E07 LSJ Redacted.pdf

SOURCE SELECTION SENSITIVE

SEE FAR 2.101 and 3.104

Government intends to make award under the new contract prior to October 20, 2021. Consequently the full POP of OY3 is not necessary. It is the Government’s intent that all prices associated with the increased support services that were added via modifications P00001, P00002, and P00004, as were previously evaluated and found to be fair and reasonable, will be used in herein for P00010.

Efforts are currently underway for the recompete (HS0021-21-R-0008) of the subject requirement. The original intent was to have the recompete completed by May 2021, however due to unprecedented variables created by the global pandemic, the recompete effort was not concluded as originally contemplated. Extending the current requirement will allow for adequate time to solicit and appropriately compete the DITMAC requirement resulting in a quality solution. The KO is actively continuing the procurement of these services to ensure the new effort is completed prior to October 20, 2021, allowing for appropriate transition from the incumbent contractor to the newly awarded provider prior to the current effort’s November 20, 2021 end-date.

3. DESCRIPTION OF SUPPLIES OR SERVICES TO MEET THE AGENCY’S NEEDS:

On December 12, 2014, the Director of the Defense Security Service (DSS, later renamed DCSA) was directed by the Secretary of Defense to incubate the DITMAC. Responsibility for overseeing the operations of the DITMAC was formally assigned to the DSS Director by DoD Directive 5205.16 (The DoD Insider Threat Program, September 30, 2014, Incorp. Chg 1, January 25, 2017). The mission of the DITMAC is to enable information sharing, collaboration, analysis, and risk mitigation across the DoD components to address current and emerging threats posed to DoD personnel, assets, and information by insiders. It fills a critical gap within DoD by empowering and entrusting a single senior Defense official with the task of working with all DoD component InT programs to promote best practices, drive innovation, promulgate a fundamental set of standards, and provide resource and policy advocacy to senior decision makers, and through an enterprise-level analytic function to close seams between components that are potentially exploitable by insiders.

Presidential Memorandum, dated November 21, 2012, The National InT Policy and Minimum Standards for Executive Branch InT Programs, require agency heads to establish an integrated capability to monitor and audit information for InT detection and mitigation that leverages counterintelligence, security, cybersecurity, human resources, law enforcement, and other relevant functions and resources to identify and counter the InT. This order supports the DITMAC mission of providing an enterprise-level capability for InT information management that has the ability to assess risk, refer recommendations for action, synchronize responses, and oversees resolutions of identified issues.

The requirement to provide InT Analyst, Unauthorized Disclosure (UD) Analyst, and EMPO Analyst support to the DITMAC was awarded on May 3, 2018 for a total value of $ The base period of performance began on May 21, 2018. The task order was for a one-year base period and four one-year option periods, concluding May 20, 2023. At the time of award the order had four Senior InT Analysts, three Senior UD Analysts, one EPMO Senior Program Analyst, and one EPMO Program Analyst for a total of nine FTEs.

On September 11, 2018, DCSA AQ received a request to increase the level of support on the order by three Senior InT Analysts for a total of 12 FTEs on the order. The KO approved the request based on DITMAC documenting that the InT mission had been continuously evolving since its inception at (then) DSS and as a result the amount of flexibility and redirection in tasks has been necessary to effectively support the critical requirements of the DITMAC.

In addition, the KO signed a determination on September 27, 2018 stating the additional work was in-scope. As a result, modification P00001 to the subject order was issued bilaterally on September 30, 2018, adding the three aforementioned FTEs to the life of the task order. This modification increases the total order value by $ from $ to $

In April 2019, DITMAC had an immediate and urgent need for an additional 10 Senior InT Analysts to reduce risk to the DoD and greater DoD InT security by 1) addressing immediate unforeseen mission increases and 2) providing support to this new normal case reporting volume, which was, and continues to be, significantly more than current processing capability. As a result, modification P00002 to the subject order was issued bilaterally on April 1, 2019, adding 10 additional Senior InT Analysts to the remaining two months of the base year and the first option period.

