Limited Sources Justification COR KO signed 6.9.26.pdf

Limited-Sources Justification

Pursuant to the Multiple Award Schedule Program (as authorized by 40 U.S.C. § 501), this justification is prepared in accordance with the requirements of Federal Acquisition Regulation (FAR) 8.405-6(c) for the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3. The circumstance justifying restriction is FAR 8.405-6(b)(1) through the following facts and rationale:

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), CG-HQ- COCO-32 proposes to enter into an order on the basis of a limited-sources justification. This acquisition strategy will use a General Services Administration (GSA) Multiple Award Schedule (MAS) contract on a basis of other than full and open competition.

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

USCG has a requirement to procure professional advisory and consulting support services from the National Academy of Public Administration (NAPA) in support of the overhaul and digital-first transformation of the U.S. Coast Guard Capability Analysis and Operational Requirements Generation framework in support of the Futures, Development & Integration (FD&I) Directorate and Office of Strategic Capabilities (CG-SC).

An order will be placed under a GSA MAS vendor contract at an estimated price of $900,000.00.

(a) Nature of action: USCG intends to limit competition in accordance with FAR 8.405-6(b)(1).

(b) Name and address of the contractor:

National Academy of Public Administration (NAPA) 1600 K Street NW, Suite 400 Washington, DC 20006

PH: (202) 347-3190

www.napawash.org

(c) Contract type: Firm-Fixed-Price

(d) Estimated total value (including options): $900,000.00

(e) Type of funding: FY26 O&S

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: 70Z02326Q7710001

Period | PoP | Quantity | Unit Price | Total Base | 06/20/2026 – 03/19/2027 | 9 Months | $900,000.00

(3) Description of Supplies/Services.

The requirement is for professional advisory, governance, organizational transformation, mission engineering, acquisition integration, and policy development support services associated with modernization of the USCG operational requirements generation framework in accordance with the attached Statement of Work.

The effort includes:

• Assessment of the current requirements framework;

• Stakeholder engagement workshops and forums;

• Best practices research and benchmarking;

• Development of a Mission Engineering-based “To-Be” framework;

• Governance and organizational structure recommendations;

• Development of replacement policy and governance documentation for

COMDTINST 5000.4A;

• Digital engineering and governance recommendations;

• Workforce competency and implementation planning;

• Executive briefings and final reporting.

The anticipated period of performance is from 20 June 2026 through 19 March 2027.

(4) Identification of the justification and rationale.

Justification for this action will permit the USCG to obtain highly specialized advisory and organizational transformation support from a uniquely qualified source possessing extensive federal governance expertise, independence, and Congressional charter authority specific to public administration and government modernization.

• FAR 8.405-6(b)(1) – 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 National Academy of Public Administration (NAPA) is uniquely qualified to support this effort due to:

• Its Congressional charter under Public Law 98-257;

• Its status as an independent, nonpartisan organization dedicated to improving government operations and administration;

• Its extensive experience supporting federal governance transformation initiatives;

• Its access to distinguished Fellows and senior public administration experts;

• Its demonstrated expertise in acquisition reform, mission engineering integration, organizational governance, and federal capability development frameworks.

The contemplated effort is not a routine consulting engagement. The work involves enterprise-level transformation of the Coast Guard’s operational requirements generation and capability development framework, including governance modernization, strategic policy development, Mission Engineering integration, and alignment with evolving DHS and Department of Defense acquisition and force design initiatives.

Market research determined that no other source provides the same combination of:

• Congressional charter authority;

• Federal public administration specialization;

• Organizational independence and objectivity;

• Executive-level governance expertise;

• Demonstrated experience performing comparable federal transformation efforts.

NAPA currently maintains an active GSA MAS contract, 47QRAA24D002L, under SIN 541611 for Management and Financial Consulting, Acquisition and Grants Management Support, and Business Program and Project Management Services.

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

The Contracting Officer has determined that placing an order against a GSA MAS contract represents the best value and will result in the lowest overall cost alternative, considering price and administrative costs, to meet the Government’s needs.

The ordering activity has considered the following:

a) GSA has already determined the prices under the MAS contract to be fair and reasonable.

b) The Contracting Officer will evaluate the proposed labor mix, level of effort, and pricing against the Independent Government Cost Estimate (IGCE).

c) The Contracting Officer may request price reductions prior to award.

d) Use of the existing MAS contract minimizes procurement lead time and administrative burden while providing access to a uniquely qualified source.

(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 through review of available GSA MAS contractors, review of available federal advisory and consulting organizations, and assessment of organizations capable of supporting large-scale federal governance and acquisition transformation initiatives.

Although other consulting organizations may provide management consulting services, market research determined that no other source provides the same combination of:

• Congressional charter authority;

• Independence and nonpartisan status;

• Federal governance specialization;

• Public administration expertise;

• Experience supporting comparable government transformation efforts.

The Government determined that use of another source would introduce increased performance risk and reduce the level of independence, credibility, and specialized public-sector expertise required for this effort.

(7) Any other facts supporting the justification.

NAPA has previously supported numerous federal departments and agencies through similar organizational transformation, governance, and strategic modernization efforts.

Federal law and NAPA’s Congressional charter specifically authorize the Federal Government to call upon NAPA to investigate, examine, and report upon matters of government administration and public management.

The contemplated effort supports a high-visibility strategic modernization initiative within the USCG Futures, Development & Integration Directorate and requires an organization possessing exceptional credibility and specialized expertise in federal governance and public administration.

(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 FAR 8.405-1 and FAR 8.405-2 before any subsequent acquisition for the supplies or services is made.

The USCG will continue to assess future requirements individually and evaluate opportunities for competition where practical and appropriate.

At this time, due to the unique nature of the requirement and the specialized expertise required, the Government has determined that NAPA is the only responsible source capable of meeting the Government’s requirements at the level of quality required.

(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.

Adam Petty Date Contracting Officer

(10) Technical/Requirements Personnel Certification.

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

Technical Representative/COR Date