A18_JOFOC_-_Final_LSJ_Signed_Redacted_1.pdf

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FEDERAL ACQUISITION REGULATION 8.405-6

and 40 UNITED STATES CODE 501

SOLICITATION # 140D0424Q0540

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 document is a Limited-Sources Justification executed by the Department of Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division 5, Branch 2, Team 2 for the Department of Defense (DoD), National Guard Bureau, Joint Staff National Guard Coordination Center (NGCC).

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

Vendor information:

The Millennium Group International, LLC (Millennium) 46169 Westlake Dr Ste 240 Sterling, VA 20165-5875

UEI: K2WEU9NU1K63

This action is a limited source justification in accordance with Federal Acquisition Regulation (FAR) 8.405-6(a)(1)(i)(C), in the interest of economy and efficiency. The work is a logical follow-on to an original Federal Supply Schedule order to Millennium.

The current Task Order (TO), GS10F0412P/W9133L19F0004 was awarded by NGCC and competed amongst the eight Blanket Purchase Agreement (BPA) awardees utilizing North American Industry Classification System (NAICS) 541911-Administrative Management and General Management Consulting Services.

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

This acquisition is to support the NGCC in achieving Headquarters’ level strategic analysis for the success of multiple programs. The work under the proposed TO is for non-personal services to provide the necessary level of administrative, professional, and technical support required to facilitate the overall objectives of the Operations, Strategy, Intelligence, and Program Services Directorates to support the NGCC. The

SOLICITATION # 140D0424Q0540

areas of support specifically include business operations support services for: 1.

Strategic level plans and analysis, strategic event planning, and policy reviews; 2.

Knowledge management, collection, implementation, integration, and maturity assessments, and 3. Readiness assessments, data collection and analysis. The support services encompass separate and distinct offices under the Army National Guard (ARNG) Operations & Training Division(G-3/5/7) and the ARNG Readiness Plans Division (G-3/5/7).

The estimated period of performance is a base year plus four one-year options and FAR 52.217-8 (six-month Option to Extend).

Base Year: August 1, 2024 – July 31, 2025 Option Year One: August 1, 2025 – July 31, 2026 Option Year Two: August 1, 2026 – July 31, 2027 Option Year Three: August 1, 2027 – July 31, 2028 Option Year Four: August 1, 2028 – July 31, 2029 6-month Option: August 1, 2029 – February 1, 2030

The estimated contract value, inclusive of all options and FAR 52.217-8, is

4. The authority and supporting rationale (see FAR 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

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

The solicitation for the current TO was issued to multiple qualified contractors on the Multiple Award Schedule (MAS) as a total small business set-aside in accordance with the procedures at FAR 8.405-2(c)(3)(iii)(B). A total of eight competitive offers were received in response to the incumbent solicitation. Given these facts, the current project meets the requirements of a logical follow-on.

There are multiple contributing factors to support the logical follow-on including Millennium’s unique qualifications:

Transitioning with the same contractor offers several advantages, leading to minimal disruption. Since Millennium is already familiar with the current requirement, its objectives, and the working environment, there is inherently less learning curves involved. They understand the intricacies of the tasks and can continue its tasks without significant adjustments.

Continuity in the contractor-Government relationship fosters trust and understanding. The contractor is already aware of preferences, expectations, and communication styles, reducing the likelihood of misunderstandings or conflicts that may occur during the transition period.

With the same contractor, there’s an expectation of consistent quality in deliverables. Millennium has a track record of performance, and the Government can rely on their expertise and capabilities to maintain those standards.

The continuity of services provided utilizing the same contractor ensures that knowledge and expertise are retained within the contractor personnel.

Given that contractor personnel already possess top-secret clearances as required, the likelihood of the contractor needing to find individuals with that qualification is significantly reduced. Key personnel who have been working the requirement can continue their roles minimizing the impact of any potential turnover or knowledge gaps.

Given that Millennium is the current contractor and has positive Contractor

Performance Assessment Ratings (CPARS), they have demonstrated the unique expertise and experience of providing the services under this requirement.

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

Pursuant to FAR 8.404(d) Pricing, “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. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d).” In accordance with FAR 8.405-2(d) Evaluation, the Contracting Officer will consider the level of effort and the mix of labor to perform a specific task being ordered and for determining the total price reasonable.

The Contracting Officer believes that the anticipated prices will be fair and reasonable based upon Millennium’s intimate knowledge of the work and prices on the current TO W9133L19F0004.

In addition to evaluating the total price and level of effort, the Contracting Officer will calculate the highest possible price for an additional six-month extension permitted under FAR 52.217-8 in accordance with the AQD Evaluation of Option Provision (March 2022).

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 indicates the services are available in the commercial marketplace.

However, competition is not appropriate for this acquisition as a logical follow-on based on economy and efficiency is in the best interest to support the mission of NGCC in achieving Headquarters’ level strategic analysis for the success of multiple programs.

The NGCC last acquired these services June 26, 2019 with contract GS-10F-0412P/ W9133L19F0004. The current task order contains a base year of August 1, 2019 through July 31, 2020 and four one-year options through July 31, 2024. The task order was established as a firm-fixed price contract with Not-to-Exceed travel line items for travel as necessary. To date, the task order has been performed in accordance with the construct with no performance issuance noted. The acquisition history of similar requirements was provided by NGCC.

There are no DOI or DoD Mandatory Use vehicles applicable to this requirement.

The required services are not available through the procurement list maintained by the Committee for Purchase From People Who Are Blind or Severely Disabled. A review of the Schedule Products and Services located on the Unicor.gov website revealed that these services are not available from the Federal Prison Industries.

7. Any other facts supporting the justification.

A Request for Quotation is not anticipated to be released on GSA e-buy as procedures will be limited following FAR 8.405-6(a)(1)(i)C. In the interest of economy and efficiency, the new work is a logical follow-on to a Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures.

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.

For future acquisitions for the same or similar requirements, AQD and NGCC will conduct comprehensive market research to understand the current market landscape and available vendors; utilize market surveys, industry days, and request for information (RFI) processes to gather data; and broaden the understanding of available solutions and vendors.

By systematically addressing these elements, the agencies can effectively remove barriers that previously led to restricted consideration, fostering a more competitive and inclusive acquisition process.

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.

JeanMarie Marriam 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.

William Mountain Contracting Officer’s Representative

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 a Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

JEAN MARIE

MARRIAM

Digitally signed by JEAN

MARIE MARRIAM

Date: 2024.06.12 03:22:38 -04'00'

12. Reviews and Approvals

Concur

JeanMarie Marriam Contracting Officer

Approve

Michael Farrell Bureau Competition Advocate

JEAN MARIE

MARRIAM

Digitally signed by JEAN

MARIE MARRIAM

Date: 2024.06.12 03:22:57 -04'00'

MICHAEL FARRELL

Digitally signed by

MICHAEL FARRELL

Date: 2024.06.12 08:13:57 -04'00'