Gordon_JA_2019_98_Redacted.pdf
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Control No.: MICC 2019-98 Contractor: Dawson Federal, Inc.
Program: CCoE Information Technology (IT) Support Services
Version – September 2018 FOR OFFICIAL USE ONLY
JUSTIFICATION REVIEW DOCUMENT
FAR PART 6 JUSTIFICATION AND APPROVAL FOR OTHER
THAN FULL AND OPEN COMPETITION
Program/Equipment: The Cyber Center of Excellence (CCoE) requires a bridge contract for its Information Technology Support Services to avoid a break in service due to a timely filed Protest action.
Authority: 10 U.S.C. 2304(c)(2) as implemented by FAR Part 6.302-2 -- Unusual and Compelling Urgency
Amount: $3,017,942.40
Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.
Version-September 2018 FOR OFFICIAL USE ONLY
FAR Part 6 Justification and Approval for Other than Full and Open Competition
1. Contracting Activity: U.S. Army Mission and Installation Contracting Command – Ft. Gordon, 271 Heritage Park Lane, Fort Gordon, GA 30905-5719
2. Description of Action: The Cyber Center of Excellence (CCoE) requires a bridge contract for its Information Technology Support Services to avoid a break in service due to a timely filed Protest action under urgent and compelling circumstances. This bridge contract would be issued to the currently performing vendor, Dawson Federal, Inc. 112E Pecan St. Ste 300, San Antonio, TX 78205.
The Office of the G6 is a primary staff section to the Commanding General (CG) Cyber Center of Excellence and Fort Gordon Senior Mission Commander. Under the Mission Command concept the G6 receives guidance and orders from the following Headquarters (HQs): Combined Arms Center (CAC) G6, Training and Doctrine Command (TRADOC) G6, HQ Department of the Army (DA) Chief Information Officer (CIO)/G6; Army G2, Defense Information Systems Agency (DISA), and Army Cyber Command (ARCYBER). All formal directives must go through the CCoE G3 and be approved by the CCoE’s Chief of Staff (CofS). The G6 works to ensure CCoE CG’s priorities are supported by capabilities. The G6 recognizes the rapid rate of change in today’s environment, especially as it pertains to Cyber, Signal and IT equipment and training. A G6 is necessary in order to address and meet the challenges of these rapid changes and to further support enhancement and maintenance of the CCoE’s IT requirements.
CCoE requests a six (6) month bridge contract to allow for the successful conclusion to the GAO protest under urgent and compelling circumstances.
An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d) (i) (B).
3. Description of Supplies/Services: The contract will deliver commercial services to support the CCoE G6 mission to provide IT services and support at the Non-Secure Internet Protocol Router (NIPRNET), Secure Internet Protocol Router (SIPRNET), and Joint Worldwide Intelligence Communications System (JWICS) levels for the CCoE and all schools through the following: Cyber Security, Training Network, Operations, IT Project Management, IT Procurement, and Enterprise Service Desk.
Period of Performance: 29 September 2019 - 28March 2020 Value: $3,017,942.40
4. Authority Cited: 10 U.S.C 2304(c)(2) as implemented by FAR Part 6.302-2 – Unusual and Compelling Urgency.
5. Reason for Authority Cited: As described at FAR 6.302-2(a)(2), when the agency’s need for the supplies or services is of such an unusual and compelling urgency that the Government would be seriously injured unless the agency is permitted to limit the number of sources from which it solicits bids or proposals, full and open competition need not be provided for.
a. Contract W91249-17-C-0175 was issued on 25 September 2017 to Dawson Federal, Inc as a direct 8(a) award IAW FAR 19.805-1(b)(2). The period of performance for the base period was 29 September 2017-28 March 2018. Option Year one was exercised in March of 2018 for a period of performance of 29 March 2018-28 March 2019. On 05 March 2019, P00004 was executed to utilize the clause at 52.217-8 to extend the current contract by three months in order to reach award on the follow on effort. On 11 June 2019, P00006 was executed adding 2 more months of service under 52.217-8 and again, on 13 August 2019, P00007 was issued to add the final 1 month of service allowed under the FAR clause to the contract.
