HQ003420F0111P00006_LSJ_Redacted.pdf
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DEPARTMENT OF DEFENSE
WASHINGTON HEADQUARTERS SERVICES
1155 DEFENSE PENTAGON
WASHINGTON, DC 20301-1155
Control No. WHS-2023-1642
JUSTIFICATION FOR LIMITED SOURCE JUSTIFICATION (LSJ)
UNDER FEDERAL ACQUISITION REGULATION SUBPART 8.4
1. AGENCY AND CONTRACTING ACTIVITY:
Agency: Office of the Undersecretary of Defense for Research & Engineering (OUSD(R&E)), Science & Technology (S&T) Futures, Technology Innovation & Industrial Base, Manufacturing Technology (ManTech)
Contracting Activity: Department of Defense (DoD), Washington Headquarters Services (WHS), Acquisition Directorate (AD)
2. DESCRIPTION OF ACTION:
WHS/AD has prepared this memorandum as justification for the use of other than full and open competition procedures to modify an existing task order GS-35F-494GA / HQ003420F0111 to extend services for at most 12 months. Limiting sources in this case is justified under (FAR) 8.405-6(a)(1)(i)(A) which allows for limiting sources where an urgent and compelling need exists and 8.405-6(a)(1)(i)(C) which allows for limiting sources in the name of economy and efficiency when the new work is a logical follow-on to a competed FSS order.
The purpose of this action is to modify order by extending the current period of performance to add one six-month option period (option period three), and to provide for the six-month option to extend services in accordance with FAR Clause 52.217-8, Option to Extend Services. This modification would increase the contract value by approximately $2,813,547.70, from $6,262,588.25 to $9,076,135.95. This modification would affect the duration of the order, but not the substance or the number of FTEs
On October 25, 2019 WHS/AD issued a request for quote (RFQ), No. 1400966 to obtain program support services for the Manufacturing Technology Program (ManTech). The solicitation was issued against the Federal Supply Schedule using the procedures of FAR Subpart 8.4 and full and open competition. On March 13, 2020 WHS/AD awarded order GS-35F-494GA / HQ003420F0111 to Barbaricum. The original contract was valued at $1,873,543.64 and consisted of a base year and two one-year option periods.1 The PoP will expire on March 15, 2023.
Since award, OUSD(R&E) has experienced significant changes. Through the realignment of the organizations under the OUSD(R&E), ManTech’s program mission has grown from ~$100M, on average over $185M per year since award, and is expected to expand by 191%+ in fiscal year (FY) 2023 based on the current Congressional appropriations plan for ManTech. The ManTech Program is responding to address the National Strategy for Advanced Manufacturing Report to enable transitioning of advanced manufacturing processes and technologies to increase Manufacturing Readiness Levels (MRLs) to higher MRLs through the scale up of advanced manufacturing methods, development of related tools, and application of secure supply chains for the defense industrial base.
WHS/AD is seeking to modify the current order to assist ManTech in bridging the gap while it adjusts to the rapidly increased scale of its mission. The strategy for this modification would be to extend the PoP of the existing order by no more than 12 months by adding one six-month option period (option period three) and providing for a six-month option to extend services in accordance with FAR clause 52.217-8. This would extend the end of the period of performance to March 15, 2024.
This modification will allow for a continuation of the ManTech’s program support services without interruption.
It will also provide the program office the necessary time to assess market conditions for the upcoming recompete efforts in support of their exponential program growth, where hundreds of millions of Congressional dollars are being
1 The original award also provided for a -8, but the -8 was not evaluated at the time and was, therefore, not usable.
allocated to support increasing tasks, and to accommodate a new reorganization, which will include tasks from additional program offices. The Government intends to start the recompete process for this requirement in FY 2023 soon after the new third option period and full six-month extension allowed under FAR clause 52.217-8 are exercised.
