EIS II - Determination for Consolidation_Redacted.pdf

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FCC - Determination for Contract Consolidation
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This document is a Determination for Contract Consolidation for the Federal Communications Commission's (FCC) Enterprise Infrastructure Solutions (EIS) II Managed Services contract. The procurement consolidates multiple existing telecommunications and IT infrastructure services into a single task order under the GSA Enterprise Infrastructure Solutions (EIS) Governmentwide Acquisition Contract (GWAC), with an estimated total dollar value exceeding $2 million. The modernization effort aims to transition from legacy systems to a unified, advanced infrastructure, including Software-Defined Wide Area Networking (SD-WAN), Unified Communications Services, Managed Network Services, and Managed Security Services.

The current environment involves services from multiple providers like AT&T, Lumen, Verizon, MetTel, and others, which will be integrated into a more modern framework. While market research showed limited small business capabilities, the FCC's strategy ensures maximum practicable small business participation by competing the requirement among all EIS GWAC vendors. The consolidation is expected to deliver approximately $14.3 million in cost savings, reduce administrative complexity, improve cybersecurity, enhance network performance, and align with federal technology standards like Zero Trust Architecture and TIC 3.0. The contract will have a 36-month base period with four 12-month options and includes advanced features such as quantum encryption, automated threat response, and centralized management capabilities.

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Determination for Contract Consolidation

FAR 7.107-2 Consolidation

Date: 10/22/2025

Subject: Determination for Contract Consolidation for Enterprise Infrastructure Solutions (EIS) II Managed Services

I. Introduction and Purpose

This document serves as the written determination for the modernization effort to consolidate requirements for Enterprise Infrastructure Solutions (EIS) II, with an estimated total dollar value exceeding $2 million, in accordance with Federal Acquisition Regulation (FAR) 7.107-2 and 15 U.S.C. 657q.

II. Acquisition Details

Acquisition Title: Enterprise Infrastructure Solutions (EIS) II Managed Services

Agency/Component: Federal Communications Commission OMD/OCIO

Estimated Total Dollar Value (including options):

Description of Consolidated Requirements: To support the transition from legacy telecommunications and IT infrastructure to the modernized EIS-II framework, this justification outlines the requirements necessary for a seamless transition from a deprecated infrastructure. The transition is essential to ensure continuity of mission-critical services while aligning with evolving federal technology standards and operational efficiency goals.

The current environment includes a range of services, ranging from WAN/MTIPS, IP voice, toll-free calling services, local telecommunications, and satellite communications; all delivered through multiple providers. These services are scheduled for transition following structured extension or bridge periods, ensuring no disruption.

In parallel, legacy services such as DSL, VoIP, and fiber circuits are being phased out as Software Defined Wide Area Networking (SD-WAN) and other modern capabilities are deployed, replacing the current outdated technology stack. Telecom Expense Management Services (TEMS) remain critical for lifecycle oversight and cost control, while cybersecurity support is being restructured to replace legacy SOC operations with Managed Security Services (MSS), enhancing threat response and risk mitigation capabilities.

Operational infrastructure support, including IT operations and data architecture, is being modernized to address outdated systems, with legacy monitoring functions replaced by a

Managed Network Service. Additional investments in VoIP, audio conferencing, and wireless services ensure continued support for hybrid work environments. Commodity IT buys, such as load balancers, endpoint protection, and SSL certificates, will continue as needed until they are fully integrated or rendered obsolete by broader service contracts.

Previous Contracting Approach (if applicable): As part of the FCC’s modernization efforts under the EIS-II initiative, a broad consolidation of telecommunications and IT services currently sourced from multiple vendors is underway. AT&T, operating under an unrestricted competition contract as a large business provider, delivers the FCC’s primary Wide Area Network (WAN), Managed Trusted Internet Protocol Services (MTIPS), and cloud connectivity, core components enabling cloud-centric modernization and ensuring operational continuity across the agency’s three data centers. Lumen, also a large business under similar contract terms, provides secondary MTIPS and toll-free voice services. Verizon supports Public Safety and Homeland Security Bureau (PSHSB) WAN connectivity, as well as IP voice and long-distance telephony. These disparate services will be integrated into a unified, modernized infrastructure leveraging Software-Defined Wide Area Networking (SD- WAN) and enterprise-grade Voice over IP (VoIP) solutions to enhance performance, scalability, and security across FCC operations.

