Redacted_CCaR_II_JA.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

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NOTE: If a Justification and Approval was approved for the preceding acquisition, a copy of the approved J&A for the predecessor action must be included in the staff package for approval of the instant J&A. This applies to J&A staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor J&A will be used as a reference document by the approving official.

Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )

Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan? Yes No

Funding level for this acquisition: < $700K > $700K and < $13.5M > $13.5M and < $93M > $93M

Contracting Activity: AFTC/PZIE

Purchase Request / Local ID Number: FA2487-18-R-0056

Program / Project (and PE, if applicable): COMPREHENSIVE COST AND REQUIREMENTS (CCaR™) SYSTEM SUPPORT II

Program Type (PEO or Other Contracting): Other Contracting

Authority: 6.302-1 – 10 USC 2304(c)(1), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

Estimated Contract Cost (including options): $9,998,334.06 J&A Type: Class Individual

COORDINATION (AFFARS 5306.304(a) )

APPROVAL (AFFARS 5306.304(a) )

Date

18 Sep 2018

Competition Advocate

KATHERINE B. HODGES

AFLCMC/PK OL Eglin / (850) 882-0150

Signature

HODGES.KATHERINE.B.

1230368038

Digitally signed by

HODGES.KATHERINE.B.1230368038

Date: 2018.09.18 15:09:16 -05'00'

(b) (6)

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I. Contracting Activity.

AFMC, Air Force Test Center (AFTC), Specialized Contracting Branch (PZIE), Eglin AFB, FL is responsible for the proposed contracting action.

II. Nature and/or description of the action being processed.

The proposed contract action will be awarded as a Firm Fixed Price (FFP) type contract to ensure uninterrupted deployment and sustainment support of the Comprehensive Cost and Requirements (CCaR™) system. The contractor will be Integrated Data Services (IDS), Inc., 2141 Rosecrans Ave., Suite 2050, El Segundo, CA 90245-4733, Cage Code: 1GWD4.

III. Description of supplies/services required to meet agency needs.

The Comprehensive Cost and Requirement (CCaR™) System is an automated requirement management system which assists program and financial managers in planning, budgeting, and execution of those requirements. CCaR™ interfaces with a variety of Department of Defense (DOD) financial software tools including:

- Automated Business Services System (ABSS)

- General Accounting and Finance System (GAFS/BQ/G2)

- Process Management Resource Tool (PMRT)

- Specialized Accounting and Finance Enterprise System (SAFES)

- Defense Enterprise Accounting and Management System (DEAMS)

- Local Contract Writing System(s)

CCaR™ creates a central repository of requirement, cost, and budget information - reducing the time required to review, manage, program, and execute financial resources as well as standardizing the formats used across multiple organizations for these efforts. Additionally, the system is mandated for use by Air Force Material Command (AFMC) for all financial information and is used by their staff to review execution and other related subjects versus tasking calls to users locally.

Because of the complexity of the CCaR™ System these following positions are required to support organizations in funding, planning, execution, and reporting requirements within organizations and at higher headquarters. These positions will also provide functional and administrative expertise, and train personnel to adapt and maintain business processes:

- Experienced CCaR™ Business Analysts (BA)

- Experienced CCaR™ Database Administrator (DBA)

The Experienced CCaR™ personnel listed above will provide support to the following organizations including any geographically separated units:

- Air Force Life Cycle Management Center Other Locations (AFLCMC/OL) Staffs at Eglin AFB, FL

- Air Force Life Cycle Management Center Armament Directorate (AFLCMC/EB), Eglin AFB, FL

- Foreign Military Sales within Armament Directorate (AFLCMC/EB), Eglin AFB, FL

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- Foreign Military Sales within Armament Directorate (AFLCMC/EBH), Hill AFB, UT

- Air Force Test Center 96th Test Wing (AFTC/96 TW), Eglin AFB, FL

- Air Force Material Command A3F (AFMC/A3F), Wright-Patterson AFB, OH

- Air Force Research Laboratory Munitions Directorate (AFRL/RW), Eglin AFB, FL

PERIOD OF PERFORMANCE: IGCE:

