Eustis JA 2021_03_Redacted_Final.pdf

Control No: Eustis-2021-3 Contractor: Booz Allen Hamilton, Inc.

Program: FCC ExD Support

Version – September 2018 FOR OFFICIAL USE ONLY

JUSTIFICATION REVIEW DOCUMENT

FAR PART 16 EXCEPTION TO FAIR OPPORTUNITY JUSTIFICATION

For Actions Exceeding the Simplified Acquisition Threshold (SAT)

Program/Equipment: Futures and Concepts Center (FCC) Experimentation Division (ExD) formerly known as Studies and Analyses Division (S&AD) Mission Support Services, Fort Eustis, Virginia. ExD requires contractor support services to provide cost and effectiveness analysis in the form of Cost-Benefit Analyses (C-BA), Business Case Analyses (BCA), and Analyses of Alternatives (AoA) for the FCC at AFC’s Centers of Excellence (CoE).

Authority: 10 U.S.C. 2304c(b)(1) as implemented by FAR 16.505(b)(2)(i)(A) – The agency need for supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

Amount: $865,420.80

Prepared by:

Contracting Officer:

Technical:

Requirements:

Reviews: I have reviewed this justification and find it adequate to support an exception to fair opportunity.

Program Manager:

Signature: Date: See Digital Signature

$865,421

Program: FCC ExD Support

Version – September 2018 FOR OFFICIAL USE ONLY

Small Business Specialist, Small Business Program:

Signature:

MICC Office of Counsel:

Contracting Officer:

Director, MICC – Ft Eustis:

Assistant Director, Small Business Program:

Date: See Digital Signature

Date: See Digital Signature

Date: See Digital Signature

Program: FCC ExD Support

Version – September 2018 FOR OFFICIAL USE ONLY

FAR Part 16 Exception to Fair Opportunity Justification Under Multiple Award Indefinite Delivery Contracts

For Actions Exceeding the Simplified Acquisition Threshold (SAT)

1. Contracting Activity: U.S. Army Mission and Installation Contracting Command (MICC)-Fort Eustis, 705 Washington Avenue, Fort Eustis, Virginia 23604

2. Description of Action: Futures and Concepts Center (FCC) requests a firm-fixed price (FFP) task order with Booz Allen Hamilton (BAH) Inc. located at 8283 Greensboro Drive, McLean, VA 22102-3830 for a base period of six (6) months and six (6) one-month option periods in order to maintain continuity of services. This bridge will cover the period between the end of a current services task order (W911S0-15-D-0001 – W911S0-18-F-0067) and the beginning of new competitive Indefinite Delivery Indefinite Quantity (IDIQ) Multiple Award Task Order Contract (MATOC) planned for award in June 2021.The Government projects award for December 2020 using FY 21 Operations and Maintenance funds. The current MATOC expired on 18 June 2020. No new orders could be placed after this date, and all existing order deliveries cannot exceed 18 December 2020. There are no options to exercise or additional extensions available.

Therefore, to avoid unacceptable delays in service until the new MATOC is competitively awarded, a bridge task order is required. The General Services Administration (GSA) One Acquisition Solution for Integrated Services (OASIS) Unrestricted Pool 1 will be used. An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d)(i)(B).

3. Description of Supplies/Services: One of the leading organizations helping the Army prepare for current and future warfighting challenges is the Futures Concepts Command (FCC), a subordinate organization of Army Futures Command (AFC). The mission of the FCC is to develop, evaluate, and integrate warfighting concepts, requirements and solutions for the Army across the domains of Doctrine, Organization, Training, Materiel, Leader development, Personnel, and Facilities (DOTMLPF) to provide soldiers and units the capabilities they need to support Combatant Commanders' operations in a Joint, interagency, intergovernmental and multi-national (JIIM) environment. The successful development and integration of DOTMLPF solutions by the FCC is essential to improving the survivability and lethality of Army soldiers and their warfighting capabilities. The purpose of this effort is to obtain the necessary technical services and expertise to enable FCC to meet its mission requirement to support the Experimentation Division (ExD). The support includes conducting Cost- Benefit Analyses (C-BA), Business Case Analyses (BCA), and Analyses of Alternatives (AoA). It also includes technical services to identify, describe, and quantify the benefits and costs associated with each proposed warfighting capability. This effort provides decision makers with facts, data, and analysis required to make informed decisions. The primary emphasis of the support effort will be on the quality control review of C-BAs, C- BA development and assistance, and cost and benefit/effectiveness analysis support for AoAs and BCAs. Specific tasks included in the Performance Work Statement (PWS) comprise C-BA support, Analysis of Alternatives support; Business Case Analysis support; Critical Review of Cost Benefit Analysis support; Staffing and presentation of analysis support; analytic best practices support; Army Experiment & Studies Information System Support; and C-BA Training support. The estimated price for this bridge contract is $865,420.80 with a Period of Performance from 19 December 2020 to 18 December 2021.

