80HQTR21D0003 SpectRE JOFOC Mod 10.pdf

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Rev.:10/2025

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

HEADQUARTERS

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For

SPECTRUM AND RESOURCES MANAGEMENT, ENGINEERING AND

PROGRAMMATIC SUPPORT (SPECTRE)

80HQTR21D0003

1. Federal Acquisition Regulation (FAR) 6.104-1(a)(1) – Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

This document is a justification for other than full and open competition prepared by

National Aeronautics and Space Administration (NASA) Headquarters.

The procuring agency is the National Aeronautics and Space Administration (NASA), and the contracting activity is NASA Headquarters (HQ).

2. FAR 6.104-1(a)(2) – The nature and/or description of the action being approved:

This justification provides the rationale for contracting by other than full and open competition to award an extension to contract 80HQTR21D0003 with Agile Decision Sciences, LLC (ADS) for Spectrum and Resources Management, Engineering and Programmatic Support (SpectRE) services to NASA Headquarters. This Space Communication and Navigation Program (SCaN) support contract, 80HQTR21D0003, was competitively awarded on February 23, 2021, with an effective date of April 1, 2021, as a hybrid Cost-Plus-Fixed Fee (CPFF) and Firm-Fixed Price (FFP), Indefinite Delivery Indefinite Quantity (IDIQ) contract. The initial maximum ordering value was $68,000,000.

The ordering period is five (5) years. On June 4, 2024, the contract was unilaterally adjusted to increase the maximum ordering value of the contract in accordance with GSFC clause 52.216-90, Minimum/Maximum Amount of Supplies or Services by 10% to $74,800,000. On April 17, 2025, the contract was bilaterally adjusted again to increase the maximum ordering value by $38,724,995.52 to $113,524,995.52.

3. FAR 6.104-1(a)(3) – A description of the supplies or services required, to meet the

Agency’s needs (including the estimated value):

NASA HQ is proposing to extend the ordering period for one year and increase the maximum ordering value of the current contract. The estimated maximum ordering value will increase by $22.4M , which will result in a total maximum ordering value of approximately $135.9M.

As the SCaN Program office continues to implement and execute organizational restructuring changes, an increase in administrative and technical writing support was needed to meet the requirements of the new program leadership. SCaN manages complex changes to the future space communications architecture and develops advanced communications and navigation capabilities resulting in growth in the engineering and technical areas. The SCaN Cloud, the Organic Architecting Capability, and the Moon to Mars (M2M) Strategic Analyses Cycles (SAC) and Architecture Concept Reviews (ACRs), are continued growth areas in SCaN that require support. More recently, additional engineering and technical analysis support was needed to support the Mars Campaign Office and the new Mars Telecommunications Orbiter project (now the Mars Telecommunications Network project).

In the Spectrum Management and Policy area, continued support is needed to perform an in-depth study of the 7125-8400 MHz band to determine suitability for repurposing in support of the National Spectrum Strategy. Also, a new task order was issued and will be continued to provide collaborations with National Oceanic and Atmospheric Administration (NOAA) for the NASA Electronic Radio Database System (NERDS) system. Additionally, increased requirements in support of the Artemis missions and the Mars program created a need for additional technical support.

Over the course of the contract, the volume of technical support increased that were not anticipated at the time of contract award. For example, organizational changes such as the division of the Human Exploration and Operations Mission Directorate (HEOMD) into two

(2) mission directorates, the Space Operations Mission Directorate (SOMD) and the Exploration Systems Development Mission Directorate (ESDMD), created the need for additional administrative, strategic integration, and general support services.

There will be no changes to the scope of services provided by ADS under the proposed contract modification. The contract’s scope of work requires the Contractor to provide Spectrum and Resources Management, Engineering and Programmatic support to the SCaN Program, as well as other Mission Directorates and programs at NASA HQ.

