D2AI JEFO-Redacted.pdf

CUI//SP-SSEL

JUSTIFICATION FOR AN EXCEPTION

TO FAIR OPPORTUNITY

UNDER INDEFINITE

DELIVERY/INDEFINITE QUANTITY

(IDIQ) CONTRACTS

Award PIID 47QFHA25F0004

Office of the Under Secretary of War for Personnel and Readiness (OUSW(P&R)) in support of:

47QFHA25F0004 Personnel and Readiness, Data Analytics and AI

United States (U.S.) General Services Administration (GSA) Federal Acquisition Service

Assisted Acquisition Services (AAS) Civilian

Interagency Agreement Number 47QFHA25K0003

Controlled by AAS Contracting Officer Forrest Hancock: forrest.hancock@gsa.gov

Version 02/28/2025 Page 1

Docusign Envelope ID: 06A8BA0E-2158-4FD5-91C3-0CA5DC48C3BE

The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this Justification for the issuance of an Exception to Fair Opportunity order pursuant to Federal Acquisition Regulation (FAR) 16.5 (GSA Class Deviation RFO-2025-16).

a. Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of Office of the Under Secretary of War for Personnel and Readiness (OUSW(P&R))

Contracting Activity:

GSA AAS Contracting Office (QFCA) 2300 Main Street Kansas City, MO 64108

b. Nature and/or Description of Action Being Approved:

This Justification for Exception to Fair Opportunity (JEFO) addresses the critical need for a second consecutive one-year extension to the existing Data Analytics and Artificial Intelligence (AI) task order (DA2I), contract number 47QFHA25F0004, currently held by Booz Allen Hamilton (BAH). This extension, covering the period from February 15, 2026, through February 14, 2027, is essential to maintain uninterrupted mission-critical data analytics services supporting the Office of the Under Secretary of War for Personnel and Readiness (OUSW(P&R)) while the competed re-procurement effort is completed.

The original DA2I task order's period of performance ends on February 14, 2026. It was a sole-source, and its JEFO can be found here. Delays in the award of the re-compete task order, primarily due to new requirements for a pending commerciality determination, have been further compounded by the most recent Government Shutdown and subsequent organizational changes within OUSW.

The primary factor contributing to this delay is that a formal non-commerciality determination was not previously required. To comply with current Revolutionary FAR Overhaul (RFO), Executive Order (EO) 14271, and GSA Office of Government-wide Policy (OGP) guidance, AAS is in the process of drafting a commerciality determination around the upcoming DA2I re-compete. The original DA2I procurement fell under the MATOC-wide commerciality determination, but under the new regulations a new commerciality determination has been written. The IPT issued RFIs in accordance with the commerciality determination guidance issued by OSO. The RFIs were sent to PRISM contract holders as well as to all contract holders on the OASIS non restrictive platforms.

Consequently, a SPE Commercial Determination Request document was completed by the IPT and ready for review by the client SPE for approval consideration. At the same time, our IPT was informed that due to recent organizational changes within OUSW that our requirement would be changing and would result in a new requirement that can accommodate OUSW’s new organizational changes. In early December 2025, our client informed us that the requirements from their Comptroller’s division would now be part of this requirement.

Additionally, the federal government shutdown from 1 October to 12 November 2025 greatly impacted ongoing coordination and document reviews. The 43 day shut down created a significant lapse in operations due to key client agency staff being furloughed.

These unforeseen circumstances have significantly shifted critical acquisition milestones, making it impossible to award a “competed” task order before the current DA2I expiration date. To mitigate the anticipated gap in critical Data Analytics and AI support services, an extension of a minimum of twelve (12) months is necessary. The need to maintain critical services absent of a 6-month extension on the original contract, is due to the aggressive workforce reductions (federal employee layoffs) resulting in OUSW P&R not benefiting from the required Procurement Administrative Lead time (PALT) to create specialized requirements ensuring an on time execution, meeting efficiency goals. This extension will ensure the continuity of these essential services while allowing sufficient time to finalize the re-compete process and award a follow-on task order without disruption.