Period of Performance Base Period: 19 Dec 20 to 18 Jun 21 Value: $432,710.40 Option Period 1: 19 Jun 21 to 18 Jul 21 Value: $ 72,118.40 Option Period 2: 19 Jul 21 to 18 Aug 21 Value: $ 72,118.40 Option Period 3: 19 Aug 21 to 18 Sep 21 Value: $ 72,118.40 Option Period 4: 19 Sep 21 to 18 Oct 21 Value: $ 72,118.40 Option Period 5: 19 Oct 21 to 18 Nov 21 Value: $ 72,118.40 Option Period 6: 19 Nov 21 to 18 Dec 21 Value: $ 72,118.40

Total Value: $865,420.80

4. Authority Cited: This action is authorized under provisions of 10 U.S.C. 2304c(b)(1) as implemented by FAR 16.505(b)(2)(i)(A) – The agency need for supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

5. Reason for Authority Cited:

a. With the impending lapse in services described above in paragraph two (2), proposed acquisition must be accomplished through an exception to fair opportunity for the reasons stated the paragraphs below.

1) The new IDIQ MATOC (ref. Solicitation W911S0-19-R-0002) is not yet awarded due to delays caused by the changing and evolving mission of the FCC as well as changes in their internal personnel assigned to the re-compete of this requirement.

2) The planning for the new MATOC has been ongoing for at least two (2) years.

A procurement of this magnitude would take approximately two (2) years to complete under normal circumstances. During the last two (2) years, the procurement was encumbered due the mandated transition of Army Capabilities Integration Center (ARCIC) to FCC that created turbulence in the timely development of the requirement.

The transition resulted in organizational changes in the Army Futures Command and personnel moves that contributed to delays as the new organization shifted personnel to new positions. The personnel new to the requirement process required time to become familiar with the requirement. Mandatory telework in 2020 also hampered progress of the MATOC award to a minor degree. The impact is that the new MATOC award will not be in place before the current task orders expire creating a lapse in critical services required by the agency.

3) There is insufficient time and resources available to award a bridge task order on a competitive basis without further delaying award of the follow-on contract.

4) Until it is awarded, these vital services must continue without delay or lapse in service. The bridge requirement is necessary to facilitate the competitive award of the new MATOC anticipated in June 2021.

5) ExD utilized the services of BAH to ensure successful delivery of its mission requirements of enabling the FCC to conduct C-BA, Business Case BCA, and AoA across all domains in order to support Army modernization. The ExD’s mission is highly leveraged with contractor support. The ExDs’s non-military workforce consists of three

(3) government employees and seven (7) BAH employees. This level of reliance on highly technical contractor support makes their work no-fail and hard to replace rapidly.

BAH was awarded the current task order competing with all other IDIQ MATOC holders using fair opportunity procedures. BAH was awarded the current task order because of its unique and highly specialized services required by the ExD. As the incumbent, BAH already employs the proper individuals necessary to continue performance without delay or lapse. This makes BAH the only source available to immediately fulfill this urgent need without undue delay; therefore, the exception to fair opportunity under 10 U.S.C. 2304c(b)(1) applies.

6) The incumbent, BAH, is currently satisfying the Army’s mission for these complex services listed in paragraph 3 above. BAH is the only responsible contractor that can satisfy the Army’s requirement during this interim period. The services performed by BAH are essential to the successful execution of the ExD mission and a priority for the Chief of Staff of the Army’s readiness initiatives. Any disruptions in the performance of this critical training program could result in gaps in defense knowledge and skills or adversely affect readiness. BAH is the only offeror with the necessary manpower, resources, and proven technical proficiency to perform these mission critical services during the bridge period because of the complexity and integrated nature of the ongoing and upcoming exercises and the size of its supporting staff.

7) This bridge extension provides the needed time to procure these services in a timely manner, without a break in service, at a price that is fair and reasonable. The skill sets required to support the ExD effort are complex in nature and deemed hard to fill.

