Extension_Direct_Access_TO_LSJ__redacted.pdf

LIMITED SOURCE JUSTIFICATION (FAR PART 8.405-6)

PR No. 2118238PCI002 Task Order No. 70Z02318FPCI00200

This acquisition is conducted under the authority of Section 201 of the Federal Property and Administrative Services Act of 1949 (40 U.S.C. 501) Multiple Award Schedule Program Federal Acquisition Regulation (FAR) 8.401, and is justified by the following facts and rationale required under FAR 8.405-6 (a)(1)(i)(B): Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Assistant Commandant for Acquisition (CG-9), Office of Contract Operations (CG-912), Formal Contracts Division III (CG-9123) proposes to issue a modification to Task Order No. 70Z02318FPCI00200 to extend the services using the authority provided in FAR 52.217-8 Option to Extend Services.

The modification will extend the period of performance of the task order by six (6) months from April 1, 2018 to September 28, 2018 on the basis of other than full and open competition.

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

In support of the USCG Human Resource (HR) and payroll system known as Direct Access (DA), the USCG is issuing a modification to the task order for Contractor Technical and Administrative support services in order to exercise the FAR 52.217-8 Option to Extend Services. The USCG has a requirement to support the existing level of effort provided under Task Order No. 70Z02318FPCI00200 for Capital Planning and Investment Control, Information Assurance, and Audit Risk Management Support for DA. This system provides support services for the active duty, reserve, and retired military components of the USCG. The current task order is administered by the CG-912 Contracting Office and the Contracting Officer’s Representative (COR) duties reside in CG-631. The place of performance for this requirement is USCG Headquarters (HQ).

The modification will extend the period of performance of this task order for six (6) months (April 1, 2018 to September 28, 2018). The estimated price for this Firm-Fixed Price (FFP) extension is $900,000.00, which will be funded with fiscal year 2018 Operating Expenses (OE) funds.

The proposed contractor is:

Total Systems Technology Corporation (TSTC) 12400 Rochester Dr Fairfax, VA 22030

Command United States Coast Guard

2703 Martin Luther King Jr. Ave SE

STOP 7111

Washington, DC 20593-7111 Staff Symbol: CG-9123

(3) Description of Supplies/Services.

The purpose of this task order is to obtain current technical and administrative support services for Information Technology (IT) Audit, Capital Planning, Investment Control, Information Assurance, and Audit Risk Management support within CG-63, for Direct Access and the United States Coast Guard’s (USCG) Exchange Systems (CGES). Contractor tasks shall include certification and accreditation (C&A) analysis, IT security technical assurance, program management support services, independent verification and validation (IV&V), requirements gathering and documenting, and administrative support.

Coast Guard Command, Control, Communications, Computers & Information Technology (C4IT) systems are required to complete a C&A and annual self-assessment. The Coast Guard has selected National Institute of Standards and Technology (NIST) SP 800-37 for unclassified C4IT systems, Defense Information Technology Security Certification and Accreditation Process (DITSCAP)/Department of Defense (DOD) Information Assurance Certification and Accreditation Program (DIACAP) for classified and National Security Systems, and NIST SP 800-26 for annual self-assessments for all systems.

• A robust information assurance (IA) program defends information and information systems by ensuring their availability, integrity, authentication, confidentiality, and non-repudiation. This policy applies to C4IT assets, including systems and products that enable C4IT capability in support of the Coast Guard’s missions or business functions.

• The Coast Guard Information Assurance Program (IAP) includes periodic assessments of risk, including the magnitude of harm that could result from the unauthorized access, use, disclosure, disruption, modification, or destruction of information and information systems that support the operations and assets of the organization. Policies and procedures that are based on risk assessments cost-effectively reduce information security risks to an acceptable level, and ensure that information security is addressed throughout the life cycle of each organizational information system.

The Office of Management and Budget (OMB) requires federal agencies to establish and maintain a capital programming process that links mission needs and capital assets in an effective and efficient manner. Effective capital programming requires long-range planning and a disciplined budget decision making process as the basis for managing a portfolio of assets to achieve performance goals and objectives with minimal risk, lowest life-cycle costs, and greatest benefits to the agency's business.

OMB requires that capital requests be captured and submitted electronically in a consistent format known as Exhibit 300. The information reported on Exhibit 300 helps OMB:

• Understand agency capital programming and investment decision-making processes;

• Ensure that spending on capital assets directly supports agency missions and will provide a return on investment equal to or better than alternate uses of funding;

• Identify poorly performing projects, i.e. projects that are behind schedule, over budget, or lacking in capability using earned value management techniques and systems;

• Identify capital assets that no longer fulfill ongoing or anticipated mission requirements or do not deliver intended benefits to the agency or its customers.

• For IT, ensure that strong business cases are provided for IT investments. These business cases should include security, privacy, enterprise architecture, and provide the effectiveness and efficiency gains planned by the business lines and functional operations.

