F03_JA_Extension_LSJ_-Redacted_1.pdf

This action ensures that critical support to the OCIO will continue in the interim while the competitive follow-ons are being competed via GSA MAS and STARS III. POWTEC LLC is uniquely qualified to support the OCIO, as the incumbent, they have current system knowledge, access, and proper security clearances and have the capability to support this task with minimal disruption or schedule impact. The resources provided by this contract are vital to the Department’s mission of protecting DOI’s IT systems and data from security threats.

The development of the acquisition strategy for the competitive follow-on requirement experienced delays therefore requiring this extension. In addition, the follow-on requirement will be competitive instead of a directed award because the value of the requirement exceeds the 8(a) direct award threshold as the period of performance needs to be expanded. Awarding a bridge contract to a Contractor other than POWTEC LLC would result in additional time needed for hiring/onboarding staff and other transition related issues. OCIO anticipates 30 – 45 days of additional time for the transition. Furthermore, a transition for a short-term solution would be highly inefficient given that a second transition period would be required in the subsequent competitive acquisition for USAccess and Registrar services. Extending this task order would meet short-term requirement needs while the OCIO and AQD prepare to complete the follow-on actions.

If a break in service of the DOI Access Services and USAccess Registrar Services would occur, it would cause risks to all DOI bureaus, offices, approximately 80,000 active DOI Access Card holders, and other all Federal Agencies relying on the six DOI USAccess sites supported by the DOI contract Registrars.

USAccess Registrar Support is critical during the current seasonal hiring cycle and required by FIPS 201 to complete identity proofing activities for DOI and other Federal Agencies at six critical geographic locations across the country. These locations average 880 appointments a month, with 520 appointments servicing other Federal agencies.

DOI Access Services develop and maintain operational capability of the Department’s Enterprise Identity Management System. All DOI personnel identity accounts are created within DOIAccess during on-boarding, and DOIAccess manages the issuance and maintenance of all DOI Access Cards for over 80,000 personnel. Catastrophic failure occurs in the following areas when the system is not maintained: delays in on boarding all personnel (including critical seasonal hires), 100% stoppage of bureau transfers, delayed deprovisioning requests, and thousands of DOI Access Cards getting disabled causing the loss of access to the DOI network and systems. Protecting information systems and federal data are mission critical for the entire Federal Government. Leaving these systems and data vulnerable to attack is not an option.

Therefore, it is in the Government’s best interest to extend the current task order with the incumbent to avoid risk that OCIO does not meet their requirements under this task order.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

The Contracting Officer determined that the anticipated labor category rates will be fair and reasonable as MAS Contracts are competitively awarded. The labor mix and level of effort have been considered and the expectation is that the cost for the period from 07/01/2023 through 12/31/2023 will be the same as the last six months that are already under the task order. The Contracting Officer will separately seek discounts from the established schedule pricing and will conduct a thorough price evaluation prior to issuing the modification to ensure that the pricing is fair and reasonable. The Contracting Officer's price evaluation and analysis will be documented in the contract file. The documentation will also ensure the additional requirements under DOI- AAAP-0024 are addressed, specifically when only one offer is received.

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

Market research for the original task order found that the services required were commercially available and abundantly available through 8(a) small business vendors on GSA’s Multiple Award Schedule (MAS) 54151S and GSA’s STARS III contract vehicle. The market research for the original task order was completed 6/29/2022 and is still valid as the time between initial award and the addition of additional six (6) one-month option periods is so short that the additional market research is not needed for this extension.

7. Any other facts supporting the justification.

None.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

The work associated with this effort is a continuation of the work required to maintain continuity of operations. The need for this service is on-going and a re-competition is already underway. In order to facilitate a re-competition and to have a proper transition period, this short-term requirement is necessary to avoid a break in critical services.

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

I certify the technical data which forms a basis for this justification is complete and accurate and meet the Government’s minimum needs.

- Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.