Table 1: Existing and Proposed Periods of Performance (highlighted) with Funding Amounts
Performance Periods Performance Period Dates Amount Base Period 16 Mar 2020 – 15 Mar 2021 $ 1,873,543.64 Option Period I 16 Mar 2021 – 15 Mar 2022 $ 2,008,732.12 Option Period II 16 Mar 2022 – 15 Mar 2023 $ 2,380,312.49 Option Period III 16 Mar 2023 – 15 Sep 2023 $ 1,406,773.85 6-month extension IAW 52.217-8 16 Sep 2023 – 15 Mar 2024 $ 1,406,773.85 Base + All Options 16 Mar 2020 – 15 Mar 2024 $ 9,076,135.95
3. DESCRIPTION OF SUPPLIES/SERVICES:
The Office of Secretary of Defense (OSD) ManTech Program is part of the DoD Manufacturing Technology Program authorized under 10 United States Code (U.S.C.) § 4841. The ManTech Program focuses on crosscutting defense-manufacturing needs that are beyond the ability of a single service. This program addresses and stimulates the early development of manufacturing processes and enterprise business practices concurrent with science and technology development to achieve the largest cost-effective impact and to facilitate developments to enable delivery of advanced manufacturing capabilities to support our warfighters.
The ManTech Program manages the investment portfolio of more than $250 million per year to create and sustain a manufacturing innovation ecosystem via activities within three projects:
(1) The Manufacturing Science & Technology Program (MSTP) focuses on crosscutting defense manufacturing advancements and stimulates early development of manufacturing processes and enterprise business practices.
(2) The nine current DoD Manufacturing Innovation Institutes (MIIs), create and provide public and private partnerships with members from industry, academia, and federal and state governments that together mature manufacturing processes, build out a supporting ecosystem – all a part of the government-wide Manufacturing USA network.
(3) Manufacturing Education and Workforce Development (M-EWD), which provides strategic leadership of advanced manufacturing talent development within the Defense Industrial Base.
ManTech currently only has one Federal civilian assigned to direct the ManTech Program; therefore, these contractor support services are vital to the execution of ManTech’s mission and the ManTech Program. The contractor currently provides all personnel, supervision, and non-personal services necessary to complete the following tasks:
(1) Coordinate administrative program activities to meet the strategic mission of ManTech, including meetings, travel schedules, and routing of documentation for internal and organizational review and approval.
(2) Deliver financial management support to execute and track program funding across multiple program elements and project codes.
(3) Develop and manage strategic communications for the unique requirements of all three DMS&T projects.
(4) Provide MSTP and Interagency portfolio support to include topic development, project oversight, vetting projects ideas for crosscutting applicability, and coordinating stakeholder meetings across the Military Services and Defense Agencies.
(5) Sustain M-EWD program initiatives driven by the ManTech M-EWD strategy, portfolio, and emerging White
House initiatives.
(6) Facilitate cybersecurity resiliency for Small and Medium Manufacturers (SMMs) including implementation of policy and legislation that requires the development of tools, technology, and training to support SMMs.
(7) Add surge support for program activities that must be expanded due to the addition of Congressional funds to the President’s Budget and/or expansion of related manufacturing initiatives that increase the ManTech Program workload.
(8) Contract support for Other Direct Costs such as travel, printing, shipping, and purchase of items (e.g., conference displays) required for program support.
4. CIRCUMSTANCES JUSTIFYING LIMITED SOURCES:
In accordance with 8.405-6(c) this action is conducted under the authority of the Multiple-Award Schedule Program. This limited source justification is authorized under FAR 8.405-6(a)(1)(i)(A), and 8.405-6(a)(1)(i)(C).
FAR 8.405-6(a)(1)(i)(A) provides that limiting sources may be justified where an urgent and compelling need exists and where following competitive procedures would result in unacceptable delay. The need for the services that will be provided under this modification is urgent and compelling.
ManTech has grown more rapidly than WHS/AD and the customer were able to predict, increasing by almost
200% in FY23 with hundreds of millions of dollars added by Congress and Program Decision Memorandum (PDM) decisions. Any gaps in support services caused by competition at this time would cause ManTech to be unable to execute its mission effectively in accordance with 10 U.S.C. § 4841; meet OSD Comptroller benchmarks for program funding execution; meet the intent of the President’s Budget for advanced manufacturing; or respond to current and future significant Congressional program requirements. ManTech’s current team does not have the resources necessary to support the DoD and White House initiatives in biotechnology, hypersonics, education and workforce development, and other DoD critical technology areas without continuous contractor support. A loss or gap in program support would lead to severe mission degradation and probable failure.