This action is supported by an Individual Fair Opportunity Exception IAW FAR 16.507-6(b)(1)(GSA Class Deviation RFO-2025-16), stating that “The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays”. This extension will provide continued enterprise-level data support to OUSW(P&R) and strategic partners in the areas of Information Technology (IT) engineering, Operations and Maintenance (O&M), technical, consulting, cybersecurity, and planning subject matter expertise to develop, maintain, sustain, and enhance the DoW Enterprise Government-owned Data Analytics environment, such as ADVANA, Power BI, or other platforms including connections to IT supporting systems across the DoW.

The total estimated value (TCV) for this Fair Opportunity Exception is incrementally funded with FY26 Operations and Maintenance (O&M) appropriations.

Additionally, FY26 Research, Development, Test, and Evaluation (RDT&E) appropriations are considered appropriate for this action, as certain tasks involve advanced data analytics, artificial intelligence, and machine learning efforts in support of the OUSW. These tasks include exploratory data analysis, development and testing of analytical models and AI-enabled decision-support tools, evaluation of data architectures and algorithms, and assessment of emerging technologies to improve policy analysis and enterprise decision-making. Such efforts are developmental in nature, intended to mature capabilities, assess feasibility, and inform future investment and operational decisions rather than support steady-state operations, and therefore meet the purpose criteria for the use of RDT&E funds.

This TCV is based on the average monthly cost of the Data Analytics support provided under the original DA2I task order with confirmation from OUSW (P&R). The anticipated order will continue to be Cost Plus Fixed Fee, with a twelve (12) month period of performance, from February 15, 2026 to February 14, 2027.

The Personnel and Readiness Infrastructure Support Management (PRISM) Multiple Award Task Order Contract (MATOC) was specifically designed to meet the needs of the Office of the Under Secretary of War for Personnel and Readiness. The Deputy Under Secretary of War for Personnel and Readiness has directed that all requirements under their portfolio satisfy their requirements by leveraging the PRISM MATOC. The Data Analytics and AI requirements outlined in this justification are bona fide needs under the Personnel and Readiness portfolio and are directed to satisfy these needs under the

PRISM MATOC.

This Fair Opportunity Exception provides a continuation of Data Analytics support under order 47QFHA25F0004 - DA2I, previously awarded to BAH utilizing an Exception to Fair Opportunity procedures under the PRISM P&R Pool contract. A key tenet of this order is to provide analytical support for ADVANA, which makes data accessible, understandable, and useful to leaders, commanders, analysts, mission owners, and developers throughout the DoW enterprise to describe, predict, and optimize mission and business performance. Derived from the term Advancing Analytics, ADVANA is a modern data platform that pulls data from hundreds of business systems to make data discoverable, understandable, and usable for advanced analytics aligned to the National Defense Strategy. From finance and contracts to logistics and readiness, this system drives informed decision making across the organization through common data models, natural language discovery, and self-service analytics.

The acquisition team determined the PRISM P&R Pool contract was the only solution that would lead to an award without realizing a gap in these critical services. The PRISM

Multiple Award Task Order Contract (MATOC) is tailored for the scope of work covered by the requirement specifically under readiness, reduces the lengthy timeline associated with the traditional acquisition milestones, allows for a quicker award, and saves funding and resources compared to mainstream contracting award processes. No outside requirements will be levied on the team utilizing the PRISM construct.

c. Description of Supplies/Services and Estimated Value:

Please reference:

47QFHA25K0003_ExceptiontoFairOpp_Data Analytic_2024-12-06

The contractor shall continue providing comprehensive data analytics, artificial intelligence, and machine learning support services that are essential to OUSD(P&R)'s mission of developing and implementing personnel and readiness policies affecting the total force. The scope of services includes:

Advanced Analytics Platform Development and Maintenance

● Design, development, and deployment of enterprise-scale data analytics platforms supporting personnel, readiness, health affairs, and force management decisions