BASE YEAR:1 Oct 2018 to 30 Sep 2019 OPTION 1: 1 Oct 2019 to 30 Sep 2020 OPTION 2: 1 Oct 2020 to 30 Sep 2021 OPTION 3: 1 Oct 2021 to 30 Sep 2022 OPTION 4: 1 Oct 2022 to 30 Sep 2023

TOTAL: $9,998,334.06

Cost Estimate for Labor Categories applied across the CLINS (locations) as required POP: 1 Oct 2018 to 30 Sep 2023

FY19 FY20 FY21 FY22 FY23

Labor Cat. Hrs Cost Cost Cost Cost Cost

Funding for this requirement will come from several sources: Research, Development, Test and Evaluation (3600); Weapon Procurement (3010, 3011, 3020); Operation & Maintenance (3400); and Foreign Military Sales funds. The anticipated value of the contract is $9,998,334.06. The table above provides estimates for each CLIN over each year of the 5 year period of the contract.

This J&A covers more than one fiscal year's requirements because there are no feasible actions to be taken to develop future competition. The same issues described in Sections V, VI, and VIII below are expected to exist as long as CCaR™ system remains AFMC's exclusive command-wide requirements management tool for all financial management requirements.

IV. Statutory authority permitting other than full and open competition.

Statutory Authority 10 U.S.C. 2304(c)(1) as implemented by FAR 6.302-1(a)(2)(iii)(B), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, and required by FAR 6.303-2(b)(4).

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

Subsection 1

(b) (4)

(b) (4)

(b) (4)

(b) (4)

(b) (4)

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Comprehensive Cost and Requirements (CCaR™) system is a Commercial-off-the-Shelf (COTS) customizable enterprise system tailored to fit the way the Air Force does business - resulting in a highly specialized software program. This enterprise software product was created by and proprietary to the company Integrated Data Services, Inc. (IDS). IDS controls CCaR™ data rights and does not allow any other contractors access to their CCaR™ source code. Therefore all service contracts supporting CCaR™ must be awarded directly to IDS and the personnel involved in sustaining the system must have proper licenses issued by IDS to work with CCaR™. Personnel support is critical to CCaR™ functionality. In accordance with the Performance Work Statement (PWS) dated 8 Nov 2017 these experienced CCaR™ personnel provide program support, system integration, testing and installation, end-user training, data migration, consulting services, on-site support, metrics and feedback, coordination of system improvements, troubleshooting activities, resolve reconciliation issues, user account administration, customer service, running monthly reports, reporting database issues, and overall CCaR™ system support. IDS has provided CCaR™ service/support over the past 13 years via contracts FA9200-06-C-0264 (sole source); and FA2487-14-C-0015 (sole source). The proposed sole-source effort FA2487-18-C-0056 is for continued sustainment support based on IDS's sole-ownership of the CCaR™ source code. Since IDS owns all the base source code, it is the only vendor capable, qualified, and legally able to sustain the current baseline. Therefore, this acquisition will be a follow-on contract for continued performance of a highly specialized service.

Subsection 2 Award to any other source would result in unacceptable delays in fulfilling the agency's requirements.

Selecting another contractor would create a delay of at least 8 years. The new contractor would not be able to change source code required to run the application. Advanced report templates are licensed through a third party vendor via IDS. Since CCaR™ is proprietary software IDS will still maintain control of this privilege and any modifications. A new contractor would not be able to modify database elements because CCaR™ is proprietary software. CCaR™ is housed at US Army Acquisition Logistics and Technology Enterprise System and Services (ALTESS) and requires a BASTION host Citrix connection to the database servers which is limited to IDS personnel only.

BASTION host is the only means for modifying source code and troubleshooting support on database servers. Any contractor other than IDS cannot provide SME support without acquiring/developing another software application containing the same requirements and functionality present in CCaR™.

The only government option to gain control of the above support requirements would be to purchase full data rights to the software. There is no price associated with this purchase and IDS will not entertain negotiations to purchase its software. The result of selecting another contractor would be a loss of specialized corporate knowledge developed over 15 years of support of automated financial management, requirements management, tracking and reporting capabilities. Loss of the specialized knowledge would increase government workload and loss of efficiencies, which would divert a significant amount of already scarce organic FM and PM resources from other critical activities. The CCaR™ customer base within the AF does not have the manpower to be able to revert to accomplishing the support tasks which are currently being performed by IDS. If a new contractor was selected to do this work rather than IDS it is very likely that the Air Force would also have to procure or develop a new software tool to replace CCaR™.

