A04 Justifications and Approval Feb2026RFO REDACTED.pdf

DEPARTMENT OF WAR

WASHINGTON HEADQUARTERS SERVICES

1155 DEFENSE PENTAGON

WASHINGTON, DC 20301-1155

ACQUISITION DIRECTORATE

WHS-2026- 2014 - JA

JUSTIFICATION FOR

OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

UNDER FEDERAL ACQUISITION REGULATION FAR SUBPART 6.103

1. AGENCY AND CONTRACTING ACTIVITY: The Department of Defense (DOD), Washington Headquarters Services, Acquisition Directorate (WHS/AD); Enterprise Facility Construction Division (EFCD), Building Maintenance Operation Branch

(BMOB).

2. DESCRIPTION OF ACTION: This is a sole source procurement under Revolutionary

FAR Overhaul (RFO) 6.103-1, “Only one responsible source and no other supplies or services will satisfy agency requirements,” for services at the Pentagon Heating & Refrigeration Plant (HRP). This sole source bridge contract is necessary to avoid a break in service until the follow-on contract is awarded. This action is for a two month base period and four one-month options to be awarded to the incumbent, QCM, Inc. This is a Firm Fixed Price (FFP) contract with a total estimated value of $4,110,700.00.

3. DESCRIPTION OF SUPPLIES/SERVICES: The contractor shall furnish all parts, labor, materials, supervision necessary for the Preventative Maintenance (PM), Predictive Maintenance (PdM), Corrective Maintenance (CM), repairs, Service Calls (SC), and inspections, of the equipment and systems as specifically defined in the Performance Work Statement (PWS).

Performance Periods

Performance Period Dates Amount

Base Period 1 April 2026 – 31 May 2026 $ 1,703,500.00 Option Period I 1 June 2026 – 30 June 2026 $ 601,800.00 Option Period II 1 July 2026 – 31 July 2026 $ 601,800.00 Option Period III 1 August 2026 – 31 August 2026 $ 601,800.00 Option Period III 1 September 2026 – 30 September2026 $ 601,800.00 Base + All Options $ 4,110,700.00

4. AUTHORITY CITED: This action is authorized under provisions of 10 U.S.C. §

3204(c)(2), as implemented by RFO 6.302-1, “Only one responsible source and no other supplies or services will satisfy agency requirements.”

5. REASON FOR AUTHORITY CITED: The WHS, Facilities Services Directorate

(FSD) requires continuous, critical support for the Operations and Maintenance (O&M) of the Pentagon's Heating & Refrigeration Plant (PHRP). This plant is a mission-essential facility that runs year-round. This contract covers all Operations and Maintenance (O&M) for the Pentagon Heating & Refrigeration Plant (PH&RP), including all associated equipment. All preventive maintenance and repairs must follow Original Equipment Manufacturer (OEM) recommendations. The scope of work includes the maintenance, repair, and calibration of the following systems:

• Boiler and Steam Distribution

• Chiller and Chilled Water Distribution

• Compressed Air

• Condenser Water

• Distribution Controls System (DCS)

• Electrical Distribution

• Feedwater

• Fuel Oil

• HVAC

• Sewage Lift

• Auxiliary Systems

Any interruption in the required services—which cover all maintenance, repairs, and calibration of mechanical systems in the PHRP—will severely disrupt operations at the Pentagon Reservation and will directly and negatively impact the Department of War’s primary mission to support the warfighter.

The incumbent, QCM Inc., is currently providing these services under contract HQ003420D0018, which expires on March 31, 2026. WHS/AD has already exercised the contract’s final six-month extension in accordance with FAR 52.217-8, “Option to Extend Services”, leaving no further extensions available. Furthermore, because the SBA suspended QCM from the 8(a) program, WHS/AD would otherwise be unable to exercise any options, making this sole source bridge the only method available for maintaining the requirement until the follow-on contract is awarded.

The requirement for this bridge contract is not from a lack of advance planning or deficient procurement execution. The agency has an active, ongoing competitive procurement in the Small Business Administration’s 8(a) business development program for the long-term follow-on requirement. That award is forthcoming upon completion of all mandatory acquisition procedures. Additional time was needed because discussions with offerors became necessary. Discussions will require the agency evaluate the revised proposals and complete the requisite internal reviews prior to contract award.

All available options under the current contract have been fully exercised, and a bridge contract is therefore required to ensure continuity of operations while the source selection process is finalized. Transitioning to a new interim contractor prior to the expiration of the current contract is not practicable due to the complexity of the requirement, the specialized personnel involved, and the time needed to execute an orderly transition.

To mitigate the risk of requiring any additional bridge actions, this bridge contract is structured with a two-month base period and four one-month option periods, providing WHS/AD with the flexibility necessary to complete the competitive procurement without interruption to mission-essential services.

We have exhausted all options in the current contract and need the bridge contract to provide services while the competitive proposals are undergoing required source selection evaluations. In addition, there is not enough time to award and transition in a new temporary contractor before the current contract ends due to the nature of the work required and to meet the personnel requirements in this contract. To avoid executing another bridge contract, this bridge contract will have a two-month base period and include four one-month options of service.

The current contract is currently in the 8(a) program, but this requirement is considered a new requirement since it’s a bridge contract. WHS/AD has notified the Small Business Administration (SBA) despite that it’s no longer required in the RFO, and WHS/AD has complied with all the obligations under the SBA Code of Federal Regulations.

6. EFFORTS TO OBTAIN COMPETITION: A bridge contract is necessary to avoid a disruption in service is the maintenance and operations for the PHRP, which directly supports the Pentgon’s functions and the DoW’s defense mission. A disruption in service is unacceptable. The follow-on requirement is currently underway as a 100% 8(a) set-aside and proposals are currently under evaluation.

