fair_opportunity_exception_justification Security Coop_Redacted.pdf
PDF 345 KB Posted
- Attached to
- HQ USCENTCOM Security Cooperation Support Bridge
- Solicitation number
- FA481420F0220P00018
About this file
This document is a Justification for an Exception to Fair Opportunity for a bridge contract action with the U.S. Air Force's 6th Contracting Squadron under the Air Mobility Command.
The Government seeks a one-month bridge extension to Task Order FA481420F0220 for Security Cooperation Support Services to U.S. Central Command (CENTCOM), valued at approximately $10,491,648.27. The incumbent contractor, Lukos LLC, operates under GSA OASIS contract 47QRA0D2D1155. The current contract expires on 12 March 2026, and this bridge is necessary to prevent service interruption while a competitive follow-on procurement under GSA OASIS+ is finalized. The bridge period runs from 13 March 2026 through 12 April 2026 and maintains the existing scope of work covering critical security cooperation support, strategic planning, policy development, and program management for partner nation activities across the CENTCOM Area of Responsibility. The services encompass multiple task categories including SC and ICB Programs Management, SC TSC Senior Analyst/Planner, Strategy and Planning, Senior Leader Engagements, FMS Analyst support, Regional/Country Desk Officer activities, Travel, and Contract Access Fees—all for one month each. The contracting officer justified the sole-source award under FAR 16.507-6(b)(1) citing urgent agency need, as a lapse in service would disrupt mission-critical security cooperation activities essential to regional stability and CENTCOM operational objectives. Price reasonableness was determined through comparison to the incumbent contract rates, which carried no escalation. The bridge approach ensures continuity of mission support with the cleared, experienced incumbent contractor while preserving competition for the long-term follow-on requirement.
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| File | Type | Posted |
|---|---|---|
| Released SF30 - FA481420F0220P00018 - Signed.pdf |
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Text version
Justification for an Exception to Fair Opportunity or to Use Brand-Name Restriction
CONTROLLED UNCLASSIFIED INFORMATION
v 18 Jan 2024 CONTROLLED UNCLASSIFIED INFORMATION Page 2 of 6v 18 Jan 2024 CONTROLLED UNCLASSIFIED INFORMATION Page 2 of 6
6011 Regional/Country Desk Officer/Senior Political Military Analyst 1 month $ Task 5 6014 Travel 1 month $ 6015 Contract Access Fee (CAF) 1 Lot $ 6016 SC TSC Strategy, Planning and Assessment (SC/ICB) 1 month $ Task 2 6017 Senior Leader Engagement and Events Planning/Mgmt Task 3 1 month $ Total: $
The Period of Performance is 13 March 2026 - 12 April 2026
(4) Identification of the exception to fair opportunity and the supporting rationale:
Revolutionary FAR Overhaul 16.507-2(a)(1) requires the Contracting Officer to provide each awardee a fair opportunity to be considered for each order or BPA valued above the micro-purchase threshold according to paragraph (c) and 16.507-3 through 16.507-5, unless a sole source order or BPA is justified and approved according to 16.507-6. The specific exception that precludes the fair opportunity process for this acquisition is RFO 16.507-6(b)(1): "The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays." The incumbent task order for Security Cooperation services for CENTCOM expires on 12 March 2026. These services provide critical operational, strategic planning, policy development, and program management support necessary to sustain ongoing security cooperation activities with partner nations across the USCENTCOM Area of Responsibility (AOR). A lapse in service would cause a complete stoppage of support to the U.S. Military Group in the CENTCOM AOR, specifically CENTCOM would be unable to plan, manage, execute and assess Security Assistance and Security Cooperation programs and activities directly impacting the ability to advance the CENTCOM Campaign Plan and U.S. objectives in the CENTCOM AOR."
The current contract supporting these services is scheduled to expire on 12 March 2026, and an interruption in contractor support would result in an immediate disruption to ongoing security cooperation initiatives that are essential to regional stability, partner capacity building, and the execution of USCENTCOM operational objectives. These services directly support mission planning, international partner cooperation, and security cooperation activities that underpin current operational priorities.
The Government is currently conducting a competitive procurement for the follow-on requirement, which has been issued under the GSA OASIS+ contract vehicle and is presently in the solicitation phase. However, sufficient time is required to allow offerors to prepare and submit proposals, for the Government to evaluate their proposals, conduct any necessary exchanges, and complete the source selection process in accordance with applicable procurement regulations.
During the the timing of the current contract expiration and the time required to complete the ongoing competitive acquisition, a short-term bridge contract is necessary prevent a lapse in critical mission support services.
Providing fair opportunity to all contract holders for this short-term requirement would introduce additional time into the acquisition process that would likely result in a gap in contractor support before the follow-on competitive award can be completed. Such a lapse would disrupt essential security cooperation activities and negatively impact USCENTCOM's ability to maintain continuity in mission planning, partner coordination, and ongoing program execution.
