A15 Justification and Approval_Redacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

Business Operations Support Services (BOSS)

1. Identification of the agency and contracting activity.

The United States (US) Department of War (DoW) Defense Counterintelligence and Security Agency (DCSA) Procurement Solutions (PRS) proposes to enter into a contract on a basis of other than full and open competition on behalf of the DCSA Acquisition and Technology (A&T) Information Resource Management office.

Requiring Activity / Program Office:

DCSA – Information Resource Management (ATB) 27130 Telegraph Road Quantico, VA 22134

Contracting Activity:

DCSA – PRS

27130 Telegraph Road Quantico, VA 22134

2. The nature and/or description of the action being approved.

The purpose of this document is to obtain the necessary approvals for a sole source acquisition in accordance with Federal Acquisition Regulation (FAR) 6.103-1, Only one responsible source and no other supplies or services will satisfy agency requirements. Due to delays in executing the competitive follow-on and to prevent a lapse in mission-essential services, DCSA is executing a short, sole-source bridge to the incumbent while the full and open follow-on completes governance and award/transition. The DCSA A&T Directorate’s Information Resource Management Branch Program and Execution (P&E) Office requires uninterrupted Business Operations Support Services (BOSS) to sustain mission-critical Information Technology (IT) planning, execution, acquisition support, and enterprise management activities. These services provide P&E with strategic business management, technical expertise, and program oversight in support of DCSA’s broader mission.

The proposed contract action is for a sole source Firm Fixed Price (FFP) short term bridge contract to The Prospective Group (TPG). This bridge action is required to maintain continuity of services currently performed under DCSA Contract HS002123F0061, preventing operational disruption to priority A&T programs and ongoing enterprise IT initiatives. It ensures uninterrupted operational, financial, acquisition, and program management support during a critical period in which the competitive follow-on contract is being finalized. This temporary contract will maintain the current level of service and prevent disruptions until the competitive award is completed and transitioned.

The period of performance for this contract will consist of four (4) months from date of award, with an optional extension of up to six (6) months in accordance with FAR 52.217-8, if needed to align with completion of the competitive follow-on award and transition.

3. A description of the supplies or services required to meet the agency’s needs (including estimated value).

The services required under this action provide comprehensive continued business, financial, acquisition, analytical, and program management support to the DCSA A&T P&E office. These services encompass a broad range of analytical, technical, and programmatic functions essential to A&T’s enterprise mission execution. Core support needs include budgeting and financial management assistance, program and portfolio analysis, acquisition and contract management support, technical writing and documentation, project and program management services, strategic communications development, customer requirements analysis, and business process and performance improvement activities.

The required services also include support to A&T leadership in planning, coordinating, and executing activities that enable effective and compliant management of A&T programs and investments. This includes the development and maintenance of program documentation;

preparation of executive-level briefings, reports, and decision materials; tracking of milestones and governance requirements; and the review and routing of requirement packages through applicable systems. Additional support requirements include conducting routine and ad hoc data analyses; preparing and updating spend plan documentation; reconciling financial and programmatic information across internal systems; maintaining internal trackers and dashboards;

facilitating Program Management Reviews and other governance activities; supporting administrative and operational workflows; coordinating meeting and event logistics; and ensuring timely responses to internal and external taskers.

These combined services ensure that A&T P&E can maintain operational tempo, meet statutory and policy-driven deadlines, support acquisition planning and oversight, sustain financial execution activities, and provide consistent program management and governance support across the DCSA enterprise. Continuity of these services during this interim period is critical to maintaining the analytical capability, institutional knowledge, and operational capacity required to support ongoing mission requirements and leadership priorities while the competitive follow-on action is completed.

The complexity and interdependencies of these services require provider personnel to possess not only broad business operations expertise but also an established understanding of DCSA’s organizational structure, internal processes, customized IT and financial systems, governance mechanisms, and mission-specific challenges. This embedded knowledge ensures the ability to perform at the level necessary to support A&T’s operational demands without disruption during the bridge period.

The total estimated value of this contract action is .

4. Identification of the statutory authority permitting other than full and open competition.

This action is authorized by 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.” This authority is applicable because the required BOSS support demands an immediate and uninterrupted continuation of highly specialized services that are uniquely tied to the contractor’s existing knowledge of DCSA’s internal processes, systems, governance structures, and mission priorities.

A transition in service providers at this time would create unacceptable delays across multiple mission‑critical activities. In particular, a new contractor, without the incumbent’s established understanding of DCSA’s financial systems, acquisition workflows, governance processes, and ongoing project portfolios, would be unable to rapidly assume responsibility for urgent and time‑sensitive tasks. These include support to several current ongoing high visibility recompete efforts, which require continuous coordination, documentation, and acquisition package development.

