CREAS_JA_FAR52.217-8_Extension_PPO HCA 3 Signed.pdf

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JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. § 3204(a)(1)

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-111) and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Command, Control, Communication, Computer, Cyber and Intelligence (C5I) Contracting Division 3 Branch 3.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the action: USCG intends to procure on a sole source basis

(b) Name and address of the contractor: Ekagra Partners Limited Liability Company, 161 Fort Evans Rd NE Ste 200, Leesburg VA 201763373.

(c) Contract Type: Firm Fixed-Price Contract Modification

(d) Estimated total value (including options): $157,085.11

Period Unit Price Total OY 5 (52.217-8) 1 mo. $157,085.11 $157,085.11 Total $157,085.11

(e) Type of funding: Operations and support funds

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: N/A

(h) Background information about the requirement: This is an Indefinite Delivery

Indefinite Quantity (IDIQ) contract HHSN316201200131W, for Task Order

1 In this document, citations to RFO Parts 6, 10, 15, 25 are citations specifically to FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 Rev. 1 for FAR Part 15, and FAR Class Deviation 25-09 Rev.1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

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70Z04421F21003400 with Ekagra Partners, LLC (Ekagra). This Firm-Fixed-Price (FFP) Task Order provides for the critical sustainment of services which maintain authoritative operational, functional, and system-level baselines; sustain the Integrated Technical Architecture (ITA); and operate and govern the Digital Engineering Ecosystem (DEE). The contract is set to expire on 28 September 2026.

This action will extend the performance period for up to one month, from September 29, 2026, through October 28, 2026. This J&A also authorizes an increase to the Task Order maximum value by $157,085.11, from $7,138,319.48 to $7,295,404.59, to accommodate the full potential value of the one-month extension to be funded with Operations and Support (O&S) Fiscal Year 2026 funds.

3. Description of Supplies/Services.

The required services provide engineering, architecture, and governance support for the U.S. Coast Guard’s C5I enterprise. These services include maintaining authoritative operational, functional, and system-level baselines; sustaining the ITA; and operating and governing the DEE. The contractor analyzes approximately 40 enterprise changes annually, maintains more than 300 C5I system and requirements models, converts legacy document-based architecture into trusted digital models, applies common enterprise standards, integrates transitioning systems, and supports modernization, cybersecurity, cloud, automation, and data initiatives.

These services have a direct and critical impact on the Coast Guard’s statutory missions, including maritime safety, maritime security, defense readiness, search and rescue, law enforcement, environmental response, and protection of the Marine Transportation System. C5I systems enable command and control, operational coordination, intelligence sharing, communications, mission execution, and situational awareness across Coast Guard operations. Any disruption or degradation in the Government’s ability to maintain C5I baselines, assess enterprise impacts, govern digital engineering data, or support modernization decisions would increase operational risk, delay mission-critical initiatives, and impair the Coast Guard’s ability to deliver reliable and secure capabilities to the field.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(a)(1) implemented by the RFO Subpart 6.103-1 entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Identification of Exception to the Buy American Statute. Not Applicable.

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Ekagra is uniquely qualified to continue performance during the proposed one-month extension due to its incumbent knowledge, established technical baselines, cleared personnel and facility capability, and direct experience supporting the Coast Guard

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Requirements Enterprise Architecture Services (CREAS) environment since 2021. The nature of this short-term extension requires continued performance by the incumbent because any transition to another contractor for this limited period would create unnecessary operational, technical, schedule, and security risks while the Government completes award of the competitively solicited follow-on contract.

Ekagra possesses extensive institutional knowledge of the CREAS enterprise architecture and digital engineering services that support the Coast Guard’s C5I enterprise. Through its incumbent performance, Ekagra has developed a detailed understanding of the Coast Guard’s architecture governance structure, authoritative baselines, digital engineering models, system dependencies, operational requirements, data relationships, stakeholder coordination processes, and modernization priorities. This knowledge is embedded in the contractor’s current team, processes, and support approach and is necessary to maintain continuity of services during the extension period.

Ekagra’s uniqueness is based on several factors directly tied to uninterrupted performance:

Incumbent knowledge of CREAS requirements: Ekagra has supported the CREAS requirement since 2021 and understands the specific mission, technical, governance, and documentation requirements associated with the Coast Guard’s enterprise architecture program.

Familiarity with USCG C5I systems and dependencies: Ekagra maintains working knowledge of the C5I enterprise, including how system-level, functional, and operational baselines relate to ongoing modernization, cybersecurity, cloud, automation, data, and system integration initiatives.

Established digital engineering and architecture expertise: Ekagra currently supports the maintenance of C5I system and requirements models, conversion of legacy document-based architecture into trusted digital models, application of common enterprise standards, and integration of transitioning systems.

Continuity of cleared performance: Ekagra holds a SECRET facility clearance, which is required for performance and is vital to avoid delay or disruption in accessing, handling, and supporting classified or security-sensitive aspects of the requirement.

Experienced incumbent team: Ekagra has personnel currently supporting the Coast Guard who understand the program’s stakeholders, tools, workflows, priorities, and recurring deliverables. Replacing this team for a one-month period would require onboarding, knowledge transfer, system access provisioning, and clearance validation that would likely exceed or consume the extension period.