Without an increase to the maximum ordering value and ordering period, NASA HQ would be precluded from continuing current ongoing support requirements and issuing new task orders for services under this contract. The extension and ordering value increase are necessary to continue performance through the effective ordering period of the contract.

Additionally, the extension of the ordering period will allow sufficient time to determine, evaluate and execute different commercial procurement strategies, as well as the utilization of existing NASA contract vehicles for the continuation of the SCaN work.

The required mission critical support includes planning, scheduling, configuration management, system engineering, integration services, systems operation, and system development, among other services. These services are essential to ensure the success of the following critical activities:

a. Provide expert knowledge in domestic and international spectrum management and regulatory services such as spectrum management, regulations and policies, communication and senior technologies, space and ground networks and orbital debris management.

b. Provide expert knowledge in programmatic and management accounting tools and services such as government planning, programming, budgeting and execution process, accounting principles, management accounting, cost projections of ground systems, and operations analysis.

c. Provide expert knowledge in web presences and applications, education, and public outreach activities such as development of websites and applications including social media, and maintenance of intranets.

d. Provide expert knowledge in space communications and navigation engineering services such as optical communication technologies, space navigation, development of space communication and navigation standards and ground systems development, and network operations.

The current value of task orders issued through March 2026, is $113 Million. Based on current projections and future estimated continuing support, the remaining ordering value is insufficient to cover the technical requirements of the SCaN Program, as well as other Mission Directorates at NASA HQ, including but not limited to, , Mars Campaign Office, Moon to Mars program, and Space Technology Mission Directorate (STMD). Without an increase to the maximum ordering value, NASA Headquarters will be precluded from continuing current ongoing support requirements under this contract. As noted above, the required maximum ordering value will be increased by approximately $22.3M which will result in a total maximum ordering value of $135.9M.

4. FAR 6.104-1(a)(4) – An identification of the 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) as implemented by FAR 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements.

5. FAR 6.104-1(a)(5) – A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

The rationale supporting the use of 10 U.S.C. 3204(a)(1) “Only one responsible source and no other supplies or services will satisfy agency requirements” is described below.

Under FAR 6.302-1(a)(2)(iii), NASA may contract without providing full and open competition when services may be deemed available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in: (1) substantial duplication of cost to the Government that is not expected to be recovered through competition; or (2) unacceptable delays in fulfilling the agency’s requirements. In addition to technical requirements, the regulatory environment for NASA acquisition is evolving as the Agency implements measures to comply with the Executive Order 14240 “Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement,” goals of enhancing efficiencies, decreasing duplication, and increasing value to taxpayers in government operations.

This contract extension will allow NASA to transition to the current Administration’s objectives and align with its priorities by establishing a procurement strategy that is simple, usable, and efficient, and protects economic and national security interests. This transition period will mitigate any duplication of costs stemming from the acquisition process and allow the agency to be in the best position to execute this Administration’s initiatives.

If NASA attempts to procure these services from any other source, the combination of delay due to the competitive process and the time required to transition a new management team to coordinate staffing levels, schedules, and to become familiar with work requirements and systems would cause unacceptable delays in fulfilling NASA’s mission. Based on the time and costs that would be involved in procuring and phasing in another contract, ADS is the only entity possessing the detailed knowledge necessary to provide seamless continuation of the services provided under the SpectRE contract without risk of an unacceptable interruption or delay of critical services. Failing to increase the maximum ordering value and extend the period of performance would result in significant costs to the government. Also, it is very likely that there would be significant ramp up costs for a new contractor to try to quickly replicate the knowledge/systems/processes that the incumbent has, and it would take significant effort and cost to do so.

