E07 HS002119F0141_P00005_Justification_20230214_Redacted.pdf

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JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

IDIQ HS002118D0002 / Task Order HS002119F0141 / Rockwood Company, LLC

1. Identification of the agency and contracting activity.

Defense Counterintelligence and Security Agency Acquisition and Contracting 27130 Telegraph Road Quantico, VA 22134

2. The nature and/or description of the action being approved (e.g., sole source, limited competition, establishment of a new source).

This justification supports the sole-source modification of Defense Counterintelligence and Security Agency (DCSA) task order HS002119F0141, under which Rockwood Company LLC (Rockwood) provides change management services to the Industrial Security (IS) Directorate. This task order was awarded on September 30, 2019 under indefinite-delivery/indefinite-quantity (IDIQ) contract HS002118D0002, one of five IDIQs providing Consultation, Facilitation, Leadership Alignment, and Strategic Collaboration (ConFLASC) Support Services across the DCSA enterprise.

3. A description of the supplies or services required to meet the agency’s needs (including estimated value).

An in-depth manpower assessment, comprising a four-month sprint capability extending February 1, 2023 through May 31, 2023, is required by DCSA’s IS Directorate for an estimated total cost of $924,451.24. This formal manpower analysis, conducted in accordance with Department of Defense Instruction (DoDI) 1100.22, Policies and Procedures for Determining Workforce Mix (April 12, 2010, as amended) will result in quantitative manpower estimates and identification of the proper workforce mix to support the IS Directorate in fulfilling 100% of its current oversight mission. The assessment will identify current mission strengths and resource shortfalls within the National Industrial Security Program (NISP) and Arms, Ammunition, and Explosives (AA&E) division, as well as training deficits that impact workforce readiness in this mission space. Assessment results will be used to inform the agency’s Program Objective Memorandum-2025 (POM-25) submission—due in early June 2023—which will describe how the agency plans to allocate resources in response to program requirements and outline anticipated needs over the next five years. Identification and inclusion of additional staffing requirements in POM-25 is crucial to avoid unacceptable delays in manpower authorizations and decrease the threat to the Nation’s industrial base.

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4. Identification of the statutory authority permitting other than full and open competition or fair opportunity.

Modification of task order HS0021190141 will allow for the addition of a manpower assessment to the change management services currently provided by Rockwood is permitted under the authority of FAR 16.505(b)(2)(i)(C) in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract.

All ConFLASC IDIQ holders were given a fair opportunity to compete for the original order under solicitation HS002119R1903. Four proposals were received and evaluated, and award was made to Rockwood for a period of performance extending September 30, 2019 through March 29, 2024 (one six-month base period and four 12-month option periods) with a total anticipated value of $1,537,613.76. This modification will increase the total anticipated value of the task order by $924,451.24, from $1,537,613.76 to $2,462,065.00.

5. A demonstration that the proposed Contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

A manpower study is required to support the addition of personnel in accordance with DoDI 1100.22. In order to identify additional personnel requirements for inclusion in POM-25, the required manpower study must commence by February 1, 2023 and reach completion by May 31, 2023 in order.

Rockwood is currently supporting change management initiatives for IS under the subject task order. Given Rockwood’s involvement and familiarity with DCSA’s IS mission sets under the current change management task order, as well as their performance of similar work under other Directorates, the Contractor is optimally positioned with the necessary historical background, data, and infrastructure to immediately begin work on this additional in-scope requirement. Rockwood has invaluable expertise that qualifies the company to expedite the analysis and synthesis of manpower data into useable metrics that will strengthen the IS Directorate’s POM-25 request within the desired timeframe. Using innovative approaches to problem solving in the areas of workforce readiness and analytics, Rockwood employs a step-by-step methodology to assess organizational effectiveness through benchmarking and analysis to identify areas for improvement in organizational processes, structure, and systems.

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6. A description of efforts made to ensure that offers were solicited from as many potential sources as is practicable. Include whether or not a SAM.gov announcement was made and what response, if any, was received, or include the exception under FAR 5.202 if not synopsizing. Describe whether any additional or similar requirements are anticipated in the future.

A pre-solicitation notice was posted to the Governmentwide point of entry on June 13, 2017 for the ConFLASC multiple-award IDIQ (solicitation HS002117R0005). In accordance with the exceptions found at FAR 5.202(a)(6) and FAR 5.202(a)(11), no further synopsis is required. This is a one-time follow-on requirement; no similar IS manpower studies are anticipated in the future.

7. The anticipated dollar value of the proposed acquisition, including options if applicable, and a determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The prices offered by all ConFLASC IDIQ contract holders were determined to be fair and reasonable at the time of award. Task order HS002119F0141 was issued under the terms and conditions of ConFLASC IDIQ HS002118D0002. The rates used to develop the manpower assessment quote provided by Rockwood were based on labor rates in Rockwood’s ConFLASC IDIQ, HS002118D0002, and were $174,603.64 less than the Government cost estimate of $1,099,054.88. Furthermore, market research completed in March 2022 (prior to exercise of the current task order option period) concluded that the prices offered by Rockwood Company LLC were still competitive in the marketplace.

The manpower assessment services incorporated via the proposed modification are considered non-severable and have an anticipated dollar value of $924,451.24, which was fully obligated at the time of award.

8. A description of the market research conducted (FAR part 10) and the results or a statement of the reason market research was not conducted.

In accordance with FAR 10.002(b)(1), the Contracting Officer may use market research conducted within 18 months prior to the award of any task or delivery order if the information is still current, accurate, and relevant. Market research was last completed on March 6, 2022 for the exercise of option period 3 under task order HS002119F0141. It revealed there have been no significant changes in the marketplace for comparable services that would preclude Rockwood prices from being deemed fair and reasonable and in the best interest of the Government.

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9. Any other facts supporting the use of other than full and open competition or fair opportunity.

Pursuant to FAR 16.505(b)(2)(i)(C), this action is made in the interest of economy and efficiency because it is a logical follow-on to a task order issued for change management services. Award to a source other than Rockwood would result in increased risk—cost risk associated with re-procurement costs and possible increase in cost of services, performance risk in hiring a new Contractor without the historical knowledge and imbedded change management experience in IS, and schedule risk resulting in delayed delivery of the manpower analysis by May 31, 2023, which would negatively impact the Directorate’s ability to accurately forecast required manpower data needed to inform its POM-25 submission.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

No other sources have indicated interest in this requirement.

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required, if subsequent acquisitions are anticipated.

The acquisition of this manpower study is considered to be a one-time procurement to determine personnel and space allocations necessary to meet the mission requirements of IS. No further procurements for these services are anticipated at this time.

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Certification

Program Official:

I certify that the facts and representations under my cognizance, which are included in this justification for an exception to fair opportunity and which form a basis for this justification, are complete and accurate.

Program Official

Contracting Officer:

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer

Reviews and Approvals

Advocate for Competition (if over $750K):

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Since this justification does not exceed $15M, this review serves as approval.

Activity Advocate for Competition