The Program Office has reviewed and the Contracting Officer has determined the above services are neither inherently governmental functions nor personal services. The modification extends the period of performance of this Task Order for six (6) months (April 1, 2018 through September 28, 2018).

(4) Identification of the justification and the rationale.

In accordance with FAR 8.405-6 (a)(1)(i)(B), only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized. Through Direct Access, the USCG provides payroll and HR support to USCG Active Duty, Reserve and retired military personnel, as well as the United States Public Health Service (USPHS) and the National Oceanic and Atmospheric Association

(NOAA).

The incumbent contractor has performed this requirement for more than five years and overcame an early significant learning curve providing these services for this complex HR and payroll system. There is a continuing requirement for these critical services supporting Direct Access and the CGES; an interruption in these services would severely impair the USCG’s ability to provide human resource support, payroll, and exchange services to its active duty, reserve, and retired military personnel, as well as to USPHS and NOAA. A lapse in service would result in many high risk consequences. The loss of ISSO support would render CG-6813 unable to respond to weekly CG CYBERCOM security scan reviews and vulnerability assessments, bi-weekly status updates for the DISA Manta Rally Task Order, activities for the FedRAMP Moderate Impact Level 4 Compliance, and continuing ISSO responsibilities. Failure to complete these requirements could result in DISA taking action by directing the CG to disconnect Direct Access from the DoD Information Network (DoDIN). Disconnection from the DoDIN would result in the inability to pay CG personnel, because connectivity is required to process Military Pay & Personnel and transmit the Pay File to Department of the Treasury. In terms of the Audit & Risk Management requirements, preparations are underway for the FY19 A-123 and IT Financial Systems audits. Without FISCAM expertise and ISSO support, CG-6813 personnel would be unable to respond to multiple auditor requests for information, reports, data, and interviews relative to Direct Access. Untimely and or incomplete responses to auditor requests could result in the audit team issuing multiple Notices of Finding and Recommendation (NFR) to the CG. The CG CIO emphasized in 2017 that all efforts should be applied to ensuring no CG information systems receive NFRs, and to that end in 2017 none were issued to Direct Access.

There is a high risk of receiving NFRs in 2018 without the expert resources provided under the current task order.

(5) Determination by the ordering activity Contracting Officer that the anticipated order represents the best value consistent with 8.404(d).

The Contracting Officer has determined that the prices for Task Order No. 70Z02318FPCI00200 are fair and reasonable based on the GSA FSS contract awarded to Total Systems Technologies Corporation (TSTC) and the 5.47% discount offered when the task order was awarded. The Contracting Officer will ensure that the proposed price for the six (6) month extension to the task order is fair and reasonable by comparing the proposed rates to the rates previously determined fair and reasonable for Task Order No. 70Z02318FPCI00200 in accordance with FAR 15.404- 1(b)(2)(ii). Prior to awarding the modification, the ordering activity will conduct a price evaluation in accordance with FAR 8.405-2(d) by considering the level of effort and mix of labor hours proposed for the six (6) months in determining the price to be fair and reasonable.

(6) A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research was conducted in 2017 and indicated that at least three vendors were available to meet the requirement, including small businesses under GSA Schedule 70 SIN 132-51, GSA OASIS, and EAGLE II Functional Category II. Contractors having previous experience directly supporting the US Coast Guard Direct Access Human Capital Management system are favorable for this work. While other contractors are capable of meeting this requirement, bringing in a new contractor would create substantial delays overcoming a learning curve and impair the USCG’s ability to deliver payroll and HR support to the workforce.

(7) Any other facts supporting the justification.

Bringing in a new contractor would create substantial delays overcoming this learning curve and impair the USCG’s ability to deliver payroll and HR support to the workforce. Transition of work to a successor contractor will require approximately 45 days, as a new contractor will be required to complete the USCG on-boarding process and gain an understanding of the complex HR and payroll systems prior to the expiration of the contract. There is not adequate time due to the current task order period of performance end date of March 31, 2018.

(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that preclude the agency from meeting the requirements of 8.405-1 and 8.405-2 before any subsequent acquisition for the supplies or services is made.

CG-9123 is processing a competition for a new contract action. The new solicitation will be posted during the month of June 2018 and should be awarded no later than the end of September 2018. In order to complete the new competition, a six (6) month extension to the task order is necessary to avoid a break in services and allow adequate time to accommodate a competition for the new contract action.

5.47%

(9) Contracting Officer’s Certification.

In accordance with FAR 8.405-6(c)(2)(ix), I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

XXXXXXXXXXXXXXXX Date Contracting Officer

(10) Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Technical Representative/COR

APPROVAL:

Contracting Officer

Competition Advocate

(11) Legal Review and Concurrence:

I have reviewed this justification.

Attorney