924 Justification for Exception to Fair Opportunity (4mo).pdf

Justification for an Exception to Fair Opportunity contractor program, technical and administrative Support Services CG-924

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

(Exceeding the SAT pursuant to FAR 16.505(b)(2)(i)(B))

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Assistant Commandant for Acquisition and Chief Acquisition Officer (CG-9), Office of Contract Operations (CG-912), Formal Contracts Division III (CG-9123) prepared this justification for an exception to fair opportunity.

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

USCG intends to extend the period of performance on task order 70Z02319FADW01000 under General Services Administration (GSA) One Acquisition Solution for Integrated Services (OASIS) Contract No. GS00Q14OADU108 without considering other awardees on the basis of an exception to fair opportunity. The Office of Acquisition Support (CG-924) serves as advisor to the Assistant Commandant for Acquisition for investment decisions and major systems acquisition program management processes and procedures. It provides oversight of and support to major and non-major systems acquisitions and is the primary point of contact with DHS for the acquisition review process.

The USCG proposes to award a firm, fixed-price task order extension for a total of four (4) months for contractor program, technical and administrative support services on a sole-source basis to support CG-924. This will support the existing level of effort provided under Task Order No. 70Z02319FADW01000 under GSA OASIS Contract No. GS00Q14OADU108 that expires in 30 November 2019. The services provided under this task order will support the USCG’s major and non-major procurements and is required until the USCG awards a new contract.

The proposed awardee is:

Booz Allen Hamilton Inc.

8283 Greensboro Drive McLean, VA 22102

The place of performance for this requirement is the USCG Headquarters (HQ). The period of performance of this task order is currently 1 December 2018 through 30 November 2019. The USCG intends to extend the period of performance by four (4) months, from 1 December 2019 through 31 March 2020. The estimated price for this effort is $1,934,201.84.

(3) Description of Supplies/Services.

The purpose of this task order is to obtain contractor program, technical and administrative Support for CG-924. The support services under this task order fall within four categories:

1. Program Management / Policy

2. Systems Engineering

3. Program Protection / Cyber

4. Administration / Information sharing

In addition to these four areas, the Office of Acquisition Support (CG-924) is often tasked with initiatives that are beyond the existing staff’s experience or knowledge, such as Non-Major Acquisition Program support, Major Acquisition support, and multi-year & block buy contracting support services. This requires the assistance of subject matter experts in relevant fields required to deliver accurate, current, and useable information to the Director of Acquisition Programs and Program Executive Officer (CG-93), Senior Procurement Executive & Head of Contracting Activity (CG-91), and the Assistant Commandant for Acquisition and Chief Acquisition Officer (CG-9).

(4) Justification for Exception to Fair Opportunity.

This acquisition is being conducted under the authority of FAR 16.505(b)(2)(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.

The proposed support services are a continuation of to the previously competed support services provided under Task order No. HSCG23-13-J-ADW182 that was awarded under DHS Technical, Acquisition, and Business Support Services (TABSS) Contract No. HSCG23-13-DATB024. This continuation uses the knowledge gained by the contractor and builds upon previously completed deliverables to meet required near-future deliverable due dates. The contractor has the requisite knowledge and has begun completing these deliverables for the USCG.

The deliverables which are required during the four (4) month continuation include:

• Non-Major Acquisition Process (NMAP) Update to be completed in December/January

• Program Systems Engineering Tailoring Plan update to include improved Program

Protection/Cybersecurity alignment

• Department of Defense (DoD) policy review - 5000.02 analysis for proven practices to incorporate into CG acquisition policy, findings and recommendations

• USCG Acquisition Policy Template Updates: Acquisition Program Baseline (APB), Capability Development Plan (CDP), Alternatives Analysis Study Plan (AASP), Alternatives Analysis Report (AAR), drafting and reviewing with findings and recommendations

• USCG Policy Document Policy Update Major Systems Acquisition Manual (MSAM) -series “G” (5000.10): Chapter 5 reorganization/rewrite; Chapter 3 policy review/reorg/rewrite; and Chapter 2 reorganization/rewrite

