JOFOC - ETS bridge - for review - redacted.pdf

Justification for Other than Full and Open Competition (JOFOC)

RFO - FAR 6.103-1 – Only one responsible source and no other supplies or services will satisfy agency requirements

1. Acquisition Title: Enterprise IT Operations and Maintenance (EIT O&M) Services

Division: Division of Acquisition Policy on behalf of Indian Health Service (IHS), Office of

Information Technology (OIT), Division of IT Operation (DITO)

Contracting Activity: IHS, Division of Acquisition Policy (DAP)

Author: Julie Corbin, Contracting Officer.

Basis for approval under Revolutionary FAR Overhaul (RFO) - FAR 6.104(c): Individual

Basis.

2. Nature and/or Description of the Action being Approved: IHS, OIT requests a 12-month firm-fixed-price follow-on bridge contract with the incumbent contract Kadiak LLC. (Kadiak) to ensure continuity of critical EIT O&M services for IHS while the competitive acquisition is completed. The Government projects award for this follow-on bridge contract in January 2026 using fiscal year 2026 funds.

Contractor: Kadiak LLC., 3800 Centerpoint Dr. Ste 502, Anchorage, AK 99503

Performance

Period

Dates/Duration Unit Price/CLIN

Multiplier Total

Base Period 12 months $12,289,167.85 1 $12,289,167.85

Option to Extend Services per RFO

FAR Clause 52.217-8 up to 6 months

$6,144,583.93 1 $6,144,583.93

Estimated Total Dollar Value: $18,433,751.78

New Contract Value: $12,289,167.85 for 12 months which includes the

$1.725 million limited optional services potentially needed to support the existing scope for “PATH

EHR” implementation

(Note, the required CLIN is

$10,563,323.60) and

$18,433,751.78 if including

RFO FAR 52.217-8)

3. Description of Supplies and/or Services:

The IHS, an operating division of the United States Department of Health and Human Services

(HHS), provides a comprehensive health service delivery system for approximately 2.2 million of the nation’s estimated 2.4 million American Indians and Alaska Natives. The IHS OIT is required to support and maintain the availability, integrity, and confidentiality of the IT systems that support the IHS mission. As such, the IHS requires EIT O&M support services to ensure the availability, integrity, security and confidentiality of critical IT services provided by OIT.

Under this contract, the contractor shall provide skilled, experienced and highly knowledgeable technical support resources for the IHS Enterprise level IT operations and maintenance services for the Headquarters (HQ, OIT) Data Centers and the Enterprise IT systems (non-Health IT) that support the IHS mission. This includes the maintenance and improvement of the availability, integrity and confidentiality of the IT architecture and engineering, systems administration, Data

Center infrastructure systems and storage, desktop and service desk services for the HQ user base as well as Tier 3 support of critical Enterprise infrastructure services to the IHS Regional

Areas and facilities. The purpose of this acquisition is to provide onsite and remote contract support to manage, sustain and improve the existing in-scope IT services and systems.

4. Statutory Authority Cited and Rationale:

a. RFO - FAR 6.103-1, Only one responsible source and no other supplies or services will satisfy agency requirements. Authority: 41 U.S.C. 3304(a)(1). Per RFO - HHSAR 306.103-1, for acquisitions covered by 42 U.S.C. 247d-6a(b)(2)(A), “available from only one responsible source” must be deemed to mean “available from only one responsible source or only from a limited number of responsible sources.”

Pursuant to RFO FAR 6.103-1, Only One Responsible Source and No Other Supplies or Services

Will Satisfy Agency Requirements. The IHS requires award of a one-year bridge contract to the incumbent contractor to ensure uninterrupted continuity of critical EIT O&M services. The incumbent is the only responsible source capable of immediately and successfully providing these highly integrated services due to its unique combination of demonstrated technical expertise, institutional knowledge, and operational experience supporting IHS’s enterprise IT environment. These services include, but are not limited to, data center operations, enterprise network and security services, Active Directory and identity management, cloud and hybrid infrastructure, Service Desk and Tier 3 support, cybersecurity and compliance, and continuous operations supporting clinical and administrative systems as defined in the Performance Work

Statement (PWS). Market research indicates that no other contractor could assume responsibility for this scope of work within the required timeframe without extensive transition, onboarding, security accreditation, and knowledge transfer efforts that would introduce unacceptable operational risk. The incumbent’s familiarity with IHS-specific architectures, configurations, security boundaries, ServiceNow workflows, and mission-critical dependencies is essential to meeting IHS requirements and cannot be replicated or substituted by alternative sources or products without disruption.

