CUI 622673726 JA MOD1 - Redacted.pdf

DoDNet Microsoft Azure Cloud Usage Subscriptions Bridge, CSS #622673726

-LIMITED SOURCE JUSTIFICATION & APPROVAL (J&A)

FEDERAL ACQUISITION REGULATION (FAR) PART 8 ACQUISITIONS

Multiple Award Schedule (MAS)/Multiple Award Contract Orders under MAS/General Services Administration Schedules (GSA)/Federal Supply Schedules

(FSS) FAR 8.4

Purchase Request Number: To Be Determined (TBD) Contract Number: GS-35F-309AA Task/Delivery Order Number: HC104726F0010 Procurement Title: Department of Defense Network (DoDNet) Microsoft Azure Cloud Usage Subscriptions Bridge Estimated Value:

Statutory and Regulatory Authority: 10 U.S.C. 3204(a) and FAR 8.4

J&A Number: NIA AMD 01 (all changes to the previously approved J&A are in bold, red text).

Upon the basis of the following justification, I, as Contracting Officer, hereby approve this limited source justification pursuant to the authority of FAR 8.4 and GSA Ordering Procedures 538.7104-3(b)(l)(i). The acquisition referenced herein is conducted under the Statutory Authority of the Multiple Award Schedule Program, 41 U.S.C. 152(3).

1. REQUIRING AGENCY AND CONTRACTING ACTIVITY:

Requiring Agency:

Defense Information Systems Agency (DISA) I J6 - Endpoint and Global Services - Endpoint and Customer Service Directorate (FE), Department of Defense Network (DoDNet) Program Management Office (FEl 1) 6910 Cooper A venue Fort Meade, MD 20755

Contracting Activity:

DISA / Defense Information Technology Contracting Organization (DITCO) National Capital Region (NCR) / PS62 6910 Cooper A venue Fort Meade, MD 20755

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2. NATURE/DESCRIPTION OF ACTION(S): This requirement is to purchase proprietary, commercial, Microsoft Azure Cloud Usage subscriptions supporting DISA / FE/ FEl 1. This procurement will be awarded as a firm-fixed-price order to Minburn Technology Group, LLC, an authorized reseller of Microsoft's Cloud Computing solution, Azure, utilizing their GSA MAS GS-35F-309AA. This is a bridge action, and the period of performance is for 90 days which will be December 12, 2025- March 11, 2026. The applicable North American Industry Classification System code is 511210 Software Publishers, with a size standard of $41.5 million. The total estimated price for the proposed acquisition i and this requirement will be funded via Fiscal Year 2026 Defense Working Capital Funds.

AMD 01: This modification is to increase the current contract ceiling b~ his increase is necessary for two reasons. First, the final contractor negotiated price at time of award (December 2025) came in at ~ hich is higher than the IGCE and original approved J&A amount. Additionally, actual cloud usage exceeded original estimates by The Government exceeded the original ceiling amount, which was based on historical usage, due to an unforeseen enterprise compliance mandate. During the fourth quarter of 2025, DISA released new Security Technical Implementation Guide requirements that mandated the collection of additional Object Access and Handle Manipulation audit logs that were not a part of the Government's historical usage. The additional compliance requirements increased log consumption across all DoDNet servers, and the input of these logs into the Sentinel cybersecurity platform drove consumption above historical estimates for the time period of December 2025 through March 2026.

3. DESCRIPTION OF SUPPLIES/SERVICES: DISA's DoDNet PMO requires cloud capabilities to support Defense Agency and Field Activities (DAF A) migrations onto the existing DoDNet. DISA currently utilizes Microsoft Azure Cloud Usage Subscriptions to support DoDNet printing services, Dynamic Host Configuration Protocol, Domain Name System, Internet Protocol address management, and ongoing monitoring and operations. In addition, Microsoft Azure Cloud Usage Subscriptions provide networking capabilities, container services, serverless capabilities, Application Programming Interface gateways, data analytics, Structured Query Language (SQL) and Not Only Structured Query Language (NoSQL) databases, Artificial Intelligence / machine learning, and storage. Microsoft Azure Cloud Usage Subscriptions are currently deployed across multiple OAF As. Microsoft Services integration ensures that the DoDNet Program Management Office (PMO) can leverage Microsoft's robust cloud services while maintaining compliance with Zero Trust authentication standards. DoDNet PMO's mission has a requirement to provide integration for all DoDNet customers within all of the current environment gateways as well as SQL and NoSQL databases to reduce risk. In addition, Microsoft's Zero Trust capabilities, unified identity platform, and pre-integrated, fit-for-purpose security tools offer repeatable, comprehensive coverage across the seven pillars of the DoD Zero Trust Strategy for target and advanced activities.