Additionally, the contractor plays an essential role in the Planning, Programming, Budgeting, and Execution (PPBE) cycle, where delays in financial reconciliation, spend plan preparation, and budget formulation would have immediate downstream impacts on DCSA’s ability to meet statutory deadlines and execute its fiscal responsibilities.

Any disruption in these services would diminish DCSA’s ability to manage ongoing programs, support leadership decision‑making, and fulfill national security responsibilities. Therefore, only the incumbent contractor has the familiarity, technical expertise, and operational continuity required to meet the agency’s immediate needs under this interim action.

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The services required under this short‑term bridge include not only the continued execution of critical business operations support but also the transition out activities necessary to prepare for the follow‑on competitive contract. Because transition out support depends on knowledge accumulated during performance, only the incumbent is capable of performing these functions immediately.

TPG is uniquely qualified to provide the support required, and award to any other source at this time would result in unacceptable delays and substantial duplication of cost. The nature of the acquisition, with its complex, integrated, and time‑sensitive support across budgeting, acquisition, governance, and program management, requires a contractor with an established, embedded understanding and real‑time situational awareness of DCSA’s enterprise operations, internal systems, governance cycles, and mission priorities. A new contractor, regardless of general experience, would lack the DCSA‑specific knowledge and system familiarity necessary to immediately perform effectively from the outset and would require Government time and resources to onboard at the expense of mission execution.

TPG’s personnel possess a deep understanding of DCSA’s organizational structure and the interdependencies between its various mission areas. This institutional knowledge has been developed through two years of direct, embedded support and consists largely of operational awareness, process familiarity, and stakeholder relationships that cannot be rapidly transferred.

Much of this expertise is tacit knowledge gained through hands‑on experience and is not available in formal documentation that could immediately be provided to a new vendor without an appropriately phased transition period.

In addition to day‑to‑day execution, the required effort includes stewardship and handoff of in‑flight work products (e.g., acquisition packages, spend‑plan artifacts, governance materials) and alignment to upcoming PPBE and governance milestones, all of which are inherently transition‑out activities. The incumbent team has hands‑on, applied experience within DCSA’s customized business systems and workflows, as well as related tracking/reporting mechanisms.

Effective execution of A&T’s spend planning, package routing, financial reconciliation, and governance reporting requires tool‑specific proficiency that a new vendor would take significant time to acquire. DCSA personnel are not currently staffed to provide the level of immediate onboarding and training a replacement workforce would require without diverting attention from mission delivery.

TPG’s workforce holds the necessary clearances and is fully integrated with A&T program offices and ongoing mission essential activities, including support to several priority recompete procurement actions and the PPBE cycle. The combination of clearances, integration, and current task ownership allows for seamless support to sensitive planning and execution activities that could not be replicated by a new team without significant time, risk, and operational disruption.

A lapse in services or replacing the incumbent during this period would create unacceptable delays in critical activities, such as time‑bound acquisition actions, package development and routing, budget execution, and governance reviews, and would incur additional costs associated with knowledge transfer, system access provisioning, and rebuild of analytical products and workflows. Those delays and costs would materially degrade A&T’s ability to meet statutory and policy‑driven deadlines and to support DCSA’s national security mission.

This action serves as a limited‑duration bridge solely to maintain uninterrupted support while DCSA completes the competitive procurement for the follow‑on requirement. DCSA is actively executing the competitive strategy for the successor contract, including requirements finalization, acquisition planning, and preparation for solicitation release. The bridge is constrained to the minimum period necessary to conclude the competitive award and transition; upon award of the follow‑on, work will transition in accordance with an approved phase‑out plan.

Given the incumbent’s unique institutional knowledge, tool‑specific expertise, and fully integrated, cleared workforce, combined with the unacceptable mission risk and duplicative costs of a transition, the Government determines that only one responsible source can meet the immediate requirement at this time. This immediate requirement includes both continued performance and transition‑out to the competitively awarded successor; only the incumbent can provide both without disruption. Use of the cited authority is therefore warranted to ensure continuity of mission‑essential services while the competitive follow‑on proceeds to award.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart

5.2 and, if not, which exception under 5.202 applies.

In accordance with (IAW) FAR Subpart 5.2, the Government will publicize a Notice of Intent to Sole Source this bridge requirement. The notice will be posted in accordance with FAR 5.201 and will remain open for a period of fifteen days.

A separate Sources Sought notice was not issued for this short‑term bridge because the Government’s recent market research for the competitive follow‑on requirement already confirmed a competitive environment for the longer‑term effort. However, that research does not mitigate the near‑term continuity risk for this interim action. Based on the Government’s assessment, a new vendor would require an estimated 4 months to onboard fully, obtain/verify clearances, secure internal system accesses, and acquire sufficient institutional knowledge of A&T processes to reach a level of performance that avoids mission disruption. Given the bridge period of performance of 4 months, that ramp‑up would consume most or all of the bridge, yielding little to no value to the Government and risking missed acquisition and fiscal milestones.

