CGPM_Limited Source Justification.pdf

City, State, Zip: Tacoma, Washington 98422-3352

2. Description of Supplies or Services:

This effort requires project management oversight and technical architecture governance advice, guidance and support services under OIT to facilitate consistent and effective planning and monitoring of the progress and status of cloud operations at CMS. This support includes contract and procurement support. It also includes project management and technical architecture support needed to transition legacy cloud operations to the new, agile support structure. It will also foster establishment of technical governance of a new platform for future growth of CMS cloud hosting as a self-service, assist CMS business and system owners with architecture and transition requirements, and deliver a stable, governed cloud service model to CMS cloud stakeholders and customers. This requirement was originally competed as a total small business set aside on the GSA MAS under Special Item Number (SIN) 518210C “Cloud and Cloud- Related IT Professional Services, using the procedures under FAR 8.405. This requirement was awarded in April 2022, and this is the first time the exception is being used.

The current order period of performance:

Base Year: 05/01/2022- 04/30/2023 Option Year One: 05/01/2023- 04/30/2024 Option Year Two: 05/01/2024- 04/30/2025

Anticipated Extension (24 months):

Option Year Three: 05/01/2025- 04/30/2026 Option Year Four: 05/01/2026- 04/30/2027

3. Authority:

: ORDER AGAINST FSS: Authority of the Multiple Award Schedule Program, Title III of the

Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C.

501, Services for Executive Agencies; and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6. Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405-6(c)(2)(iv).

An urgent and compelling need exists, and following the procedures would result in unacceptable delays (FAR 8.405-6(a)(1)(i)(A));

Only one source is capable of providing the supplies or services required at the level or quality required because the supplies or services are unique or highly specialized (FAR 8.405-6(a)(i)(B)); or

In the interest of economy and efficiency, the new work is a logical follow-on to an original 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 (FAR 8.405-6(a)(1)(i)(C)); or

The Centers for Medicare and Medicaid Services (CMS), Office of Information Technology (OIT) requires a modification to extend the period of performance of the Cloud Governance and Project Management (CG&PM) task order for continued services to ensure completion of the final phase of operationalizing the Hybrid Cloud Ecosystem, including private cloud capabilities from Kent and Ashburn data centers.

The outcome of this will be full integration with CMS’ public cloud hosting services (both Amazon Web Services and Microsoft Azure). Recent contracts such as Infrastructure as a Service (IaaS) and Managed Infrastructure Service Provider (MiSP) are ramping up to solidify the delivery of services to Application Development Organizations (ADOs) in these new environments. In addition, the award of the CMS Hybrid Cloud Product Engineering & Operations (PEO) task order experienced delays due to a pre-award protest received September 2024. The PEO effort will assist ADOs and their system or business owners in transferring and deploying applications and systems to CMS cloud environments. An extension of the CG&PM POP will allow for smooth transition to contract award once a protest decision is reached. A decision for the PEO protest is anticipated for late January 2025.

Introducing change to key information technology (IT) architecture and program management support attained through this order would be extremely disruptive and would severely hamper CMS’ ability to maintain overall program goals and meet timelines. This could potentially cost CMS millions of dollars in fees related to delays and inefficient architecture/operations. Maintaining the same services, from the same contractor, will enable a smooth transition to the new operating model. This extension is necessary because it provides critical support to complex activities related to the re-architecting of various legacy systems and improving CMS’s hybrid cloud operations.

This is a critical time in the Government’s implementation of the IT infrastructure strategy previously described. CMS needs consistent continuity of services provided by a contractor that is familiar with CMS systems, capable of supporting the implementation of the new strategies, and a contractor that is able to simultaneously maintain the effective delivery of work that is currently underway.

The requirements in this effort/contract require in-depth and extensive knowledge of CMS systems, expertise in operations and hybrid cloud architecture in order to recommend actions in relation to the evolution of CMS’ long-term goals and objectives while simultaneously optimizing costs and operational efficiencies.