An evaluation of the time/schedule involved with the development of new software to the capability levels currently in use would involve a contracting process to award to a vendor, the development and BETA testing of the software. Throughout development, links to other AF systems dependent upon IDS products to include CCaR™ would be required which includes multiple Financial Independent Audit Readiness aspects, as demanded by law for DoD/AF to have auditable financial statements by FY18. When you add the award, development and testing period of the vendor to the government's rigorous processes which include Developmental and Operational testing (estimated at 12 months);

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Cyber/Penetration testing (estimated at 4 months); a full risk management framework to support the Authority to Operate certification process (estimated at 12 months); JTIC certification (estimated at 8 months), the government faces another 3 years on top of development, none of which is in parallel but consecutively accomplished, to meet the financial management needs of the user. When you add several years for development, at least 3 years for the validation and verification as well as certification of system plus the final movement of over ten years worth of accumulated financial data at a detail, document by document level, by program, to the new system, you have added at least another 2 years to work through 11 divisions alone within EB x 2 months per division to move, arrange, ensure access of that data. There are also other customers beyond EB served by this contract: AFRL, AFTC organizations likely would require one more year for the data transfers. A total of approximately 8 years would be faced without ability to use CCaR™ today without the expertise required by the system owner. Mission impact with no accepted or supported software would be severe and drive a work stoppage without use of system by financial managers across organizations serviced by this contract.

Subsection 3 Accordingly, IDS Inc. is the only firm capable of providing the services described in Section III above without the Air Force experiencing unacceptable delays in fulfilling its requirements.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

In accordance with DFARS PGI 206.302-1, a Sources Sought announcement for this requirement was posted to Federal Business Opportunities (FedBizOpps) on 8 December 2017. It was posted as Comprehensive Cost and Requirements (CCaR™) System Support II, FA2487-18-R-0056. It included a description of the tasks for this contemplated requirements contract and a response date was established as 9 January 2018. The incumbent, IDS, responded with a capability matrix addressing the technical requirements of the pending acquisition (e.g.: financial capability, technical proficiency and experience of personnel, and CCaR™ certification).

This action will require a Notice of proposed Contract Action (NOCA) in accordance with FAR 5.201.

The NOCA is expected to be published on in the 3rd Quarter of FY18.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will ensure the final price will be fair and reasonable. Cost and price analysis will be performed in accordance with the FAR. The Government will use a traditional pricing approach to determine fairness and reasonableness using the following means: (1) technical evaluation; (2) cost analysis IAW FAR 15.404-1(b)&(c) of labor categories, labor rates, indirect costs (IDC), and other direct costs (ODC); and 3) utilization of weighted guidelines to determine profit.

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VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

As described in Section VI above, market research, in accordance with FAR Part 10, was conducted, advising industry of the pending acquisition and soliciting inquiries from interested parties.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

No other facts.

X. List of any sources that expressed, in writing, an interest in the acquisition.

None (See Section VI above).

XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required.

According to the last J&A (2014) it stated "because of the AFMC memorandum dated 23 June 2005 which mandates that AFLCMC/AFRL, EB and AFTC/96/TW use CCaR™, the opportunity for full and open competition is non-existent. IDS owns all intellectual property rights to the CCaR™ base source code. IDS developed the CCaR™ software source code and associated technical documentation at private expense. To date, IDS has refused all offers to purchase the CCAR™ source code."

The AFMC memo dated 23 June 2005 which was referenced as a mandate in the previous J&A is still current to date and has been incorporated into AFI 63-101/20-101 dated 9 May 2017. The only conceivable actions the government could take to make this acquisition competitive in the future would be to either purchase the source code from IDS or develop our own software. As of 20 June 2018 IDS remains firm on not selling the data rights to the government and as further explained above in Section V, Subsection II the time it would take to develop our own software would cause unacceptable delays.

We will continue to conduct market research to determine vendor capabilities in an effort to foster competition and seek to find vendors who can support all of the requirements. In addition, we will research and analyze the cost, security, and efficiency of alternatives such as web services, cloud services, and other operating systems as projects/deployments move forward.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.

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