A3. MRA ITSS Bridge MCINCR-RCO JA No. 26-004 Redacted.pdf

UNITED STATES MARINE CORPS

MARINE CORPS INSTALLATIONS NATIONAL CAPITAL REGION

MARINE CORPS BASE QUANTICO

2010 HENDERSON ROAD

QUANTICO VIRGINIA 22134 5001

CUI/SP-PROCURE/CONREG/DL ONLY

DISTRIBUTION: DoD COMMUNITY ONLY

IN REPLY REFER TO:

C-21

M00264-26-JA-004

JUSTIFICATION AND APPROVAL FOR

USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity

Marine Corps Installations National Capital Region – Regional Contracting Office (MCINCR-RCO), Quantico, VA 22134.

2. Description of Action Being Approved

Approval is requested to contract for the continued provision of critical, highly specialized services for the Marine Corps Manpower and Reserve Affairs (M&RA) Information Technology Service and Support (ITSS) requirement using other than full and open competition procedures. This is a non-competitive action to award a bridge contract to the incumbent contractor, ECS Federal, LLC (CAGE 1T1E5).

The contract bridge will consist of a hybrid firm-fixed-price (FFP), labor-hour (LH), and time-and-materials (T&M) structure. The period of performance will be for an eight-month base period, two, 2-month option periods, and one 1-month option exercisable under FAR 52.217-9, while the competitive follow-on contract is completed.

3. Description of Supplies / Services

M&RA requires highly specialized services to execute its mission. M&RA's mission is to employ integrated manpower systems across the Marine Corps enterprise to attract, develop, retain, and support Marines, their families, and its civilian workforce as they pursue their professional aspirations and personal career goals. Successful execution of this mission provides Marine commanders with the human "steel" necessary to fight and win the Nation's battles. One of M&RA's eight (8) divisions is Manpower Information (MI) which provides the staff assistance necessary to plan, develop, control, integrate, and enhance manpower information systems for both garrison and expeditionary environments. The MIT Branch within MI provides ITSS and is responsible for the Manpower Information Portal (MIP) System. The MIP supports all active and reserve Marine components, as well as separated and retired Marines.

The purpose of this performance-based, non-personal services requirement is to provide uninterrupted ITSS for the MIP system, which critical applications essential to M&RA's mission. These services include:

• Project Management

• Database Administration

• Information Technology Service Management

• Application Development

• Help Desk Services

Controlled by: DON, USMC, I&L HCA Controlled by: MCINCR RCO CUI Category(ies): CONREG, PROCURE Limited Dissemination Control: DL ONLY POC: Monica L. Curley, 703.784.0081

• Web Design Services

• Information Assurance

Due to the scope and complexity of the required services, personnel are required with extensive experience in the unique M&RA technical environment, including specific programming languages and platforms. A lapse in these services would severely impact the Marine Corps’ ability to manage promotions, casualty affairs, retirements, and other critical manpower functions.. Unique personnel requirements include experience with systems utilizing Red Hat Enterprise Linux 7 and Oracle WebLogic; experience with web applications having a standard three tiered architecture and coded in Java Server Pages (JSP), Java Server Faces (JSF), Angular 8, PowerBuilder 2017, Microsoft Dot Net, Java Enterprise Edition (EE), Oracle Application Express (APEX), and Procedural Language (PL) Structured Query Language (SQL).

The period of performance requested is for a total of 13 months; an eight-month base period from 11 May 2026 through 10 January 2027, two 2-month option periods and one 1-month option under FAR 52.217-9, Option to Extend the Term of the Contract. The total estimated value is as shown below:

Estimated Dollar Value

Performance Period Duration Start Date End Date Estimated Value Base Period Eight Months 11 May 2026 10 January 2027 Option Period One Two Months 11 January 2027 10 March 2027 Option Period Two Two Months 11 March 2027 10 May 2027 Option Period Three One Month 11 May 2027 10 June 2027 Total 13 Months 11 March 2026 10 June 2027

4. Statutory Authority Permitting Other Than Full and Open Competition

This action is pursuant to 10 U.S.C. § 3204(a)(1), as implemented by FAR 6.103-1(c)(2)(ii), “services may be deemed as available from only one source […] when awarding a follow-on contract for […] the continued provision of highly specialized services, would result in […] unacceptable delays in fulfilling the agency's requirements.” Specifically, an award to any source other than the incumbent would result in unacceptable delays in fulfilling the agency's requirements.

