DOFEMS Test Environment JA.pdf

J&A#: 20-00029

JUSTIFICATION AND APPROVAL (J&A)

JUSTIFICATION AND APPROVAL FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

Contracting Activity: Naval Medical Logistics Command (NMLC), Acquisition and Analytics Directorate, Code 05, 693 Neiman Street, Fort Detrick, MD 21702, acquiring on behalf of the requesting agency, Naval Ophthalmic Support and Training Activity (NOSTRA).

2. Description of the Action Being Approved.

The government intends to add a requirement for testing services in a virtual environment to the contract with the incumbent contractor, Optical Lab Software Solutions, Inc. (OLSS). The requirement is to have a non-production based testing environment maintained for security patches and upgrades to the operating system, database, and associated software of the system to validate and confirm system’s operational performance post modifications before deployment to the actual production environment. Ensuring operational functionality while maintaining the Department of Defense’s (DoD) cyber requirements. Additionally, the contract currently has a delivery date of 31 March 2021 which will be extended to 24 July 2021.

3. Description of Supplies/Services.

This contract is for Defense Optical Fabrication Enterprise Management System (DOFEMS) in support of NOSTRA. DOFEMS is a standardized, enterprise-wide, global-reaching, optical fabrication Laboratory Management System (LMS) interfacing with existing and planned logistic, and electronic optical order entry programs and including a data warehouse to provide visibility of fabrication information across the DoD’s optical fabrication labs.

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

10 U.S.C. 2304(c)(l), One source or limited sources. See also FAR 13.501(a) Sole Source acquisitions.

5. Rationale Justifying Use of Cited Statutory Authority.

Contract N6264516P2025 was executed on 25 July 2016 with OLSS for the DOFEMS in support of the NOSTRA and has a delivery date of 31 March 2021. Major delays were incurred obtaining the Army and Navy Information Assurance (IA) approvals and later with the Risk Management Framework (RMF) approval through the current Defense Health Agency (DHA) transition. The original language within the contract required individual Army and Navy IA requirements. During the IA process, OLSS was informed by the Government that OLSS must comply with the RMF process instead of the individual Army and Navy IA requirements as outlined in the contract terms and conditions. As a result, the contractor was notified to start the process over. OLSS has not been able to acquire the ATO due to significant Government delays incurred from the transition to the Defense Health Agency (DHA), which resulted in multiple DHA RMF process changes since the contract was awarded in 2016.

NOSTRA has a need to add a virtual testing environment to the subject contract to provide a way for OLSS and DoD to conduct activities as they relate to security compliance, DOFEMS version testing, and SRTS (Rx Ordering system) integration testing. The test environment will be an integral part in allowing the contractor to continuously monitor the RMF process and vulnerabilities throughout the life of the system/contract. In March 2020 the contracting office was notified that an additional testing environment would be needed prior to deployment to the

J&A#: 20-00029

Production Data Center. Because DOFEMS is so complex it is important to be able to pre-test system and network changes before they are applied to the production system. This new testing environment will allow the contractor to:

operate on a DoD subnet; install, run, patch and test HBSS (McAfee) on a DoD information and technology infrastructure; and connect/communicate with SRTS to test the interface, SRTS upgrades, etc. NOSTRA noted that having these systems is a critical part of the Change Management Process that the DHA uses for all updates to the Production Environment. Technical representatives from NOSTRA and NMLC reviewed the additional services and verified that the services were not included in the original contract requirement. The addition is essential to allow a connection to the DoD Certification authority, which the vendor can't host in their environment. The vendor needs the test environment to install it within the Government servers in order to install, run, patch or test HBSS (McAfee). This need for the additional testing environment was uncovered as the newly formed DHA developed its RMF process. According to NMLC’s technical expert, the addition of testing environment is a new standard practice for similarly complex requirements.

Additionally, the timeline to receive ATO had shifted due to significant delays experienced by changes in the RMF process and the transition to the DHA. The delivery date will be extended through to the full five years of the contract to 24 July 2021.

OLSS is the original equipment manufacturer (OEM) of the DOFEMS system and no other entity is qualified to access the system due to the proprietary nature of the system; therefore, OLSS is the only source that can provide the virtual testing and any resultant fixes/patches to the DOFEMS system.

Given the proprietary nature of the software and the operating system, OLSS is the only vendor with rights to change the software code and the necessary knowledge, experience and staff to maintain services currently being provided. No sources other than the incumbent can satisfy this need given the proprietary nature of the system and the transition period that would be required to implement the new system while also training new users.

Without an LMS in place NOSTRA would cease optical fabrication operations and the expense to outsource this work would cost the Government $42,000 per month or $500,000 annually, which may cause potential unnecessary delays providing patient care and negatively impact the Navy’s mission readiness. OLSS is required to have the virtual testing environment and to fix all issues in order to receive and maintain ATO approval to be able to begin deployment of the software. Based on historical knowledge of the RMF process no other contractor is capable of completing this process and obtaining approval sooner than OLSS.

OLSS is the only source capable of providing the necessary system in the timeframe required.

For the reasons noted above, NMLC intends to issue a modification against N6264516P2025 to ensure that NOSTRA is able to maintain its mission. This action will result in one Firm-Fixed Price (FFP) contract modification to add a CLIN for the virtual testing environment and to extend the delivery date to 24 July 2021.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

A Notice of Intent to sole source this effort was posted to FedBizOps’ website on 20 March 2020 at www.beta.sam.gov. No responses or potential interest was received.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer anticipates the cost to the Government of the supplies/services covered by this J&A will be fair and reasonable. The contract action will not be awarded unless a price increase can be determined fair and reasonable.

8. Actions to Remove Barriers to Future Competition.

It is fully anticipated to compete future follow-on acquisitions.

http://www.beta.sam.gov/

APPROVAL BLOCK COMPETITION ADVOCATE