Local telecommunications services are provided by MetTel, a small business under unrestricted competition, supporting national call center operations. Additional VoIP and internet services at field offices are delivered by Vonage, Comcast, Frontier, and Neptuno, all large businesses operating under miscellaneous obligations. These legacy services will be phased out as SD-WAN and unified communications are deployed.

Cybersecurity services are currently fragmented across several vendors. Software Information Resource (Cylance), Swish Data Corporation (Checkpoint), 4 Star Technologies (CIS SecureSuite), and DH Technologies (SSL Certificates and reCAPTCHA) provide endpoint protection, firewall maintenance, and compliance tools. These vendors range from small to other-than-small businesses under unrestricted or HUBZone set-aside contracts. These services will be modernized into a Managed Security Services (MSS) model.

Operational infrastructure is managed by Evoke, a small business under a small business set-aside contract, providing IT operations and data architecture support. This will transition to Managed Network Services (MNS). Chenega, a small business under an 8(a) set-aside, supports VoIP and audio conferencing through Cisco platforms, which will be scaled to support all FCC field offices.

Telecom Expense Management Services (TEMS) are provided by WidePoint, a large business under unrestricted competition, and will continue under the current structure. Satellite communications from Satcom Direct and wireless services from Verizon are also retained.

Commodity IT services, including F5 load balancers, SSL certificates, and CDN services, are sourced from vendors like GOVSMART INC, Thundercat Technologies, CarahSoft Technologies, and Iron Bow Technologies. These vendors span small and large businesses under unrestricted competition and will either be subsumed into broader infrastructure contracts or phased out as their functions are integrated into the new enterprise architecture.

This modernization effort under EIS-II will streamline operations, reduce vendor complexity, and enhance the FCC’s technological agility and security posture.

III. Compliance with FAR 7.107-2(a)

Before making this determination, the following steps have been taken:

1. Market Research Conducted (FAR 7.107-2(a)(1))

Description of Market Research: The market research conducted for the FCC’s OCIO Managed Services Modernization Initiative was carried out in accordance with FAR Part 10 and employed a comprehensive, multi-method approach to determine the most effective acquisition strategy. Key methods included issuing a Request for Information (RFI), hosting an Industry Day, conducting vendor meetings, and reviewing similar contracts, particularly the National Labor Relations Board’s (NLRB) SD-WAN procurement experience. The RFI and Industry Day provided valuable insights into vendor capabilities and market readiness, while the NLRB case study highlighted the importance of early industry engagement, phased implementation, and streamlined procurement processes to avoid delays and confusion.

Sources consulted included GSA’s Federal Supply Schedules (FSS), Government-Wide Acquisition Contracts (GWACs), and mandatory sources such as Federal Prison Industries and Ability One. The research concluded that only the GSA Enterprise Infrastructure Solutions (EIS) contract fully meets the FCC’s requirements for transitioning to SD-WAN, Unified Communications Services (UCS), Managed Network Services (MNS), and Managed Security Services (MSS). Other vehicles like MAS 54151S, NETCENTS-2, Alliant 2, and SEWP V were found to be either too limited in scope or administratively burdensome.

Key Findings Relevant to Consolidation: Key findings from market research revealed that the EIS contract is uniquely positioned to support the FCC’s modernization goals, offering compliance with OMB mandates such as Zero Trust Architecture, IPv6, and TIC 3.0. The research also determined that a small business set-aside was not feasible due to limited responses and capabilities among small vendors. Only one small business, MetTel, responded to the RFI. Additionally, the EIS contract allows for vendor-managed services, eliminating the need for the FCC to manage or store equipment, which further supports operational efficiency.

