FOE_Redacted.pdf

'°'· FOR OFFICIAL USE ONLY

Justification for an Exception to Fair Opportunity rs this a brand name product justification? D Yes IZI No !fyes, please provide thefollow·1ng information.

Brand Name Product Title:

Brand Name Product Description:

1. Contracting Activity: AFLCMC/AZS

2. Purchase Request: FA8721-13-D-0002 0002

3. Program Name (and Program Element, if applicable): Professional Acquisition Support Services (PASS) II

4. Estimated Cost/Price of the Order (including options):

5. Type Program {see -~F_E~R£_S302J_Q_l for definitions): IZJ PEO Program 0 Other Contracting

6. Fair Opportunity Exception: f:_6_8__J_QdQ51QlGU.(Q, subparagraph

7. Type Determination: D Class lZJ Individual

Date

Date

Date

Program Manager

Contracting Officer

Local Legal Reviewer

Zo I I.rt 0 7 f r

Chief of the Contracting Office (COCO)

Competition Advocate

AFLCMC/PK/PZ

DIAi DIBI IZI ICJ

Signature

Signature

£;lick her~. to access the instructions for the boxes below.

(1) Contracting Activity:

DIDI DIEi

The contracting organization responsible for this Fair Opportunity Exception justification is Air Force Materiel Command (AFMC), Air Force Life Cycle Management Center (AFLCMC), Strategic Serv·1ces Division (AZS), 20 Schilling

Circle, Bldg.1305, 3rd Floor, Hanscom AFB, MA 01731. The Contracting Officer is Mr. David Giordano, (781} 225-1209 or DSN 845-1209. The Program Manager is Ms. Deborah Bibeau, (781} 225-1251 or DSN 845-1251.

FOR OFFICIAL USE ONLY Page1of5

FOR OFFICIAL USE ONLY

(2) Nature and/or description of the action being approved:

This proposed procurement is a modification to PASS II Contract FA8721-13-D-0002 0002, Strategic Warning & Surveillance Systems (SW&SS) Division (AFLCMC/HBQ) Task Order. This proposed procurement includes additional support to the Cost Plus Fixed Fee (CPFF) and Firm Fixed Prices (FFP) CLINs. This modification is adding additional scope that is required to avoid gaps in critical support services to the AFLCMC/HBQ programs. This additional effort includes the following work with a six (6) month PoP extension of 18 August 2016 - 17 February 2017, slated during during Option Year 1, which is 18 August 2016-17 August 2017.

- Program SSA OPS, Project ID 138 add PM, FM, Admin, Security, Data Management, and SME Support

- Program GLOBUS II, Project ID 1727 add PM Support

- Program GEODSS, Project ID 1046 add PM Support

The current T9sk Order amount is . The value of this FOE is bringing the total Task Order value to .

(3) Description ofthe supplies/services- required to meet the agency's needs:

PASS II is a mandatory strategic sourcing contract vehicle for A&AS support. AFLCMC/CC Policy Memo dated 30 Jul

2012, identifies the PASS II contracts as a subset of the mandatory use vehicles supporting all knowledge-based A&AS requirements at Hanscom AFB, and its Geographically Separated Units (GSUs). The PASS II program provides -a broad range of knowledge-based, non-engineering support. The support provided under PASS II includes non-personal Advisory and Assistance Services support to the program offices and functional staff at AFLCMC/Hanscom, GSUs, detachments and operating locations (including but not limited to locations inside the contiguous United States and outside the contiguous United States). The PASS II program provides support for the HBQ Division.

PASS II provides AFLCMC/Hanscom PEG-Directorates and Functional staff offices with a variety of non-engineering acquisition support capabilities which cannot be obtained from the Government's current and limited organic resources. The type of services being acquired under this program include but are not limited to a full spectrum of project management, financial management, administration, data management, and security assistance to system/ program activities across AFLCMC/Hanscom.

