A28 Consolidation Determination Memo_Redacted.pdf

CUI//SP-PROCURE

CUI//SP-PROCURE

Determination that Consolidation is Necessary and Justified

This determination is made in accordance with (IAW)

Federal Acquisition Regulation (FAR) 7.107-2(a) and 15 U.S.C 657q. This determination details the research and analysis performed in order to justify that consolidation is appropriate, necessary and justified, and in the best interest of the Government.

A. Background

Solicitation number: HS002123R0009

Requirement: Instructional Development and Delivery (IDD)

Estimated Value (including option): $

Defense Counterintelligence and Security Agency (DCSA) requires services for a broad range of IDD training products and support services in order for DCSA’s Security Training Directorate (ST), Industrial Security (IS) Entity Vetting Division (EVD), and Defense Insider Threat Management and Analysis Center (DITMAC) to ensure the preparedness and readiness of the security workforce in a continuously changing security environment. The purpose of this requirement is for the analysis, design, development, implementation, evaluation (ADDIE) and maintenance of security related training products and to provide support services, which includes Instructional Systems Design, Security Discipline Subject Mater Experts (SME)/Instructors, Editing/Writing, Website Development and Programming, Courseware Development and Programming, and Technical Quality Assurance. The mission critical IDD services include a broad range of training products and support that requires the Contractor to interact with other Government Contractors and employees during the day-to-day operations in order to prevent disruption of the mission. The Contractor shall ensure compliance with all applicable Federal, State, and Local laws, regulations and policies including those of ST, DITMAC and IS EVD.

The requirements for this acquisition are enduring and have been met with the previous contracts administered by both DCSA and the General Service Administration (GSA) as outlined in the following chart:

Contract No. Contractor Name

Business Designation

Description Period of Performance

Contract Value

GSQ1017EC0010 Team Carney Small Business Instructional Development and Delivery

9/15/2017 – 3/14/2023

HS002117F0023 Piton Science & Technology

Service- Disabled Veteran-Owned Small Business

Insider threat instructional system design and threat content support

9/29/2017 – 3/28/2023

Procurement History: The previous contracts were awarded under the GSA Human Capital and Training Solutions (HCaTS) Indefinite-Delivery Indefinite-Quantity (IDIQ) contract. HCaTS has two general pools, specifically Training Solutions (Pool 1) and Human Capital (Pool 2). Each Pool has an unrestricted, small business, and 8(a) awardee pool. Contract GSQ1017EC0010 was solicited under Pool 1 via the unrestricted award pool; however, an award was made to a small business, more specifically Team Carney. Contract GSQ1017EC0010 was awarded in support of DCSA’s ST division, and, with the exception of a few minor changes, the scope of this contract mirrors the performance work statement (PWS) for this consolidated effort. The period of performance reflected above for both contracts includes a six (6) month extension in

IAW FAR 52.217-8.

Contract HS002117F0023 was solicited under Pool 2 via the small business award pool, and was awarded to Piton Science & Technology. Contract HS002117F0023 was awarded in support of DCSA’s DITMAC and IS EVD divisions. The requirement was for Instructional System Design Specialists and Insider Threat SME support.

Given the similarities in support services between ST, DITMAC, and IS EVD’s requirements, more specifically for insider threat instructional system design and threat content support, DCSA is seeking a streamlined enterprise solution for all aspects of IDD training products and support services. Additionally, DCSA Acquisition’s (AQ) has the established capacity and manpower to support the enhanced requirement, whereas in 2017 the predecessor agency was reliant upon GSA contracting for the ST support. The independent government cost estimate (IGCE) of was developed based on a one (1) year base period and the potential for a six (6) month extension IAW FAR 52.217-8. The IGCE was developed by evaluating historical pricing information from the previous contracts, and conducting an industry analysis of current pricing.

B. Market Research - FAR 7.107-2(a)(1)

Historically, this requirement has been met through two separate commercial service task orders, awarded by two different agencies, that were both awarded under the GSA HCaTS IDIQ contract (as identified above). Initially, market research was conducted in April 2022 to re-compete the ST requirement only.

After further analysis of the DITMAC and IS EVD needs, the acquisition strategy evolved to enhance the existing ST PWS to include the scope of work in contract HS002117F0023, which included instructional system design and insider threat content support. Updated market research was conducted in November of 2022 given the enhanced PWS, which captures the consolidation of requirements. The following outlines the research conducted:

1) AQ requested a scope review of the ST PWS by the HCaTS program office on 4 April 2022.