The DISA DoDNet PMO requires a 90-day bridge contract for unclassified and classified Microsoft Azure Cloud Usage Subscriptions to support DoDNet cloud computing environment operations. Minburn Technology Group, LLC is the current reseller responsible for managing

Page 2 of 7 Pages the licensing and payment for DoDNet's essential Microsoft Azure services. The existing agreement has expired, and additional time is required to complete the competitive award process for a successor contract. A competitive solicitation for this interim requirement is not feasible due to the time-sensitive nature of the need. Authorizing this bridge contract with the incumbent reseller is the only viable course of action to prevent a lapse in service and maintain operational readiness of a mission critical system. This is a vital program and there is an urgent and compelling mission need for the cloud capability that is only offered by Minburn Technology Group, LLC. Introducing another Cloud Service Provider environment will increase risk, and prevent mission-critical integrations with current and new DAF A migrations.

AMD 01: The total ceiling of this J&A is now value including the delta at time of award and the increase due higher than anticipated actual usage). Although this is a Firm-Fixed-Price (FFP) order, the underlying cloud services are consumption-based.

This J&A modification serves as a "usage based true up," which is the process of reconciling estimated or contracted consumption negotiated at award against the actual, higher-than-anticipated usage at the end of a specific period.

4. IDENTIFICATION OF LIMITED SOURCE AUTHORITY AND DEMONSTRATION

OF CONTRACTOR'S UNIQUE QUALIFICATIONS:

(a) Circumstances Justifying Limiting the Source: FAR 8.4 and GSA Ordering Procedures

538. 7104-3(b )(1 )(i), the need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need.

(b) Description of the Justification: DISA's previous Microsoft Azure Cloud Usage Subscription contract with Minburn Technology Group, LLC expired on July 16, 2025, but the contractor continued to provide Microsoft Azure cloud support. The requirement was planned to transition to the Joint Warfighting Cloud Capability (JWCC) Indefinite Delivery/ Indefinite Quantity (ID/IQ) contract vehicle with an expected award in July 2025, but the package was not completed due to changes in staffing resulting from the Deferred Resignation Program and a J6 Reorganization. As a result, the JWCC requirements package to support the required cloud capabilities was not drafted and no award was ever made. On December 1, 2025, the Government became aware that Minburn Technology Group, LLC continued to provide the Microsoft Azure Cloud Usage Subscriptions after the prior contract expired. Minburn Technology Group, LLC requested funding for the Cloud Usage Subscriptions provided from July 16, 2025 to the present day, or the contractor would terminate the cloud support. On December 4, 2025, the contracting office was advised of the Government's unforeseen requirement. The Government contacted Minburn Technology Group, LLC point of contact Tim Swann on December 8, 2025. The contractor should not be providing cloud usage subscriptions without a contract in place and since the Government cannot go without the cloud usage subscription the Government plans to award a 90-day bridge action to Minburn Technology Group, LLC with a compressed timeline executing task order award by no later than December 12, 2025 (less than 8 days from when notification of the action was sent to the contracting office), to continue the required critical cloud services. The

- Page 3 of 7 Pages incumbent contractor Minburn Technology Group, LLC would not require any transition period or lead time to continue providing the required Microsoft Azure Cloud Usage Subscriptions, allowing for seamless continuity.

( c) Justification:

(1) Minimum Government requirements. The Government requires Cloud Computing

Solutions through Microsoft's Azure product. This consists of both unclassified and classified cloud services including Development, Security, and Operations, monitoring tools, application, security- Zero Trust, database, networking, storage, audit tools, Infrastructure as a Service, Platform as a Service, and Software as a Service, Cloud Service Provider Network migration tools, and developer tools.

(2) Proposed sole source contractor. Minburn Technology Group, LLC is uniquely positioned to fulfill the Government's needs. As the incumbent contractor Minburn Technology Group, LLC, is currently providing these cloud computing solutions, and the contractor could continue providing the required Cloud Usage Subscriptions without a gap in service. This 90-day bridge action would allow the Government transition time to move this requirement to the JWCC contract vehicle, which will be a competitive action.

(3) Discussion regarding cause of the limited source situation.

This action is a result of an unforeseen mission critical need that occurred after staffing changes through the Deferred Resignation Program and the J6 re organization. The COR working the contract renewal left the Government and the ownership of the contract renewal was then shifted a second time with the reorganization. These staffing issues caused a delay lasting into September of 2025 when the package was submitted to JWCC. The lapse in appropriations in October and November 2025 stalled all JWCC work since the employees assigned to this action were placed on furlough until a Continuing Resolution was signed. Since the contract for cloud computing is now expired, there is no additional time available for a competitive procurement without unacceptable impacts on DoDNet operations, which is vital for the mission execution for all 4th Estate DoD agencies including DISA. Without the Azure cloud environment any cloud hosted services would come to a complete work stoppage.

