80JSC019A0001_SPEAC LSJ.pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA)

LYNDON B. JOHNSON SPACE CENTER (JSC)

LIMITED-SOURCES JUSTIFICATION (LSJ)

For Strategic Professional Engineering Assessment Contract (SPEAC)

80JSC019A0001

This is a LSJ prepared by the NASA JSC.

The initial Strategic Professional Engineering Assessment Contract (SPEAC) acquisition was conducted under the Multiple-Award Schedule Program (Title 41 United States Code 152(3)).

This action is for the modification of the SPEAC Blanket Purchase Agreement (BPA) 80JSC019A001, under General Services Administration (GSA) Schedule Contract GS-00F- 008DA. The current total estimated value of SPEAC is $112,000,000. The purpose of this action is to increase the estimated value of the SPEAC BPA from $112,000,000 by $60,000,000 to $172,000,000. The SPEAC BPA was competitively awarded to Booz Allen Hamilton (BAH) on December 11, 2018, as a single award firm-fixed-price BPA. SPEAC provides independent programmatic and institutional assessment capability support to NASA and other government agencies.

Given the increased demand for SPEAC requirements an increase in the amount of $60,000,000 is required. JSC has begun the re-competition process for the follow-on acquisition. The follow-on to the current BPA is being started early enough to allow for adequate planning with the intent to conduct full and open competition for the follow-on BPA. The increase will allow NASA to continue critical support of institutional assessment support activities while follow-on actions are completed. SPEAC support is critical to current and new programs and projects across the Agency.

The total estimated ceiling amount of the proposed BPA is $172,000,000. The SPEAC BPA period of performance consists of a 1-year base period (February 27, 2019 through February 26, 2020), and four 1-year options (Option one from February 27, 2020 to February 26, 2021, Option two from February 27, 2021 to February 26, 2022, Option three from February 27, 2022 to February 26, 2023, and Option four from February 27, 2023 to February 26, 2024).

80JSC019A0001 – SPEAC LSJ

Authority Cited and Rationale:

Federal Acquisition Regulation (FAR) 8.405-6(a)(1)(A). An urgent and compelling need exists and following normal procedures would result in unacceptable delays.

FAR 8.405-6(a)(1)(B). Only one source can provide the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

FAR 8.405-6(a)(1)(C). In the interest of economy and efficiency, the new work is a logical follow-on to an original GSA Federal Supply Schedule (FSS) order provided that the original order was placed in accordance with the applicable GSA FSS ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

FAR 8.405-6(b). Items Peculiar to One Manufacturer. An item peculiar to one manufacturer can be a brand name, product, or a feature of a product, peculiar to one manufacturer. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer.

Rationale:

In accordance with FAR 8.405-6, Limiting Sources, orders placed under FSSs are exempt from the requirements of FAR Part 6, Competition Requirements; however, an ordering activity must justify its action when restricting consideration of schedule contractors. This justification provides the rationale for limiting sources to increase the estimated value by $60,000,000 to ensure continuity of work under the SPEAC BPA. As demonstrated below, in the interest of economy and efficiency, new work under SPEAC is a logical follow-on to the already existing SPEAC BPA.

In order to meet the criteria under FAR 8.405-6(a)(1)(C) and issue an order on a noncompetitive basis, three criteria must be met: (1) the new work must be a logical follow-on to an original GSA FSS BPA; (2) the original BPA may not have been previously issued under sole-source or limited sources procedures; and (3) the decision to issue the follow-on order on a noncompetitive basis must be made in the interest of economy and efficiency.

The first criteria under FAR 8.405-6(a)(1)(C) is met as the new work will be a logical follow-on to the existing BPA. The increase in value will allow for new work under SPEAC to provide continuation of the same services to NASA and other government agencies. The contractor currently provides independent programmatic and institutional assessment capability support to NASA and other government agencies and will continue to do so in the work resulting from the BPA value increase. Reviews and assessments are performed in support of organizational, tactical, and agency institutional support activities. SPEAC currently provides support for the Science Mission Directorate, International Space Station (ISS) Program, Exploration Science Directorate (ESD), Commercial Crew Program (CCP), Office of the Chief Information Officer, Space Launch System (SLS), Human Landing System, Office of the Chief Human Capital Officer, Equal Opportunity and Diversity Management, Human Exploration Office Mission Directorate, Gateway, Orion, and Exploration and Integration and Science Directorate. The follow-on work will provide a continuation of these same services, with no changes to the overall scope of the BPA, therefore it is a clear and logical follow-on to the current BPA.

