FedMall Extension EFO - Final - Redacted.pdf

Source Selection Information See FAR 2.102 and 3.104 payment. FEDMALL is a web-based application running in a virtualized environment made up of commercial ecommerce Commercial Off the Shelf (COTS) products with customized Government Off the Shelf (GOTS) code.

Under the current contract, US Information Technology Company provides all labor, tools, materials, and other services necessary to operate, maintain, improve, patch, upgrade, and maintain FedMall for DLA. The period of performance for the current contract ends July 20, 2020. USIT has maintained an aggressive development schedule and, at the direction of the Program Management Office (PMO), worked numerous simultaneous system improvements requested by key stakeholders or mandated by current Department of Defense (DoD) policies and procedures. While a detailed plan for the remaining months of the current task order was in place, directives from the DLA Director and the Office of the Under Secretary of Defense to implement critical and urgent system changes have now made it impossible to complete the necessary work during the current period of performance.

This extension is necessary to continue implementing enhancements and to remain compliant with cybersecurity requirements. Specifically, the Contractor Contingency corridor/store and State & Local Government corridor/store enhancements and the Operating System (OS) software upgrade are all urgent, high priority items that must be implemented as soon as possible. As a result of the COVID-19 pandemic, the DLA Director has tasked us with implementing a Contractor Contingency corridor/store. A corridor/store is a subset of the 53 million individual items of supply on FedMall that support a specific mission or need. In addition, at the request of the Undersecretary of Defense for Acquisition and Sustainment, DLA has been tasked with developing a State & Local Government corridor/store as soon as possible.

The unforeseen introduction of, and emphasis on the development of these two corridor projects has delayed a mandatory Operating System and eCommerce component software upgrade affecting all parts of the system. This delay has pushed the software upgrade beyond the current option 1 expiration date. Specifically, while the OS software upgrade is 85% complete, it is at a standstill due to technical and resource considerations until the corridors are complete/delivered.

As part of the current contract, USIT is required to keep FedMall in compliance with all applicable Laws, Regulations, and Policies, to include Cyber Security policies. The OS software upgrade is necessary to maintain the cybersecurity posture required by DoDI 8510.01 Risk Management Framework (RMF) for DoD Information Technology (IT) and supports FedMall ecommerce products that are already end of life and unsupported. To comply with RMF requirements, all systems are required to run supported versions of software. To meet this requirement, FedMall is upgrading the currently configured OS software version to maintain its compliance posture in accordance with RMF as well as the majority of the ecommerce products that comprise the system itself. The upgrade requires USIT to install and configure more recent and supported versions of the software across all of FedMall’s operating environments (development, test, and production). The end state will be FedMall development, test, and production environments with fully supported software in compliance with RMF requirements.

The FedMall contingency corridor will provide the ability for small business government contractors to purchase non-medical PPE for use while performing on their government contract(s). This capability will support reconstitution of our contractor workforce as small businesses have experienced difficulty purchasing sufficient quantities of PPE for their employees. Additionally, the corridor creates another sales avenue for textile companies entering the federal PPE market, targets suppliers transferring from FEMA/HHS to DLA and enables sales of PPE direct to military services and authorized DoD contractors.

The FedMall state & local corridor will provide the ability for state and local governments to purchase non-medical PPE products. Initiation of corridor development was delayed pending determination by the DoD OGC to confirm the authority to allow state and local Governments to purchase under the open corridor of FEDMALL within the limitations and procedures provided under specific statutory authority such as 10 U.S.C. 381. We have now been directed to proceed and to complete the corridor as soon as possible. We expect the effort to take 6-8 weeks to implement.

The extension Period of Performance (POP) is expected to begin on July 21, 2020 and continue through September 20, 2020. The for this requirement is .

4. IDENTIFICATION OF THE EXCEPTION TO FAIR OPPORTUNITY (SEE FAR

16.505(b)(2)) AND THE SUPPORTING RATIONALE, INCLUDING A

DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF

THE EXCEPTION CITED:

Per FAR 16.505(b)(2)(i)(B) an exception to the fair opportunity process is justified because only USIT is capable of providing the services required at the level of quality required in the required timeframe because the services ordered are unique and highly specialized.

