LSJ_52_217-8_v2.pdf

DEPARTMENT OF DEFENSE

WASHINGTON HEADQUARTERS SERVICES

1155 DEFENSE PENTAGON

WASHINGTON, DC 20301-1155

LIMITED SOURCE JUSTIFICATION

This acquisition is conducted under the authority of the Multiple Award Schedule Program

I. Identification of Agency and Contracting Activity [FAR 8.405-6(c)(2)(i)]

The contracting activity responsible for this Limited Source Justification (LSJ) is the Washington Headquarters Services, Acquisition Directorate (WHS/AD), 1155 Defense Pentagon, Washington, DC 20301-1155.

The requiring activity for this LSJ is the Office of the Department of Defense , Chief Information Office (CIO), 1155 Defense Pentagon, Washington, DC 20301-1155.

II. Description of the Action Being Approved [FAR 8.405-6(c)(2)(ii)]

The purpose of this action is to execute a modification to exercise the up-to-six-month extension of services in accordance with (IAW) FAR 52.217-8 for HQ0034-07-A-1010-0004. This task order was awarded to CACI Inc. Federal after a competition among five BPA holders for the following performance period:

• Base Period: 27 SEPT 2010 – 26 SEPT 2011

• Option Period One: 27 SEPT 2011 – 26 SEPT 2012

• Option Period Two: 27 SEPT 2012 – 26 SEPT 2013

• Option Period Three: 27 SEPT 2013 – 26 SEPT 2014

• Option Period Four: 27 SEPT 2014 – 26 SEPT 2015

Implementation of FAR 52.217-8, Option to Extend Services for a period of five months is necessary to bridge the gap between the current task order expiration and the performance start of a new multiple-award BPA and task order award. Although FAR 52.217-8 was included in the base BPA, the option was not negotiated as part of the task order award decision. As stated in GAO decision, B-401472 and FAR 6.001, exercising an extension under FAR 52.217-8 requires evaluation at the time of award, or a Limited Sources Justification, in order to meet the requirements of FAR Part 6 and the Competition in Contracting Act.

III. Description of Services Required to Meet the Agency's Needs [FAR 8.405-6(c)(2)(iii)]

The Defense Industrial Base (DIB) Directorate, Office of the DoD CIO, is THE DIB Program Office for the Department Of Defense responsible for managing all Cybersecurity and Information Assurance (CS/IA) requirements and activities, the goal of which is to protect critical DoD program and technology information that is resident, or transits, unclassified information systems and networks belonging to, or under the purview of, the private businesses and corporations that comprise the defense industrial base. This is in accordance with the authority in DoD Directive (DoDD) 5144.1 for directing the conduct of DIB CS/IA, as implemented by DoDI 5205.13, “Defense Industrial Base (DIB) Cyber Security/Information Assurance (CS/IA) Activities”. The CACI Corporation provides support to the DIB Program Office for analysis and policy development, in synchronizing various DoD and interagency cyber security stakeholders and protecting unclassified DoD program information on DIB networks, and support of web-based database applications and administrative management tools to manage the interaction with DIB Partners and government stakeholders. A key working partner is the Defense Cyber Crime Center (DC3), the operational focal point for the Defense Industrial Base Cybersecurity and Information Assurance Program, and operating under the Air Force Office of Special Investigations, IAW DoD D 5505.13E.

The requirement for the extension remains unchanged from the basic task order. Approval of this LSJ will result in execution of a contract modification to implement 52.217-8, Option to Extend Services for a period of five months. The task order expiration date will be extended from 26 SEP 2015 to 26 FEB 2016.

IV. Authority and Supporting Rationale [FAR 8.405-6(c)(2)(iv)]

The authority for permitting other than full and open competition for this acquisition is FAR 8.405-6(a)(1)(i)(B), “Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.”

CACI Corporation, the incumbent contractor, is the only readily capable source that can provide the highly-specialized services at the level of quality and expertise required in the short amount of time available. A disruption of any duration in these support services would significantly degrade the Defense Industrial Base Cybersecurity/Information Assurance (DIB CS/IA) Program's ability to complete mission-critical tasks.

1) The expertise needed to support the DIB CS/IA Program Office's knowledge management requirements - ensure synchronization of compliance and risk mitigation activities for approximately 127 Defense Industrial Base companies that have joined the Program -- cannot be easily replaced. Furthermore, the DIB CS/IA Program is likely to suffer adverse consequences if it experiences a gap in support at this critical juncture. CACI contractors represent roughly 25% of the DIB CS/IA Program's manpower and they are heavily engaged in the policy development and technical activities required to expand the program to meet Congressional mandates. CACI team members have significant experience with the development of the Program. They have demonstrated the ability to analyze legislative requirements and understand the operational environment. Additionally, they can adeptly analyze data from various sources, to include various sources and characteristics of cyber incidents, and recommend appropriate actions to ensure the day-to-day mission success of this Program Office. Risk mitigation and consequence management involve policy implications, technical defenses, and remediation actions. The DIB Program Office can best preclude, or minimize the risk of, mission failure by retaining the experienced incumbent CACI team.