Modification P00002 increased the total order value by $ from $ to $ While the order expires May 20, 2023, the KO decided that the AQ office would not exercise option periods two, three, or four because of the continued increase in FTE, but would instead begin to recompete this growing requirement in the coming year (2019/2020) while anticipating a new award prior to May 20, 2020 with the expiration of option period one.

In April 2019, DITMAC also submitted a package to exercise option period one. As a result modification P00003 to the subject order was issued unilaterally on April 29, 2019 to exercise option period one.

In August 2019, DITMAC had another immediate and urgent need for one additional EPMO Program Analyst (an increase of one FTE, from two to three FTE). The Under Secretary of Defense for Intelligence & Security (USD(I&S)) is required to monitor and report the progress and status of the DoD InT Program to the Secretary of Defense. The USD(I&S) assigned the DCSA InT EPMO the responsibility to implement and manage a quarterly self-assessment reporting process to meet this requirement and to conduct independent assessments of the DoD Component InT Programs. The additional EPMO Program Analyst was required to assist in the development of an assessment and engagement plan and would ultimately participate in the independent assessments of the adequacy and effectiveness of the DoD Component Programs. As a result, P00004 to the subject order was issued bilaterally on September 20, 2019, adding one EPMO Senior Analyst to the remaining eight months of option period one. This modification increased the total order value by $ from $ to $

In the interim of the contemplated option year, P00005 and P00006 were administered for incremental funding and the realignment of funding.

Thereafter, DCSA DITMAC had an immediate and urgent need to exercise option period two, with the increased level of support services that was added through P0001, P00002 and P00004, to reduce risk to the DoD and greater DoD InT security by maintaining the support services listed above. As such, P00007 was issued May 20, 2020 in lieu of the unsuccessful completion of the recompete effort. This modification increased the total order value by $ from $ to $

Following P00007 were two additional administrative modifications; P00008 and P00009, for administrative purposes and incremental funding, respectively. As a result, the total contract value was unchanged.

This immediate effort is now for P00010 to support only the six-month period from May 21, 2021 through November 20, 2021. Funding for the six-month period is available via purchase requisition (PR) HS0021112329 via fiscal year 2021 Operations and Maintenance funds. The total estimated value of this action is $

44. AUTHORITY AND SUPPOTING RATIONALE AND THE PROPOSED CONTRACTOR’S QUALIFICATIONS:

In accordance with FAR 8.405-6(c) this acquisition is conducted under the authority the Multiple-Award Schedule

Program. This limited source justification is authorized in accordance with FAR 8.405-6(a)(1)(i)(A).

Per FAR 8.405-6(a)(1)(i)(A), the work required will fulfill an urgent and compelling need utilizing the existing order (HS0021-18-F-0004) and avoid any unacceptable delays in fulfilling the DITMAC’s requirement for these services, which could be a severe detriment to DITMAC’s mission. Per USD(I&S) direction and instructions from the USD(I&S) leadership, the level and maturing of insider threat capabilities across the department has significantly increased resulting in a dramatic increase in mission. There are no Government personnel or billets available to complete this mission, and contract personnel are the only viable mechanism available to support this need.

The DITMAC continues to see an increase in reporting as new DoD component hubs come on-line and department-wide insider threat processes mature. There are currently over 40 components that are each developing their own standard for reporting as directed by the USD(I&S). Once these components develop their own reporting hubs, then those hubs are required per USDI guidance, to send those reports that meet specified thresholds to the DITMAC.

