Justification for An Exception to Fair Opportunity - NSFDACS13T1290 Fully Executed.pdf

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Identification of the agency and contracting activity

The agency is the National Science Foundation, Division of Acquisition and Cooperative Support proposes a Justification for an Exception to Fair Opportunity for continued Information Technology Infrastructure Services.

2. Nature and/or description of the action being approved

The action to be approved is a one (1) month extension to the existing Task Order NSFDACS13T1290 with Phacil, Inc. (Phacil). This extension takes the end date from November 30, 2019 to December 31, 2019.

3. Description of services

The vendor shall continue to provide professional Information Technology Infrastructure Services (ITIS) at current levels, on behalf of NSF, to include but may not be limited to:

• Accomplish routine and daily IT Operations and Maintenance (O&M) activities and dependencies relating to all NSF IT infrastructure platfornis and services in real-time; i.e. Data Center, Network, PhoneNoice, Enterprise Services (Directory, Email and Instant Messaging, Identify Management, Remote Access, Software, Incident & Problem Management, and Root Cause Analysis), Business Systems (Database Management), Service Recovery, respond to ongoing and new IT Security and Vulnerability situations, and accomplish IT tasks related to a number of ongoing IT related projects and initiatives;

• Ongoing planning, preparation, and execution of scheduled and adhoc monthly and quarterly operating system (OS) patching requirements necessary to ensure NSF's IT infrastructure remains secure and fully operational;

• Ongoing Cloud Smart (IT Reliance) activities which include the ongoing development of NSF's cloud capabilities during the first half of Fiscal Year 2020 — including operational process improvements, formalizing approved standards, and development of demonstration and acceptance environments to ensure the availability of Cloud Smart systems at NSF in order to have NSF data available at all times. Ongoing efforts to achieving this initiative include cohesity implementation; replicating mission data to Amazon Web Services (AWS) Cloud Volumes virtual (CVO) ONTAP, Demonstration and Acceptance Testing, migration to AWS, verifying trusted intemet connections (TICs), Implementation Planning for future implementation(s);

• Ongoing initiatives to identify the appropriate Cloud Smart (Monitoring

Evaluation) tools which when proven and approved will be implemented to serve as NSF's ITIS operations web-based solution for monitoring related fault data/events from a single platform to the network, storage area network (SAN), and other IT components across the enterprise using trial licenses in a test environment, and technology bakeoff of the selected monitoring tools.

Assist ISB Government leads with presenting the test results to DIS' Engineering Review Board (ER13) for determination and approval(s) on how to proceed;

• Ongoing NSF data migrations from Symantec NetBackup and AltaVault legacy systems to a more cost effective Cohesity solution platform that allows NSF data exchanges to AWS;

• Ongoing builds, migrations, and decommissioning of the DevOps, CIS, IDM, Mail, MSA, NCSES, PIMS, SAS and Security Red Hat Enterprise Linux 6 (RHEL6) servers and virtual machines (VMs) to RHEL7 servers which will allow NSF to release and repurpose storage to other activities within the NSF network; such as PSM, R.GOV, Single ID, Service Enablement and result in a significant cost savings;

• Ongoing migration and decommissioning of end of life Windows 2008 servers to Windows 2016 that support NSF's Applications and ITHC team's abilities to migrate their applications over to the new Windows 2016 servers. Assist in the planning and coordination of the DevOps migration for servers and decommission the remaining Radia servers - as well as migrating and validating a large amount of custom code to ensure no code breaks, vulnerabilities, or operational malfunctions occur that would negatively impact these NSF application functions;

• Ongoing initiatives to disable Transport Layer Security (TLS) on internal servers within the boundary firewall to ensure outside data would not be communicating with NSF servers over the weaker cipher set; and work with the Applications groups to disable and verify TLS on the internal applications servers and test their functionality with the strict ciphers enabled;

• Ongoing migration from MS SQL 2016 and SQL Server 2008 (which have both reached its extended end of life) to SQL Server 2012 (SP03). This migration is necessary to increase data security and data encryption; but may also simultaneously enhance overall system performance and productivity and could eliminate weekend analytics workloads;

• Ongoing Information Systems Monitoring (S SL Break and Inspect) requirements to allow security tools to view encrypted traffic in accordance with National Institute of Standards and Technology (NIST) guidelines to monitor outbound communications traffic checked at the external boundaries to detect potential unauthorized exfiltration of information (e.g. anomalous volumes of data, anomalous traffic patterns, elements of PII, etc.) with a solution that is centrally visible at the enterprise-level;

• Ongoing activities to replace/upgrade the current F5 Networks Solutions hardware that is approaching end of life support with newer hardware products; and ongoing coordination and validations with all stakeholders prior to the cutover schedule for each device and upgrade hardware at NSF's backup recovery site to eliminate other equipment dependencies;

• Ongoing efforts to analyze, plan, and prepare an execution strategy to migrate from Solaris 10 to Solaris 11 impacting 56 NSF systems (308 servers);

• Ongoing efforts to comply with FISMA audit requirements and the root cause identified by an auditor for the Inspector General's (IGs) office. An outside firm, Kearney & Company, P.C. (Kearney) noted that Data in Transit (App to Web) was not encrypted on the NSF Network.