Accordingly, the Government is taking the following practicable competition steps for this interim action:

https://www.acquisition.gov/far/part-5#FAR_Subpart_5_2 https://www.acquisition.gov/far/part-5#FAR_Subpart_5_2 https://www.acquisition.gov/far/part-5#FAR_5_202

• Posting a Notice of Intent in SAM.gov IAW FAR 5.201 to inform industry and allow capability statement submissions.

• Follow‑On Competition: Proceeding in parallel with a competitive procurement for the long‑term follow-on requirement; the bridge covers only the minimum time needed to complete that competition and transition.

Despite public notice, the nature of this specialized, embedded support renders only the incumbent immediately capable of performing without a transition period. Award to another source would create unacceptable delays and/or substantial duplication of cost, consistent with the conditions described in FAR 6.103-1 for “only one responsible source.”

The Government is maximizing practicable outreach by publicizing the Notice of Intent in SAM.gov and by executing a competitive follow‑on. Nevertheless, for this limited‑duration bridge, only the incumbent can meet immediate operational needs without disruption, and use of FAR 6.103‑1 remains warranted for the interim period.

7. The anticipated dollar value of the proposed acquisition, including options if applicable, and a determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will establish price reasonableness in accordance using price analysis techniques described in FAR 15.404‑1(b).

The Contracting Officer will compare the contractor’s proposed pricing to the Independent Government Cost Estimate (IGCE), historical pricing from prior contract HS002123F0061, and published commercial market information.

These comparisons will ensure that the overall price is consistent with prevailing commercial practices and is fair and reasonable for the level of effort, performance period, and labor mix required.

Because this requirement meets the definition of commercial services, certified cost or pricing data are not required under FAR 15.403‑1(b).

The Contracting Officer will document the price reasonableness determination in the contract file.

8. A description of the market research conducted (FAR Part 10) and the results or a statement of the reason market research was not conducted.

Market research supporting the long‑term, competitive follow‑on requirement was conducted in January 2026 and confirmed that multiple capable vendors exist to perform the full requirement.

This research validated the acquisition strategy to conduct a competitive acquisition for the follow‑on contract.

However, the results also underscore the need for a sole‑source bridge for the immediate requirement. Although the broader market includes qualified vendors, none other than the incumbent can assume performance without a transition period. The short‑term bridge requires a contractor with personnel holding the necessary security clearances, hands‑on proficiency with DCSA‑specific business and financial systems, and institutional knowledge of A&T workflows, governance structures, and interdependent mission activities.

This combination of attributes is essential to avoid unacceptable operational delays during the bridge period. For this immediate limited‑duration need, only the incumbent is capable of providing seamless continuity until the competitive follow‑on award is made and transitioned.

9. Any other facts supporting the use of other than full and open competition.

DCSA is actively executing a full and open competitive procurement for the long‑term requirement;

however, award and transition cannot be completed in time to avoid a service lapse. The bridge action is strictly limited to the minimum period necessary to maintain continuity while the competitive follow‑on is finalized and transitioned. Market research confirms that multiple capable vendors exist for the long term, but none, other than the incumbent, can assume performance immediately without a phased transition. A new contractor would require an estimated 4-6 months to obtain/verify clearances, secure access to DCSA’s mission‑unique business systems and acquire sufficient institutional knowledge to perform without degradation. Replacing the incumbent during this interval would cause unacceptable delays and create substantial duplication of cost within the short bridge period.

A lapse or degraded performance would materially impair A&T’s near‑term execution of budgeting/spend‑plan activities, ongoing competitive IT acquisitions, and governance timelines that underpin DCSA’s national‑security support. DCSA does not have sufficient in‑house capacity to absorb these specialized functions during a contractor transition; diverting Government program and financial managers to train and oversee a new team would reduce mission output across multiple portfolios and generate unrecoverable rework and onboarding costs during the short bridge. In parallel with this bridge, the Government is publicizing a Notice of Intent in SAM.gov pursuant to FAR Subpart 5.2 and proceeding with the competitive follow‑on; the bridge covers only the time required to complete that competition and effect an orderly transition.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

Not applicable.

11. A statement of the 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, if subsequent acquisitions are anticipated.

DCSA is fully committed to maximizing competition for the long-term requirement. This sole-source bridge is a temporary measure solely intended to maintain continuity of critical services while the competitive acquisition is completed. The follow-on contract is already in development and will be conducted competitively. During the bridge period, DCSA will finalize the competitive solicitation package, complete all required acquisition planning milestones, and ensure that no barriers exist that would prevent broad industry participation for the subsequent competitive award.

Certification

Program Official:

I certify that the facts and representations under my cognizance, which are included in this justification, and which form a basis for this justification, are complete and accurate.

Program Official

Contracting Officer:

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

Contracting Officer

Reviews and Approvals

Advocate for Competition:

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Since this J&A does not exceed $15M, this review serves as approval.

Competition Advocate