Ultimately, the market research informed the decision to consolidate requirements under a single task order on the GSA EIS GWAC. This approach ensures a streamlined procurement process, reduces administrative burden, and aligns with federal modernization directives. It also enables the FCC to leverage a competitive environment among qualified vendors, ensuring best value and robust support for its IT transformation objectives.

2. Identification of Alternative Contracting Approaches (FAR 7.107-2(a)(2))

Alternatives Considered:

Maintaining Separate Contracts for Each Service This approach would entail issuing individual contracts for each component of the modernization effort, such as Software- Defined Wide Area Networking (SD-WAN), Unified Communications Services (UCS), Managed Network Services (MNS), and Managed Security Services (MSS). While this model could leverage the expertise of specialized vendors in each domain, it was ultimately deemed impractical due to the significant administrative overhead, increased coordination demands, and heightened risk of integration challenges. Managing multiple discrete contracts would also impede the FCC’s ability to deploy a cohesive, secure, and scalable IT infrastructure aligned with its modernization goals.

Grouping Services into Fewer, but Still Distinct, Contracts Under this model, services would be bundled into logical groupings (e.g., network services in one contract, security services in another). Although this would reduce the number of contracts compared to the fully separate model, it still posed challenges in terms of interoperability, contract management, and ensuring consistent performance standards across vendors. The FCC determined that this approach would not sufficiently streamline operations or support the end-to-end modernization goals of the initiative.

Using Multiple Award Contracts with Set-Asides This strategy would involve leveraging multiple award contracts with small business set-asides to encourage competition and meet socioeconomic goals. However, market research revealed that only one small business (MetTel) responded to the RFI, and others lacked the technical capability to deliver SD-WAN and related services. As a result, the FCC concluded that there were not at least two capable small businesses to justify a set-aside, making this approach nonviable for meeting the agency’s technical and performance requirements.

Each of these alternatives was carefully evaluated and ultimately set aside in favor of a consolidated approach using a single task order under the GSA EIS contract. This decision was based on the need for operational efficiency, reduced procurement risk, and alignment with federal mandates for IT modernization and cybersecurity.

Reason for Non-Selection of Alternatives: As part of the FCC’s market research for the OCIO Managed Services Modernization Initiative, several federal contract vehicles were evaluated to determine their suitability for supporting the agency’s transition to modern IT infrastructure. The primary alternative considered was the GSA Multiple Award Schedule (MAS) 54151S, which offers a broad range of IT professional services. However, it was found to lack the depth in telecommunications services required for the FCC’s needs.

The NETCENTS-2 contract, primarily used by the Department of Defense, was also reviewed but deemed administratively burdensome due to its decentralized ordering process and pre-approval requirements. The Alliant 2 GWAC was considered for its IT service offerings, but only a small subset of vendors specialized in telecommunications, and none were active on EIS task orders. NASA’s SEWP V was also examined but found to be hardware-focused and near expiration, posing risks of service disruption.

Ultimately, the GSA Enterprise Infrastructure Solutions (EIS) contract was selected as the only vehicle that fully met the FCC’s technical, operational, and compliance requirements. It supports a wide range of managed services, aligns with federal mandates (e.g., Zero Trust, IPv6, TIC 3.0), and offers the flexibility and vendor pool necessary for a successful modernization effort. This comprehensive evaluation of alternatives confirmed that EIS was the optimal choice for consolidating the FCC’s requirements under a single task order.

The Office of Management and Budget (OMB) have designated the EIS Contract as Best-in- Class and considers this a high-performing, and preferred solution designed to streamline the procurement process, reduce administrative costs, increase transparency, and leverage the government's buying power.

Further, Memorandum M-25-31 dated July 18, 2025, the OMB Director issued guidance to support increased use of centralized contracts. Notably, the guidance announces that the Federal Acquisition Regulation (FAR), which currently encourages agencies’ use of existing government-wide contracts, will be amended to require that agencies “must use the existing contract vehicle instead of awarding a separate new contract” to procure commercial products or services meeting the agency’s requirements, absent an exception.