5. Rationale Justifying Use of Cited Statutory Authority

An award to any source other than the incumbent contractor, ECS Federal, LLC, would result in unacceptable delays and a severe degradation of mission-critical services. A bridge contract is necessary due to a series of unanticipated, cumulative delays in the competitive follow-on procurement. These factors prevent the award of the long-term contract before the current contract expires on 10 May 2026.

The primary factors necessitating this action are:

Office of Small Business Programs (OSBP) Delays (6 months): The acquisition timeline was significantly impacted by an extended, six-month review and collaboration period with the Office of Small Business Programs (OSBP). What is typically a 5-10 day administrative concurrence evolved into a multi-stage, iterative process involving extensive analysis, documentation, and supplemental market

Impact of Unanticipated Competition Levels (2 months): Market research revealed a significantly higher level of industry interest (42 responses) than historical data suggested. The Government now anticipates 15-20 proposals for the $46M follow-on contract. To ensure fairness and make a sound "best value" decision for this complex requirement, we necessitate a minimum of five business days to evaluate each proposal. This extended timeline is crucial because proposal evaluation is a collateral duty for our subject matter experts, not their primary job responsibility, meaning their time must be carefully allocated to ensure thoroughness without disrupting their core mission functions.

This disciplined, five-day-per-proposal approach allows for a comprehensive review: Day 1 focuses on the initial read-through and compliance check against the PWS, Day 2 on deep-dive analysis of the offeror’s proposed technical and management approach, Day 3 on evaluating the proposed staffing plan, key personnel qualifications, and assessing the realism of the labor mix, Day 4 on team consensus and narrative development, and Day 5 on finalizing the evaluation report. Given the number of anticipated proposals, this necessary, deliberate schedule will extend beyond the current contract's end date, making a bridge contract the only viable option to prevent service disruption.Using a conservative metric of five business days per proposal for evaluation, the source selection phase is now estimated to take two months longer than originally planned, should the competition be as high as anticipated. Therefore, the sole source award and this J&A include 5 months as an option period, for the potential need for more time.

Government Resources Impact (2 months): The Government’s capacity to execute this complex acquisition on its original timeline has been significantly degraded by specific, unanticipated personnel losses within key organizations. This reduced capacity has created a two-month delay as internal processes were adjusted and PALTs were extended to mitigate risk. This loss of key knowledge and technical expertise means the remaining personnel cannot absorb the substantial workload of a source selection evaluation without creating significant risk to their primary, mission-critical operational duties.

This creates a bottleneck that can only be resolved with the additional time this bridge provides.

While the standard PALT per MCICOM Bulletin 4200 for a services acquisition of this dollar threshold is 290 days, that standard does not account for the compounded complexities of this specific effort. Given the high visibility and dollar value of the $46M follow-on contract and the concurrent administrative workload required to justify, process, and award this essential bridge action, the acquisition team has established a more realistic plan derived from the revised PO&AM to award by 03 May 2027 for this specific procurement. This extended timeline is a necessary risk mitigation measure. It further diverts the limited available contracting personnel from focusing exclusively on the follow-on competition and reinforces the need for the requested bridge period to ensure both critical actions are executed properly and without error while avoiding the need for additional bridge contract actions.

Transition Period (1 month): A mandatory 30-day transition period is required upon award to ensure a seamless turnover of this mission-critical function. This brings the total time required to account for the complex competition and subsequent transition to thirteen months. The inclusion of priced option periods in this bridge contract provides a necessary contingency to account for this extended evaluation, discussions and hand-off timeline, ensuring service continuity without committing the Government to a longer bridge than may be necessary.

As a result of the aforementioned delays, there is insufficient time remaining to award the competitive follow-on contract prior to the expiration of the existing contract. This bridge action would cover the gap between the end of the current contract and the award of the competitive follow-on contract.

The Plan of Action and Milestones (POA&M) for the follow-on contract effort had a contract award date of 10 March 2026. Due to delays, award date is now anticipated to be 03 May 2027. The aforementioned delays were not considered in the original POA&M.

