Gordon JA 2026_28 Final FFS 20260723_Redacted.pdf

Control No: Gordon 2026-28

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

Program/Equipment: Full Food Service (FFS) at Fort Gordon, Georgia

Authority: 10 U.S.C. 3204(a)(1) as implemented by RFO FAR 6.103-1 - Only one responsible source and no other supplies or services will satisfy agency requirements.

Amount: $67,300,000.00

Prepared by:

Contracting Officer:

Technical:

Requirements:

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

Director of Logistics Readiness Center:

demonstrated the capability to assume full performance within the required timeframe or to provide the specialized support necessary to avoid mission degradation.

a. Background. Prior to Army initiatives designed to dramatically change how food service is offered to Soldiers, a follow-on 5-year full food service contract at Ft. Gordon had been projected to be awarded prior to the end of July 2026. However, these initiatives continue to rapidly change and have delayed of the Dining Excellence Initiative (DINEX) to support Transformation and Training Command (T2COM) Garrisons that include Fort Gordon. The Army launched DINEX with the goal of seeking innovative, flexible solutions that deliver superior outcomes compared to the existing food service model. To achieve this, DINEX employs a Commercial Solutions Opening (CSO) that allows the Government to solicit and evaluate cutting-edge commercial solutions, while the intent to award an Other Transaction Agreement (OTA) ensures the Government can streamline the negotiation process, attract non-traditional providers, and structure the resulting partnership around measurable, performance-driven superior outcomes. This combined use of a CSO and an OTA is a direct implementation of the DOW's directive to maximize acquisition agility, rebuild and diversify the industrial base, and ultimately deliver better, faster results for the warfighter.

A draft CSO for DINEX operations was issued to industry on 11 December 2025, with the final CSO released on 26 January 2026. The resulting OTA will involve a prototype prototype is successful, then Fort Gordon has been identified for implementation of DINEX through the award of a FAR-based contract at T2COM locations. The prototype will require at least 12 months for implementation, testing and validation. Acquisition Planning will tentatively begin for the FAR based follow-on in June 2027, with the procurement lifecycle expected to take 12-17 months, with award anticipated no later than November 2028.

To avoid a lapse in service, the current Full Food Service requirement at Ft Gordon can efficiently be met by a non-competitive, thirty-month extension of services with the current incumbent, Georgia Vocational Rehabilitation Agency. This extension is necessary to prevent a lapse-in-services for mission-essential food services until execution of the DINEX initiative involving Fort Gordon is completed.

The Georgia Vocational Rehabilitation Agency has all required tools and highly trained employees on board that have been supporting this requirement for Full Food Services in various compacities dating back to 2013. In the past, the five Dining Facilities (DFACs) on the current full food service contract have previously either been separate stand-alone contracts or combined together on the same contract. Introducing a new contractor to provide the service would require a phase-in period to complete all the necessary functions to be compliant (background checks, CAC cards, training certifications for employees). There is not adequate time for a new vendor to accomplish this. This Georgia Vocational Rehabilitation Agency would be able to seamlessly continue work under the new contract and avoid a lapse-in-service while the Army tests and finalizes their approach to deliver improved full food service.

b. Alternatives. Pursuing a full, competitive solicitation for a short-term 30-month requirement would necessitate dedicating significant acquisition and legal resources over a 90-day period to acquire a service that would be superseded by the DINEX FAR-based contract at T2COM locations. The 30-month bridge contract for Fort Gordon aligns the end of the interim requirement with the scheduled implementation of a DINEX solution at T2COM. Awarding a new short-term contract to a non-incumbent would also require the Government to incur duplication of costs of a 30-day contractor transition twice during this 30-month period. Extending the current incumbent avoids the need for any transition costs for the interim period, reserving those resources for the final transition to the new T2COM FAR-based contract.

c. Impact if this justification is not approved. If the justification is not approved and the bridge action is not executed, the Government will be unable to issue funded task orders to continue full food services at Ft. Gordon. As a result, the 406th Army Field ability to support the dining facilities operating 24 hours a day at these locations will be severely impacted. There are no viable alternatives available, and the timeline to procure a new contract competitively exceeds the time remaining before service interruption would occur. A lapse in service would directly result in the inability to feed Soldiers, which would compromise mission readiness and daily operations. The risk to personnel support and operational continuity is unacceptable, and therefore urgent action for this IDIQ bridge is required to mitigate the risk while the long-term solution is competed.