(4)_ Identification of the exception to fair opportunity and. the SlJpportlng .rationale:

The Exception to Fair Opportunity is IAW FAR 16.505(b){2)(i)(C). This action is being awarded on a sole source basis in the interest of economy and efficiency because it is a logical follow on to an order already issued under the PASS II

ID1Q. All IDIQ awardees were provided a fair opportunity to be considered for the Basic Task Order award which this action is modifying. The overall JDIQ ceiling for PASS ti is and the awarded ceiling for the HBQ task order was . Odyssey Systems Consulting Group, Ltd. is the contractor that was awarded the Basic Task

Order. This Task Order is for A&AS support to the HBQ division. As discussed below, the work logically follows the initial HBQ task order and it is in the interest of economy and efficiency to award the additional work to Odyssey since the costs associated with performing another fair opportunity are unlikely to be recovered through competition.

Logical Follow-On

The HBQ task order was competitively awarded on 19 Jun 2015 and performance started on 18 Aug 2015. This task order supports the A&AS needs of the SW&SS Division with a one-year base period and two one year options. Due to the nature of the acquisition of services currently being performed by Odyssey, it is in the best interest of the Government to issue this FOE on a sole source basis in the interest of economy and efficiency. The work included in

FOR OFFICIAL USE ONLY Page 2 of 5

""" FOR OFFICIAL USE ONLY '\

this FOE is a logical follow-on to tne initially awarded task order oecause it is acquiring the same type at A&AS support for the same programs during the same period of performance in the SW&SS Division. When offerers initially proposed on the HBQ task order, the programs requiring A&AS support were listed in the Performance Work Statement (PWS). As discussed in detail below, the additional work consists of the same labor categories proposed in the original task order solicitation (i.e., financial management, program management, administrative, data management). The PASS II acquisition strategy envisioned the task order awardee providing A&AS support at the Division level for the programs identified in the PWS. The work covered by this FOE is in the same programs and logically follows on the work originally awarded to Odyssey. SMC/SYG is transitioning to another contra_ct vehicle later than originally planned. Due to the delay, the current support on all associated programs needs to be extended so there will be no lapse in the warfighter efforts and overall mission of the organization.

Additional Costs

1. Award to any other contractor would likely result in substantial duplication of costs to the Government that is not expected to be recovered through competition

Re-competing the services currently being performed would result in substantial duplication of cost to the Government that is not expected to be recovered through competition. If the Government conducted a new fair opportunity and if a different contractor than the incumbent won the task order, there would be an inefficiency of costs during transition that would result in significant cost impacts to the Government. These costs exist because of the ramp-up time required for a potential new contractor to fully perform the requirements of the PWS in the HBQ division.

Additionally, there would be significant costs to the Government associated with an un-planned fair opportunity.

These costs include the following: time to develop the requirements, issue the solicitation, perform technical and cost evaluations, award the task order, and defend a protest at eitherthe Government Accountability Office or the Court of Federal Claims. The duplication of costs are estimated to be

2. Impractical to have two contractors in the division

PASS II envisioned awarding task orders at the division level ensuring that one contractor would perform the requirements of one division. It is impractical for the Government to carve out the additional work that was not originally competed and award that work under a new task order. If the incumbent contractor did not win the new task order for the additional work, it would be very impractical for two contractors to be working within the same division. The delineation of tasks to be provided by more than one PASS It contractor within a division would remove any economies and efficiencies that the original HBQ PASS II TO awardee could realize by performing all PASS II tasks within the division. From a program management perspective, it is unclear how any new work after the award of the task order associated with the incoming work would be apportioned if there were two contractors in the division. This is because the new contractor would be working on the same programs as the incumbent contractor and it would be extremely difficult to identify which contractor is responsible for which portion of the program. Having two contractors working on the same tasks would add a large degree of difficulty to the COR's duties (i.e., working with two

(2) Task Managers, completing two {2) different Surveillances and verifying the hours and work completed per contractor invoice, etc.). The additional overhead costs associated with having two contractors support one division as opposed to one contractor to the Government would not provide any savings that could be recovered from competing the effort.