3. Coordination with the FCC Office of Small Business Programs (FAR 7.107-2(a)(3))

• Date(s) of Coordination: 10/22/2025

• Small Business Programs Representative: Susan L. Nicholson, FCC Small Business Advisor

• Summary of Coordination and Feedback: I have reviewed the FCC’s requirement and support the procurement strategy by issuing a task order to use the GSA Best In Class, EIS Contract which demonstrates a number of benefits as the author has identified in this document. Further, this effort is a migration to a different business model in which current services procured will become obsolete. The current contracts would no longer be used to support FCC’s required services, nor are they not being reprocured as a single contract under the modernization effort. These are the facts as presented as I understand them.

4. Identification of Negative Impact on Small Business Concerns (FAR 7.107-2(a)(4))

Potential Negative Impact: Market research revealed that only one small business, MetTel, responded to the Request for Information (RFI), and no other small businesses demonstrated the technical capability to deliver the full scope of services required, particularly in areas like SD-WAN implementation and managed security services. This lack of sufficient small business participation led to the conclusion that a small business set-aside was not feasible.

As a result, aggregating the requirement into a single, large-scale contract may limit the ability of small businesses to compete directly for the prime contract. It also reduces the likelihood of awarding multiple smaller contracts that could have been more accessible to niche or specialized small business vendors. Additionally, the use of a single task order under a large GWAC like EIS inherently favors vendors with the scale and infrastructure to manage complex, integrated service delivery—capabilities that many small businesses may not possess.

While subcontracting opportunities may still exist within the larger contract, the direct impact is a decrease in the number of small business prime contractors and fewer opportunities for specific small business categories to participate meaningfully in the procurement.

Quantification (if feasible): Currently, at least 7 small businesses are serving as prime contractors across various task orders and miscellaneous obligations. It should be noted that these contracts will not continue, nor will the work be performed under these contracts be continuing under the modernization effort. It will become obsolete upon award of the EIS contract. These include:

• MetTel – Local Telecommunications Services

• Contract 273FCC20F0164 ($264,557.23)

• UEI: C5D6CL7CMPH5

• Chenega – VoIP and Audio Conference Support

• Contract: 273FCC24C0008 (

• UEI: F22YM6F7WNH2

• Evoke Research and Consulting – Network Operations

• Contract: 273FCC23F0062 (

• UEI: E3HENZDGJQ85

• GOVSMART INC – F5 Load Balancers

• Contract: 273FCC22F0155 (

• UEI: DJACUETFQUL8

• Thundercat Technologies – F5 Load Balancers (2nd order)

• Contract: 273FCC22F0162 (

• UEI: UER4AJLUB8D5

• DH Technologies – SSL Certificates and reCAPTCHA Subscription

• Contract: 273FCC25F0001 (

• Contract: 273FCC24F0020 (

• EUI: NKC2AB3ESFP5

• 4 Star Technologies – CIS SecureSuite Membership

• Contract: 273FCC24F0054 (

• UEI: UYLVJZ49BFC6

Under the proposed strategy, again, these services will become obsolete. New services will be provided by a single task order under the GSA Best-In-Class EIS II contract, under the EIS vendors. As a result, the number of small business prime contract opportunities could drop from 7 to 0.

While subcontracting opportunities may still exist, the shift from multiple small business primes to a single large business prime significantly reduces direct access for small businesses to federal contracting dollars and decision-making authority. This change may also limit the FCC’s ability to meet certain small business participation goals unless proactive subcontracting plans are enforced.

5. Steps Taken to Include Small Business Concerns in the Acquisition Strategy (FAR 7.107- 2(a)(5))

Mitigation Strategies: To ensure maximum practicable small business participation under the EIS II acquisition strategy, even though the requirement is not set aside exclusively for small businesses, the FCC implemented several deliberate and inclusive steps.