The second criteria under FAR 8.405-6(a)(1)(C) is met as the original SPEAC BPA was conducted as full and open competition in accordance with FAR 6.102(d)(3) and FAR Subpart 8, and a Request for Quotations was released on June 11, 2018, via the GSA eBuy website.

Quotations were received from two offerors; BAH and Science Applications International Corporation. The SPEAC BPA was competitively awarded to BAH on December 11, 2018, as a single-award BPA issued under the GSA FSS. The original BPA was not issued in a sole-source environment; therefore, this action is compliant with the requirements for the second criteria of FAR 8.405-6(a)(1)(C).

Orders have been issued under SPEAC at a much higher rate than initially anticipated due to new programs and initiatives utilizing the BPA’s requirements. The current BPA value (amount of all task orders issued to date) is $69,809,628.26 and is progressively increasing. At the current spend rate of approximately $4 million per month, SPEAC is anticipated to exceed its estimated value by August 2021, 2.5 years prior to the end of its current period of performance.

Consequently, a BPA value increase is necessary to continue the critical services being performed under SPEAC while a follow-on competition is being conducted. Increasing the current estimated value by $60,000,000 will allow for performance on the BPA through November 2022.

The contractor is currently supporting NASA in the independent programmatic and institutional assessment capability support. BAH currently performs services in support of the Gateway, Orion, and CCPs, among many other critical program support assessments. All these major programs are operating with very little schedule margin. Changing contractors during these critical milestones would create substantial disruption to these programs. Near and mid-term milestones would be impacted by any disruption in services.

The third criteria of FAR 8.405-6(a)(1)(C) requires that the order be issued in the interest of economy and efficiency. Considering the substantial work already performed by BAH in support of the current SPEAC BPA, utilizing another contractor to complete these efforts would adversely impact the economy and efficiency of NASA's efforts. Since most of the new task orders build from previous orders, significant re-work of previously completed tasks would be required for a new contractor to satisfactorily complete critical projects that are already in work.

Leveraging the incumbent's knowledge will eliminate redundancy and allow resources to be allocated in the most economical and efficient manner. The intellectual capital gained through the prior work completed by the incumbent cannot be transferred to a new contractor without some duplication of effort, increased costs, and schedule delays. It is estimated that a new vendor would require a minimum of six months to reach an acceptable level of competency.

This follow-on work is in the interest of economy and efficiency as any course of action other than increasing the current estimated value of the BPA would lead to unacceptable delays in fulfilling the Government’s needs and pose significant schedule risks to major NASA programs.

Increasing the estimated value of the BPA provides a strategy that mitigates risk substantially and balances mission success for Gateway, Orion, Commercial Crew among other major NASA programs. A discontinuity of services would create significant burdens to the Gateway, Orion, CCPs and would not be in the best interest of NASA due to resulting delays and lack of continuity of services in fulfilling the Agency’s requirements. Upon consideration of the technical, cost, and schedule risks to NASA based on the disruption of continuity of services and unacceptable delays that would be incurred, the potential benefits from competing this action do not justify acceptance of the substantial programmatic risks.

There are multiple Gateway program milestones that would be impacted by a disruption of services to the BPA as identified in the following five paragraphs. This impact includes the Gateway Preliminary Design Review Informed Sync Review (Fall 2021) where the contractor manages data integration and document management for approximately 40 Subsystem specifications with associated verification plans, as well as over 20 Interface Requirements Documents. Additionally, critical steps in the planning, design, installation, and certification of the Gateway integrated test and verification labs would be at risk. In addition, the SPEAC contractors working with Gateway on Model Based Systems Engineering are the same team working across the ESD and Artemis Enterprises on these models, so the SPEAC tasking provides significant synergy and overall savings to the government. Bringing in a new contractor for this support would lose that synergy and require more government oversight and multi-contract integration throughout the Enterprises.

Additionally, there are several Artemis I near-term and mid-term milestones that would be significantly impacted if an increase in value doesn’t materialize: Artemis I Launch August- September 2021, Artemis I Post-Flight Assessment Review January 2022, Launch Abort System Systems Acceptance Review/Design Certification Review February 2022, Mission Integration Review March 2022, SLS Certification Review August 2022, Flight Operations Review January 2023, Orion Pre-Flight Readiness Review May 2023, and several other upcoming milestones.