( 4) Demonstration of limited source.

The current contract has expired so the DoDNet is at extreme risk for loss of service to multiple 4th Estate Agencies, including DISA. Loss of service would result in all cloud hosted services coming to a complete work stoppage. There is not time to transition cloud computing support to another vendor or compete this requirement through JWCC and as a result there is an urgent and compelling need to ensure these services are continued and that the Government does not lose access to the Microsoft Azure environment.

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( 5) Procurement discussion.

As stated above, the previous contract expired in July 2025, however, the contractor has continued to provide services in the absence of a contract. This has resulted in an unauthorized commitment as services should have ended, however, due the critical nature of the usage credits the contractor continued to perform. There cannot be a lapse in service so this action is required while the follow-on effort is award via JWCC. The Government faces a schedule constraint with this time-sensitive procurement due to this urgent need as the cloud computing solutions are mandatory for the DoDNet environment to operate. The requirement needs to be executed as soon as possible without a gap in service as that would cause unacceptable consequences to DoDNet users.

(6) Impact.

Any delay or gap in service could lead to the termination ofDoDNet's cloud computing solution through Microsoft Azure, which would have detrimental impacts to mission readiness of the DoDNet impacting DISA and Defense Agencies worldwide. Any delay or gap resulting in termination would affect all DAF As that have migrated to DoDNet and could result in mission failure. Personnel at migrated DAF As would lose access to any services requiring Internet Protocol resolution. A lapse in service would lead to the immediate termination of all DoDNet cloud-hosted services and the virtual desktop infrastructure, resulting in a massive operational disruptions for the Defense Agencies that depend on this critical support for operational and security monitoring, commodity Information Technology services, access to mission services including email, printing, web browsing, and resolution of mission hosted software. Failure to provide Microsoft Azure cloud support and ongoing network monitoring would increase the risk of successful cyberattacks, data compromise, loss of ZeroTrust authentication compliance. In addition, the warfighter would lose access to critical Department of Defense communication and be unable to conduct command and control (C2).

5. BEST VALUE DETERMINATION: A proposal will be solicited from Minburn Technology Group, LLC for the required Microsoft's Azure Cloud Usage Subscription via their GSA Multiple Award Schedule (MAS) GS-35F-309AA. GSA has already determined that prices of supplies, fixed price services, and rates for services offered at hourly rates are fair and reasonable for the purpose of establishing the schedule contract. The Contracting Officer will make a determination of fair and reasonable pricing of the proposal received using the proposal analysis techniques at FAR 15.404-1. The complexity and circumstances of the acquisition should determine the level of detail and analysis IA W FAR 8 .404( d) for acquisitions under FAR 8.405-2(d). Discounts from GSA MAS pricing will also be sought prior to award.

6. MARKET RESEARCH: Market research was conducted in December 2025. Because this effort is a bridge contract action, a formal market research report is not required IA W DARS

5810.002 (S-92). Market research included contacting the incumbent contractor, conducting

Page 5 of 7 Pages internal discussions, reviewing Government-wide acquisition contracts, and researching the DISA Market Research Repository.

Based on current market research, the Government determined that only the Microsoft Azure cloud computing solution provided by Minburn Technology Group, LLC, can fully meet the Government's need. DISA requires cloud support to meet mission-critical DAF A migrations to DoDNet that meet the Zero Trust authentication requirements. The Government will continue to conduct market research to determine if there are changes in the marketplace that would enable future competitive actions; i.e., there are similar products and/or product support in the marketplace that provides the same functionality, the original equipment manufacturer releases ownership rights of the product, or it is economically feasible to procure a new system.

7. ANY OTHER SUPPORTING FACTS:

None.

8. ACTIONS THE AGENCY MAY TAKE TO REMOVE BARRIERS THAT LED TO

THE RESTRICTED CONSIDERATION:

(a) Procurement History:

Incumbent Contractor: MINBURN TECHNOLOGY GROUP, LLC Contract Number: 47QTCA21A0003 Task Order Number: 47QFSA23F0032 Period of Performance: April 17, 2023 - July 16, 2025 Competitive Status: Small business (SB) set-aside Business Size: Small business

(b) Actions to remove barriers. At this time, only Minburn Technology Group, LLC, can provide the required Microsoft Azure Cloud Usage Subscriptions within the time line required by the Government. Market research indicates that other cloud service providers are partnering with Microsoft to offer similar capabilities through the JWCC ID/IQ in the future. The effort to award a competitive contract through the JWCC is being worked in parallel to this bridge contract.

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ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO:

Elizabeth A. Bono, Contract Specialist, elizabeth.a.bono.civ@mail.mil, (667) 890-5174, or Michelle L. Rand, Contracting Officer, michelle.l.rand.civ@mail.mil, (667) 891-1833

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