Justification_for_EFO_TO2F_PM_signed_CO_Signed.pdf

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General Services Administration Federal Systems Integration and Management Center

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

UNDER IDIQ CONTRACTS

Task Order: GSQ0016AJ0087

FEDSIM PROJECT NUMBER HS00958

The General Services Administration (GSA) makes this Justification for the issuance of an Exception to Fair Opportunity task order modification pursuant to Federal Acquisition Regulation (FAR) 16.5.

a. Identification of Agency and Contracting Activity:

Agency:

General Services Administration (GSA) Federal Systems Integration and Management Center (FEDSIM) Acting in support of: U.S. Department of Homeland Security (DHS)

Contracting Activity:

GSA FEDSIM Contracting Office (QF0B) 1800 F Street, NW Washington, D.C. 20405

b. Nature and/or Description of Action Being Approved:

This Justification authorizes an Exception to Fair Opportunity modification, based on the authority provided in FAR 16.505(b)(2)(i)(A) (The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays), to an existing Alliant GWAC task order (TO) to provide Continuous Diagnostics and Mitigation (CDM) services on a cloud-based Shared Services Platform (SSP) to all non-Chief Financial Officer (CFO) Act Government agencies.

c. Description of Supplies/Services and Estimated Value:

TO GSQ0016AJ0087 was awarded to ManTech Advanced Systems International, Inc., of Fairfax, VA, on June 29, 2016. The TO was intended to provide CDM services on a cloud-based SSP to forty-seven (47) non-CFO Act Agencies. The proposed modification will add one year to the TO to allow ManTech to continue the requirement to provide CDM services on a cloud-based SSP to forty-seven (47) non-CFO Act agencies, expand the SSP service to cover additional non-CFO Act agencies which have joined the CDM program since the TO was awarded, and allow time for FEDSIM to conduct a competitive follow-on procurement. The modification will also provide for a 6 month option period in order to allow for an orderly transition to the competitive follow-on TO and to provide for continued TO performance in the event of a protest. The estimated value of the modification is $18,089,477.

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d. Identification of the Exception to Fair Opportunity and Rationale:

This Justification is being prepared as required by FAR 16.505(b)(2)(ii)(B):

The rationale is:

The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays (FAR 16.505(b)(2)(i)(A)).

GSA FEDSIM, DHS and an estimated 75 non-CFO Act agencies have an urgent need for cloud-based CDM services that comply with numerous federal security standards (NIST moderate controls, FEDRAMP moderate controls, DHS 4300A moderate controls, and 66 additional NIST High Confidentiality and High Integrity controls). DHS has made a commitment to the White House that it will implement these services NLT July 2019.

ManTech is the only contractor capable of supplying these services within the required timeframe. Providing a fair opportunity would result in unacceptable delays in implementing the services and would cause DHS to fail in meeting its commitment to the White House.

TO2F was awarded as a Time and Materials (T&M) TO and, at the time of TO award, the Government had a limited understanding of the difficulty involved in building and accurately pricing a CMaaS private cloud shared service, which drove cost overruns in the base year of the TO. These overruns were caused by difficulty in obtaining accurate agency network configuration information prior to award and a limited understanding of the difficulty of building and accurately pricing a CMaaS private cloud shared service, which had not been attempted in any previous CDM TO. In December 2017, FEDSIM modified TO2F and changed the labor contract type from T&M to FFP in Option Period 1, in order to encourage the Contractor to deliver the shared service solution. While this modification resulted in improved technical performance on the TO, it also required a substantial portion of the Option Period 2 ceiling to be moved forward to Option Period

1. The SSP solution also had to be modified to include security changes regarding access to the SSP, virtual desktop infrastructure and safeguarding data at rest. A mandatory third party assessment organization security assessment review identified the need for several security upgrades. This required ManTech to implement data at rest encryption and storage area network encryption and procure and install additional firewalls. As the ceiling to fund the previously discussed FFP CLIN and the aforementioned security upgrades was brought forward from Option Period 2, and the remaining Option Period 2 ceiling did not allow the contractor to complete implementation at all 47 agencies, DHS and FEDSIM chose to focus on achieving initial operational capability for the first 4 of 47 agencies.

The additional year authorized in this Justification is required in order to allow ManTech to complete implementation at the remaining 43 of 47 agencies and begin implementation at additional agencies, which have joined the CDM program since the TO was awarded.

ManTech has already conducted significant preparations for (and in some instances has begun) installing the solution at the remaining 43 of 47 agencies and is poised to begin implementation at the additional agencies. Over the past two years, ManTech has conducted extensive surveys of the IT infrastructure at the remaining 43 of 47 agencies and identified the unique requirements for implementing the solution at each agency. If a competitive procurement was conducted at this time, and a vendor other than ManTech

FEDSIM is a Client Support Center housed within GSA, FAS, AAS Page 3 was selected, that vendor would have to receive, study and verify ManTech’s data and implement the solution based on ManTech’s technical approach. This would introduce additional, unnecessary cost, technical, and schedule risk and would not encourage competition for the follow-on procurement.

FEDSIM anticipates that the remaining ceiling on the TO will be exhausted in January 2019, and that approximately 1 year will be required to conduct a competition for the follow-on TO. If this Justification is not approved, DHS and the existing 47 non-CFO Act agencies will experience a lapse in service. Implementation at the remaining 43 of 47 agencies will be further delayed, and the timeline to begin implementation at the new agencies will be extended. The additional year requested in this justification is essential to establishing a complete solution that can be transitioned with a competitive order. The additional year will enable ManTech to complete deployment of the SSP solution for the remaining 43 of 47 agencies covered under the existing order, extend SSP coverage to the additional agencies, and allow time for FEDSIM to conduct the competition for the follow on TO.

This justification also authorizes an additional 6 month option period. FEDSIM exercised option clause 52.217-8, Option to Extend Services, in September 2018 in order to provide ceiling for continued TO performance. The additional 6 month option period authorized in this justification is required in order to facilitate an orderly transition to the competitive follow-on TO and to provide for continued TO performance in the event of a protest.

e. Determination That the Anticipated Cost is Fair and Reasonable:

ManTech will provide a proposal, including certified cost or pricing data, as required by FAR 15.403-4 a (1)(iii). ManTech’s proposal will be evaluated by experienced cybersecurity subject matter experts. The contract specialist will perform cost and price analysis as required by FAR 15.404. The contracting officer will make a determination that the task order pricing is fair and reasonable after reviewing the technical evaluation and cost and price analysis.

f. Other Facts Supporting the Justification:

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

g. Statement of Actions:

As stated in paragraph (d) above, the Government is planning a competitive follow-on TO to support the Group F agencies. This modification will allow the Government to plan and execute a follow-on competition.

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h. Certification by Technical or Requirements Personnel:

I hereby certify that the supporting data is accurate and complete.

Bob Hribar Date Senior Project Manager

i. Signature of Authorized Official(s):

I hereby certify that the Justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that the exception to fair opportunity is in accordance with the requirements, and is in the best interest of the Government.

Greg Lee Date Contracting Officer

Tom Howder Date Head of Contracting Activity