3. Inefficient, costly, and a strain on the HBQ mission to have a fair opportunity for a 6-month contract extension Under PASS II, the fair opportunity task order awards have taken, on average, 11 months. The HBQ task order under PASS II was awarded on 19 June 2015. Since the requirements for this FOE are generally known, this period should be

FOR OFFICIAL USE ONLY Page 3 of 5 accurate for the 11-month estimate. This 11 months allows 2 montns to gather requirements and put the RFTOP together, 1 month for solicitation, 3 months for evaluation and task order award, 4 months for protest and re-award, and 1 month for phase-in and contract start. This amount of time exceeds the projected 6-month PoP extension for the SMC/SYG work while it awaits transition to the new contract vehicle. Therefore, it would be inefficient and costly to have an additional fair opportunity competition between now and the SMC/SYG transition off of PASS II.

(5) Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable:

The Government will obtain certified cost or pricing data from Odyssey systems Consulting Group, Ltd. and perform a comprehensive technical evaluation and cost/price analysis of the submitted proposals. The final contract cost will be negotiated in accordance with procedures in FAR Part 15, which will ensure the cost to the Government is fair and reasonable.

{6) Other facts supporting the justification:

Justification for each individual program requiring additional A&AS support is listed below:

Program SSA OPS, Project ID 138 add PM, FM, Admin, Security, Data Management, and SME Support Program GLOBUS II, Project ID 1727 add PM Support Program GEODSS, Project ID 1046 add PM Support

Justification:

SMC/SYG is transitioning to another contract vehicle later than originally planned. Due to the delay, the current support on all associated programs listed above need to be extended so there will be no lapse in the warfighter efforts and overall mission of the organization.

(7) A'c_tions the agency may take to remove or overcome any barriers to increasing faii" ,opportunity before an.Y stJbsequent acq_uisitioh for the supplies or services:

AFLCMC/AZS has taken all requisite approaches and maximized industry participation in the PASS ll competitive effort. PASS II is a total small business set~aside, multiple award IDIQ contract. Per Policy Memo, Guidance on the Mandatory Use of Advisory & Assistance Services (A&AS) Contract Vehicles (supersedes ESC/CC Policy Memo# 08-006, 20 Feb 08), dated 30 July 2012, issued by Lieutenant General C.D. Moore II, PASS II is a mandatory use and centrally managed contract vehicle.

There are (10) PASS 11 IDIQ contract holders. As of June 2016, there have been fifteen {lS) PASS II Task Order awards to six (6) separate small businesses (STAS Inc., Gemini Industries Inc., Quantech, P31, Odyssey Systems Consulting Group, Ltd., and Oasis Systems, LLC.). For each PASS IJ Task Order awarded, all JDIQ contract holders were provided a fair opportunity to submit offers.

The basic task order was competitively awarded on 19 June 2015 with performance beginning 18 August 2015. Given the recency of this competition, it would be inefficient to compete this new work within the same division. Jn addition, the acquisition strategy and the Basic IDIQstate that it is the Government's vision to award task orders at the division level. This A&AS work was slated to move to a different contract vehicle during February 2016, but due to the delay in transition the SMC/SYG work was extended six [6) months under the first FOE. The SMC/SYG transition to the new contract vehicle is again delayed due to the new contract award and is now slated to move to the contract vehicle after

FOR OFFICIAL USE ONLY Page4of5 an additional six (6) months of task order performance under PASS 11.

(8) Contracting Officer's certification that the justification is accurate and complete:

The Contracting Officer's signature on the signature page provides evidence that he/she certifies that the justification is accurate and complete to the best of his/her knowledge and belief.

(9) Certification of technical/requirements pe-rsonnel t_hat supporting data is accurate and, complete:

As evidenced by his/her signature-on the signature page, the Program Manager certifies that any supporting data, contained herein, which is his/her responsibility, is both accurate and complete.

(1 O) Determination by the approving official that one of the circurnstances in FAR 16.505{b){2)(i) applies to the order

As evidenced by my signature on the signature page, I hereby determine that the fafr opportunity exception checked in block6 (Page 1) applies.

FOR OFFICIAL USE ONLY Page 5 of 5