AR00985_2018081AR_MAVNI_Bridge_J&A_for_Bridge_Contract_Final_FBO_posting_Redacted.pdf

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Version 3/15/18

General Services Administration (GSA)

Federal Systems Integration and Management Center (FEDSIM)

JUSTIFICATION AND APPROVAL

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

FOR BRIDGE CONTRACT

47QFCA18F0101

FEDSIM PROJECT NUMBER AR00985

The General Services Administration (GSA) makes this Justification and Approval

(J&A) for Other Than Full and Open Competition orders pursuant to Federal

Acquisition Regulation (FAR) 6.302.

1) Identification of Agency and Contracting Activity:

Agency:

General Services Administration (GSA)

Federal Systems Integration and Management Center (FEDSIM)

Acting in support of: United States (U.S.) Army Intelligence and Security Command

(INSCOM)

Contracting Activity:

GSA FEDSIM Contracting Office (QF0B)

1800 F Street, NW

Washington, D.C. 20405

2) Nature and/or Description of Action Being Approved:

The FEDSIM Contracting Office, in support of the U.S. Army INSCOM, proposes to award a sole source Cost-Plus-Fixed-Fee (CPFF) (Term) contract for Military Accessions

Vital to the National Interest (MAVNI) and Screening and Vetting Enterprise, to

Absolute Business Solutions, Incorporated, dba, Absolute Business Solutions Corp.

(ABSc) under an open market contract.

The purpose of this exception to other than full and open competition contract is to provide interim support to allow INSCOM and GSA FEDSIM adequate time to execute a competitive contract and minimize service disruption to INSCOM’s MAVNI and screening and vetting programs. Other direct costs (ODC), tools, and travel will be executed on a cost reimbursable basis.

The proposed Period of Performance (PoP) for the contract is a 10-month base period from September 30, 2018 to July 29, 2019, with an estimated value of . This based period will be followed by one, two-month option period with an estimated value of . The total estimated value of the requirement is .

3) A Description of Supplies/Services Required to Meet Agency’s Need:

INSCOM HQ and US Army 902 nd

Military Intelligence group (902D MI GRP) require continuous support to their counterintelligence (CI) and security screening and vetting

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Version 3/15/16 missions. These missions require personnel with unique CI and analysis skills and Top

Secret (TS)/Sensitive Compartmented Information (SCI) clearances.

The products and services will be performed under the following task areas:

Task 1: Provide Program Management: The contractor shall provide management and oversight of all activities performed by contractor personnel, including subcontractors, to satisfy the requirements identified in the performance work statement. The contractor shall also complete short-suspense actions in response to urgent Government requirements.

The contractor shall provide training support including developing training materials and conducting training for newly hired/assigned Government employees to perform all required tasks.

Task 2: Provide Interview and Screening/Vetting Support: The contractor shall provide CI and/or security screening and vetting support. This screening/vetting support includes in-person interviews, coordination, deconfliction, and liaison with lateral and higher Commands to include: CI, Counterterrorism (CT), Law Enforcement (LE), Human

Intelligence (HUMINT), security, and other Federal, DoD, DA, and Intelligence

Community agencies and organizations. The contractor will also perform support tasks to

CI and/or security investigations, operations, activities, and Threat Awareness and

Reporting Program (TARP) requirements.

Additionally, the contractor shall support coordination and scheduling of interviews and screenings as well as the preparation of reports, products, summaries, and database entries in the appropriate system and/or format, in accordance with established standard operating procedures (SOPs). The contractor shall be required to complete short-suspense actions in response to urgent Government requirements.

Task 3: Provide Analytical Support: The contractor shall provide all-source analysis, CI analysis, and operational research and systems analysis. This analysis will use Non-

Classified Internet Protocol Router (NIPRNet), the Secret Internet Protocol Router

Network (SIPRNet), and Joint Worldwide Intelligence Communications System (JWICS) systems, to conduct analysis in support of analytical products and assessments and to perform required screening and vetting activities, to include CI, Cyber, CT, Security, Insider Threat, Force Protection (FP), Foreign Intelligence Entity (FIE), investigations, operations, and interviews, in the form of reports, trend analyses, data queries, finished intelligence products, research, briefings, white papers, and other products as required in accordance with established SOPs, protocols, and requirements.

Analytical support will also include communication of analytic findings in written assessments, formal analytic notes, briefings with graphics, written inputs to designated intelligence products or responses to Requests for Information (RFIs), and informal and formal verbal briefings and participation in working groups, conferences, and one-on-one sessions with consumers of intelligence information. The contractor shall be required to complete short-suspense actions in response to urgent Government requirements.

