FLW JA 2025_102_Redacted.pdf

Control No: 2025-102

Justification Review Document FAR Part 6 Justification and Approval for Other than Full and Open Competition

Program/Equipment: The Fort Leonard Wood Directorate of Public Works (DPW)

Facilities Maintenance Support Services.

Authority: 1 O U.S.C. 3204(a)(2) as implemented by Federal Acquisition Regulation (FAR) Part 6.302-2 -- Unusual and Compelling Urgency.

Amount: $32.2M

Prepared by:

Contracting Officer:

Technical:

Requirements:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Requiring Activity: Directorate of Public Works (DPW), Fort Leonard Wood, MO.

2. Contracting Activity: U.S. Army Mission and Installation Contracting Command (MICC)-Fort Leonard Wood, 8112 Nebraska Avenue, Building 11400, Fort Leonard Wood, MO 65473.

3. Description of Action: Requests approval to award a 12-month bridge contract to continue services with TSAY Professional Services, Inc. (TSAY). The Government projects award for 01 December 2025 using fiscal year (FY) 2026 Operations and Maintenance funds.

4. Description of Services: The contractor shall provide all services, materials, supplies, transportation, plant, supervision, labor and equipment, except as specified as Government furnished, to operate, maintain, alter and repair real property facilities and appurtenant structures at Fort Leonard Wood, Missouri and the Lake of the Ozarks Army Recreation Area (LORA). The contractor shall provide the above as well as related services in accordance with (IAW) terms, conditions and specifications.

Period Period of Performance Estimated Value Base 01 DEC 2025 — 30 NOV 2026 $32.2 M

5. Authority Cited: 10 U.S.C. 3204(a)(2), as implemented by FAR 6.302-2 — Unusual and compelling urgency.

6. Reason for Authority Cited: IAW FAR 6.302-2, the Government would incur significant adverse effects if a bridge contract is not awarded by 30 November 2025.

The combination of a lapse in appropriations for FY 26 and delays in the solicitation of a new contract caused by the furlough has created a situation that necessitates the issuance of a sole source contract to the current contractor. This action is critical to the maintenance of the base and loss of services would result in severe injury to the Government. Facilities maintenance services cover emergencies and all maintenance, for the “entirety” of Fort Leonard Wood infrastructure.

a. Background: W911S7-20-C-0004 expired on 31 May 2025 and FAR Clause 52.217-8 was executed for six months beginning 01 June 2025 and ending on 30 November 2025. The MICC – Installation Readiness Center (IRC) was tasked with completing a new facilities maintenance award by 31 May 2025. In March 2025, it was apparent to MICC and the Requiring Activity (RA) there would not be a new requirement awarded by the expiration of the current contract. The Contract Management Support Officer (CMSO) sent a request for a bridge contract meeting stating that IRC was not projected to have a new contract awarded until August 2026. This delay in award would result in Fort Leonard Wood being without a facilities maintenance contract for nine months at minimum.

While competition is generally beneficial, the costs and logistical challenges associated with multiple transitions of services within this timeframe outweigh the potential advantages. TSAY currently possesses the established infrastructure and personnel necessary to provide both emergency and routine maintenance services.

This puts TSAY in an exclusive position to continue these services currently, making them unique and the sole entity capable of fulfilling the expiring contract. The performance work statement (PWS) requires a phase-out/phase-in period of no less than two months. The contract expiring prevents another company from receiving the phase-in period they are supposed to be guaranteed in according to the PWS. In addition to not being able to provide a phase-in period for a new contractor, it is not reasonable to expect a new contractor to have time to hire and on-board new employees for a contract that is expected to last less than 12 months. This would drastically increase the costs incurred by the Government as this is a cost reimbursement contract with the full burden of expense being charged to the Government.

Other alternatives were researched after discussions with the Small Business Administration (SBA) but the lapse in appropriations has made all other feasible solutions impossible to implement. With the current contract expiring on 30 November 2025, the available time remaining dictates that a bridge contract with the incumbent will avoid injury to the Government or installation caused by a lapse in services. We are entering into the winter season in Missouri and Snow and Ice Removal (SNAIR) and emergency repairs are exclusively covered by the facilities maintenance contract. A lapse without these services would risk serious injury to those who live and work on the installation. It would also delay all training and missions, impacting Army readiness.

Facilities maintenance is mission essential to the Army.

b. Alternatives.

1) Multiple Stand-Alone Contracts: Awarding individual stand-alone contracts is not a feasible option. The process of awarding a new contract to a contractor other than the incumbent would jeopardize response times for critical emergency projects during the transition and break in services. Furthermore, the consistent volume of small projects required for routine installation maintenance would be inefficiently managed through numerous individual contract awards.

2) Multiple Award Task Order Contract (MATOC): Utilizing a MATOC is not a viable solution due to the time required to award individual task orders. While the Fort Leonard Wood MATOC would introduce competition, its firm-fixed-price structure could potentially increase the overall costs associated with providing maintenance services.