Relevant federal enterprise architecture experience: Ekagra has performed more than ten federal contracts involving enterprise architecture services that are highly relevant to this requirement, providing the contractor with specialized experience applicable to complex federal IT, architecture, and digital engineering environments.

The incumbent contractor’s knowledge of the Coast Guard’s people, processes, tools, architecture products, governance forums, and technical requirements cannot be effectively

Last Updated 07/23/26 4 or efficiently replicated by another contractor during the limited one-month extension period. A new contractor would require transition time to understand the CREAS environment, obtain necessary accesses, become familiar with existing architecture baselines and models, and establish working relationships with program stakeholders. This transition effort would create a high risk of disruption and would not be practical or cost-effective for the short duration of the extension.

Accordingly, Ekagra’s incumbent expertise, cleared capability, established technical knowledge, and ongoing support of the CREAS environment make it uniquely qualified to provide uninterrupted services during the extension period. Use of the cited authority is required to maintain continuity of critical services until the Government can award the competitively solicited follow-on contract.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

The Government's market research for the follow-on requirement included publishing an Acquisition Planning Forecast System record (F2025071685) on August 28, 2025, and posting a Request for Information (RFI) to all contract holders of the Polaris GWAC WOSB on May 1, 2026. A solicitation for the follow-on contract was posted on eBUY on July 8, 2026, to all thirty (30) Vendors in the POLARIS HUBZone pool and a total of four (4) proposals were received. Award of the follow-on contract is scheduled for FY 2027. The Period of Performance will be a 12-month Base Period and four (4) Option Periods.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The contracting officer determines that the anticipated prices will be fair and reasonable.

While pricing for the FAR 52.217-8 option was not separately evaluated at the time of award, the contractor has formally agreed to hold and apply the rates from the Task Order's final option period for this extension.

Those final option period rates were previously determined to be fair and reasonable based on a thorough cost and price analysis during the initial award negotiation. Because the contractor is offering these same validated rates with no escalation, the price for the extended services is determined to be fair and reasonable.

9. Description of Market Research.

Market research was conducted to determine the most appropriate acquisition strategy for satisfying the Government’s continued requirement during the proposed 30-day extension period. The Government reviewed the current contract status, the availability of existing contractual vehicles, the time required to solicit and award a replacement requirement, and the potential impact to mission continuity if performance were interrupted.

The market research indicates that award of a 30-day extension to the incumbent contractor under FAR 52.217-8, Option to Extend Services, is the most practical and

Last Updated 07/23/26 5 advantageous course of action. The incumbent contractor is currently performing the required services, has personnel and processes in place, and possesses the necessary familiarity with the task order, technical environment, and operational requirements to continue performance without transition delay. Awarding the short-term extension to the incumbent will allow uninterrupted performance while the Government completes the follow-on acquisition and avoids a lapse in critical support services.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

The need for this extension stems from an unforeseen delay in awarding the follow-on contract, caused by unavailability of funds and a descoping of the requirement during solicitation that was beyond the control of the contracting office. Extending the existing task order is the only method to guarantee uninterrupted performance and mitigate risk to the USCG's core missions during this interim period. This extension serves as a necessary interim measure to ensure continuity of critical services pending the award of the follow-on contract. Given the limited 30-day period of performance, competing this interim requirement would not be practicable or in the Government’s best interest.

11. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition. None

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome

Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

The Government has taken affirmative steps to remove or overcome barriers to competition for the follow-on requirement. Specifically, the Government conducted acquisition planning and issued a competitive solicitation for the follow-on requirement under the U.S.

General Services Administration (GSA) Multiple Award, Indefinite-Delivery, Indefinite- Quantity (IDIQ) POLARIS Governmentwide Acquisition Contract (GWAC), Historically Underutilized Business Zones (HUBZone) Small Business Pool. The POLARIS GWAC is a competitive, multiple-award vehicle and is an authorized source for this requirement. Use of the HUBZone Small Business Pool supports small business participation while preserving competition among eligible awardees.

The Government has received and evaluated offers under the competitive follow-on solicitation. The follow-on award process is substantially complete, and the Government anticipates awarding the follow-on contract once Fiscal Year funding becomes available.

The need for this one-month extension is therefore limited to maintaining continuity of critical services during the short period between expiration of the current contract and award of the competed follow-on contract.

The principal barrier to immediate competition is not a lack of market capability or inadequate acquisition planning, but rather the timing of funding availability for the follow-on award. To address this, the Government has already competed the follow-on requirement, evaluated proposals, and positioned the acquisition for award upon receipt of

Last Updated 07/23/26 6 funds. Accordingly, no additional actions are required to remove barriers to competition before the subsequent acquisition, because the subsequent acquisition has already been competed. The Government will continue to use competitive procedures for future requirements to the maximum extent practicable and will continue to conduct acquisition planning, market research, and timely solicitation activities to avoid or minimize the need for future extensions.

13. Technical/Requirements Personnel Certification.

I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

John W. Edwards Date Technical Representative

14. Contracting Officer’s Certification

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Leon G. Hazley Date Contracting Officer

15. Approval

Mia D. Grant Date (Acting) Procuring Activity Advocate for Competition (PAAC)