As the hubs evolve their processes and reporting, the DITMAC is starting to see an increase in caseload. In addition to the number of hubs that are reporting, the scope of the population covered by the DoD Insider Threat Program has also increased. Individuals within this population have expanded beyond those who have or have had clearances. Since January 2017, DITMAC has received more than 2,304 submissions (reports and RFIs) from 37 of 44 DoD component hubs. For comparison purposes, in fiscal year (FY) 17 DITMAC received 336 reports total, in FY18 DITMAC received 457, in FY19 DITMAC received 3,297 reports, in FY20 DITMAC received 2,184 reports, and as of March 15, 2021 for FY21 DITMAC has received 1,654 reports. This is the new normal reporting volume, which is significantly more than current processing capability. At the time of the initial performance work statement development in 2016, the DITMAC had just achieved initial operating capability. The majority of component hubs were previously not reporting case information and DITMAC was not receiving continuous evaluation results as it is now. In addition, DITMAC is currently negotiating access to law enforcement (LE) and counterintelligence (CI) information for the insider threat enterprise which is expected to dramatically increase reporting across the enterprise over this FY. Consequently, there was no baseline at the time of award to foresee the current eight-fold increase in reporting to the DITMAC.

Not maintaining these resources could have an immediate detrimental impact on the DITMAC’s ability to not only track reports, but hamper its ability to mitigate potential insider threats. Examples of detrimental impact include potential loss to DoD of physical resources to include people, classified, and controlled unclassified information, potential work place violence (death/physical injury/loss of Government equipment), suicide, unauthorized disclosure of information, and espionage.

Dependable Global Solutions, Inc. (DGS) has been performing the PWS tasks successfully and DGS is the only contractor that immediately has the personnel to infuse into the operation without any delays in processing. The current national security threats active within the United States require action and mitigation. Without maintaining the current support services on this current task order, the price and risk to the Government increases daily.

Allowing a break in service while recompete efforts are underway, or otherwise transitioning to a new contractor, would be detrimental to the mission and national security.

Per FAR 8.405-6(a)(1)(i)(A) the work within this modification is urgent and compelling and therefore only possible via one source. The original order was placed in accordance with the applicable FSS ordering procedures and was competed appropriately with other FSS holders.

5. DETERMINATION OF BEST VALUE:

The contracting officer has determined that adding a six-month period of performance to the existing task order under FSS represents the best value to the government resulting in the overall lowest cost alternative (considering price and administrative burden/costs). This determination is made on the basis that the previous effort was made on a competitive basis and that the contractor’s proposed prices are fair and reasonable.

6. DESCRIPTION OF MARKET SURVEY/EFFORTS TO OBTAIN COMPETITION:

This limited source order action is a short-term solution. This requirement could not be competed due to the degradation of security and increased risk to DITMAC’s mission that would result from the time necessary to compete a contract for this work. This solution answers the immediate need to reduce risk to the department and mission security and provides time to recompete appropriately. The new solicitation will utilize a more flexible ordering vehicle that is appropriate to the growing DITMAC mission and fluctuating reporting requirements of the department components.

However, the recompete effort will take into account and review all available sources in the market. Lastly, the Government now has more concrete knowledge that can be used in future acquisition planning to include a future flexible contract vehicle that can handle any surge to insider threat reporting and growth within the DoD reporting components. The KO is strategically working through recompete efforts and shows a good faith effort to post the requirement for recompete in the coming weeks.

7. ANY OTHER SUPPORTING FACTS:

N/A

8. ACTIONS TAKEN TO REMOVE BARRIERS TO COMPETITION:

DCSA will continue with the DITMAC recompete efforts with full intentions of awarding a follow-on contract prior to November 20, 2021. Additionally, the six-month option will allow for appropriate transition from the incumbent contractor to the newly awarded provider.

9. APPROVALS:

TECHINCAL AND REQUIREMENT CERTIFICATION:

I certify that the supporting data under my cognizance which are included in the LSJ are accurate and complete to the best of my knowledge and belief. FAR 8.405-6(c)(2)(x)

CONTRACTING OFFICER CERTIFICATION:

I certify that this justification is accurate and complete to the best of my knowledge and belief. FAR 8.405- 6(c)(2)(ix)

PROCURING ACTIVITY COMPETITION ADVOCATE APPROVAL:

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 $13.5M, this review serves as approval and my written determination that the aforementioned FAR circumstances apply. FAR 8.405-6(d)(2).