Task 4: Provide Operational Planning Support

The contractor shall provide operational planning support to assist INSCOM with the

Military Decision Making Process (MDMP) for the MAVNI and Screening and Vetting

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Enterprise. The contractor shall provide analysis and recommendations to integrate processes and staff multiple Army and DoD organizations in support of planning and tracking MDMP requirements. The contractor shall also develop and manage plans, battle rhythms, and other mission management, synchronization, assessment and development tools.

Task 5: Provide Database, Network Administration and IT Support

The contractor shall manage, maintain and develop government owned SharePoint or other government identified portals and databases to support MAVNI and Screening and

Vetting Enterprise. Contractor SharePoint and database support will include new configuration and capability development, installation, maintenance, management, upgrades and migration as needed.

The contractor shall also work with Army and DoD IT organizations to provide the

Network Administration and IT Support required by MAVNI and Screening and Vetting

Enterprise.

Task 6: Provide Field Interviews, Analysis, and IT Support

The contractor shall conduct CI and/or security interviews and required analysis and associated support at CONUS and OCONUS field locations.

This field support also includes Network Administration, IT, and Program Management support required to setup, manage and maintain field locations and IT systems required to conduct field CI interviews at the locations specified.

4) An Identification of the Statutory Authority Permitting Other Than Full and Open

Competition:

This sole source contract will be awarded pursuant to the authority of 41 United States

Code (U.S.C.) 253(c)(2) as implemented by FAR 6.302-2, Unusual and compelling urgency. The agency need for the services is so urgent that providing a fair opportunity would result in unacceptable delays leading to serious injury to the government. The mission and contractual history that led to the unusual and compelling requirements follows:

INSCOM awarded TO W911W4-14-D-0012-0007, to ABSc under the authority of FAR

16.505(b)(2)(i)(A) with a PoP from April 7, 2017 to February 28, 2018. This TO provided analytical and CI/Security interview support as well as IT administrative support to INSCOM and 902D MI GRP for the screening and vetting of a backlog of

MAVNI population members as required by Undersecretary of Defense (USD) of

Personnel and Readiness (P&R) memorandum dated September 30, 2016, Subject:

Military Accessions Vital to the National Interest Pilot Program Extension. The TO supported CI and security interviews and analysis for MAVNI Service Members.

This MAVNI population was made up primarily of awaiting accession into the Army with approximately that were already Army service members. In May

2017 the Secretary of Defense placed a temporary hold on the Interview and Screening portion of the TO while reviewing the early program results, dealing with political concerns, and making policy determinations. Interviews and screening resumed in

August 2017.

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To continue its support of the MAVNI program, INSCOM planned to award a competitive TO after W911W4-14-D-0012-0007. In September 2017, six months prior to the end of the PoP, INSCOM began to plan the competitive contract. In preparation of the competitive TO, INSCOM developed an entire acquisition package including

Performance Work Statement (PWS), Independent Government Cost Estimate (IGCE), Justification & Approval (J&A), and Market Research. INSCOM arranged an acquisition kickoff meeting with ACC-Warren for the week of October 16, 2017. This requirement was based on early information from anticipated guidance on the MAVNI program from the Secretary of Defense. INSCOM received and incorporated multiple drafts of the guidance into the acquisition strategy. However, because policy drafts and mission requirements varied so significantly, INSCOM was advised to standby until the pending policy was published.

On October 13, 2017, DoD issued new and unexpected guidance that directed INSCOM to reduce the MAVNI mission by eliminating the requirement for interview and screening support, and instead reduced the mission focus to CI and security analysis on

MAVNI service members already in the Army who previously completed security and suitability screening, prior to the USD 30 September 2016 policy. DoD policy directed that the analysis of MAVNI personnel would be completed within 180 days of issuance, with an additional requirement to complete follow-on CI and security protocols and activities for any information found during the analysis.

To support the updated DoD guidance and meet the 180 day deadline, INSCOM stopped its acquisition planning for a competitive enterprise solution and awarded a second non-competitive TO, W911W4-14-D-0012-0008, to ABSc. This TO is ongoing and supports critical CI and security analysis of the existing MAVNI population. This analysis identifies and protects the Warfighter from security and insider threats. The PoP of this

TO was from January 11, 2018 to April 30, 2018. INSCOM exercised the six month option to extend services pursuant to FAR 52.217-8, extending the PoP to October 31, 2018.

W911W4-14-D-0012-0008 was justified as urgent and compelling in response to the changing security, political and legal climate. The publicity of the MAVNI program and a temporary halt to MAVNI screenings introduced a heightened risk of insider threats.

Essentially, the increased scrutiny and potential reduction of the program could accelerate any planned adverse actions.