ADS has the specialized training, experience, and expertise necessary to continue providing essential support and information technology services to the SCaN Program, as well as to other Mission Directorates, without disruption. The SCaN program requires a multitude of skills and expertise, much of which is acquired through the work experience and specific in-house training for understanding network operations and spectrum regulatory policy. The Contractor develops and maintains multiple customized applications and systems, which are critical to the management and operations of the SCaN Program, that cannot quickly or easily be transitioned to another vendor. The success of NASA's missions relies on maintaining the operational readiness of space communication and navigation systems, while also advancing these capabilities through technological development, new system implementation, and leadership in international standards for space communications and navigation. ADS possesses the critical knowledge and insight gained from its ongoing support of the forementioned directorates, which is essential for a Contractor to effectively continue meeting contract requirements.

The SCaN Program provides the Agency with essential communication and navigation capabilities and serves as the primary authority for managing spectrum allocations and assignments, supporting both the Agency and the U.S. commercial space communication sector. The program also leads coordination with national and international spectrum management organizations. ADS’s continued support is vital for the uninterrupted delivery of services, including general spectrum management, compatibility analysis, communication and sensor technologies, radio-investigation, and Global Positioning System (GPS) technologies, spectrum considerations for extraterrestrial missions, life assessments, and orbital debris management. These services are vital for NASA to remain a leader in national spectrum management and to support both its mission objectives and its role in assisting the U.S. commercial space communications industry.

Award to any other source will result in an unacceptable delay to fulfilling the agency’s requirements. ADS and its subcontractors have deep expertise in the areas described above that was developed through its ongoing work under this contract as well as the previous contracts also supported by this vendor. Additionally, transitioning this work to another Contractor will likely cause a 13–18-month lapse in services due to the time necessary to re-acquire these services through a new acquisition. This delay will jeopardize service continuity and pose substantial programmatic risks and delays. An award to another source would cause unacceptable delays in meeting the Agency's requirement creating a gap in services. Any disruptions would adversely impact SCaN’s ability to meet the space communications needs for NASA's Lunar and Mars Missions and could hinder the successful execution of initiatives across partnering mission directorates.

Additionally, acquisition activities during the past year have been paused at the behest of the acting agency leadership until an Administrator was confirmed to ensure alignment with the Fisal Year (FY) budget and mission priorities. The NASA Administrator, Jared Isaacman, was confirmed on December 17, 2025. NASA is diligently pursuing acquisition activities, however, will be unable to complete them before the end of the current ordering period (March 31, 2026), however, intends to make contract award(s) on or before March 2027.

Extending ADS’s contract will result in the total ordering period exceeding 5 years, however, this document explains in detail the exceptional circumstances surrounding this acquisition and demonstrates that utilizing this contract is the most prudent course of action and is necessary. Accordingly, the findings in this document, and the approval thereof, serve as the determination and findings that extending ADS’s contract beyond its original five year period is in the best interest of the Government and made under the authority of FAR 16.501-2(c)(1) and 10 USC 3403.

6. FAR 6.104-1(a)(6) – A description of the efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by part 5 and, if not, which exception under part 5 applies:

A notice to the Government Point of Entry (GPE) website (Sam.gov) was published on March 6, 2026, in accordance with FAR part 5. This posting informed potential sources of NASA’s intent to award this sole-source contract extension to ADS. The results of this synopsis are summarized in Section 10 below.

7. FAR 6.104-1(a)(7) – A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer’s (CO) signature on this document indicates that the CO has determined that the anticipated cost to the government will be fair and reasonable. The contract has approved and verified labor rates through fiscal year 2027.

The SpectRE contract was a competitively awarded hybrid IDIQ contract with work allocated through individual task orders, which are priced using the labor categories and fully burdened direct labor rates established in the contract. These rates are pre-established under the contract to cover the remaining ordering period and up to a year thereafter. In addition, the Contracting Officer’s Representative (COR) and the CO will review the Contractor’s task plans and estimates to determine that the direct labor rates, direct labor hours, skill mix, other direct costs, indirect costs, and fee(s) are fair and reasonable prior to each task being issued, as is the practice with the current contract.