7. FAIR AND REASONABLE COST DETERMINATION: I determine that the anticipated price for this contract action will be fair and reasonable by using the techniques identified under 15.404-1(b)(5) Comparison of proposed prices with Independent Government Cost Estimate (IGCE). The IGCE was created using historical pricing with 3% escalation rate.

8. MARKET RESEARCH: Market research was conducted via a Sources Sought Notice

(SSN) posted to Sam.gov from April 4, 2025, to May 5, 2025, which identified six technically capable 8a small businesses. Because the requirement is unchanged, no additional market research was conducted for the bridge contract. The existing market research on file, signed on December 5, 2025, remains current, accurate, and sufficient in accordance with FAR 10.001.

9. OTHER FACTS:. On March 13, 2026, an urgent request was submitted to the Small

Business Administration (SBA) for guidance concerning contract #HQ003420D0018 with the incumbent contractor, QCM, Inc. WHS/AD informed the SBA that QCM, Inc.

had been recently suspended from the 8(a) program, creating a challenge as the follow-on contract is currently in source selection. To ensure the continuity of services, WHS/AD proposed awarding a short-term bridge contract to QCM, Inc. outside of the 8(a) program and requested SBA’s recommendation on this proposed solution or that SBA suggest any other contracting options that would allow us to continue working with this vendor while we complete our evaluation process.

On March 16, 2026, the Small Business Administration (SBA) emailed WHS/AD, stating: “Currently, the SBA is unable to take any action to allow a follow-on award to QCM due to their suspension. Suspension matters are managed by the Office of General Counsel (OGC). QCM is working with OGC regarding an appeal; however, the Business Opportunity Specialist (BOS) cannot take any action given the current status. This information was provided by QCM BOS”. Further communications were received by WHS/AD from the SBA's Business Opportunity Specialist on March 18, 2026. The first email confirmed the situation: “Unfortunately, QCM is currently pending review of suspension by Office of General Counsel and cannot get anything.” A second email on the same day simply added, “we are awaiting Headquarters’ response.”

QCM is only suspended from the 8(a) program. That suspension does not negate the contractor's demonstrated technical capabilities and unique qualifications to perform these specific, urgent requirements. Nor does the suspension from the 8(a) program prohibit QCM from being awarded contracts outside the 8(a) program. The justification for this award to QCM is not only because QCM is the only responsible source, it is also based on the need for continuity of critical services and the unacceptable harm the DoW would suffer from a gap in performance.

QCM, Inc. possesses unique and highly specialized knowledge of the agency's systems, processes, and specific requirements. Their personnel hold certifications and have years of experience with the agency's unique systems that are not readily available in the marketplace. WHS/AD cannot compete this short term bridge requirement because a new contractor would require a significant ramp-up period of at least two months, which would directly cause unacceptable delays. In addition, a competition is not possible in the time remaining before the incumbent contract expires on March 31, 2026. QCM’s suspension from the 8(a) program does not negate the contractor's demonstrated technical capabilities and unique qualifications to perform these specific, urgent requirements.

WHS/AD acknowledges the regulations governing 8(a) contracts, specifically FAR 19.815(e) and 13 CFR 124.504(d). However, we have determined that we do not need to seek a formal release of the procurement from the SBA because this bridge contract is considered a new, short-term requirement. This action does not remove the original requirement from the 8(a) program. The long-term, follow-on contract will be awarded to a qualified 8(a) firm. The bridge contract is solely to prevent a break in service while we finalize the recompete process. In addition, pursuant to DARS Tracking No. 2026- O0037, contracting officers must use the RFO. FAR 19.815 (e) was removed from the RFO. Accordingly, the Contracting Officer is not required to notify the SBA that she intends to award this short-term bridge.

A review of the System for Award Management (SAM.gov) and the Federal Awardee Performance and Integrity Information System (FAPIIS) indicates that QCM Inc. has no exclusions and is therefore eligible for awards outside of the 8(a) program.

10. INTERESTED SOURCES: Other sources are capable of performing the work;

a. Capitol United Solutions Inc.

b. Capital Brand Group

c. Decca Environmental Solutions

d. K&G Contracting Solutions Inc.

e. Teya Support Services LLC.

However, due to the time remaining under the incumbent contract there would be unacceptable delays in temporarily transitioning-in a new contractor for this short-term bridge. Also, these sources are competitors in the long-term source selection currently underway.

b. ACTIONS TO INCREASE COMPETITION: All future requirements shall be posted on PIEE to continue to receive responses from multiple sources.

c. Is this acquisition for a non-competitive follow-on acquisition previously awarded on a non-competitive basis?

☐ Yes. A copy of the previous justification is attached. The actions to remove any barriers to competition cited on the previous justification ☐ were ☐ were not completed

☒No. The original acquisition was conducted on a competitive basis.

☐ Not Applicable. This is a new requirement.

CERTIFICATION

I, hereby, certify that the supporting data under my cognizance included in this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer’s Representative/Program Office Date

ANTHONY.STORMY.L.13

81406411

Digitally signed by

ANTHONY.STORMY.L.1381406411

Date: 2026.03.24 12:24:45 -04'00'

APPROVAL

This justification is approved.

KAO.DAVID.HOBERT.111217

Digitally signed by

KAO.DAVID.HOBERT.1112172870

Date: 2026.03.24 18:16:36 -04'00'

David H. Kao, Competition Advocate Date

Contracting Officer Date

24March2026 ABELS.MARK.R.138701 Digitally signed by

ABELS.MARK.R.1387018430