Client TDL# TDL Description

Office of Drug Demand Reduction 16.1 DDRP

Office of Command Climate and Well-Being Integration

(OCCWI) 12.1 OCCWI OSIE

Defense Human Resources Activity (DHRA) 11.1 DHRA Beacon CS-AE

Defense Civilian Personnel Advisory Service (DCPAS) 11.2 DHRA Beacon DCPAS

Defense Civilian Personnel Advisory Service 11.3 DHRA Beacon CPDW

DoD Sexual Assault Prevention and Response Office 13.1 DHRA SAPRO IRC-SAM

DoD Sexual Assault Prevention and Response Office (DoD

SAPRO) 13.2 DHRA SAPRO SARW

DoD CIO Workforce Innovation Directorate (DoD CIO WID) 14.1 CIO WF

Office of the Secretary of Defense for Policy, Special Operations/Low Intensity Conflict, Counternarcotics and Stabilization Policy 15.1 CNSP

Resource & Program Integration (RPI) Directorate 8.1 RPI DMPRA

Resource & Program Integration (RPI) Directorate 8.2 RPI DAMD

Resource & Program Integration (RPI) Directorate 9.1 PMO SME Support

● Integration of multiple data sources including personnel systems (DMDC, DEERS), medical systems (MHS GENESIS), training systems, and readiness reporting platforms

● Development and maintenance of data pipelines processing over 500 million transactions monthly

● Implementation of real-time analytics capabilities supporting immediate decision-making needs

● Creation of predictive models for personnel retention, force shaping, and readiness forecasting

● Support for over 10,000 active users across DoW components

Artificial Intelligence and Machine Learning Capabilities

● Development of AI/ML models for workforce optimization, including predictive analytics for recruitment, retention, and talent management

● Natural language processing capabilities for analyzing personnel feedback, exit interviews, and climate surveys

● Computer vision applications for training assessment and safety compliance monitoring

● Deep learning models for health trend analysis and predictive healthcare resource allocation

● Anomaly detection algorithms for identifying personnel security risks and readiness degradation

● Continuous model training and validation using DoD-specific datasets

Data Engineering and Integration Services

● ETL (Extract, Transform, Load) processes managing data from over 200 source systems

● Data quality assurance and governance implementation ensuring accuracy for Congressional reporting

● Master data management for personnel records affecting 2.1 million active duty, 800,000 reserve, and 750,000 civilian personnel

● Real-time data synchronization across classified and unclassified networks

● API development and management supporting system interoperability

● Data lake architecture supporting petabyte-scale analytics

Cybersecurity and Compliance

● Implementation of Zero Trust architecture principles across all analytics platforms

● Continuous monitoring and threat detection for data analytics infrastructure

● Compliance with FISMA, DISA STIGs, and DoD cybersecurity policies

● Regular security assessments and penetration testing

● Incident response and forensics capabilities specific to data platforms

● Encryption and data protection measures for sensitive personnel information

Strategic Planning and Consultation

● Executive-level briefing support for SECWAR, DEPSECWAR, and Congressional leadership

● Development of data strategies aligned with National Defense Strategy objectives

● Capability roadmap development for emerging technologies

● Change management and organizational transformation support

● Best practices implementation from commercial sector adapted to DoD requirements

● Strategic partnership facilitation with other federal agencies and coalition partners

Technical Infrastructure Support

● 24/7 operations center maintaining 99.9% uptime for critical systems

● Cloud infrastructure management across multiple classification levels

● Disaster recovery and business continuity planning and execution

● Performance optimization and capacity planning

● Technology refresh and modernization initiatives

● Help desk and user support services

Specialized Analytical Products

● Daily readiness dashboards for senior leadership

● Monthly personnel trend analysis affecting force structure decisions

● Quarterly reports to Congress on personnel and readiness metrics

● Ad-hoc analytical support for emerging crises or policy decisions

● Predictive models for future force requirements

● Cost-benefit analyses for personnel policy changes

The estimated combined value of the Base Period (Original JEFO: 15 February, 2025 - 14 February, 2026) and the addition of this 12-month JEFO (This Extension JEFO: 15 February, 2026 - 14 February, 2027) is . This reflects the full cost of maintaining this comprehensive suite of services, including labor costs for approximately 45 FTE positions requiring clearances, infrastructure and licensing costs, and continuous capability development to meet evolving requirements.