The HCaTS program office confirmed the requirement was in-scope of the HCaTS contract and recommended use of Pool 1 for the requirement.

2) AQ released a Request for Information (RFI) to Pool 1 Small Business and 8a vendors on 5 April 2022. The response to this RFI is summarized below.

3) In July of 2022, a decision was made to expand the existing ST PWS to include the scope of work in contract HS002117F0023, which provides instructional system design and insider threat content support for DITMAC and IS EVD.

4) In October of 2022, an updated PWS was developed to merge the ST, DITMAC and IS EVD requirements into one streamlined PWS.

5) AQ released an update RFI with the enhanced PWS to Pool 1 Small Business vendors on 2 November 2022. The response to this RFI is summarized below.

6) AQ requested an updated scope review of the enhanced PWS by the HCaTS program office on 16 November 2022. The HCaTS program office confirmed the requirement was in-scope of the HCaTS contract and recommended use of Pool 1.

April 2022 RFI Responses: The RFI, which included the ST PWS, was released to eighteen (18) HCaTS 8(a) Pool 1 contractors and thirty (30) HCaTS Small Business Pool 1 contractors to assess the pool’s capabilities of meeting the requirement. Of the eighteen (18) 8(a) Pool 1 contractors, only one (1) vendor stated that they were cable of meeting the requirement. Of the thirty (30) small business Pool 1 contractors, eight (8) stated that they were capable of meeting the requirements of the PWS.

November 2022 RFI Responses: An updated RFI, which included the enhanced PWS with ST, DITMAC, and IS, was released to thirty (30) HCaTS Small Business Pool 1 contractors to assess the pools capabilities of meeting the requirements of the enhanced PWS. Of the thirty (30) small business Pool 1 contractors, five (5) stated that they were capable of meeting the requirements of the PWS. Of note, two

(2) of the five (5) vendors, Team Carney and Piton, are the incumbent contractors for the current GSA and DCSA contracts, which are noted in the background section above. Piton stated that their intention is to team as a subcontractor on the requirement under Small Business Pool 1.

The DCSA Contracting Officer (KO) determined that a consolidated contract for IDD support services, specifically solicited under HCaTS Pool 1 Small Business, is the best fit for the Government given that HCaTS is an existing best in class vehicle awarded to support the scope of this effort. Furthermore, the previous contracts were awarded under HCaTS with proven satisfactory support to the Government.

C. Alternative Contracting Approaches - FAR 7.107-2(a)(2)

The known alternative to a single contract covering this requirement is:

(1) To split the requirement and make multiple awards

As stated above, the previous contracts were awarded by two different agencies, more specifically DCSA and GSA. These awards were made prior to DCSA’s inception in 2019. AQ has the established capacity and manpower to support the enhanced requirement, whereas in 2017 the predecessor agency for GSQ1017EC0010 was reliant upon GSA contracting to support the requirement. Therefore, the need to separate the actions is no longer necessary and is not advantageous to the Government. More specifically, this approach has high schedule risks as this would at least double the procurement acquisition lead time, acquisition documentation and reviews, and require duplicate pre- and post-award administration for AQ and the three directorates, specifically ST, IS EVD and DITMAC. Furthermore, administering multiple contracts for similar services would impose a heavy burden upon the Government, and is no longer necessary given the established AQ support that did not exist in 2017 when the previous contracts were awarded.

D. Negative Impact on Small Business - FAR 7.107-2(a)(4)

The existing contracts, GSQ1017EC0010 and HS002117F0023, were awarded to small businesses, and the acquisition strategy remains a small business set-aside, which will impose little impact to small business.

Additionally, the incumbent contractors on the current contracts have expressed their intent to propose on the follow-on requirement in either a prime- or sub-contractor capacity. The North American Industry Classification System (NAICS) for this requirement is 611430, Professional and Management Development Training, with a small business size-standard of $ (size standard effective as of 1 October 2022). The NAICS and small business size-standards comparisons for the existing contracts are below:

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Contract NAICS NAICS Description Small Business Size Standard

HS002117F0023 541611

Administrative Management and General Management Consulting Services

GSQ1017EC0010

611430

Professional and Management Development Training $

E. Small Business Inclusion in Procurement - FAR 7.107-2(a)(5)

This consolidated requirement will be solicited to GSA HCaTS Small Business Pool 1 vendors.