The proposed bridge action is limited to one-month $ , representing minimum duration and value necessary to allow finalization of the competitively solicited follow-on task order. The bridge maintains the current scope and level of effort and does not introduce new requirements. The need for this exception to fair opportunity is not the result of lack of planning or inadequate procurement execution, but several external programmatic factors that impacted the acquisition timeline. The Government initially planned to fulfill the requirement through an in-house $750M Professional Services IDIQ acquisition strategy; however, significant manpower reductions due to Department of War reduction in Personnel (DRP) impacted the requiring activity's ability to support the evaluation process, resulting in cancellation of that approach in June 2026. The Government promptly initiated a competitive procurement under GSA OASIS+. During acquisition planning, multiple directorates and outside agencies introduced scope refinements and realignments with evolving priorities. These changes v 18 Jan 2024 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 6v 18 Jan 2024 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 6 required additional coordination, requirement validation, and revision of acquisition documentation. Additionally, the requiring activity was previously directed to implement budget reductions that resulted in adjustments to the scope of the requirement;
however full funding was just recently restored December 2025. Finally, a Federal Government shutdown caused an approximate 45-day delay in acquisition activities including coordination, document review, funding certifications, and approval actions. CENTCOM operates in a rapidly evolving operational environment. Due to the cumulative impact of these external factors, additional time is required to complete the final acquisition actions and award a follow-on contract. These factors were outside the control of the contracting activity.
Accordingly, the Contracting Officer has determined that the Government's need for continued support constitutes an urgent requirement, and that applying the exception to fair opportunity under RFO 16.507-6(b)(1) is necessary to ensure uninterrupted mission support while the ongoing competitive procurement is completed. A lapse in service would cause a complete stoppage of support to the U.S. Military Group in the CENTCOM AOR, specifically CENTCOM would be unable to plan, manage, execute, and assess Security Assistance and Security Cooperation programs and activities directly impacting the ability to advance the CENTCOM Campaign Plan and U.S. objectives in the CENTCOM AOR."
(5) Contracting Officer's determination that the anticipated cost to the Government will be fair and reasonable:
The Contracting Officer has determined that the anticipated price for the proposed bridge contract is fair and reasonable. Price reasonableness was determined using price analysis techniques in accordance with RFO 15.404-1(b). Specifically, the Government compared the proposed bridge pricing to the previously awarded contract prices for the same services under the current contract, which were determined fair and reasonable at the time of award through competition.
The proposed bridge effort maintains the same scope of work, labor categories, and level of effort as the existing contract, and the contractor has proposed pricing consistent with the rates currently in effect under the incumbent contract with no escalation.
Based on a comparison of the proposed price to historical prices paid for the same services, the Contracting Officer has determined the anticipated price for the bridge contract to be fair and reasonable in accordance with RFO 15.404-1(b)(2)(i).
(6) Other facts supporting the justification:
The proposed bridge contract will ensure continuity of mission-essential Security Cooperation Support services while the Government completes the ongoing competitive acquisition doe the follow-on requirement. These services provide critical support to USCENTCOM security cooperation planning, partner engagement activities, program coordination, and strategic policy support across the Area of Responsibility.
The incumbent contractor is currently performing these services and has the cleared personnel, established processes, and operational familiarity necessary to continue support without disruption. Transitioning performance to another contractor for a short-duration bridge period would introduce significant operational risk, potential schedule delays, and inefficiencies associated with onboarding, security processing, and knowledge.
The bridge contract is limited in duration and scope to the minimum period necessary to allow the Government to complete the ongoing competitive procurement and make award for the long-term requirement. This approach ensures the Government maintains continuity of critical services while preserving competition for the follow-on acquisition.
Accordingly, the bridge action represents the most practical and least disruptive means of maintaining uninterrupted support to USCENTCOM mission requirements during the completion of the competitive acquisition.
(7) Actions the agency may take to remove or overcome any barriers to increasing fair opportunity before any subsequent acquisition for the supplies or services:
The Government has taken steps to ensure that fair opportunity will be provided for the follow-on acquisition. The requirement has been issued competitively under the GSA OASIS+ contract vehicle, allowing all eligible contract holders the opportunity to submit proposals.
v 18 Jan 2024 CONTROLLED UNCLASSIFIED INFORMATION Page 4 of 6v 18 Jan 2024 CONTROLLED UNCLASSIFIED INFORMATION Page 4 of 6
The bridge contract is limited in duration and scope solely to prevent a lapse in critical mission support while the ongoing competitive procurement is completed. No barriers exist that would restrict fair opportunity for the follow-on requirement.
The Government will continue to ensure that the follow-on acquisition is conducted using competitive procedures in accordance with applicable FAR requirements, thereby maximizing fair opportunity among qualified contract holders and promoting competition to the greatest extent practicable.
(8) Program Manager's certification that supporting data is accurate and complete:
As evidenced by my signature below, I certify that any supporting data contained herein, which is my responsibility, is both accurate and complete.
(9) Contracting Officer's certification that the justification is accurate and complete:
As evidenced by my signature below, I certify that the justification is accurate and complete to the best of my knowledge and belief.
(10) Approving Official's determination that one of the circumstances in FAR 16.505(b)(2)(i) applies to the order.
As evidenced by my signature below, I hereby determine that the fair opportunity exception checked on page 1 applies.
Date
10 Mar 2026
Program Manager Donald Hooker
CENTCOMJ5/813-529-5147
Signature
Date
10 Mar 2026
Contracting Officer LaKeisha Gamble
6 CONS/PKB, (813) 828-4783
Signature
Date
10 Mar 2026
Chief of the Contracting Office (COCO) Michael Terranova
6 CONS/PK, (813) 828-4752
Signature
HOOKER.DONALD.RA
Y.1046007600
Digitally signed by
HOOKER.DONALD.RAY
Date: 2026.03.10 06:17:55 -04'00'
GAMBLE.LAKEISHA.
NICOLE.1257945410
Digitally signed by
GAMBLE.LAKEISHA.NICOLE
Date: 2026.03.10 09:56:47 -04'00'
TERRANOVA.MICH
AEL.1384936829
Digitally signed by
TERRANOVA.MICHAEL
Date: 2026.03.10 09:52:12 -04'00'
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