The first JEFO was approved on 6 December, 2024 for the amount of but was invoiced significantly under the ceiling due to the restructuring and reduction of the effort upon the change of the administration.

d. Identification of the Exception to Fair Opportunity and Rationale:

This exception to fair opportunity is covered under FAR 16.507-6(b)(1) (GSA Class Deviation RFO-2025-16) , “The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.”

Outline of events that contributed to the inability to solicit the requirement competitively:

1. Project assigned to IPT: 11 Jul 2025

2. Commerciality Determination RFI 1 issued 2 Sep 2025

3. Commerciality Determination RFI 2 issued 12 Sep 2025

4. Government Shutdown: 1 Oct - 12 Nov 2025

5. Notification of client realignment with additional tasks to be included in the competitive acquisition (added comptroller division): 1st week of Dec 2025

This exception is invoked based on the critical nature of the services and the severe operational impacts that would result from any interruption. The urgency is demonstrated by:

Immediate Operational Impacts of Service Interruption:

1. Loss of Decision-Making Capabilities : Senior DoD leadership would lose access to critical analytics platforms within 24 hours of contract expiration, affecting decisions on force structure, personnel policies, and readiness assessments that impact national security.

2. Statutory Reporting Failures : The Department would be unable to meet over 30 Congressional reporting requirements, including monthly personnel strength reports, quarterly readiness assessments, and annual military family quality of life reports mandated by law.

3. System Interdependencies : Over 40 interconnected DoD systems rely on data feeds and analytics services provided under this contract. Interruption would cascade across multiple domains including recruiting, retention, healthcare, and training systems.

4. Personnel Impact : This interruption would have immediate effects on 3.8 million service members and civilians who rely on analytics-driven services for career planning, benefits administration, and family support programs.

Complexity Preventing Rapid Re-competition:

1. Security Requirements : All contractor personnel require Secret-level clearances with extensive background investigations taking weeks to months for new hires.

2. System Knowledge : The contractor maintains specialized knowledge of over 200 data sources, custom algorithms, and system interfaces that would require 2-3 months to fully document and transfer.

3. Commerciality Determination : Recent regulatory changes require a comprehensive commerciality analysis that has determined these services are non-commercial, necessitating a complete restructuring of the acquisition approach from FAR Part 12 to FAR Part 16 procedures.

4. Multi-Tenant Coordination : The addition of OUSD(Comptroller) as a second tenant requires extensive coordination, requirements reconciliation, and funding arrangements that extend the procurement timeline.

Timeline to Compete:

● Current Order Expiration: February 14, 2026

● Commerciality Determination Approval: Estimated Q3 FY26 (SPE Approval)

● Procurement Process: 6-8 months including TOR, Q&A, & Evaluation

● Total Time Solicit: 8 months from current date

● Total Time to Award: 11 months

The 12-month extension aligns with the minimum time necessary to complete a thorough competition while maintaining service continuity. This represents a second and final extension, with the Government committed to awarding competitively by Q1 FY27.

Estimated Period of Performance: February 15, 2026, through February 14, 2027

Estimated Dollar Value: (Cost Plus Fixed Fee)

Funding Source: FY26 Operations and Maintenance, Potential RDT&E, and Defense-wide Appropriations

A stoppage of work would have significant negative effects on the Department of War’s ability to carry out priorities that leverage the myriad of data that are found in OUSW P&R’s dashboards and analytic environments. The OUSW P&R dashboards are essential to senior leadership and help guide Department efforts related to sexual assault, suicide, reducing drug use, addressing the Department’s hiring crisis, evaluating and preparing for health crises, and decisions that rely on person-based, human resources data. A stoppage in Data Analytics support would delay leadership’s ability to use advanced analytics and data-driven insights to better inform their strategic decision-making. And a delay in decision making will have severely negative consequences to the readiness of the military workforce.