The CI and security analysis of the additional MAVNI service members demonstrated an ongoing need for continued CI and Security Analysis and support functions on the MAVNI population. This analysis and support is responsible for identifying CI and security threats actively within the U.S. Army for immediate action.

During performance of W911W4-14-D-0012-0008 base period from January to April

2018, INSCOM identified insider and security threats that required additional review.

INSCOM began educating leadership on the developing information and advocating for a long term Enterprise Screening and Vetting solution. INSCOM requested for

Headquarters Department of the Army (HQDA) to explicitly define INSCOM future responsibilities for MAVNI and other similar populations. To support this request, INSCOM conducted a Mission Analysis including a mission planning conference in

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October 13, 2017; Task Order W911W4-

14-D-0012-0008.

In addition to the sole source bridge acquisition activities, INSCOM conducted a Mission Analysis on the results generated through the support services provided by Task Order W911W4-14-D-

0012-0007. This information was provided to the HQDA to assist with the development of INSCOM’s future role and responsibilities for the MAVNI program.

January to April 2018 During performance of W911W4-14-D-

0012-0008, INSCOM identified insider and security threats that required additional review. INSCOM began educating leadership on the developing information and advocating for and

Enterprise Screening and Vetting solution.

April 23, 2018 INSCOM contracted GSA FEDSIM to arrange a meeting to discuss its requirements.

May 9, 2018 INSCOM met with GSA FEDSIM to discuss the requirement and move forward with acquisition planning.

July 2, 2018 GSA FEDSIM received waivers for a bridge contract and competitive requirement. At this time, GSA FEDSIM evaluated acquisition alternatives and determined there was not adequate time for a competitive award by the end of the

PoP for W911W4-14-D-0012-0008.

August 8, 2018 INSCOM received definitive guidance for its screening and vetting mission.

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CONCERNS.

October 31, 2018 Task Order end date for W911W4-14-D-

0012-0008; support services to MAVNI screening and vetting program end.

This bridge contract must be awarded to ABSc to support INSCOM in its effort to meet the unusual and compelling circumstances leading to the issuance of

; delay in award of this bridge contract would result in serious injury to the

Government in terms of interruptions of critical security analysis and vetting activity that creates undue risk to the Warfighter. This bridge contract will allow adequate lead time for the pre-award, source selection and award activities required for the competitive acquisition with ample transition time after award that will provide INSCOM and 902D

MI GRP with a flexible contract vehicle that can meet its current and future requirements.

ABSc is currently the only contractor that can assume this mission without unacceptable delays. This contractor is uniquely qualified to provide the TS/SCI cleared personnel to complete critical screening and vetting support tasks, in a timely and accurate manner.

ABSc is currently supporting Army INSCOM and is uniquely familiar with INSCOM and 902D MI GRP practices, processes, procedures and systems. Any other contractor will need a transition period with the outgoing contractor, become familiarized with the mission, processes and procedures, establish a robust recruiting base and bring people on board immediately. At a minimum, gaining proficiency in this type of work requires two months of intensive hands-on training. It is not reasonable to assume a new contractor could obtain the necessary cleared, trained and proficient workforce capable of accomplishing the MAVNI mission before October 31, 2018. This knowledge and expertise is crucial for the successful, accurate and timely accomplishment of INSCOM’s screening and vetting missions. Therefore, this sole source bridge needs to be procured of the unusual and compelling nature of the evolving Screening and Vetting Enterprise

Mission.

5) A Demonstration that the Proposed Contractor’s Unique Qualifications or the

Nature of the Acquisition Requires Use of the Authority Cited:

INSCOM, 902 MI GRP and subordinate commands require the submission of accurate and timely screening results to the U.S. Army and results used for suitability determinations that influence U.S. Army and U.S. Army Reserve end strength. Failure to meet these mission requirements would result in critical to security risks to U.S. Army personnel and technologies, and risks the U.S. Army’s ability to meet its congressionally mandated end strength, and annual accession requirements. Any delay will adversely impact HQ INSCOM’s ability to identify and mitigate security threats within the U.S.

Army.

A delay or stop of work on MAVNI mission contract support could have serious security implications. Any contract delays would likely require 902D MI GRP to surge organic

Army assets and resources to the MAVNI mission; this effectively shifts focus from

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902D’s mandated CI mission sets to assume significant risk to the nation’s critical assets, technologies, and security.