First, the FCC conducted comprehensive market research in accordance with FAR Part 10, including issuing a Request for Information (RFI) and hosting an Industry Day. These engagements were designed to assess the capabilities of small business vendors and gather feedback on the feasibility of meeting the full scope of the OCIO Managed Services Modernization Initiative. Although only one small business (MetTel) responded to the RFI and others, such as Core Technologies, Inc., did not demonstrate relevant SD-WAN experience, the FCC used this data to make an informed determination that a small business set-aside was not practicable.

To mitigate the impact of this determination, the FCC structured the procurement to be competed under the GSA EIS Governmentwide Acquisition Contract (GWAC), which includes both large and small business vendors. This ensures that qualified small businesses still have a meaningful opportunity to compete under fair opportunity guidelines. Additionally, by consolidating requirements into a single task order, the FCC reduces the administrative burden and complexity that can disproportionately affect small businesses, making it easier for them to understand and respond to the solicitation.

These steps reflect a balanced approach that prioritizes mission-critical performance while actively seeking to include small business concerns wherever feasible. The strategy aligns with federal acquisition policy by promoting competition, transparency, and inclusivity, even under circumstances where a formal set-aside is not justified.

Expected Small Business Participation: Under the merged EIS II approach, the expected level of small business participation is shaped by both the structure of the GSA EIS contract and the FCC’s inclusive acquisition strategy. While the requirement is not set aside exclusively for small businesses due to insufficient market capacity, only one small business (MetTel) responded to the RFI with relevant capabilities, the strategy still ensures that qualified small businesses can compete under fair opportunity guidelines. The EIS contract vehicle includes both large and small business vendors, and the FCC’s decision to compete the requirement among the full pool of EIS GWAC vendors allows capable small businesses to participate directly or through teaming arrangements.

Moreover, the FCC’s market research and industry engagement efforts, including the RFI and Industry Day, were designed to identify and encourage small business involvement.

Although the technical scope of the requirement, particularly the need for SD-WAN, managed security, and unified communications services, limits the number of small businesses that can independently fulfill the contract, the structure of the task order and the use of a single, streamlined procurement vehicle reduce barriers to entry. This creates opportunities for small businesses to contribute as subcontractors or niche providers within a larger integrated solution. In this way, the strategy balances mission-critical performance with the federal objective of maximizing small business participation to the greatest extent practicable.

IV. Necessity and Justification for Consolidation (FAR 7.107-2(b) and (c))

The merger of these requirements is determined to be necessary and justified because the benefits of this acquisition substantially exceed the benefits that would be derived from each of the alternative contracting approaches identified under paragraph (a)(2) of FAR 7.107-2.

A. Substantial Benefits (FAR 7.107-2(c))

The following benefits are anticipated from this consolidation:

Cost Savings or Price Reduction: The anticipated cost savings over the life of the EIS II contract are conservatively estimated at approximately $14.3 million, . This estimate is based on a comparison between the projected total expenditure under the new contract and the combined costs of maintaining existing services along with the necessary transition investments.

). The most significant cost reduction is expected in Year 4 once the transition to the new solution is fully implemented. At that point, the annual cost is projected to drop by approximately compared to the annual baseline cost, reflecting the full impact of service modernization, reduced administrative overhead, and optimized resource utilization. These savings are primarily driven by consolidating services under a single provider, which enables economies of scale, reduces administrative overhead, and improves operational efficiency. Additionally, the adoption of modern technologies such as software-defined networking and cloud-based communications contributes to more optimized resource allocation and long-term cost avoidance.

Quality Improvements: C Modernization under the EIS II initiative is set to improve service quality, performance, and efficiency across the FCC’s IT infrastructure. Transitioning to a single task order and a fully vendor-managed model streamlines operations, eliminates contract fragmentation, and centralizes accountability for service delivery. With SD-WAN, Managed Network Services (MNS), and Managed Security Services (MSS), the FCC gains advanced QoS features such as dynamic traffic prioritization, real-time visibility, and automated threat response, enhancing network performance, security, and resilience. IP-based and serverless technologies reduce the physical footprint and maintenance burden, while centralized management supports a self-healing, scalable architecture. These enhancements align with federal mandates like Zero Trust and TIC 3.0, ensuring compliance and delivering a secure, high-performing, and agile IT environment.