FAR 8.405-6(a)(1)(i)(C) provides that limiting sources may be justified where the new work is a logical follow-on and the original order was not issued under limited procedures. The original order was an FSS order fully competed under Part 8 procedures. The work provided for in this modification is a logical follow-on. It is merely a continuation of the work performed under the original requirement and remains substantively within the original General Services Administration (GSA) Federal Supply Schedule (FSS) executed order.
Impact Statement: ManTech conducting a recompete effort at this time could have serious mission implications. A six- to eight-month break in service would cause immediate mission failure. Without maintaining the current support services on this current order, the risk to the Government sustaining quality level support and meeting the needs of Congress is extremely high.
5. BEST VALUE DETERMINATION:
It is anticipated that the pricing for this modification will be fair and reasonable, as previously determined under the terms and conditions of this order in conjunction with Barbaricum’s GSA FSS rates. FAR 8.404(d) states that “Supplies offered on the schedules are listed at fixed prices. Services offered on the schedules are priced either at an hourly rate, or at a fixed price for performance of a specific task (e.g., installation, maintenance, and repair).” While GSA has determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates through their FSS’ to be fair and reasonable, the Contracting Officer still reviewed the market to ensure award of a third six-month option period and the full six-month option to extend services are the best value for the Government.
Since there is no change to the scope of tasks being extended by way of this proposed modification, the analysis in Table 2 below looked at the rates that are on the current order (HQ003420F0111), compared them with the current contractor’s GSA rates and two other Offerors (Barbaricum (Awardee), Eccalon (Offeror 1), Teracore (Offeror 2)) who proposed on the original effort. The analysis shows that the current rates on order are still lower than what is available through the current marketplace. The labor categories listed are necessary to maintain continuity of services.
Table 2 - GSA Scheduled Rates
[Table intentionally removed for Redaction]
6. MARKET RESEARCH:
General market research conducted by ManTech indicates that a post-COVID and highly inflationary environment in 2022 / 2023 presents a continued good universe of potential performers but portends increased costs for labor and travel. Market research by ManTech, and its parent organization S&T Futures, includes the following:
(1) ManTech met with GSA government Contract Specialists in the Office of Information Technology Category to discuss the requirement and had multiple discussions on how the GSA FSS program could be utilized to meet the requirement. ManTech discussed a range of possible schedules, Special Item Numbers (SINs), vendors and pricing with GSA Contract Specialists. GSA Schedule 70 132 99, Introduction of New Technology Services and/or Products, emerged as a good path forward to meet the needs of the requirement due to the innovative nature of ManTech and S&T Futures requirements. According to the GSA Contract Specialists, this SIN provides the most flexibility for product/service offerings and a wide latitude for solution-based pricing.
(2) ManTech internal discussions explored possible North American Industry Classification System (NAICS) codes that would fit the requirement and looked at current vendors and order prices to determine the appropriate size and scope of the effort. The results of this effort revealed NAICS code 541511, Computer Programming Services, NAICS code 541519, Other Computer Related Services, or NAICS code 541611, General Management Consulting Services, are all probable good fits due to the nature of the technical, information technology, and program management needs of the ManTech requirement.
(3) ManTech had discussions with Defense Innovation Unit, National Security Innovation Network (previously named the MD5 National Security Technology Accelerator), and the Office of Small Business Programs to get ideas on the best methods to engage non-traditional suppliers and to find innovative companies that could have extensive reach into these networks and could be better positioned to engage academia and the defense workforce.
(4) ManTech utilized the Small Business Administration Dynamic Small Business Search tool to locate capable companies. Given the niche type of company needed for this requirement, the search tool was not extremely helpful in narrowing the field of possible vendors through market research.
