Justification and Approval Mess Attendant Base LALB 2_Redacted.pdf

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JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. § 3204(a)(1)

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-111) and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity.

Department of Homeland Security, United States Coast Guard (USCG), Contracting Division LOG-9 proposes to enter into a contract on a basis other than full and open competition.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the action: USCG intends to procure on a sole source basis Mess

Attendant Services at USCG Base Los Angeles, Long Beach, San Pedro, CA for a period of ten (10) months from 01 September 2026 through 30 June 2027.

(b) Name and address of the contractor:

(c) Contract Type: Firm Fixed-Price Contract, Purchase Order

(d) Estimated total value (including options):

Period Unit Price Total

Base Year 01 September 2026 through 30 June

10 mo.

(e) Type of funding: Operations and support funds

(f) Year of funding: Fiscal Year 2026

1 In this document, citations to RFO Parts 6, 10, 15, 25 are citations specifically to FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 Rev. 1 for FAR Part 15, and FAR Class Deviation 25-09 Rev.1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

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(g) Solicitation number:

(h) Background information about the requirement: The current contract and bridge is a Firm Fixed-Price contract set-aside 8(a) that expires on 31 August 2026.

3. Description of Supplies/Services. The requirement is to provide Mess Attendant Services to assist government dining facility cooks by preparing some food for cooking.

Mess Attendants shall also prepare, organize, and stow all foods for display on the salad bar(s). Mess attendants must assist in the accumulation of items used for cooking for cleaning/stowage; and cleaning all dishes, cutlery, pot/pans, preparation/serving areas, and dining room areas.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(a)(1) implemented by the RFO Subpart 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements

5. Identification of Exception to the Buy American Statute.

N/A

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The original contract was an 8(a) sole source award and set-aside. The current vendor, is currently performing under that contract requirement. This requirement is set to expire on 31 August 2026. The vendor graduated from the 8(a) so a request to make the 8(a) competitive with a preference for the Randolph Shepperd Act was submitted to Small Business Administration. The approval was received from SBA on June 2, 2026. The continued service by the current vendor is necessary to avoid interruption of critical mess attendant services requirement to allow for ongoing discussions with the SBA and the pending request for approval to release the requirement from the 8(a) set-aside program. Additionally, negotiations are continuing under the Randolph-Sheppard Act process.

Current guidance from legal counsel is to continue negotiations under the Randolph- Sheppard Act, consistent with 34 C.F.R. § 394.33(a). Per this guidance, we are required to afford the California Department of Rehabilitation’s vendor priority under the Randolph- Sheppard Act in accordance with 34 C.F.R. § 394.33(a).

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many

Potential Sources as is Practicable.

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Acquisition Planning Forecast System APFS was published under F2025071716 on 28 August 2025. Two solicitations, , were posted on SAM.gov but no proposals were received. A solicitation for 8(a) competitive with preference for the RSA will be publicized by March/April 2027 once the requirement is released from the 8(a) program.

8. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable.

The contracting officer determines that the anticipated price(s) will be fair and reasonable based on FAR 15.404-1(b)(2) comparison of the proposed prices to historical prices paid to be fair and reasonable.

9. Description of Market Research.

This is a continuous requirement for the U.S. Coast Guard Base Los Angeles Long Beach (LA/LB), San Pedro, CA and is an 8(a)-set-aside firm fixed price contract. The current contract expires on 31 August 2026, and USCG intends to award a base period of one-year and four one-year option periods, after the bridge. Market Research was conducted between 17 August 2026 is in accordance with 7.107-2, Acquisition Planning Policy and FAR 10.001, Market Research Policy. The incumbent contractor is The Severson Group LLC.

Acquisition Planning Forecast System (APFS) was published on 28 August 2025. The requirement history was awarded IAW FAR Part 19.203(c). The NAICS Code is 722310 for Food Service Contractors with PSC code of S203 Housekeeping – Food Services. The NAICS maximum size is considered $47M. The award of a bridge is IAW FAR 6.103-5 Authorized or required by statute.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

None, all facts are already provided above.

11. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

None.

12. 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 requirement was awarded as an 8(a) sole source; however, the incumbent contractor has since graduated from the 8(a) program. The USCG subsequently requested approval to pursue an 8(a) competitive acquisition under the applicable threshold, and the Office of Management and Technical Assistance approved the request on June 2, 2026.

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After two solicitations were posted on SAM.gov, no 8(a) proposals were received.

Based on additional market research, the USCG identified a limited number of qualified 8(a) vendors capable of performing this requirement. In contrast, numerous small businesses under NAICS 722310, Food Service Contractors, were identified in the State of California.

Market research indicates that Veteran-Owned Small Businesses and other small business concerns may be capable of performing the requirement, particularly given the limited 8(a) interest and availability. Therefore, for the subsequent acquisition, the USCG may pursue a competitive small business set-aside with Randolph-Sheppard Act preference once the requirement is released from the 8(a) program.

13. Technical/Requirements Personnel Certification.

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

Date Contracting Officer Representative

14. Contracting Officer’s Certification and Approval

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.

Date Contracting Officer