The cost to extend is $1,512,860.90.

4. Identification of the exception to fair opportunity and supporting rationale including a demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires use of the exception cited.

The statutory authority permitting other than full and open competition is FAR 16.505(b)(2)(i)(B) - Only one responsible source can provide these services.

NSF's IT infrastructure environment is more modern, robust, secure, reliable, scalable, and interoperable supporting an enterprise-wide agency network that facilitates and sustains the IT (Data Center, Network, Phone/Voice, Enterprise Services (Directory, Email and Instant Messaging, Identify Management, Remote Access, Software, Incident & Problem Management, and Root Cause Analysis), Business Systems (Database Management), Service Recovery, respond to ongoing and new IT Security and Vulnerability situations, and accomplish IT tasks related to a number of ongoing IT related projects and initiatives) requirements of a national and global user community. As the current contractor, Phacil, is the most qualified and familiar with NSF's current enterprise voice, data, virtual/cloud, network environment and security protocols. NSF relies heavily on knowledgeable, professional IT technical support services to achieve and sustain federal and agency IT operational and security mandates; and ensure our newly established enterprise network, voice, and data center operations are maintained properly and remains secure and compliant with the Federal Information Technology Acquisition Reform Act (FITARA) and the Federal Information Security Management Act (FISMA).

Phacil is currently performing these services under Task Order NSFDACS13T1290.

Phacil is the only source capable of providing these services during this extension period because the services ordered are highly specialized. A new competition is currently being conducted, and disruption of services at this juncture would be detrimental to the Agency. Any attempt to solicit from other sources would result in failure of these services, and significant duplications of costs from what is currently being performed.

Awarding a new contract/task order to another contractor other than Phacil, Inc., for a short/limited time period of performance would require NSF to accelerate the time necessary to conduct or verify individual background/clearance checks of incoming contractor personnel, assign IT permissions and access to a large number of multiple IT systems; and then for new contractor personnel to become moderately familiar with internal NSF IT and security protocols, configurations, and business processes with all NSF network, data center, and communication systems, operations, and protocols in a very short timeframe (which normally takes approximately four (4) to six (6) months to achieve an operational level of proficiency) while also attempting to support mission critical IT systems and operations in real-time.

Based on the above information, an extension of the current Task Order for an additional one (1) month is critical for NSF operations, which if not maintained properly would impose unacceptable risk to NSF's IT infrastructure, operations, network, and security postures across multiple IT platforms and negatively impacting NSF's mission critical and mission essential IT operations and services.

5. A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer (CO) intends to analyze the contactors quote upon submission and ensure it represents a fair and reasonable price prior to authorizing an extension of the Task Order period of performance. Phacil's Task Order labor rates and labor categories were established at the time of award.

At a minimum, the Contracting Officer intends to review Phacil's labor rates and labor categories covering the extension period to ensure consistency with their Task Order pricing and GSA pricing. The Contracting Officer also intends to review Phacil' s level of effort to ensure labor hours are reasonable for the extension period.

6. Any other facts supporting the justification.

All facts supporting this justification to extend the Task Order period of performance are identified in section 4 above. NSF personnel have been working consistently and diligently to finalize an award.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

This requirement is currently being re-competed under GSA Alliant 2 Large Business. The source selection decision is currently in the review and approvals process. We anticipate having the source selection completed and award issued by December 31, 2019.

8. Contracting Officer's Certification that the justification is accurate and complete to the best of the Contracting Officer's knowledge and belief.

I certify that the data supporting the exception to fair opportunity to extend the Task Order for one (1) month is accurate and complete to the best of my knowledge and belief.

9. Evidence that any supporting data that is the responsibility of technical or requirements personnel and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

The Contracting Officer's Representative certifies that all the necessary supporting technical information was provided for this justification for an exception to fair opportunity.

10. A written determination by the Approving Official that one of the circumstances in paragraphs (b)(2)(i)(A) through (E) of this section applies to the order.

I certify that the facts supporting this justification applies.