Senior DoW leaders would be completely blind to current data and trend analysis related to military readiness of military personnel at a time of heightened geopolitical tensions in areas such as the Middle East and South America. DoW personnel readiness is an imperative for a fully functioning, operational, and effective fighting force that can meet the challenges of the current global threat environment. Senior leaders cannot afford to make decisions blindly and the impacts of these decisions are a matter of national security. Delays to these services would be unacceptable and would likely result in the additional loss of life due to service-connected suicides and drug use in addition to resolving other issues pertaining to force readiness.

e. Determination That the Anticipated Cost is Fair and Reasonable:

The current pricing in support of the Data Analytics under the DA2I task order was determined fair and reasonable. The PRISM MATOC contains approved labor rate categories and ceiling rates for each prime contractor, of which BAH is one of those contract holders. GSA requires the incumbent contractor to provide rates at or below their approved PRISM ceilings, which were determined fair and reasonable by the contracting officer at the award of the MATOC. The rates will also be reviewed against the DA2I order to support any resultant fair and reasonable determination.

f. Other Facts Supporting the Justification:

Please reference:

SPE Approval of Non-Commerciality Determination_20260123

1. Approval of Non-Commerciality Determination for the Office of the Under Secretary of War for Personnel & Readiness Requirements

“I have reviewed the assessment and findings provided in the contracting officer’s documentation regarding the commerciality of the requirements and proposed acquisition in support of missions and functions of the Office of the Under Secretary of War for Personnel & Readiness (OUSW(P&R)).

The requirements support missions for multiple elements of OUSW(P&R) and impact strategic partners throughout the Department of War (DoW). They provide enterprise-level data support across the DoW Enterprise Government-owned data analytics environment, including platforms such as Advana, Power BI, and other integrated systems and platforms that support DoW-wide missions.

I agree that adequate market research has been conducted for the purpose of determining if this requirement could be satisfied through commercial services. I agree with the contracting officer’s determination that the requirement does not meet the definition of a commercial service under FAR 2.101, as the required services include military-unique and Government-specific elements involving sensitive information and Government systems. Accordingly, as the Senior Procurement Executive for the Defense Human Resources Activity, which is part of the OUSW(P&R) enterprise, I concur with the contracting officer’s determination that, based on market research, including requests for information and a detailed task analysis, the services cannot be procured commercially without significant modifications that would result in a service that no longer meets the Governments’ requirements.”

Jeffrey R. Register (SPE - Director, Defense Human Resources Activity), Approved 23 January, 2026

2. Causes of Delay in Competitive Award

Please reference:

SPE Commercial Determination Request Data Analytics and AI Data Analytics AI and ML Commercial Services Determination

Commerciality Determination Complexities and Regulatory Changes

The primary obstacle preventing timely competition is the new requirement for an individual commerciality determination. Unlike the original DA2I procurement, which benefited from the MATOC-wide commercial determination under TSyBO, new regulations including Executive Order 14271 and the Revolutionary FAR Overhaul now mandate individual commerciality assessments for all follow-on contracts.

Our extensive market research efforts included two comprehensive RFIs issued on September 2 and September 12, 2025, which generated responses from 34 vendors across 21 detailed questions. The results were definitive:

● Zero vendors reported providing equivalent services to commercial customers under standard commercial terms and conditions

● All reviewed data analytics and AI contracts were government-only, with vendors explicitly confirming they had no comparable commercial contracts

● Vendors unanimously confirmed that security clearance requirements, classified system access, and DoD-specific compliance requirements render these services inherently governmental

This market research also revealed critical interdependencies. While certain subtasks like general program management and unclassified analytics could theoretically align with commercial practices, they are inextricably linked with non-commercial elements including military-specific compliance requirements, DoD reporting metrics, and classified system integration that cannot be accomplished using commercial tools and methodologies. As the incumbent contractor has noted, integrating commercial tools with government-specific systems while maintaining military readiness applications and compliance transforms what might otherwise be commercial services into inherently non-commercial requirements.

Organizational Restructuring and Direct Impact on PWS Development OUSW(P&R)'s ongoing reorganization has fundamentally disrupted our ability to develop a comprehensive PWS. The consolidation of separate directorates, establishment of new data standards, enhanced acquisition oversight requirements, and significant stakeholder turnover have created an environment where requirements cannot be stabilized within the original timeline.

Two critical events have made finalizing requirements impossible:

First, in early December 2025—after five months of requirements development and with the commerciality determination already prepared for SPE review—the client informed us that OUSD(Comptroller) would be added as a new tenant to the requirement. This fundamental scope change arrived just two months before contract expiration.