The MATOC ceiling would also not support the additional work required by facility maintenance.

3) Job Order Contracting (JOC): JOC is also not a feasible option. Accurately scoping and defining quantities for each project under a JOC framework would be a lengthy process and further delay maintenance. This approach could also result in increased costs for the Government due to the complexities of project definition.

c. Impact if justification is not approved. A lapse in the current facilities maintenance services will significantly hinder the Fort Leonard Wood DPW’s ability to maintain the installation effectively. DPW relies on this contract to ensure timely repairs and minimize disruptions caused by lengthy solicitation processes. Without the approval, Fort Leonard Wood would cease to function and become unsafe to both the servicemembers and civilians that live and work on the installation. Reliance on alternative contracting methods such as using stand-alone awards, a MATOC, or a JOC, would likely increase both the time required to initiate projects and the overall cost to the Government.

Facilities maintenance services cover emergencies and all maintenance, for the “entirety” of Fort Leonard Wood infrastructure. These alternatives introduce complexities and administrative burdens that could compromise the efficiency of essential maintenance operations.

7. Efforts to Obtain Competition: IAW FAR 5.202(a)(2), this action will not be synopsized since the proposed contract action is made under the conditions described in FAR 6.302-2.

a. Effective Competition: Because this is a sole source action, effective competition is not applicable.

b. Subcontracting Competition: IAW FAR 19.702(b)(1) a subcontracting plan is not required from small business concerns. TSAY (CAGE Code 7PQA8) has re-represented as a small business under NAICS Code 561210 IAW FAR Clause 52.219-28. The incumbent contractor will be required to obtain as much competition as possible for any part of the requirement that is subcontracted and will give maximum opportunity to small businesses. The incumbent contractor is required to adhere to Class Deviation 2021- O008, Revision 1, Limitations on Subcontracting.

8. Actions to Increase Competition: While this bridge contract will be awarded as a sole source, limiting immediate competition, the follow-on contract will be a competitive 8(a) procurement.

9. Market Research: IAW Defense Federal Acquisition Regulation Supplement (DFARS) 205.205-71, DFARS 206.302-1(d), and DFARS Procedures, Guidance and Information (PGI) 206.302-1(d), a request for sources sought was posted to SAM.Gov on 20 July 2025 for 17 days and 10 vendors responded. The results support there is enough small business participation to provide adequate competition and keeping the requirement in the 8(a) program. However, there was no evidence that a solicitation would result in a timely award that is more advantageous to the Government than awarding a 12-month bridge to the incumbent (TSAY) considering their unique position with infrastructure, personnel, and knowledge of the contract.

10. Interested Sources: There were a total of 10 responses from interested sources for the Sources Sought that was posted on SAM.gov. See the table below.

Vendor Cage Business Name Code Size

RJY Group LLC 5YJ43 Small

T AMCO Services Corporation 9WGD0 Small

2Bfocused, INC 7QC98 Small

Fortis Native Group 9C9K0 Small

BHPE LLC 9SWS7 Small

JBW 959V0 Small

J's Associates 3LHG1 Small

KTH Services JV, LLC 9TS64 Small

Tigua Facility Services 7HQB4 Small

Waseyabek Federal Services, LLC 7ZJW2 Small

Socio-Economic Type

8(a)

SDVOB

8(a), WOSB, EDWOSB

Tribal 8(a)

SDVOSB

NHO 8(a)

WOSB

Tribal 8(a), HUBZone

Tribal 8(a)

Tribal 8(a)

11. Other Facts:

a. Procurement History. The current facilities maintenance contract was procured as a 100% 8(a) set-aside competition. Ten offers were received in response to the solicitation, and one offeror was selected for contract award. The source selection process was completed in 2020. TSAY was awarded this contract as an 8(a).

b. Explanation of comparative pricing between current contract and proposed bridge contract. The current contract continues to incur cost overruns; therefore, the value for the bridge contract, when compared with the original value of the present contract, was increased to depict a truer picture of real costs.

12. Technical Certification: I certify that the supporting data under my cognizance which is included in the justification is accurate and complete to the best of my knowledge and belief.

13. Requirements Certification: I certify that the supporting data under my cognizance which is included in the justification is accurate and complete to the best of my knowledge and belief.

14. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. This determination will be made using price analysis, historical pricing, and the Independent Government Estimate (IGE). As part of the basis, certified cost or pricing data will be required when applicable.

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

Approval

Based on the foregoing justification, I hereby approve the procurement of a 12-month bridge to the Fort Leonard Wood DPW Facilities Maintenance contract on an other than full and open competition basis pursuant to the authority of Title 10 United States Code Section 3204(a)(2), as implemented by Federal Acquisition Regulation (FAR) 6.302-2 - Unusual and Compelling Urgency. The estimated value of the contract is $32.2 million for a 12-month period of performance from 01 December 2025 through 30 November 2026.

The approval is subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.

WADE C. COLE

Senior Contracting Official U.S. Army Mission and Installation Contracting Command, JBSA Fort Sam Houston, TX