d. The Contracting Officer has determined that the SLA is able to continue providing the required food services at a reasonable cost, with food of a high quality that is comparable to that currently provided. Notably, the SLA is the incumbent contractor, and its employees have the proper sanitation practices, personnel, staffing, menu pricing and portion sizes, menu variety, budget and accounting practices, and proven history to perform these services.

7. Efforts to Obtain Competition: This action will be synopsized.

a. Effective competition: This interim sole source action is to prevent a lapse in critical service and allow the MICC-IRC to fully develop a restructured competitive contract for Full Food Services at T2COM locations which includes Fort Gordon, Georgia.

b. The current contractor is a State Licensing Agency, and by definition in RFO FAR 19.109, a Subcontracting Plan is required. Per RFO FAR 52.219-9(d)(9), federal contractors are required to develop and maintain an acceptable subcontracting plan if they are other than a small business and the estimated dollar value of the base contract and all option periods exceed or is expected to exceed $900,000. The Government will request a subcontracting plan for this contract action and will coordinate review of the plan with the Small Business Specialist (SBS) and Small Business Administration (SBA) Procurement Center Representative (PCR) as required by 38 CFR 19.705-4(d)(7).

Additionally, the approved plan will be incorporated and made a material part of the contract as required by RFO FAR 19.206-3(e)(5). Finally, a copy of the award document will be provided to the Area Director for the SBA Area Office where the contract will be performed as required by RFO FAR 19.302-3(a) and a copy of the final negotiated subcontracting plan will be provided to the SBA PCR as required by RFO FAR 19.302- 3(c)(2).

8. Actions to Increase Competition: The requirement for a 30-month, non-competitive extension of services with the incumbent, Georgia Vocational Rehabilitation Agency, is not a retreat from competition but a strategic, temporary measure essential to facilitate the launch of a new, Army-wide, competitive acquisition to implement the

. A prototype for DINEX will be tested under an Other Transaction (OT) Agreement that is expected to last for 12-24 months depending on the prototype selected. Following a successful prototype, the model will be implemented across the remaining eight T2COM locations, which includes Fort Gordon, via a Federal Acquisition Regulation (FAR)-based contract. The acquisition process for the T2COM FAR-based contract is projected to take 12-17 months. However, the contract at Fort Gordon will expire before the new contract can be awarded, creating a potential gap in service. A solicitation for the prototype is expected to be issued no later than November 2026.

9. Market Research: The Government has conducted market research in accordance with FAR Part 10 by issuing a sources sought notice that was posted to SAM.Gov from 3-16 March 2026. The incumbent contractor currently possesses a fully trained workforce, established processes, and specialized tools required to perform this mission critical requirement. They are best suited to provide continuous services without creating undue stress to the soldiers and missions that rely on these services.

Transitioning to a new provider at this time would create unacceptable risk, including service disruption, operational delays, and undue burden on soldiers and missions that rely on these services. Based on the results of market research and the time sensitive nature of the requirement, the incumbent is the only responsible source capable of ensuring uninterrupted performance during the bridge period.

10. Interested Sources:

11. Other Facts:

12. Technical 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.

13. Requirements Certification: I certify that the supporting data under my cognizance which are 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 using the techniques contained in RFO FAR 15.404-1(b)(2) that include comparing historical contract pricing for the current contract and other contracts for FFS, and cost and price analysis performed by the contracting office. As this requirement is for commercial services, RFO FAR 15.403-2(b) provides exception to not requesting certified cost and pricing data.

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 Full Food Service at Fort Gordon on an other than full and open competition basis pursuant to the authority of Title 10 U.S.C. 3204(a)(1) as implemented by RFO Federal Acquisition Regulation 6.103-1 - Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. The estimated value of the contract is $67.3 million for a 30-month period of performance from 23 July 2026 through 22 January 2029. The approval is subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.