The overall delay is estimated to be thirteen months due to the aforementioned factors. Since the current contract services ends on 10 May 2026, it is imperative that continuation of services is in place, to which this contract bridge serves its purpose. If a bridge is not in place before current contract expiration date, the Command will experience a gap in service across all its directorates, which is mission failure. Therefore, a Bridge Contract is required.

ECS Federal, LLC is the only responsible source capable of performing these highly specialized services without unacceptable mission failure due to insurmountable startup and transition barriers. An award to any other source, even for a short-term bridge, would require a ramp-up period far exceeding the time available before the current contract expires, leading to a catastrophic gap in service. The incumbent is uniquely positioned due to the following immediate, interwoven factors:

1. Immediate Personnel and Security Barriers

A new contractor could not field a qualified and authorized team in time to prevent mission failure. The incumbent's workforce possesses unique, non-transferable advantages that cannot be replicated by a competitor within a compressed timeframe.

• Cleared and Vetted Personnel: The entire incumbent workforce has already undergone and holds the requisite security clearances and background investigations (e.g., DoD IAT Level 1, Security+) necessary to access USMC networks and sensitive M&RA data. A new contractor would face a timeline at least 30 days for clearance processing and adjudication for its proposed staff, making performance impossible from day one.

• Existing System Access and Privileges: Performance requires more than just clearances; it requires active, provisioned accounts and privileges across dozens of separate systems. The incumbent's team currently holds all necessary Common Access Cards (CACs), active user accounts for the Marine Corps Enterprise Network (MCEN), administrative credentials for the MIP application suite, and specific Identity and Access Management (IAM) roles within the AWS GovCloud environment. The process to provision these for a new team would take weeks, during which no work could be performed.

• Mission-Essential Status and Integration: All contractor staff are designated mission-essential per DFARS 252.237-7023. They are not merely augmentees; they are fully integrated into M&RA's daily operations and crisis-response workflows. This level of integration and trust cannot be established overnight.

2. Immediate Technical and Operational Barriers

The services required are not for a generic, off-the-shelf IT system. They involve a complex, bespoke ecosystem of applications that the incumbent has unique and intimate knowledge of.

• Irreplaceable Corporate Knowledge: The incumbent possesses years of invaluable, undocumented corporate knowledge regarding the MIP's architecture, its interdependencies, and its historical failure points. They understand the unique data flows between critical systems like MCTFS, the Digital Board Room (DBR), and O-RMA. A new contractor would be operating solely from formal documentation, which cannot capture the "muscle memory" needed to troubleshoot a complex outage or respond to an urgent data call in real-time. This knowledge gap represents an unacceptable operational risk.

• Unique M&RA AWS Architecture: The MIP's AWS environment is not a standard configuration.

It is a highly customized architecture with specific Virtual Private Clouds (VPCs), security group configurations, and database integrations (Oracle, SQL) tailored for M&RA. The incumbent either built or has been maintaining this exact architecture for years. A new team, even a certified AWS Premier Partner, would have to spend weeks reverse-engineering this environment to understand its intricacies before they could effectively manage or secure it, let alone develop within it.

• Zero Learning Curve for Crisis Response: The MIP system is mission-critical. When an issue arises—such as a failure in the casualty assistance reporting application or an outage during a promotion board—the response must be immediate. The incumbent team can diagnose and resolve issues instantly due to their deep familiarity. A new team would be in a reactive, discovery-based mode, extending outage times from minutes to potentially days and causing direct harm to Marine Corps personnel and operations.

3. Immediate Contractual and Administrative Barriers

Even with a technically capable team, the contractual and administrative setup for a new vendor would introduce unacceptable delays.

• Data Transfer and Sanitization: Transitioning terabytes of sensitive, CUI-level data, including personnel records and operational plans, is not a simple file copy. It requires a documented, secure, and validated process. There is insufficient time to execute this sensitive data handover without creating security vulnerabilities or data integrity issues.

• Lack of Transition Time: A standard, competitive acquisition for a requirement of this complexity would include a 30-day minimum transition period after award. This bridge is required precisely because there is no time left for such a transition. Only the incumbent, who requires zero transition, can continue performance seamlessly on 11 May 2026.