ABSc is uniquely qualified to avoid delays and maintain the current processing workload without rework, eliminating inefficiencies and reducing risks of inaccurately completed work packages. The contractor’s mission experience, capabilities current staff of TS/SCI cleared employees, and understanding of the mission requirements, processes and procedures and qualifications which formed the basis for this justification below:

a. TS/SCI Cleared Personnel: All primary screening, vetting and analysis on the incumbent contract are completed at a TS/SCI Level. Interim TS/SCI clearance is not acceptable. Any newly hired contractor personnel would be given interim security clearances. Personnel with interim clearance will not have adequate access to perform the necessary functions required to complete INSCOM’s screening and vetting mission. There is not adequate time to transition to new contractor personnel that requires a waiting period for TS/SCI access without delays or stoppages of INSCOM’s critically important work.

b. Experienced Contractor Support: For all on-going work a contractor would require unique knowledge of the organizational environment, knowledge of

INSCOM and 902D MI GRP practices, processes and procedures that have been evolving since the start of the MAVNI screening and vetting mission. The contractor unique system knowledge of MAVNI’s SharePoint system that it has developed and maintained since program inception. Even if a new contractor could provide an adequate number of personnel with active TS/SCI clearance, a new contractor would not have adequate time to conduct the transition-in activities required to support screening and vetting enterprise at the quality required without a lapse in service. During this lapse, 902D MI GRP would be required to divert organic resources which would have resulted in reduced or minimal CI and Counter-terrorism (CT) coverage of Defense and Army critical assets, technologies, intelligence, and security.

c. Acquisition Support: The award of one year this sole source contract, allows for

INSCOM and GSA FEDSIM to complete all required acquisition milestones for a competitive follow-on effort. The new competitive effort is expected to be awarded in fourth quarter of FY 2019 and tentative acquisition milestones dates will be posted on FEDSIM’s Opportunity website page shortly after the award of this sole source contract. Time will also be necessary to transition from the sole source contract to the competitive TO; a 60-day transition period is planned.

ABSc is uniquely qualified to continue INSCOM’s MAVNI and Screening and Vetting

Enterprise mission without unacceptable delays. The contractor is the only contractor with the personnel currently in place that possess the required security clearances and experience to support INSCOM. ABSc unique qualifications and expertise will achieve continuity of mission-critical services without interruption. Any attempt to replace ABSc with another contractor without adequate transition time to replace existing personnel contractor support would jeopardize the screening and vetting mission and, in turn, the rest of the warfighters supported by MAVNI and other populations. As a result, the government must award to ABSc to avoid serious injury to the government until the follow-on requirement is competitively awarded with an adequate transition-in period.

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6) A Description of Efforts Made to Ensure that Offers are Solicited From as Many

Potential Sources as Practicable:

As required by FAR Part 5.201, a synopsis was published on FedBizOpps to serve as the

Government’s notice of intent to sole source this acquisition. The NAICS Code for this effort is 541900 - All Other Professional, Scientific and Technical Services. As previously indicated, the Government is in the process of preparing a competitive acquisition to which this sole source contract will transition. As a result, the Government will not be soliciting offers from any sources other than ABSc for this sole source acquisition.

7) A Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable:

This sole source contract is planned to be solicited and awarded open market under FAR part 15 procedures. The Government has prepared an Independent Government Cost

Estimate (IGCE). The IGCE is based on historical information and the anticipated level of effort (LOE). The IGCE was developed using previously negotiated pricing for support to MAVNI screening and vetting.

Based on the data gathered, the Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable. The expectation of reaching a fair and reasonable price was determined through market research in order to determine best value for INSCOM. The total amount of funding required for the total estimated period of twelve months is approximately .

8) A Description of the Market Research Conducted and the Results or a Statement of the Reason Market Research was not Conducted:

For the reasons stated in this Justification, market research was focused on the contract vehicles available to ABSc for this sole source acquisition. Market research will be expanded to the greater marketplace for the competitive acquisition that will follow this sole source contract. FEDSIM conducted Market Research to identify any GSA contract vehicles the incumbent, ABSc, holds. The result of this research revealed that ABSc is not a contract holder on any GSA contract vehicle, hence the need to pursue this open market sole source contract.

The government must award to the incumbent to avoid serious injury due to the unusual and compelling urgent circumstances outlined in this justification. ABSc has demonstrated they are uniquely capable of providing the services required by the interim contract, and can do so without interruption to the program schedule. Based the urgent, unusual and compelling need for the services required will satisfy agency requirements, awarding to ABSc is in the best interest of the Government.

9) Any Other Facts Supporting the Use of Other Than Full and Open Competition:

All relevant facts have been identified and discussed elsewhere in this justification.

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12) Contracting Officer Certification that the Justification is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

I certify that this justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that an other than full and open competition approach is in accordance with the requirements and is in the best interest of the Government.

Frank Bottalico Date

Contracting Officer

FEDSIM Acquisition, Army/Navy

Final Approval

I certify that this justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that an other than full and open competition approach is in accordance with the requirements and is in the best interest of the Government.

Tom Howder

GSA, Head of Contracting Activity