow the CSC programmatic and systems teams to transition to the NextGen II BPA.

Due to the interdependency of the 4PL Program and delays caused by previous protests, the soonest that the award and the transition process to the USMC NextGen II BPA could begin would be late November 2026. With the current BPA expiring on January 25, 2027, this leaves most USMC CONUS locations without 4PL products for approximately 30 days with estimated 4PL coverage starting on or after February 26, 2027, and leaves OCONUS locations in Japan without 4PL products for approximately 4 months with estimated 4PL coverage starting on or after April 26, 2027. Additionally, as identified in the subsection above titled “Protest Risks”, if GSA receives a bid protest against the award of the USMC NextGen II BPA, this could easily delay coverage for all locations an additional 100 days as GSA works to litigate and address the protest. Therefore, in order to avoid a lapse in coverage and ensure continuity of 4PL products and services supporting critical mission essential USMC operations, GSA must award the aforementioned sole source bridge BPAs.

V. MARKET RESEARCH

GSA considered alternatives to this logical follow-on BPA, such as leveraging other established 4PL locations to support the locations covered by the USMC NextGen I BPA; however these requirements would be outside the geographical and scope of any other NextGen 4PL BPA.

Market Research has shown that the GSA MAS Program continues to be the most economically sound and efficient acquisition solution for the GSA 4PL Program to provide supplies for its customers. This logical follow-on BPA will ensure continuity of service until the USMC NextGen II successor BPA holder is onboarded and operational. Because of the complex scope and enterprise-wide scale and nature of these large-scale logistics, leveraging any other acquisition solution such as Government-wide Acquisition Contracts (“GWAC’s”), GSA Global Supply, or attempting an open market acquisition is not feasible. Especially considering GSA has already solicited, competed, awarded, and administered a successful GSA MAS 4PL acquisition for identical products and services, with established discounts, terms and conditions. This bridge action is merely a temporary extension of the current BPA structure already in place today.

Market Research indicates that utilizing any other acquisition vehicle or method would drastically increase costs, time, and would be duplicative of ongoing efforts.

VI. PRICE REASONABLENESS

The current USMC BPA holders were previously determined to be the Best Value awardees with regards to their pricing and discount structure being considered an evaluation factor in the original award. All items sold under the bridge BPAs will be current MAS catalog items that are already deemed fair and reasonable. and therefore the ordering activity is not required to make a fair and reasonable price determination in accordance with the authority of GSAR 538.7102-2(d)(2) (GSA Class Deviation RFO-2025-FSS-GSAR 538). Additionally, all pricing structures, catalog Flat-Rate Discount percentage structures, and GSA MAS pricing parameters will remain unchanged. The current USMC NextGen I BPAs and the bridge BPAs are not GSA-funded actions. The total value of the bridge BPAs will only be an estimate and nominal in nature. Lastly, all funding associated with the bridge BPAs will be obligated at the order-level using customer agency funding.

VII. OTHER FACTORS

The current 4PL BPA SIN Holders, awarded the USMC NextGen I BPAs, were previously determined to be the Best Value awardees, and have successfully performed as 4PL contractors servicing the USMC in brick & mortar retail operations, tool cribs, issue points, and virtual retail settings. The current awardees have demonstrated mastery of the USMC 4PL customer requirements, and have leveraged their global capabilities to consistently deliver mission-critical products on time and on cost. Additionally, the current BPA awardees have performed satisfactorily to the terms and conditions of their BPAs, and performance has been documented via the Contractor Performance Assessment Rating System (“CPARS”). A Responsibility Determination has been performed at the MAS and BPA-level and the CO finds no evidence to suggest the BPA awardees will experience any new performance risks during the bridge PoP.

VIII. RECOMMENDATION

Based on the aforementioned facts and supporting rationale documented herein, the CO recommends approval to award three BPAs issued under one requirement as a CTA with a base period of 3-months and one 3-month option period on a sole source basis. The BPAs will be awarded in the interest of economy and efficiency as a logical follow-on to the original competitively awarded FSS USMC NextGen I BPAs. This bridge action is in the best interest of the Government and established IAW FAR Subpart 8.4 (GSA Class Deviations RFO-2025-08) and GSAR 538.7104-3(b)(1)(iii) (GSA Class Deviation RFO-2025-FSS-GSAR 538).

IX. APPROVAL

Reviews and Approvals:

Michael Gause, FDBDA Date Contract Specialist

(CS)

Patrick Romero, FDBDA Date Contracting Officer

(CO)

10/20/2026 | 18:56:12 BST

10/20/2026 | 18:59:46 BST