8. FAR 6.104-1(a)(8) – Description of the market research conducted, and the results, or a statement of the reason market research was not conducted (e.g., urgent, and compelling requirement):

Tactical market research, indicates there are currently no other offerors that could take on full contract responsibility without significant performance, cost and schedule risks. NASA HQ is not aware of any alternate sources that could immediately take on full contract responsibility without risk of an unacceptable delay to the SCaN work performed under the contract. The Government would unnecessarily incur significant additional cost if another contractor were to perform this effort during this period. A competitive contract(s) is expected to be awarded by the end of this proposed contract extension, if not sooner. An assessment of other existing current contracts was made with the conclusion that no viable contract vehicles existed that could reasonably support the requirement.

9. FAR 6.104-1(a)(9) – Any other facts supporting the use of other than full and open competition:

The extension of the ordering period and increase in maximum ordering value is needed to continue performance through March 31, 2027. Since NASA does not intend on recompeting the SpectRE contract as is, this action would avoid a break in service while acquisition activities to ensure continuity of services provided under contract #80HQTR21D0003 is conducted.

Recompeting contracts that may be altered or eliminated due to changes in acquisition regulation or budgetary revisions can lead to significant cost duplication that cannot be recouped through competitive processes. These costs encompass the efforts of requirements development teams and source evaluation boards, the transition between contractors, and the administrative expenses tied to restructuring contracts under the current Federal Acquisition Regulation to fit the new regulatory framework following the Revolutionary FAR Overhaul (RFO). Additionally, pursuing follow-on contracts would divert essential agency resources needed for the expected realignment of NASA's workforce, IT, professional and engineering services, as well as operations at NASA Centers.

10. FAR 6.104-1(a)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition:

A notice of NASA’s intent to award this sole-source action was synopsized on the GPE website (Sam.gov) per FAR part 5 (See Section 6 above). The synopsis notified all interested sources that this requirement will be issued on a sole-source basis and provided them an opportunity to submit their interest and capabilities to the CO within 15 days of the synopsis publication. The synopsis closed on March 23, 2026. No capability statements were received.

11. FAR 6.104-1(a)(11) – A statement of actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required:

NASA does not intend to recompete this contract as is. To the extent possible, SCaN’s requirements will be fulfilled through existing contract vehicles and new competitive acquisition(s).

The Agency will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.

NASA is committed to fostering future competition where practicable. As the procurement strategy and requirements are being revisited, NASA HQ and procuring offices will:

• Identify and plan for acquisition strategies that reduce sole-source reliance.

• Utilize commercial practices in accordance with Executive Order 14271, Ensuring

Commercial, Cost-Effective Solutions in Federal Contracts.

• Acquire or negotiate Government Purpose Rights where feasible.

• Improve technical documentation for future competition.

• Conduct early market research and industry engagement.

• Explore segmented or modular competition strategies.

• Examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.

These steps will support competitive procurement efforts and reduce barriers to entry for qualified vendors in future acquisitions.

Spectrum and Resources Management, Engineering and Programmatic Support (SpectRE)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

I certify that the facts presented in this justification are accurate and complete.

Angela Leigh Meza Contracting Officer’s Representative

I hereby certify that the above justification is complete and accurate to the best of my knowledge and belief.

Patrick B. Dewyngaert Senior Contracting Officer

CONCURRENCES:

Eric J. Newman Competition Advocate Goddard Space Flight Center

Young Cho Office of the General Counsel at Headquarters

APROVAL:

Nipa Shah Procurement Officer and Head of Contracting Activity

Angela Leigh Meza:

Patrick B Dewyngaert:

Eric J Newman:

Young Cho:

Nipa Shah:

Signature Block1_es_:signer:signatureblock:

2026-03-25T08:52:34-0400

Angela Meza

2026-03-25T08:33:44-0400

Patrick Dewyngaert

2026-03-25T09:17:06-0400

Eric Newman

2026-03-25T10:20:19-0400

Young Cho

2026-03-25T16:40:51-0400

NIPA SHAH