2) Secondly, on an administrative security level, CACI is currently in a distinctive status since all personnel supporting the DIB CS/IA Program Office have successfully completed the adjudication process and hold the requisite clearance. A new contractor team would all have to submit applications for adjudication of all personnel for clearances which, on average, would take at least two to four months. The DIB's CACI support team has been able to build, over time, a qualified and cleared team that meets the current security needs.

If there is a break in service, the DIB CS/IA Program Office would be unable to complete mission-critical tasks, such as:

• Immediate response to all DIB company queries related to the DIB CS/IA Program

• Vetting of prospective DIB companies for participation in the DIB CS/IA program to ensure companies are legitimate cleared companies with U.S. personnel interfacing with the program.

• Coordinating with Defense Security Service to resolve security issues and maintain consistency in vetting and onboarding processes.

• Executing onboarding activities with potential and new DIB CS/IA participants:

responding to DIB hotline calls and questions from DIB Program participants, processing applications and agreements,

• Supporting policy development and implementation to include coordination with DoD CIO personnel and OSD Counsel via the Federal rulemaking process and ensuring compliance with recently enacted laws and regulations.

• Troubleshooting technical problems with program classified and unclassified web portals; facilitating DIBNet-S connections between DIB company and DISA (host)

• Developing and implementing an engagement program under which the Combatant Commanders can encourage DIB companies to join the voluntary DIB CS/IA Program.

• Facilitating and supporting DIB Outreach activities designed to increase awareness of and participation in DIB CS/IA Program activities among DIB companies.

• Conducting multimedia research to generate a list of potential Outreach events at which to inform new audiences about the Program.

• Tailoring DIB CS/IA Program introductory presentations for different audiences in support of the Program Director's outreach efforts.

• Collecting and coordinating DIB Program portal (DIBNet-U and DIBNet-S) requirements among government and industry stakeholders and approximately 979 users.

Testing new software developments to validate new portal capabilities.

• Managing and updating portal content, training personnel on portal usage, ensuring compliance with policies and agreements.

Mission failure in any of these areas is unacceptable as it would have a detrimental impact on DIB’s ability to provide the analytical efforts required to support Secretary of Defense objectives. A break in service creates a gap in the ability to manage all Cybersecurity and Information Assurance (CS/IA) requirements and activities

V. Representation of the Best Value [FAR 8.405-6(c)(2)(v)]

A determination of price fair and reasonableness will be made prior to execution of the modification to extend the services. Actions anticipated to ensure reasonableness of the price will be accomplished with the procedures contained under FAR 8.404(d). The Contracting Officer will also conduct price analysis IAW FAR 15.404-1 using historical prices paid to perform these efforts.

The Firm-Fixed Price monthly unit price for the extension will be the same as the option period four unit price of $109,590.4/month. The estimated value of the extension was calculated as follows: $109,590.40 x 5 months = $547,952.00. The IGCE also included $5,000 for Travel, resulting in a total estimate of $552,952.00. The Travel CLIN will be Cost-Reimbursable, and a reasonableness decision will be made at the point of expenditure via prior approval from the COR and IAW FAR 31.205-46, Travel Costs. In addition, an informal survey of the market was conducted with the Determination and Findings (D&F) to exercise the final option period, and the labor rates were found to be fair and reasonable.

VI. Description of Market Research [FAR 8.405-6(c)(2)(vi)]

Market research was conducted and it was determined that extending the contract term was in the best interest of the government until the requirement can be competed.

DoD CIO is in the process of restructuring its organization, mission, and work. CIO only recently understood that there would be a continuing need for this support. CIO’s requirements are currently in the pre-award phase and a solicitation will be forthcoming in the next couple of months.

Market research was completed for this requirement in the original acquisition strategy which explored multiple avenues of competition. The work was competed among this established BPA and its holders. However, the BPA has expired, and no new task orders can be issued against this vehicle. This requirement included clause 52.217-8 at time of award. The award was issued prior to DPAP’s direction requiring 52.217-8 evaluation at time of award. This work is for a short duration to ensure continuation of service while the follow-on requirement is competed.

Market research is currently being conducted for the follow-on contract which is in the pre-award stage. Market research would not influence the need for a sole source to the current contractor as this requirement is based on economy, efficiency and the need to have the continued services to meet DoD CIO’s mission and a break in service would result in unacceptable delays. Due to the transition time required, award of this requirement to a new vendor would introduce unacceptable risk as identified above in section IV of this document.

VII. Any Other Facts Supporting Facts [FAR 8.405-6(c)(2)(vii)]

The subject multiple-award BPA vehicle is expired, and no new task orders can be placed against it.

This short-term extension will enable the Government to maintain the current level of expertise and support without jeopardizing the mission pending award of a competitive follow-on contract.

This order extension is issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

VIII. Actions Taken to Remove or Overcome Barriers to Competition [FAR 8.405- 6(c)(2)(viii)]

Additional action will be taken to increase competition. The follow-on task order will be competed during the extension period after award of the new multiple-award BPA.

IX. Technical/Requirements Certification

I certify that any supporting data that is the responsibility of the requirements personnel and which form the basis for this justification is complete and accurate.

John A. Rolando Technical Representative DIB CS/IA Program

X. Contracting Officer Certification

I have reviewed the justification and find it to be accurate and complete to the best of my knowledge and belief.

Kellie E. Buck Contracting Officer

WHS/AD