Furthermore, the CCP milestones would be impacted significantly by a disruption of services to SPEAC. The CCP Requirements and Requirements Database Assessment task order directly supports Sustaining Engineering and Integration for the CCP, specifically the certification of SpaceX Crew Dragon and Boeing Starliner. Lack of continuity would impact the ability of the CCP to certify the Dragon and Starliner vehicles in the timeline required to support continuous United States presence on the ISS. SpaceX Dragon reuse certification is currently ongoing, and the team will be working this task through the end of Fiscal Year 2021. This certification is vital to the ability to reuse the Dragon capsules for crewed missions to the ISS. Without reuse certification there is a significant risk that there would be a gap in United States presence on the

ISS.

It is most efficient and economical to increase the estimated value of the BPA as switching to another contractor on an expedited basis, mid-stream, would cause delays in mission schedules and failure to meet mission requirements. Furthermore, BAH is known to have the capability to supply subject matter experts for short-term assessments. In some cases, it is within 30 days and at various locations across the United States. It has proven capability of providing a broad range of Project Management, System Engineering, Information Technology Security, and Risk Management Assessment capabilities, with their resources, reach-back capability, and breadth of expertise, which is necessary to respond to SPEAC requirements. SPEAC the necessary requirements are expected to vary significantly, from potentially no activity to numerous concurrent task calls covering a wide range four of programmatic and institutional assessment activities. Finally, BAH has security clearance to support task order requirements. Many assessments continue over several years, with current assessments building on and informed by prior work.

Determination by the contracting officer (CO) that the order represents the best value consistent with FAR 8.404(d):

FAR 8.404, use of FSSs, states that “GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable.” The Government rates under the competitively awarded SPEAC BPA are considered fair and reasonable by the GSA. The Government received a discount on the GSA rates for the SPEAC BPA and will continue to utilize the existing discounted rates for the follow-on work resulting from the value increase. Although the SPEAC BPA already contains negotiated fair and reasonable pricing, NASA will seek additional discounts to ensure the best value for the government. Furthermore, in accordance with FAR 8.405-3(e), the CO will continue to review the BPA on an annual basis and determine in writing at least once a year whether the estimated quantities/amounts have been exceeded and additional price reductions can be obtained.

Additionally, the contractor will be required to submit task order proposals to be evaluated by the Government to ensure that prices remain in line with those competed under the commercial proceedings at the time of initial BPA award. The proposal for the work under this BPA shall be in line with the previously competed and negotiated rates for this work that was accepted by the Government at the onset of this BPA. Prior to the execution of task orders, a price analysis will be performed to verify the use of the existing rates under the BPA. A technical evaluation will be performed to ensure that the proposed labor hours and materials are fair and reasonable and that the proposal is adequate to meet the Government’s requirements. The CO will verify that the contractor used the labor categories and associated hourly labor rates under GSA Schedule Contract GS-00F-008DA with an applied price reduction expressed in the BPA along with any additional price reductions. The proposal analysis will ensure that the final agreed-to price for the BPA action is fair and reasonable.

Market Research:

This action will be conducted under FAR 8.4, FSSs. Pursuant to FAR 8.404(a), this action does not require a pre-solicitation synopsis, as it is being procured under the GSA FSS 871-1, Professional Engineering Services - Strategic Planning for Technology Programs/Activities.

The Contracting Officer’s Representative’s (COR) technical knowledge of the work and companies available in the industry was used as market research. The COR and CO reviewed GSA schedule holders as well as companies currently under contract by NASA for related services. Although market research indicates that there are other sources that can perform this work, the additional time, expenses, and the risk of a lapse in services is far too great to have a follow-on award in place by the time the current BPA value is exceeded in August 2021. The increase to the SPEAC estimated value will allow NASA to continue critical support of institutional assessment activities while follow-on competition activities are completed. The follow-on activities have been started with the intent to conduct a full and open competition for the follow-on BPA.

Pursuant to FAR 8.405-6(a)(2), the approved LSJ will be posted to the Governmentwide Point of Entry at https://www.fbo.gov.

Other Facts:

A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made:

It is expected that there will be no restrictions to competing the requirements once the additional critical Gateway, Orion, and CCP milestones outlined above have been accomplished.

Therefore, the existing barriers to competition will have become obsolete and any follow-on effort requiring a new contract action to sustain any future activities can be competed.

The Agency will continue to examine the market for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements. To do so, the Procurement Office will coordinate with the COR to ensure any needs for publicizing formal request for Information and Sources Sought Synopsis are met. These postings will enable the COR and technical community to gather information regarding the options available and sources for future needs. The technical offices and the COR will continue to monitor industry capabilities.