Because BAH currently employs these individuals and, as the incumbent, is familiar with the requirements, BAH can continue performance under a new task order without a lapse in service or a phase-in period. The use of fair opportunity will create unacceptable delays and cause disruption to the services being performed to support the ExD mission. Awarding with fair opportunity procedures will reach beyond the end of the current task order period of performance creating an unacceptable gap in service.

8) The required performance delivery schedule ensures the bridge requirement is only as long as necessary in order to award the new MATOC. The base period of performance is 19 December 2020 through 18 June 2021. Additionally, there are six (6) one-month options in the event the competitive MATOC is not awarded as projected.

9) The previous task order was competed among all three (3) IDIQ MATOC holders. BAH provided a proposal that satisfied the Government’s requirements and placed the least risk on the Government. Its technical approach, key personnel, integrated management and execution of the mission can be applied to this bridge task order to seamlessly and urgently and provide this knowledge and expertise during the bridge support.

10) The ExD’s workload requirements are subject to fluctuation. A contractor must be able to successfully manage these conditions and ensure that requirements can be supported without delay as they arise. There are no other Government agencies buying these same services.

b. Alternatives

1) Forgo Services. Forgoing services is not a viable alternative. This would result in a significant disruption of providing cost and effectiveness analysis. FCC would be unable to complete the analytical rigor to identify, describe, and quantify the benefits and costs associated with each proposed warfighting capability, resulting in mission failure for this critical FCC service, as well as disrupting normal operations.

2) Use of Government Resources. Currently there are no available Government personnel (military or civilian) on-hand able to supplement this work with the experience required to execute the tasks in the mission-oriented tasks contained throughout the PWS. The organization does not have the capability to in-source personnel to meet mission requirements without a break in operational support. The Table of Distribution and Allowances (TDA) provides for adequate oversight and management of the contract effort, but lacks personnel with the requisite skill sets to execute the tasks outlined in the

PWS.

3) Re-competing a new bridge contract effort. Conducting a limited competition would be costly and create operational risk if the task order was awarded to another company other than BAH. A vendor other than the incumbent would have to learn how the FCC conducts business while simultaneously conducting the prioritization, integration, and synchronization of DOTMLPF capabilities developments. Competing the bridge task order and transitioning to a new contractor under that compressed timeline creates significant operational risk and increases the possibility that JMC will experience disruptions in the performance of these essential knowledge management functions, mission command decision-making functions, and oversight functions vital to its mission execution. Even if it were possible to compete the bridge task order, doing so would result in the award of an order with such an abbreviated performance period that the likelihood of receiving proposals is low because of the time necessary to compete the order (two months) and then phase-in a new contractor (two months).

c. Verified Minimum and Need. The minimum requirement includes of all tasks in the PWS until the new MATOC is awarded in 2021. The current services will continue until 18 December 2020. The Government requires a six (6) month base period with six (6) one-month optional periods of performance. This performance period is the minimum time needed to sufficiently provide services until the new MATOC is awarded. It will provide for a continuation of services through 18 December 2021. This extension will provide the needed time in order to award a contract that is fair and reasonable and provides adequate fair opportunity.

d. Considerations for using one source. Time available versus time required, phase-in/phase-out time, and the complexity of the requirement were considered in the decision to solicit only to one source. The time available to procure new services is not adequate to obtain both required FCC approvals, Government Procurement approvals, and solicit and award a new contract. Additionally, competing the extension and transitioning to a new contractor under that compressed timeline will create significant operational risk and enhances the possibility that ExD will experience disruptions in the performance of essential knowledge management functions, mission command decision-making functions and the ability to perform oversight functions vital to mission execution.

e. Interim Contract Cost. This is an interim task order with BAH. It would be neither cost effective nor realistic to expect another Contractor to perform during the brief interim period. A new contractor will experience manning problems including recruitment and associated relocation fees; continuity of service, variety and complexity of requirements; and preparation of management plans.

f. Interim Contract Requirement. This is an interim task order required until award of a follow-on service contract. The anticipated award of the follow-on contract is June 2021. Currently, there is no protest associated with this interim contract request.

g. Impact. The impact of not awarding a bridge contract would result in a lapse of service or work stoppage. If there is a lapse in the services being provided by BAH, ExD’s ability to fulfill its mission requirements for FCC would be placed in jeopardy, impacting FCC’s ability to accomplish its overall mission to the Army. ExD relies on BAH to perform the mission critical tasks in the PWS that support their mission requirements from FCC. No internal redundancy exists within ExD to take on the tasks performed by BAH. Therefore a lapse in service would mean the critical tasks in the PWS would not be performed and without those tasks being performed, the ExD’s and ultimately the FCC’s mission would not be accomplished. The bridge contract temporarily mitigates risks to mission success through continuing support until the ExD Mission Support Services work effort can be transitioned to the new FCC MATOC contract. For these reasons, upon review of this request and the authority cited above, a task order for one year is needed.