Reduction in Acquisition Cycle Times: Consolidation under the EIS II initiative is expected to significantly shorten the time required for future procurements and overall project execution by streamlining acquisition processes and reducing administrative complexity. By issuing a single task order under the GSA EIS GWAC, the FCC eliminates the need to manage multiple overlapping contracts, which historically introduced delays due to fragmented responsibilities and redundant procurement cycles. Lessons learned from the NLRB’s experience, where over 150 industry questions and multiple rounds of Q&A extended the procurement timeline by 12 months, highlight the value of early industry engagement and simplified contract structures. The FCC’s approach incorporates these lessons by consolidating requirements and leveraging a vendor-managed service model, which minimizes the need for government oversight of equipment and service provisioning. This not only accelerates deployment but also reduces the burden on internal resources.

Additionally, the use of pre-vetted vendors under the EIS contract expedites the solicitation and award process, while centralized management and automation further compress execution timelines by enabling faster provisioning, real-time monitoring, and self-healing network capabilities.

Better Terms and Conditions: The EIS II contract introduces several specific improvements to contract terms and conditions that enhance operational clarity, accountability, and efficiency. One major enhancement is the shift to a fully vendor-managed service model, where the contractor retains ownership and responsibility for all equipment throughout the contract period. This eliminates the need for the FCC to manage, store, or maintain hardware, streamlining logistics and reducing administrative burden. The contract also clearly defines the vendor’s accountability for end-to-end service delivery including planning, implementation, provisioning, and performance assurance, supported by measurable service-level agreements (SLAs). Additionally, the procurement is governed by FAR 16.505 procedures, which allow for more flexible and efficient task order issuance compared to FAR 8. The period of performance is structured to include a 36-month base, four 12-month options, and a 6-month extension, providing continuity and reducing the frequency of re-competition. Consolidating multiple contracts into a single task order simplifies oversight and aligns all services under a unified framework. Furthermore, the contract mandates fair opportunity among all EIS GWAC vendors, ensuring competitive pricing and innovation while avoiding unnecessary limitations such as small business set-asides when not supported by market capacity. These improvements collectively support a more agile, secure, and cost-effective modernization strategy.

Any Other Benefit: In addition to the previously discussed benefits, the EIS II initiative offers several other specific advantages. One key benefit is the elimination of the need for the FCC to take possession of or manage contractor-provided equipment. Under the fully vendor-

Operationally, the contract supports real-time visibility, automated compliance, and self-healing network capabilities, which can reduce incident response times from hours to minutes. The integration of advanced cybersecurity features, such as quantum encryption and automated threat response, enhances the FCC’s ability to defend against the 20 million monthly threats it faces. Centralized management and dynamic access controls also enable secure, seamless operations across multi-cloud and edge environments, supporting a distributed workforce without compromising security. These improvements collectively reduce downtime, improve service reliability, and ensure compliance with federal mandates like Zero Trust Architecture and TIC 3.0, all of which contribute to a more resilient and future-ready IT environment.

3. Administrative/Personnel Cost Reduction (FAR 7.107-2(d)(3))

Is reduction of administrative or personnel costs the sole justification? [No]

Administrative and personnel cost reduction is one of several important benefits of the EIS II initiative, but it is not the sole justification for the program. The initiative also delivers substantial non-monetary advantages that directly support the FCC’s mission and operational resilience. These include improved service quality through vendor accountability, enhanced network performance via SD-WAN and managed services, and strengthened cybersecurity through zero trust architecture, quantum encryption, and automated threat response. The shift to a vendor-managed model also relieves the FCC of equipment management responsibilities, allowing internal staff to focus on strategic priorities. These combined benefits, spanning security, efficiency, scalability, and compliance, demonstrate that the value of EIS II extends well beyond cost savings alone. V.