• Development of a recommendation to allocate within the CG the DoD directed Tier 1 Program Protection/Cybersecurity activities in work

• Development of a recommendation and initiation of actions for the future use of the MSAM Handbook

• Executive Secretary Tasks scheduling meetings, facilitating meetings and meeting minutes process

• Development of a recommendation to allocate within the CG the DoD directed Tier 1 Program Protection/Cybersecurity activities in work

(5) Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer anticipates that the price will be fair and reasonable based on conducting a price analysis in accordance with FAR 15.404-1(b)(2)(i) and FAR 15.404-1(b)(2)(ii), and a comparison of the proposed prices to historical prices paid under previously negotiated rates for Task Order No. 70Z02319FADW01000. Prior to award, the ordering activity will conduct a price evaluation by considering the level of effort and mix of labor hours proposed for the four

(4) month continuation.

(6) Demonstration that the Nature of the Acquisition Require Use of the Authority Cited.

These services are unique and highly specialized in that they require significant knowledge of USCG programs and information gained throughout the existing period of performance in order to meet the required deliverable due dates. The contractor has performed this requirement for over five years and has the requisite knowledge and experience necessary to support both major and non-major USCG acquisition programs. The contractor is the only company able to meet USCG requirements in and for such a short period of time, as it has been continually collecting and interpreting data required for the reviews and assessments listed above, and has maintained the status of the USCG’s current non-major and major acquisitions. The collection and interpretation of data is not a current deliverable, and the USCG would incur duplicate costs for this information if awarded to another contractor. By awarding to another contractor at this time, the USCG would not be able to maintain the progress made on these deliverables, and USCG leadership would not have accurate data and assessments to use for decision making.

Furthermore, the contractor has developed as well as obtained the requisite knowledge and experience with the Coast Guard internal policies and procedures on non-major and major acquisitions to include: Commandant Instructions, Coast Guard Acquisition Procedures (CGAP), Homeland Security Acquisition Regulations (HSAR), Federal Acquisition Regulations (FAR), and Head of Contracting Activity (HCA) Governance Memorandums and management letters.

Bringing in a different contractor would create substantial delays, likely requiring three (3) months to overcome a long learning curve and become productive. This would significantly impair the USCG’s ability to support major and non-major acquisitions and require a considerable amount of Government oversight for the four-month performance period, increasing cost and performance risk. If the USCG is unable to procure subject matter expertise during the four months proposed for this continuation, tasking will not be accomplished, or will be accomplished using less experienced staff resources. A gap of service will have a negative effect on cost, schedule and/or performance of the USCG’s largest acquisitions by delaying the analysis and acceptance of acquisition program deliverables and postponing productive support services generally. In addition, transition of work to a different contractor will require approximately 45 days, as a different contractor will be required to complete the USCG on-boarding process.

7. USCG intends to post this requirement on FedBizOpps pursuant to FAR 16.505(b)(2)(ii)(D).

8. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

The original task order, Task Order No. HSCG23-13-J-ADW182 expired on 30 November 2018, was competed among DHS TABSS Domain Category 1, Track 1 (Unrestricted), and awarded to Booz Allen Hamilton on 15 May 2013. All offerors were given a fair opportunity to be considered for the original order. In the interest of economy and efficiency, a task order modification will be awarded to the incumbent contractor under their GSA OASIS Pool 1 contract for a total of four (4) months to allow CG-9123 to finish processing a competition for this requirement. A solicitation was released 24 September 2019 and should be awarded no later than the end of January 2020. In order to complete the new competition, a four (4) month extension is necessary to avoid a break in services and to allow time to accommodate a competition and transition period, as required, for the new contract action.

9. Contracting Officer’s Certification.

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.

Ryan Shaughnessy 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.

Clare Boyle Date Technical Representative

BOYLE.CLARE.ANN

A.1535876920

Digitally signed by

BOYLE.CLARE.ANNA.1535876920

Date: 2019.11.26 09:41:25 -05'00'

11/26/2019