Second, the January 2026 Deputy Secretary memorandum (see #3 below) directing Advana's restructuring into three distinct components (War Data Platform, Advana for Financial Management, and WDP Application Services) means our follow-on DA2I requirement must align with an architecture that is still being defined.

Multi-Tenant Expansion and Complexity The addition of OUSW(Comptroller) creates complexities that prevent immediate competition. The comptroller's unique financial analytics requirements and TS-SCI classification needs fundamentally conflict with P&R's existing personnel readiness and force management analytics infrastructure, which operates at different classification levels. Adding the Comptroller as a tenant would constitute an unacceptable out-of-scope modification.

This expansion directly aligns with the Deputy Secretary's Advana transformation memorandum establishing "Advana for Financial Management" as a distinct program requiring dedicated infrastructure to ensure the comptroller maintains independence equivalent to a Military Service. To properly address both organizations' needs, AAS is developing a bridge contract for the comptroller while using this extension period to design an integrated solution that maintains appropriate classification separation while eliminating redundancies.

Risk Mitigation and Path Forward To prevent future sole source actions, AAS has implemented a comprehensive strategy maximizing competition and commercial participation. Our approach includes:

● Conducting extensive market research through multiple RFIs to identify commercial capabilities

● Potentially Hosting one-on-one industry (MAD) sessions and collaborative workshops to help vendors understand how to adapt commercial solutions for DoD requirements

● Structuring the follow-on acquisition with modular requirements, separate commercial/non-commercial CLINs, and performance-based specifications

We will invoke FAR 52.237-3, Continuity of Services, in the follow-on contract to ensure 90-day transition services. Additionally, this extension will include a deliverable requiring BAH to provide detailed commerciality analysis identifying which task areas could transition to commercial solutions, recommendations for leveraging commercial offerings, and feedback on commercial tools that could replace government-specific approaches. This analysis, required under FAR clause 52.210-1, will directly inform our follow-on solicitation structure.

Timeline Impact The convergence of these factors makes competition impossible before contract expiration:

● P&R's reorganized structure remains unstable

● New data standards are still being defined

● Enhanced acquisition oversight adds months to coordination

● Stakeholder turnover requires time for new personnel to understand existing capabilities

This 12-month extension provides the minimum time necessary to stabilize the reorganized structure, properly integrate the comptroller’s requirements, align with the new Advana architecture, develop a comprehensive PWS, and execute a meaningful competition. Without this extension, we would be forced to compete a requirement that no longer reflects organizational reality, virtually guaranteeing protests, poor performance, and costly modifications.

3. Transforming Advana to Accelerate Artificial Intelligence and Enhance Auditability

Please reference:

Transforming Advana to Accelerate Artificial Intelligence and Enhance Auditability

The Deputy Secretary of War’s transformation of Advana into three distinct program components directly validates the urgency and critical nature of this extension. This restructuring represents a fundamental shift in how the Department manages its data analytics capabilities, further reinforcing why any interruption in the DA2I services would be catastrophic to national security interests.

The memorandum establishes that data-driven decision-making is "fundamental to maintaining our warfighting advantage and making the Department a more efficient enterprise." The directive specifically acknowledges that Advana, created during President Trump's first administration, has become a cornerstone of the Department's efforts to exploit data assets for both enterprise efficiency and military advantage.

However, the evolution over six years has led to a complex technical and programmatic architecture requiring immediate rationalization to capitalize on AI's full potential.

The restructuring creates three critical components:

1. War Data Platform (WDP) - focused on expanding core data integration to provide standardized data access for agentic AI applications Department-wide

2. Advana for Financial Management - supporting USD(C) Audit Remediation Teams in achieving clean audit opinions for FY27 DWCF and FY28 agency-wide financial statements

3. WDP Application Services - rationalizing existing non-audit Advana applications and supporting migrations to the new architecture

This transformation directly impacts the DA2I requirement in several critical ways:

● The ongoing restructuring makes it impossible to finalize requirements for a competitive procurement. The contractor currently maintains the institutional knowledge of Advana's complex architecture - knowledge that is essential during this transformation period. Any transition to a new contractor during this critical restructuring would risk catastrophic failure of the transformation initiative.