An extension to the current task order will ensure continuity of service while IUSG completes their workload re-alignment. The first phase of this re-alignment is planned for fall of 2025 and planned to be completed in late spring of 2026 to coincide with the aforementioned final phase of operationalizing the Hybrid Cloud Ecosystem, including private cloud capabilities from Kent and Ashburn data centers.

An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer.

(FAR 8.405-6(b);

4. Market Research:

In accordance with FAR 10.002 (b)(1), the extent of market research will vary, depending on such factors as urgency, estimated dollar value, complexity, and past experience. The program is very familiar with the market for these, and related services based on information gained from market research efforts for similar and complementary contracts. Transition of the CG & PM team during the final stages of IAAS/MISP ramp up and transition of CMS Cloud contracting from SBIR program creates too great a risk to the program to be acceptable.

5. Actions to Increase Competition:

CMS plans on initiating the competition planning for the follow-on acquisition in fiscal year 2025. Current time constraints are a unique factor influencing the immediate need for this contract modification and will not be a limitation to future competition planned for the end of the two-year extension. At this time, CMS has not determined an appropriate contract vehicle for the work (e.g., GSA Multiple Award Schedule (MAS)), and CMS will conduct market research to determine which contract vehicle has the most qualified pool of small business vendors.

6. Any other facts supporting the justification:

N/A.

Approvals:

1. Program Office Certification: This is to certify that portions of this justification have been developed by the undersigned program office personnel, including supporting information and/or data verifying the Government’s minimum needs, schedule requirements and other rationale, which form the basis for this Limited Source Justification.

Contracting Officer Representative (COR) / Date

Program/Project Manager (P/PM) / Date

2. Contracting Officer Certification and Best Value Determination:

This is to certify that the justification for the proposed acquisition has been reviewed and that to the best of my knowledge and belief, the information and/or data provided to support the rationale and recommendation for approval, is accurate and complete.

By my signature below, after review of the relevant documents, I have determined that

Ajay V. Rao -S Digitally signed by Ajay V. Rao -S Date: 2025.01.14 11:25:04 -05'00'

Nichole M. Poist -S Digitally signed by Nichole M. Poist -S Date: 2025.01.21 11:55:41 -05'00' the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d) and constitutes a fair and reasonable price.

The basis for my determination is as follows:

In addition, 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. This effort will be a modification under the GSA MAS order for the Armavel MAS Schedule Contract. The proposed labor mix and level of effort will be evaluated for price reasonableness. In total, the CO is confident that there are sufficient resources and information to negotiate a fair and reasonable price, on a sole source basis, with Armavel.

Contracting Officer / Date

3. CMS Competition Advocate Approval

I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

Name / Date

4. Head of Contracting Activity (HCA) Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

NOT APPLICABLE________________________________________

5. Office of Small and Disadvantaged Business Utilization *If the contract is greater than $75M, OSDBU review and concurrence is required. This does not preclude the authority of the OSDBU to review all transactions at any threshold. *

NOT APPLICABLE_________________________________________________

6. OGC Legal Review *If the cumulative total (including option years) is greater than $75M the requirement must have a legal review from the General Law Division of the Office of the General Counsel prior to routing to the Department for review. *

Candace M. Straker -S Digitally signed by Candace M. Straker -S

Digitally signed by Donald Knode -S Date: 2025.01.22 09:22:39 -05'00'

_ NOT APPLICABLE________________________________________________

7. HHS Competition Advocate Approval *If the cumulative total (including option years) is greater than $75M, HHS CA review and concurrence is required. *

_ NOT APPLICABLE__________________________________________________

8. Senior Procurement Executive (SPE) Approval

*If the cumulative total (including option years) is greater than $75M, the SPE is the approving official.* Based on the foregoing justification, I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

_ NOT APPLICABLE________________________________________________