A17_JA_-_LSJ_140D0422Q0634_FINAL_Redacted_2_0_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C 501

SOL # 140D0422Q0634

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This is a Limited Source Justification executed by the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division 1 Branch 2, on behalf of the DOI Office of the Chief Information Officer (OCIO).

2. Nature and/or description of the action being approved.

The purpose of this action is to support the issuance of a firm fixed price limited source logical follow-on order to procure the recurring Cybersecurity Engineering services. The original Order was awarded to Secunetics Inc. on September 30, 2017 as a BPA Call Order after competing between the DOI multiple-award BPA awardees under BPAs D16PA00021 and D16PA00022 established for cyber-engineering support. The period of performance for the current BPA Call Order is a twelve (12)-month Base Year and four (4) one (1) year option periods that will expire on September 29, 2022. The multiple-award BPAs were competitively awarded as a small business set-aside procurement action under the authority of Federal Acquisition Regulation (FAR) 8.405-3.

The DOI is establishing new multiple award BPAs to replace the legacy BPAs. The Cybersecurity Engineer Support services will be reprocured under the new BPAs. However, the new BPAs will not be awarded in sufficient time to allow for DOI to issue a renewal BPA Call Order for the Cybersecurity Engineer requirement in time to avoid a break in service. As a short-term, interim solution to avoid risks of a lapse of services, DOI intends to issue a noncompetitive task order to Secunetics utilizing the General Services Administration (GSA)’s Federal Supply Schedule (FSS), Multiple Award Schedule (MAS), High Adaptive Cybersecurity Services (HACS), Special Item Number (SIN) 54151HACS.

3. A description of the supplies or services required to meet the agency’s needs procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

The current BPA Call Order was awarded competitively using procedures in FAR Part 8.4 – Federal Supply Schedules and the Ordering Procedure by utilizing the BPAs that were also competed under FAR 8.4. The acquisition was solicited on GSA FSS IT Schedule 70 – Professional Information Technology Services as a small business set-aside. DOI is currently working on recompete actions to award new multiple BPAs for cybersecurity support services under GSA’s MAS HACS, which will be the replacement BPAs, against which the CyberSecurity Engineer Support requirement will be competed after the new BPA awards are made.

The proposed task order is for the same work currently being performed under the current BPA Call Order D17PB00364 and therefore qualifies as follow-on work under FAR 8.405-6(a)(1)(i)(C).

The award of the one (1) six- month base period and two (3) three-month option periods now provides the Government substantial benefits, ensuring that support to the OCIO can continue with no lapse in service and, if the recompete takes only six months or less, one or both of the three-month options will not have to be exercised. Secunetics is uniquely qualified to support the OCIO. As the incumbent, it has current system knowledge, access, proper security clearances and has the capability to support this service with minimal disruption or schedule impact, and has been performing the current tasks satisfactorily. Secunetics has gained expertise over the performance of the Cybersecurity Engineer support and is the only Contractor that is able to provide immediate expertise and service to ensure uninterrupted service.

The resources provided by the proposed Task Order are vital to the CSD’s mission of protecting DOI’s IT systems and data from security threats. A break in service of this contract could result in a department-wide impact due to the insurmountable loss of highly-specialized cybersecurity personnel involved in defending DOI’s systems and data from security threats including unauthorized access or destruction of critical information (including financial data, Personally Identifiable Information (PII), and other controlled unclassified data), and/or damage/loss of protected systems (including network and internet access, email, chat, etc.) caused by malicious cyber-attacks (hacking, computer viruses, spyware, ransomware, etc.).

Awarding this interim short-term, task order to a vendor other than Secunetics will result in additional time needed for transition and would be inefficient because, in addition to the transition period between the incumbent (Secunetics) to a new awardee, there may be another transition period between the new awardee and a vendor who receives a BPA Call Order in the subsequent competitive acquisition for Cybersecurity support services. Therefore, because Secunetics is already performing the required work and no transition is required and it has necessary technical expertise for the requirement, it is in the Government’s best interest in terms of economy and efficiency to issue a short-term task order to the incumbent. Any break in service would not allow the DOI/OCIO to meet its mission of protecting information technology infrastructure and create irreparable harm.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

The original Order was issued as a result of a competitive acquisition under the multiple-award BPAs. The labor rates on the Order are based on the rates established in the BPA award and a discount from Secunetics FSS contract rates was applied. The proposed Task Order will be based on Secunetics’ FSS rates, which were already found to be fair and reasonable by the GSA Contracting Officer. DOI contracting officer will seek a discount from the FSS rates and ensure the rates for the proposed Task Order will be fair and reasonable. Upon receipt of the quote from Secunetics, the DOI Contracting Officer will conduct market research and price analysis to ensure the proposed pricing represents the best value to the Government.

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

Market research for the current requirement has been reviewed, and there are viable small businesses capable of performing the support similar to this requirement; however, due to schedule constraints and technical and financial risks, the Government’s critical and immediate need would not be met by awarding to another vendor.

7. Any other facts supporting the justification.

None.

8. 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 supplies and services is made.

The DOI’s OCIO ongoing requirement is planned to be re-competed, using the CSD multiple award BPAs and will be solicited with adequate competition using FAR Part 8 procedures.

9. The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

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

Date Contracting Officer

10. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify the technical data which forms a basis for this justification is complete and accurate and meet the Government’s minimum needs.

Contracting Officer’s Representative (COR)

11. For justifications under 8.405-6(a)(1), a written determination by the approving official identifying the circumstance that applies.

FAR 8.405-6(a)(1)(i)(C) – In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order.

12. Reviews and Approvals

Branch Chief

Division Chief

Bureau Competition Advocate