This action is a follow-on bridge contract for continued performance of highly specialized and mission-critical EIT O&M services. Award to a source other than the incumbent would result in significant duplication of cost and unacceptable delays due to the need for extensive re-engineering, retraining, system reauthorization, and transition of personnel supporting High

Value Assets and 24x7 operations. Such delays would jeopardize the availability, integrity, and confidentiality of IT systems that directly support the delivery of healthcare services to approximately 2.2 million American Indians and Alaska Natives nationwide. Additionally, the

EIT environment relies on tightly integrated tools, configurations, and processes that have been refined over the life of the current contract and are essential to maintaining continuity of operations; alternative supplies or services cannot be modified in time to meet IHS requirements in accordance with RFO-FAR Part 11. Therefore, limiting competition to the incumbent is justified to avoid catastrophic service interruption, unacceptable mission risk, and adverse impacts to patient care while IHS completes a full and open competitive recompete.

The Program Office has also identified a limited set of optional services to be included in this bridge contract that are logical extensions of the existing EIT O&M requirement and are necessary to support the mandated IHS Health IT modernization, specifically the PathEHR implementation. These optional tasks directly build upon the incumbent’s current responsibilities supporting enterprise infrastructure, security, identity management, Service Desk, and 24x7 operations that PathEHR depends upon for successful deployment and sustainment. The options will be exercised only if and when funding becomes available and are limited to minimum interim needs during the bridge period, and do not represent a material change in scope or introduce new requirements outside the existing PWS framework. Inclusion of these services avoids integration risk, duplicative transition costs, and potential disruption to PathEHR readiness that would result from introducing a new contractor during this critical modernization phase, while preserving full competition for the follow-on acquisition.

5. Special Considerations for Certain Contract Extensions or Bridge Contracts:

The current $48 million EIT O&M contract supports mission-critical IHS enterprise infrastructure and expires on 02/05/2026; a competitive follow-on acquisition is actively being developed but has been delayed due to significant organizational realignments, administration-mandated policy changes, implementation of the Revolutionary FAR Overhaul (RFO), and shifting agency priorities that required reassessment of requirements and acquisition strategy.

Key milestones for the follow-on include finalization of revised requirements, acquisition planning approval, release of a competitive solicitation, evaluation, and award; however, these actions cannot be completed prior to contract expiration without undue risk. It would be neither cost-effective nor realistic for another contractor to meet IHS needs during the interim period due to substantial start-up and transition costs, including recruitment and clearance of qualified staff, extensive phase-in and knowledge transfer, assumption of Government Furnished Property, security reauthorization for High Value Assets, and operational risk to 24x7 services. This one-year bridge contract is limited strictly to minimum mission needs and duration necessary to maintain continuity of operations while the competitive follow-on is completed, avoiding service disruption to systems supporting healthcare delivery for approximately 2.2 million American

Indians and Alaska Natives nationwide, as defined in the Performance Work Statement.

6. Actions to Increase Competition:

a. A Notice of Intent to Sole Source was Published on 12/18/2025, as required by RFO -

FAR 5.201(a).

b. Responses Were not Received:

At the closing of the Notice of Intent to Sole Source on 12/24/2025, no responses were received.

c. Sources Expressing Interest:

No responses were received therefore, no sources expressed interest.

d. Actions to Foster Competition for Future, Similar Requirements:

IHS is actively taking steps to foster full and open competition for future EIT O&M requirements. During the period of performance of this bridge contract, IHS will finalize revised requirements, incorporate lessons learned from the incumbent contract, and complete acquisition planning to support a competitive follow-on procurement in accordance with the Revolutionary FAR Overhaul (RFO) and FAR Part 6. Market research will be conducted to assess industry capabilities, identify potential sources, and refine the performance-based requirements to avoid unnecessary barriers to competition.

The follow-on acquisition will be structured to promote competition to the maximum extent practicable, including consideration of contract type, scope segmentation where feasible, and updated evaluation criteria. This bridge action is limited in duration and purpose and is intended solely to allow sufficient time to complete a full and open competitive acquisition; no proprietary data or licensing barriers preclude future competition, and advanced planning for the follow-on competitive action is underway.

