ASRS_JOFOC_Mod 26_ALL SIGNED_Redacted.pdf
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- ASRS and Related Reporting Systems
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- 2026_JOFOC
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This is a Justification for Other Than Full and Open Competition (JOFOC) document prepared by NASA's Ames Research Center for a contract modification to the Aviation Safety Reporting System (ASRS) and Related Systems contract 80ARC024DA001.
NASA seeks to increase the maximum contract value from $39,712,572.00 through a sole-source modification awarded to the incumbent contractor, Booz Allen Hamilton. The modification is necessitated by a 32 percent increase in safety report intake—from an average of 99,432 annual reports as of April 2023 to 131,138 as of April 2024—driven by expanded participation from railroad carriers in the Confidential Close Call Reporting System (C3RS) component and increased awareness of the reporting system. The contract period runs from February 9, 2024, through April 8, 2029, and the modification covers additional labor requirements, IT cybersecurity enhancements, travel, and system augmentations to meet Federal Railroad Administration and FAA requirements. The pricing table identifies four contract line items (CLINs 0001-0004) with a base period extending through August 8, 2026, followed by two option periods, plus a separate IDIQ component. Booz Allen Hamilton is deemed the sole responsible source due to its exclusive knowledge of ASRS/C3RS report processing procedures, specialized expertise required for analyst training (approximately six months), and possession of IT system configurations necessary for cybersecurity modernization. Market research conducted in September 2025, including database searches and a sources sought notice posted September 8, 2025 (with a closing date of September 19, 2025), yielded no competing offerors. The contracting officer determined that competitive procurement would require approximately 120 days and incur unrecoverable costs while creating unacceptable delays in processing the increased report intake before the base period concludes in fewer than four months.
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Rev.: 10/2025
September 8, 2025, in accordance with FAR part 5. This posting informed potential sources of NASA’s intent to award this sole-source modification to Booz Allen Hamilton. The results of this synopsis are summarized in Sections 8 and 10 below.
7. FAR 6.104-1(a)(7) – A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:
The contracting officer’s signature on this document indicates that the contracting officer has determined that the anticipated cost to the government will be fair and reasonable. The contractor must be required to submit a proposal to be evaluated and negotiated by the Government. Prior to execution of the contractual instrument, a proposal analysis will be performed. The proposal analysis will ensure that the final agreed-to price for the contract action is fair and reasonable.
The analysis of the proposal for the contract value increase will be conducted in accordance with FAR 15.404, and include a detailed cost element analysis, a comparison to the IGCE, and other appropriate cost and price evaluation techniques to ensure the final agreed-to cost and fee is fair and reasonable. Pre-negotiation objectives will be prepared prior to the initiation of negotiations in accordance with FAR 15.408-1(b). In accordance with FAR 15.408-2, a certificate of current cost or pricing data will be obtained from the contractor as required and a price negotiation memorandum will also be prepared to document the outcome of the negotiation.
8. FAR 6.104-1(a)(8) – Description of the market research conducted, and the results, or statement of the reason market research was not conducted (e.g., urgent, and compelling requirement):
Market research was performed in September 2025, which included a sources sought notice posted in the GPE Sam.gov on September 8, 2025, as stated in Section 6 above. The purpose of the sources sought notice was to notify industry of NASA’s intent to increase the ceiling of the sole sourced contract awarded to Booz Allen Hamilton. The CO received no responses to the sources sought notice.
Additional research was completed which included a search in the following databases:
- SBA Dynamic database using the NAICS Code 541990 and key words “Aviation Safety Reporting System” yielded zero matches.
- Department of Veterans Affairs website (www.vetbiz.va.gov) for any potential vendors, using NAICS code 541990 and key words “Aviation Safety Reporting System” yielded 0 results.
- SAM.gov using NAICS code 541990 and key word “Aviation Safety Reporting System” produced just the current awardee, Booz Allen Hamilton.
- GSA Advantage using the NAICS Code 541990 and key words “Aviation Safety Reporting System” yielded no matches.
Rev.: 10/2025
After reviewing the market research results, the CO has determined that there are no other potential offerors that currently have the capabilities to satisfy the agency’s ASRS requirements.
9. FAR 6.104-1(a)(9) – Any other facts supporting the use of other than full and open competition:
In accordance with FAR 6.103-1(c)(2), for DoD, NASA, and the Coast Guard, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in substantial duplication of costs to the Government that is not expected to be recovered through competition, or unacceptable delays in fulfilling the agency’s requirements.
Conducting a competition would incur delays in ongoing reviews and processing safety report intake and would cause unacceptable delays in fulfilling the agency’s requirements.
Conducting a competitive procurement for the increase in report intake would take approximately 120 days based on current Procurement Administrative Lead Time (PALT) data for acquisitions of similar value and complexity. This competition would incur approximately in additional costs to the Government, which was derived using salary and benefit data for the various cross-functional team that would be needed to develop, review, and award a standalone contract. These costs would not be expected to be recovered through competition.
Furthermore, this competition would not be completed in time to process the increased report intake for the base period of performance, which constitutes an unacceptable delay in fulfilling the agency’s requirements. The base period of performance ends in less than four months.
However, as previously mentioned, Expert Analysts undergo approximately six months of training before being authorized to independently code and de-identify reports.
10. FAR 6.104-1(a)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition:
A notice of NASA’s intent to award this sole-source action was synopsized on the GPE website (Sam.gov) per FAR part 5 (See Section 6 above). The synopsis provided instructions for interested organizations to submit their capabilities and qualifications to perform the requirements. The synopsis was posted on September 8, 2025, with a response/closing date of September 19, 2025. The Government did not receive any written capability statement submissions or interests in response to the synopsis.
11. FAR 6.104-1(a)(11) – A statement of actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required:
The Agency will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.
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