Mission Critical Exception (FAR 7.107-2(e)) - Select if applicable, otherwise remove this section.

Notwithstanding the above, the approving authority identified below determines that consolidation is necessary and justified because:

Expected benefits do not meet the thresholds for a substantial benefit at paragraph (d)(1) of this section BUT are critical to the agency's mission success. A single task order under the EIS II initiative is critical to mission success, even though it may not meet traditional financial thresholds for cost justification. The primary value lies in its ability to ensure operational continuity, security, and modernization at a scale and speed that fragmented contracting cannot support. Without a single task order, the FCC would face significant delays and inefficiencies due to the need to manage multiple overlapping contracts, each with its own terms, vendors, and performance metrics. This fragmentation increases the risk of service gaps, inconsistent security postures, and misaligned modernization timelines.

For example, the National Labor Relations Board (NLRB) experienced a 12-month delay in deploying its SD-WAN solution due to an overwhelming number of industry questions and a lack of streamlined procurement. The FCC learned from this and recognized that issuing a single task order under EIS II would avoid similar pitfalls by simplifying vendor engagement and reducing administrative burden. Failure to consolidate would also hinder the FCC’s ability to implement Zero Trust Architecture, automate threat response, and eliminate legacy systems, all of which are essential to securing the agency’s network against the 20 million monthly threats it faces.

Moreover, without a unified contract, the FCC would be unable to fully leverage centralized management, dynamic access controls, and self-healing network capabilities. These features are not just enhancements, they are foundational to supporting a distributed workforce, ensuring compliance with federal mandates, and maintaining uninterrupted mission-critical services. In short, a single task order is not merely a procurement strategy; it is a structural necessity for achieving the FCC’s modernization and cybersecurity objectives in a timely, secure, and coordinated manner.

The procurement strategy provides for maximum practicable participation by small business. The EIS II acquisition strategy ensures maximum practicable small business participation, even though the requirement is not being set aside exclusively for small businesses. The FCC conducted extensive market research, including issuing a Request for Information (RFI) and hosting an Industry Day, to assess the capabilities of small businesses in delivering the full scope of services required under the OCIO Managed Services Modernization Initiative. While only one small business, MetTel, responded to the RFI, and others like Core Technologies, Inc. did not demonstrate relevant SD-WAN experience, the FCC remains committed to inclusive competition.

To that end, the strategy leverages the GSA EIS Governmentwide Acquisition Contract (GWAC), which includes both large and small business vendors. By competing the requirement among the full pool of EIS vendors under fair opportunity guidelines, small businesses that are qualified and capable are not excluded from participation. This approach balances the need for technical capability and mission-critical performance with the federal objective of supporting small business engagement. Additionally, the use of a single task order under EIS simplifies the acquisition process, making it more accessible for small businesses to understand and respond to, compared to managing multiple fragmented solicitations. This inclusive yet performance-driven strategy ensures that small businesses have a meaningful opportunity to compete while safeguarding the FCC’s ability to meet its modernization and security objectives.

VI. Determination

Based on market research, analysis of alternative contracting approaches, coordination with the Office of Small Business Programs, identification of potential small business impacts and mitigation strategies, and the comprehensive assessment of benefits, I hereby determine that the consolidation of requirements for Enterprise Infrastructure Solutions (EIS) II Managed Services is necessary and justified in accordance with FAR 7.107-2. The benefits of this acquisition substantially exceed those derived from alternative contracting approaches, and steps have been taken to ensure maximum practicable participation by small business concerns.

VII. Approvals

Senior Procurement Executive (SPE) / Chief Acquisition Officer (CAO)

, Senior Procurement Executive (SPE), Federal Communications Commission, Enterprise Acquisition Center (EAC)

Coordination with Office of Small Disadvantaged Business Utilization (OSDBU) / Office of Small Business Programs (OSBP)

, FCC Small Business Specialist,

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