7. Market Research:

Meaningful market research was conducted in accordance with RFO FAR Part 10 by both the

Program Office and the Contract Specialist to identify qualified sources capable of providing

EIT O&M services. Research included use of GSA Market Research as a Service (MRAS), the

SBA Dynamic Small Business Search (DSBS) tool, and a sources-sought notice on SAM.gov identified multiple potential sources, including small businesses, federally recognized Native-owned firms, and three Indian Small Business Economic Enterprises (ISBEEs). The Contracting

Officer also reviewed the Bureau of Indian Affairs’ Information Technology Support Services

(ITSS) IDIQ that applies Buy Indian Act requirements. Because this action is a follow-on bridge contract driven by true urgency to ensure continuity of critical services, additional market research was appropriately limited to readily available information, including assessment of the incumbent’s GSA Schedule labor rates, which were determined to be fair and reasonable. The market research is current, relevant within 18 months of award, and demonstrates that while multiple sources may be capable under a competitive procurement, only the incumbent can meet

IHS’s immediate interim requirements without unacceptable operational risk.

8. Procurement History:

Contractor: Kadiak LLC.

Contract or Order Number: 75H70420C00004

Award Date and Period of Performance:

Awarded on 08/06/2020. See below for Period of Performance and value:

Period Period of

Performance Amt

Funded

Amount Notes

Base

Period

8/6/2020 -

2/5/2021 $3,276,831.38 $3,276,831.38

Awarded and Fully

Funded

Option

Period 1

2/6/2021 -

8/5/2021 $3,552,168.80 $3,552,168.80

Awarded and Fully

Funded

Option

Period 2

8/6/2021 -

2/5/2022 $3,631,307.54 $3,631,307.54

Awarded and Fully

Funded

Option

Period 3

2/6/2022 -

8/5/2022 $3,904,956.94 $3,904,956.94

Awarded and Fully

Funded

Option

Period 4

8/6/2022 -

2/5/2023 $4,145,290.56 $4,145,290.56

Awarded and Fully

Funded

Option

Period 5

2/6/2023 -

8/5/2023 $4,562,651.78 $4,562,651.78

Awarded and Fully

Funded

Option

Period 6

8/6/2023 -

2/5/2024 $4,642,199.85 $4,642,199.85

Awarded and Fully

Funded

Option

Period 7

2/6/2024 -

8/5/2024 $5,115,235.05 $5,115,235.05

Awarded and Fully

Funded

Option

Period 8

8/6/2024 -

2/5/2025 $5,216,563.68 $5,216,563.68

Awarded and Fully

Funded

Option

Period 9

2/6/2025 -

8/5/2025 $5,216,563.68 $5,216,563.68

Awarded and Fully

Funded

Option To

Extend

Services

8/6/2025 -

2/5/2026 $5,216,563.68 $5,216,563.68

Awarded and Fully

Funded

Total $48,480,332.94 $48,480,332.94

Competitive Status: ISBEE set-aside

Authority formerly relied upon if Not Competed: N/A

9. Additional Information or Other Facts:

None

10. Technical or Requirements Program Management Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

X Right-Click "Signature Setup"

Kathryn Lewis

Program Manager Signature &

Date:

11. Fair and Reasonable Price Determination: As the contracting officer, I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable.

This determination will be made using the following: ☐ cost analysis ☒ price analysis

☐ cost realism ☒ market pricing ☒ historical pricing

As a part of this basis, certified cost, or pricing data (see RFO - FAR 15.403)—

☐ will be required. ☒ will not be required and the following FAR part 15 exception applies:

☐ Prices that will be agreed upon are based on adequate price competition.

☐ Prices that will be agreed upon are based on prices set by law or regulation.

☒ A commercial item is being acquired.

☐ A waiver has been granted by the HCA in accordance with RFO - FAR 15.403-2(c)(4).

☐ The contract action is a modification to a contract or subcontract for commercial item(s).

☐ The estimated cost of the contract action is less than the threshold for certified cost or pricing data.

12. Contracting Officer (CO) Certification and Determination: I hereby certify that this justification is accurate and complete to the best of my knowledge and belief. And, based upon the foregoing, I also determine that using a sole-source contract is in the best interest of OIT, DITO. [Always required; CO approval authority is limited to $900 thousand.]

Julie Corbin

Contracting Officer Signature &

ELEVATED REVIEWS & APPROVALS

13. DAP Advocate for Competition (AfC) Review and Approval: I reviewed this justification find that it adequately supports other than full and open competition. [Division AfC approval authority is limited to $20 million.]

Magdalenda Hudson

IHS Competition Advocate Signature &