Throughout the acquisition planning process, potential small business industry partners have been sought out through multiple requests for information submitted to GSA HCaTS Small Business Pool 1 vendors, as well as requesting a scope review of the enhanced PWS by the HCaTS KO. A set-aside is possible as DCSA’s market research reveals that two or more small business concerns are capable of fulfilling this consolidated requirement. In addition, at least five (5) GSA HCaTS small business vendors responded to the Government's RFI and expressed their intent to compete for this consolidated requirement. As stated above, of the five (5) small business vendors that responded to the Government's RFI, two (2) are the incumbents on the existing contracts HS002117F0023 and GSQ1017EC0010.

F. Benefits of Consolidation - FAR 7.107-2(b) and (c)

To determine that consolidation is necessary and justified, you must demonstrate that the benefits of the acquisition would substantially exceed the benefits that would be derived from each of the alternative contracting approaches identified in Section C above.

Quality improvements that will save time or improve or enhance performance or efficiency - FAR 7.107- 2(c)(1)

As stated above, the previous contracts were awarded by two different agencies, more specifically DCSA and GSA. These awards were made prior to DCSA’s inception in 2019, and the support of GSA is no longer required. By consolidating this requirement into a single small business set-aside contract, efficiency and performance are enhanced as the contract will be strategically aligned to capture multiple mission-essential IDD training products and support services into a common contract for use by DCSA.

The Government will benefit from a decrease to the burdensome requirement of performing post-award contract administration under two separate contracts, and will be better able to align contract performance efficiencies. Moreover, a single contract will boost efficiency of managing delivery of services and will also simplify delivery of deliverables versus multiple KO and contracting officer's representatives (COR) attempting to manage timely delivery of deliverables across separate contracts with different vendors.

Reduction in acquisition cycle times - FAR 7.107-2(c)(2)

The acquisition cycle time from package receipt to award will be lessened as the sum total of document creation and review will be cut in half, more specifically from two (2) contract actions to one (1). Within the single award solution, the Government intends to award a single vehicle with a one (1) year base period and the potential for a six (6) month extension, thereby reducing the number of known contract actions required from two (2) contract vehicles to one (1). Also, the GSA HCaTS Small Business Pool 1 contracting vehicle features a decentralized, flexible, and responsive ordering solution with acquisition streamlining advantages that has been identified as a best in class vehicle.

Better terms and conditions - FAR 7.107-2(c)(3)

By consolidating this requirement and soliciting it under the GSA HCaTS Small Business Pool 1 IDIQ, the terms and conditions are strategically aligned as the IDIQ was developed with the participation and collaboration of 30 small business stakeholders, including incumbents Team Carney and Piton. A single new award eliminates the potential for inconsistencies or conflicts in the terms, conditions, and requirements descriptions, which may occur across multiple efforts. In addition, a combined management approach will ensure consistency in the support required to meet the defined requirements. Additionally, a single contract will assist the Government in ensuring compliance with a single set of terms and conditions rather than with two separate contract awards. This single contract will better align the ST, IS EVD and DITMAC missions at DCSA to ensure there are no gaps or inconsistencies in training the DoD security professionals.

Other benefit(s) - FAR 7.107-2(c)(4):

In addition to the benefits listed above, a single award solution will provide for a single team including:

KO, Contract Specialist (KS) and COR. The Government expects this will significantly lessen any required learning curve associated with new or different persons operating individual contracts. With a single KO, KS and COR, the Government expects streamlined and consistent contract performance reporting as well as a single contract file to review during the performance of the contract. Additionally, by contracting to a single vendor the Government expects to mitigate the likelihood of differing intelligence reports by different vendors.

G. Basis for Consolidation Determination:

This determination that consolidation is necessary and justified is based on:

Benefits of consolidation that are not quantifiable in dollar amounts (Refer to Section F) – FAR 7.107- 2(d)(2)

H. Benefits that are quantifiable in dollar amounts - FAR 7.107-2(d)

FAR 7.107-2(d)(2) states the following:

(2) Benefits that are not quantifiable in dollar amounts shall be specifically identified and otherwise quantified to the extent feasible.

The specific benefits for this consolidation have been fully outlined in Section F above.

I. Mission criticality - FAR 7.107-2(e)

Not Applicable

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Determination

Based on the above facts, I determine that in accordance with FAR 7.107-2:

1. The necessary steps have been taken to support the need for consolidation;

2. This determination has been coordinated with the agency's Office of Small Business Programs; and

3. Consolidation for the above referenced requirement is necessary and justified.

Contracting Officer Acquisition and Contracting

Approved:

Acquisition and Contracting