6. Actions to Increase Competition: In order to increase competition in the future, a new Multiple Award Task Order contract is currently being procured and will be awarded in calendar year 2021, which will provide fair opportunity among those contractors selected for the services. As the FCC is evolving, there may be changes to the way the services are provided as some of the tasks may be supported with a different task order in the future. MICC-Fort Eustis plans to issue a new competed task order following the award of the MATOC. No previous justifications exist for requirements performed under the current task order.

7. Market Research: Market research was conducted for this new task order in September 2020. Market research techniques included using the same NAICS code (541690), reviewing the procurement history, reviewing mandatory and preferred sources, and searching www.sam.gov and small business databases. Additionally, the market research for the MATOC re-compete included issuing a sources sought on 18 May 2018 and conducting an Industry Day on 7 May 2019. Eleven companies responded to the sources sought. One large business and one small business were deemed either fully or moderately capable of performing all task. The other nine vendors were not fully capable in all performance areas required to include capability development support, experimentation and evaluation support, synergy support, and information technology and information management support. The Industry Day resulted in significantly high participation. Both large and small businesses expressed interest in the procurement. The Industry Day determined the market has not changed since a Sources Sought was posted in 2018 and small businesses expressed interest in only performing a few of the task areas or seeking a teaming arrangement as a subcontractor. Small businesses do not have the capability to meet the specific and complex needs of the FCC, such as synergy support and experimentation and evaluation, to meet FCC’s mission and provide the required flexibility. While research shows the availability of multiple contractors who are capable of performing these services, this does not take into account the specialized nature of ExD services.

In July 2020, approval was received from OASIS to use the GSA OASIS Unrestricted Pool 1 contract to provide a seamless continuation of services to the FCC to provide a seamless continuation of services to the ExD until the new MATOC IDIQ contract (ref.

Solicitation W911S0-19-R-0002) is awarded.

A competitive award cannot be made without a break in service. There is not enough time to compete this action using fair opportunity procedures. The current task order expires on 18 December 2020 and competing a new task order will jeopardize the mission of FCC and cause mission failure. It would not be in the best interest of the Government to pursue a re-compete at this time. Furthermore, the requirements executed under the bridge task order are compatible with the scope of the OASIS contract vehicle.

8. Other Facts:

Procurement History: The current firm-fixed-price task order, W911S0-15-D-0001 – W911S0-18-F-0067, was awarded using fair opportunity procedures of FAR 16.505(b) within the ARCIC MATOC to BAH on 11 June 2018 in the amount of $2,598,177.17, for a base year plus two option years. The previous requirement, W911S0- 15-D-0001 – 0003, was also a firm-fixed-price task order and was awarded following fair opportunity under the ARCIC MATOC to BAH on 2 July 2015 for a base year and two option years.

Program: FCC ExD Support

Version – September 2018 FOR OFFICIAL USE ONLY

9. Technical/Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

10. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Signature:

11. Fair and Reasonable Price Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. The techniques identified at FAR 15.404-1(b)(2)(ii) and (v) will be used to ensure award will be at fair and reasonable prices. The Contracting Officer will use a comparison of proposed prices to pricing contained in the option periods and the IGCE. There is an anticipated service fee of 0.1% for using GSA OASIS. This determination will be made using price analysis. As a part of this basis, certified cost or pricing data will be required.

11. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

a

Approval

Based on the foregoing justification, I hereby approve the procurement of mission support services for Futures and Concepts Center (FCC) Experimentation Division (ExD) using an exception to fair opportunity pursuant to the authority of Title 10 United Stated Code Section 2304c(b)(1) as implemented by Federal Acquisition Regulation 16.505(b)(2)(i)(A) – The agency need for supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays. The estimated value of the task order is $865 thousand for a period of performance consisting of a base period of 6 months and 6 one-month option periods from 19 December 2020 through 18 December 2021. This approval is subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

SCOTT D. KUKES

Alternate Advocate for Competition U.S. Army Mission and Installation Contracting Command, JBSA Fort Sam Houston, TX