Conclusion:

In summary, only ECS Federal, LLC. possesses the cleared and credentialed personnel, the irreplaceable corporate knowledge of the M&RA technical ecosystem, and the existing operational posture to guarantee uninterrupted performance. Awarding this urgent bridge action to any other source would inevitably lead to a gap in service, causing unacceptable delays and direct, significant harm to the Marine Corps' mission and its personnel.

The delay that would be experienced with an award of a short-term contract through full and open competition, or even a limited competition, would result in an unacceptable lapse in services due to the required timeline to execute the competition (which is at least 6 months), a 30-day transition time necessary to complete the handling of voluminous data and sensitive personnel records, obtain requisite certifications, as well as the time needed to conduct extensive background investigations needed for performance under this contract.

The services are critical to M&RA’s operations, and it is crucial that services continue until an award is made on the competitive follow-on effort. ECS Federal, LLC., as the original provider of the highly specialized services required, is deemed the only source that can properly fulfill the Government’s requirements without unacceptable delays.

Incurring a lapse in service will severely damage M&RA’s mission. Specifically, the lapse in the ITSS contract would immediately result in severely degraded IT services that would adversely affect critical systems that support the United States Marine Corps. The MIP includes systems that impact promotions, selection boards, permanent change of station orders, official military records, retirement processing, funeral support and numerous other critical manpower functions. Existing uniformed and civilian manpower cannot absorb these mission functions without significant degradation to operational capability. The absence of contractor support would create immediate gaps in operational continuity. The resulting lapse in capability would present unacceptable risk to mission success, cyber security, and the human resource development process (HRDP).

Uniformed and civilian personnel would be forced to divert from operational priorities to assume contractor functions, further eroding readiness and the ability to respond to emerging crises or contingency operations. Additionally, necessary staffing levels do not exist among organic Marine Corps personnel to support this requirement in the absence of support provided by this contract. Approval of the ITSS bridge contract is therefore essential to maintain operational continuity and preserve M&RA’s readiness posture across the Marine Corps.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Possible.

ADC, I&L (Contracts) has granted a blanket waiver (SUBJ: Blanket Waiver of DFARS PGI 206.302-1(d) for Bridge Contracts, dated 23 December 2020) of the requirement at DFARS PGI 206.103-170(d) (formerly DFARS PGI 206.302-1(d)) for all bridge contract actions. The requirement to issue an RFI or SS notice when utilizing the authority at FAR 6.103-1 is waived when a bridge contract action is determined necessary pending award of a follow-on competitive contract action; in such an instance, no additional request is required for relief of the DFARS PGI 206.103-170(d). This memorandum applies to this action and waives the requirement to issue a request for information or sources sought notice when utilizing the authority at FAR 6.103-1.

There are no known sources who can immediately provide the required services without resulting in unacceptable delays in fulfilling the agency’s requirements. The contracting activity is currently underway on the follow-on competitive contract with an anticipated award date of 03 May 2027, barring unforeseen delays. The Government intends to provide notice of the action being approved by this Justification by publishing a synopsis of the action in accordance with

FAR 5.101.

The goal of this action is to ensure uninterrupted services are provided while a competitive follow-on procurement can be processed by MCINRC-RCO.

7. Determination of Fair and Reasonable Cost

The anticipated cost of the contract will be fair and reasonable. A price analysis will be conducted in accordance with FAR 15.404-1. The Government will rely on other than certified cost or pricing data, industry best practices and company disclosure statements and will ensure the contractor’s proposal is compliant with all applicable regulatory standards to develop a sound negotiation objective.

8. Actions Taken to Remove Barriers to Future competition

The Government is fully committed to maximizing competition and is actively executing a full and open competitive acquisition for the follow-on requirement. This bridge contract is a temporary measure solely to prevent a service gap until that competitive award can be made. The follow-on solicitation will be competed without set-asides, and the Government does not anticipate the need for future bridge contracts for this requirement.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

Technical/Requirements Cognizance:

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

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

APPROVAL

Upon the basis of the above justification, I hereby approve, as the , MCINCR-RCO, the solicitation of the proposed procurement described herein using other than full and open competition

Distribution List for DL ONLY Limited Dissemination Control

MCFCS Personnel

LB Personnel

Procurement Team Personnel (to include but not limited to: Legal, Customers/Requirements Owners, Source Selection Personnel, Small Business Representatives)

Any other individual designated by the KO