ECIOSS Consolidation Memo - Redact.pdf

SP-OCIO-64652

(3) Coordination with the Agency Office of Small Disadvantage Business Utilization (OSDBU)

The contracting officer (CO) coordinated this determination with the OSDBU in accordance with FAR 7.107-2(a)(3), OPM Contracting Policy 1.602-1(b) and OSDBU Memorandum No. 19.1. On February 1, 2024, the CO engaged in coordination efforts with OSDBU for this requirement.

Specifically, the CO partnered with OSDBU to affirmatively determine that this acquisition did meet the FAR Subpart 2.1 definition requirements of a consolidation or consolidated requirement yet did not meet the definition of bundling. OSDBU participated in multiple acquisition planning meetings and discussions regarding this effort.

(4) Identification of Impact on Small Businesses

No negative impacts to small businesses have been identified. The IT Security Staffing Support and Network Operations Support contracts are currently in the 8(a) program. The planned acquisition strategy is to execute an 8(a) competition and ensure both requirements remained within the 8(a) program.

(5) Inclusion of Small Business Concerns

Based on the highest representation from the responses from 8(a) vendors, the market research suggests that 8(a) vendors can perform these requirements with the greatest likelihood of success.

MR bore out that 22 8(a) vendors were identified and 44 SB in total responded to the requirement.

It is anticipated the 8(a) will partner with each other or other SB. Small businesses and other 8(a) companies can be a possible subcontractor for this requirement. Based on experience, it is anticipated there will be small business teaming agreements or subcontracting possibilities.

B. Proposed Contracting Approach

The proposed contracting approach is to solicit these services pursuant to FAR Subpart 6.2 – Full and Open Competition After Exclusion of Sources. More specifically, via FAR 6.204 – Section 8(a) competition where only eligible 8(a) participants will be permitted to compete. OPM will use www.sam.gov to conduct this acquisition. In accordance with FAR 7.107-5(c) the consolidation determination will be posted to www.sam.gov prior to issuance of the solicitation.

C. Benefits of Consolidation

OPM is seeking to embrace a more strategic, forward-looking, enterprise-minded approach that breaks down silos between OPM’s different programs. OPM has identified major organizational capacity and capability challenges that it must address to accomplish this goal and better serve customers. This contract consolidation presents an opportunity to decrease incident response times, optimize resources, and improve customer service.

Consolidating Network and Security Operations functions into a single requirement and the subsequent establishment of an enterprise-wide acquisition is anticipated to have several benefits which are not quantifiable in dollar amounts. The IT Security Staffing Support and Network Operations Support contracts currently have ancillary functions that are optimal for consolidation. By combining these contracts, OPM seek to eliminate duplicative program management overhead, reduce administrative burdens, and merge similarly related scopes of work into a single contract vehicle.

OPM will benefit from increased security agency-wide as OPM moves from On-Prem to the cloud which will optimize resources through unification. OPM needs to unify its network and security operations centers requirements by leveraging people, processes, and technologies to reduce security risks via improved security across the organization. Under the current two contract structure, the SOC vendor identifies system vulnerabilities while a separate NOC vendor resolves those issues. This arrangement leads to unnecessary coordination between the two vendors that leads to ineffective time management and delays the resolution and removal of threat vulnerabilities. By consolidating the two contracts, OPM seeks to realize faster threat and incident response times. OPM expects incident response times that lead to service outages will be reduced by 25 percent.

Additionally, OPM expects to optimize resources through this consolidation. Under the current configuration, OPM cannot easily manage contractor resources in response to threats, incidents, and vulnerabilities. If a new threat or incident emerges, OPM must weigh the potential consequences and decide if more resources are needed and affordable under two separate contracts, each with its own terms and conditions. Consolidation will enable a single vendor to shift resources within the combined security center to shift resources from detection to response in reacting to an incident and vice versa when the need for monitoring threats is greater. Should an incident occur that requires an increase to the vendor resources, OPM can more quickly address the incident with a single vendor.

Lastly, OPM expects a standardized and streamlined customer service response under a consolidated contract. OPM is challenged under the current structure by the siloed nature of its operations, which leads to a confusing and disjointed experience for many customers and intermediaries. This consolidation will establish a customer experience infrastructure, speaking with one voice, to coordinate agency efforts to create consistency, a shared language, and measures of success around customer experience.

DECISION BY THE SENIOR PROCUREMENT EXECUTIVE

Based on the foregoing, the consolidation is determined is necessary and justified in accordance with 15 U.S.C. 657q and FAR 7.107-2(b) because the benefits of the acquisition substantially exceed the benefits that would be derived from each of the alternative contracting approaches identified above.

Per the above, it’s been determined that small businesses, specifically members of the 8(a) program, will not be negatively impacted. The benefits are not quantifiable in dollar terms; however, the alternative contracting approach do not offer the benefits of consolidation.

Shreena L. Morris Date Senior Procurement Executive