On 01 August 2019, a timely filed pre-award protest was received by GAO from Steel Point Solutions, LLC which triggered an automatic stay IAW 31 U.S.C. 3553 (c)(1), FAR 33.104 (b) Protests before Award. On 4 September 2019, the GAO dismissed the protest after the Agency announced it would take corrective action that would include revisiting the requirement, conducting additional acquisition planning and it may issue a new Solicitation to satisfy its requirement. On 5 September 2019, Steel Point Solutions filed a GAO protest alleging the proposed corrective action was improper.
The IT support services are crucial to maintaining the effective operation of CCoE and Ft Gordon at large. Mission readiness will be directly affected if the IT support were to incur a “break” or loss of functionality. There is no other vendor available that can continue to provide uninterrupted support. A bridge contract must be awarded to the currently performing vendor on a sole-source basis in the interest of time, economy and efficiency as it will allow the unabated execution of IT support services through the end of the protest period. This also allows the continued deployment of several key IT support services that are critical to the completion of the ongoing transformation efforts, wherein a failure or delay could cost the service millions of dollars and delay the ongoing deployment of Information Technology systems. This is not just linked to the deployment of IT services but also the CCoE virtualization efforts that must meet critical timelines to prevent any delays which are tied to the ongoing Fort Gordon Transformation efforts. Any delay in this deployment risks over $10 million annually of hardware and software being deployed as part of the larger Fort Gordon transformation.
b. Alternatives:
1) Suspension of Services. Without IT support services the systems at CCoE would be at risk of non-operability or reduced functionality. A loss of functionality would severely hamper the efforts of the CCoE to provide required mission essential services.
2) Use of In-House Resources. There are no in-house resources capable of providing the required services.
3) Re-compete the effort. Since this bridge effort is a stop-gap measure to ensure vital services continue during a stay period due to protest, there is no benefit to the Government to re-compete the effort at this time. There is currently no other source that can provide the immediate capabilities necessary to meet the total requirements provided by the in place contractor.
6. Efforts to Obtain Competition: A Sources Sought Notice was not issued IAW FAR 5.202(a)(2), the proposed contract action is made under the conditions described in FAR 6.302-2 (or, for purchases conducted using simplified acquisition procedures, if unusual and compelling urgency precludes competition to the maximum extent practicable) and the Government would be seriously injured if the agency complies with the time periods specified in FAR 5.203. It is not feasible nor expeditious to engage with additional new contractors for the short term. Additionally, a new contract already has been competed but is under pre award protest at GAO.
7. Actions to Increase Competition: As indicated in the preceding paragraph, this is an interim action to allow for continued performance pending a decision from GAO on the protest submitted by Steel Point Solutions, LLC.
8. Market Research: This effort is for a bridge contract to ensure continuation of services during a protest period. Market research was not performed beyond that submitted with the original procurement package for Solicitation W91249-19-R- 0008.
9. Interested Sources: N/A.
10. Other Facts:
a. Procurement History
Contract Number
Contractor Contract Type
Award Amt.
Period of Performance
Non- Competitive
Authority W91249- 16-C-
FFP $3,680,073.60 09/29/2016-
9/28/2017
FAR 6.302-5
W91249- 17-C-
FFP $7,449,669.66 09/29/2017-
09/28/2019
FAR 6.302-5
Program: CCoE Information Technology (IT) Support Services
Version – September 2018 FOR OFFICIAL USE ONLY
11. Technical & Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.
12. Management Review/Approval: The requirement herein described is a valid requirement for the activity named in this justification. The technical and requirements information contained in this justification represent the minimum needs of the Government. The only way to satisfy this requirement is by limiting the competition as described herein.
Approval
Based on the foregoing justification, I hereby approve the procurement of Information Management/Information Technology services in support of the Cyber Center of Excellence G6, Fort Gordon, Georgia, on an other than full and open competition basis pursuant to the authority of Title 10 United States Code Section 2304(c)(2) as implemented by Federal Acquisition Regulation Part 6.302-2 – Unusual and Compelling Urgency. The estimated value of the contract is $3.02 million for a six month period of performance. This approval is subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.
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