The current task order awarded to USIT supports both sustainment and development services, an interdependency which is most efficiently managed by having one contractor responsible for both aspects. This arrangement better addresses the need for consistency in configuration management of the application and development techniques for managing versions of the application code. Introducing another vendor would require significant additional efforts and resources, as additional environments, integrations, interfaces, and testing would be required. A new vendor would have to configure their own software environments, develop the requirements in these new environments and finally migrate the changes to the existing FedMall environments. Additionally, setup and testing of new interfaces and firewall rules would be required if the government used a new contractor to complete the required corridor/store development and software upgrade work. The time and resources required for another vendor to complete this work would be cost prohibitive and inefficient, whereas allowing the current vendor to continue the development work is a logical follow-on to the current work they are tasked with and adequately completing. The introduction of an additional contractor presents severe schedule and performance risks and will jeopardize the Government’s ability to deliver the corridors by late July or early August 2020 as directed.

DCSO is currently in the process of awarding a long term competitive order for FedMall sustainment services. However, USIT is the only vendor who can immediately meet the requirements of this two month extension and seamlessly ensure the completion of the remaining tasks in a timely manner. If DCSO were to award this contract to another vendor, we can expect extreme delays in the completion of the OS software upgrade. A new contractor would require 1- 3 months to onboard their staff, and significant ramp-up time to familiarize their developers with the FedMall architecture. This will delay delivery of the upgrade several months. While such delays can be accepted during a ramp up into a new long term contract, they are not acceptable for the purpose of this two-month extension, which is designed to allow for the completion of specific tasks that are currently being performed by USIT. Given the technical complexity of the OS software upgrade and the intimate understanding of FedMall it requires, a new contractor will not be able to “hit the ground running” and finish the final 15% of the upgrade. New development schedules would have to be coordinated with interfacing partners, new firewall rules will need to be created, and additional environment platforms will have to be acquired to support OS software upgrade work by another vendor. There is also a risk that the new contractor will introduce errors due to system unfamiliarity while re-creating the code for multiple system integrations. Bringing a new vendor on will result in significant rework and duplication of effort, causing time, money and resources expended on the OS software upgrade, already at 85% completion, to be wasted. The current vendor is the most economic and efficient way to complete the necessary work as it naturally follows the work they have been doing throughout the task order.

Implementing/completing the corridors and OS software upgrade on time can only be achieved by the current contractor, USIT. Introducing a new contractor would interject unacceptable risks, delays, costs, rework and result in mission failure.

5. A DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND

REASONABLE:

As the Contracting Officer, I hereby determine that the anticipated cost to the Government will be fair and reasonable. It is anticipated that the Government will use various price analysis techniques including, but not limited to (1) Comparison with competitive price lists in accordance with FAR 15.404- 1(b)(2)(iv); (2) Comparison with Independent Government Cost Estimate (FAR 15.404- 1(b)(2)(v)); and/or(3) Comparison of proposed prices obtained through market research for the same or similar items in order to obtain a fair and reasonable price in accordance with FAR 15.404-1(b)(2)(vi).

6. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION:

None.

7. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS THAT LED TO THE EXCEPTION TO

FAIR OPPORUNITY BEFORE ANY SUBSEQUENT ACQUISITION FOR THE

SUPPLIES OR SERVICES IS MADE:

The FedMall Sustainment Support task order was solicited as a competitive acquisition under the JETS contract vehicle. A source selection team is currently evaluating the proposals that have been submitted for this follow-on contract. The circumstances leading to the need for this modification were unforeseen prior to solicitation and award because agile development processes have increased the speed at which new functionality has been delivered. This sole source action is needed before a new FedMall competitive acquisition is awarded to support future sustainment and development of the FedMall application. To that end, the Government anticipates completing the follow-on to the current task order before all available options expire on September 20, 2020. It is anticipated that the contractor contingency corridor, the state & local government corridor and the software upgrade will be implemented/completed prior to the end of the current task order, and any future custom development will be included in the Performance Work Statement for the follow-on FedMall task order.

8. CERTIFICATIONS.

TECHNICAL CERTIFICATION

Requirements Certification: I hereby certify that the support data provided for which I am responsible and which form a basis for this justification are complete and accurate.

FedMall Program Office / Deputy Program Manager

Technical Certification: I hereby certify that the support data provided for which I am responsible and which form a basis for this justification are complete and accurate.

FedMall Program Office / Program Manager

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

Contracting Officer DLA Contracting Services Office Philadelphia

In accordance with FAR 16.505(b)(2)(ii)(C)(2), I have determined that FAR 16.505(b)(2)(i)(B) applies and I approve this justification.

Competition Advocate DLA Contracting Services Office Philadelphia