(5) Informal price analysis was conducted to compare market pricing with existing order costs to determine the most advantageous cost for the Government.
7. OTHER SUPPORTING FACTS:
Cost Assessment and Program Evaluation and Defense Management Advisory Group PDM decisions in FY21 and FY22 have increased the ManTech Program budget by almost $487M over FY23-FY28 – before the program sees anticipated Congressional adds that have historically ranged from $60M to $120M per FY since 2018. This significant Congressional interest in ManTech has almost doubled the program value in recent FYs. The additional unplanned funding brings increased demands for program support on top of the general program growth.
The current ManTech support services will be severely degraded without extending support to continue their critical requirements. This would result in undue harm to ManTech’s Program and the missions of the various organizations they support.
8. ACTIONS TO REMOVE OR OVERCOME ANY BARRIERS THAT LEAD TO THE RESTRICTED
CONSIDERATION BEFORE ANY SUBSEQUENT ACQUISITION FOR THE SUPPLIES OR
SERVICES IS MADE:
This limited sources action is a short-term solution. It is the Contracting Officer’s intent, in coordination with ManTech, to recompete this effort with an expected completion of the recompete award to be prior to March 15, 2024.
On February 15, 2023 the Contracting Officer posted a notice of intent (NOI) for this limited sources extension on SAM.GOV which closes on February 24, 2023. The NOI is to inform industry of the intent to award the limited source extension but to also provide the tentative timeline for the recompete effort. These recompete efforts need to be started almost immediately after execution of option period three and exercising the full six-month extension allowed under FAR clause 52.217-8. This is why this limited sources action is necessary to reduce risk to the ManTech mission, while providing time to compete a new effort. It will take at least six to eight months to develop / complete an acquisition package, solicit, award a new order, and provide sufficient time to get a new contractor transitioned-in to support mission requirements. This is based on the WHS/AD Procurement Acquisition Lead Times (PALT) timelines and previous acquisitions of similar size and scope. And again, that PALT does not account for the time necessary for ManTech to understand where its mission growth will go in the next three to five years. By only adding option period three for six months with the six-month option to extend services by way of modification to the current order, ManTech will have enough time to forecast their mission growth and it will provide the Government time to recompete a new, larger requirement. The new solicitation will establish a contract vehicle that is appropriate to support ManTech’s growing mission responsibilities.
9. If this acquisition is for new work as a logical follow-on to on original FSS, was the original order placed under the FSS ordering procedures?
☒ Yes, the original acquisition was issued on a competitive basis.
☐ No, a copy of the previous justification is attached. The actions to remove any barriers to competition cited on the previous justification ☐ were ☐ were not.
☐ Not Applicable. This is a new requirement.
CERTIFICATION
I, hereby, certify that the supporting data under my cognizance included in this justification are accurate and complete to the best of my knowledge and belief.
/S/ signature on file
/ Manufacturing Technology Date
/ Contracting Officer Rapid Prototyping Acquisition Branch
Date
REVIEW
Base on the foregoing, I reviewed this justification and recommend for approval.
/ Division Director Enterprise Research and Engineering Division
APPROVAL
This limited sources justification is approved.
/ Competition Advocate Acquisition Directorate
| JUSTIFICATION FOR LIMITED SOURCE JUSTIFICATION (LSJ) UNDER FEDERAL ACQUISITION REGULATION SUBPART 8.4 |
| 2. DESCRIPTION OF ACTION: |
| 3. DESCRIPTION OF SUPPLIES/SERVICES: |
| 4. CIRCUMSTANCES JUSTIFYING LIMITED SOURCES: |
| 5. BEST VALUE DETERMINATION: |
| 6. MARKET RESEARCH: |
| 7. OTHER SUPPORTING FACTS: |
| 8. ACTIONS TO REMOVE OR OVERCOME ANY BARRIERS THAT LEAD TO THE RESTRICTED CONSIDERATION BEFORE ANY SUBSEQUENT ACQUISITION FOR THE SUPPLIES OR SERVICES IS MADE: |
| CERTIFICATION |
| REVIEW |
| APPROVAL |
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