● The memorandum's emphasis on AI acceleration aligns precisely with the DA2I task order's core mission of providing "analytical support for ADVANA, which makes data accessible, understandable, and useful to leaders, commanders, analysts, mission owners, and developers throughout the DoW enterprise." The contractor's deep understanding of the existing Advana ecosystem is irreplaceable during this period of architectural rationalization.

● The addition of OUSD(Comptroller) as a tenant in the follow-on requirement directly correlates to the memorandum's establishment of "Advana for Financial Management" as a distinct program component. This validates the Government's decision to expand the requirement scope and demonstrates why additional time is needed to properly integrate these new financial management analytics requirements with the existing DA2I capabilities.

● The transformation's focus on "secure, rapid development and integration of agentic AI" creates new technical requirements that must be incorporated into the follow-on solicitation. The current contractor's role in supporting this transformation is critical - they possess the only team with the security clearances, system accesses, and technical knowledge necessary to maintain operations while these new AI capabilities are being defined and implemented.

The timing of this memorandum - issued just one month before the current task order expires - underscores the impossibility of conducting a fair and open competition that adequately addresses these transformational requirements. The Government cannot risk disrupting the Advana transformation by changing contractors at this pivotal moment.

The 12-month extension will allow:

● Completion of initial transformation milestones

● Definition of new technical requirements emerging from the WDP architecture

● Integration of financial management components into the broader requirement

● Development of a comprehensive PWS that reflects the post-transformation

Advana ecosystem

This transformation memorandum provides compelling evidence that the urgency exception under FAR 16.507-6(b)(1) is not only justified but essential to national security. The Department's ability to "capitalize on the full potential of AI and support warfighting, intelligence, and enterprise needs with the speed, security, and auditability required" depends entirely on maintaining uninterrupted DA2I services during this critical transformation period.

4. Statement of Actions

The Government has undertaken comprehensive efforts to maximize competition for the follow-on requirement and remains fully committed to awarding competitively. The following actions demonstrate our systematic approach to ensuring a robust competitive procurement:

Extensive Market Research and Industry Engagement Conducted four formal Request for Information (RFI) initiatives:

● First RFI (March 2024): Focused on understanding commercial capabilities and PRISM MATOC scope, receiving 19 responses

● Second RFI (September 2024): Refined requirements based on initial feedback, receiving 15 additional responses

● Third and Fourth RFIs (September 2025): Commerciality analysis focus for SPE determination; received 34 responses

Requirements Development and Risk Mitigation To prevent future extensions and ensure timely development of the new DA2I requirement, we have implemented several critical measures:

● Established Joint Requirements Working Group: Created a formal working group with representatives from both P&R and Comptroller to ensure synchronized requirements development and prevent late additions that previously delayed this procurement. This group meets bi-weekly to validate requirements, resolve conflicts, and maintain alignment between both organizations' needs.

● Synchronized Acquisition Strategy: Developing parallel acquisition strategies with Comptroller to ensure milestone alignment for the merged competitive solicitation, preventing the timeline disconnects that necessitated this extension.

● Comprehensive Capability Gap Analysis: Completed detailed analysis to ensure the scope fully addresses all mission requirements across both P&R and Comptroller portfolios. This analysis mapped current capabilities to mission-critical needs, identified integration points between tenant requirements, and validated that all Task Delivery Lines (TDLs) align with essential Government functions.

● Modular PWS Development: Created a modular Performance Work Statement structure that allows maximum flexibility for offerors while maintaining clear performance standards and enabling easier incorporation of commercial solutions where applicable.

● Industry Capability Mapping: Systematically mapped current services to industry-standard categories and commercial equivalents, enabling vendors to better understand requirements and propose innovative solutions.

Competitive Solicitation Timeline AAS expects to release the competitive DA2I solicitation in Q4 FY26 or Q1 FY27 as a task order under the Personnel and Readiness Infrastructure Support Management (PRISM) IDIQ. This timeline accounts for:

● Completion of organizational restructuring (Q2 FY26)

● Finalization of integrated P&R/Comptroller requirements (Q3 FY26)