J&A_Redacted.pdf

Federal Acquisition Regulation Part 8

LIMITED SOURCE JUSTIFICATION AND APPROVAL

Consulting, Facilitation, Program and Project Management Services Industrial Security Field Operations (IO)

GS-00F-010CA/ HS0021-12-A-0003-0002-U04

Control Number: _18-016PR______

1. IDENTIFICATION OF THE REQUIRING AND CONTRACTING ACTIVITY:

a. Requesting Activity:

Defense Security Services Industrial Security Field Operation Office 27130 Telegraph Road Quantico, VA 22134

b. Contracting Activity

Defense Security Services Office of Acquisitions 27130 Telegraph Road Quantico, VA 22134

2. NATURE OR DESCRIPTION OF THE ACTION:

The purpose of this document is to obtain the necessary approvals for a limited source acquisition in accordance with Federal Acquisition Regulation (FAR) Part 8.405-6. “Limited source” in this case pertains to the restriction of competition to a sole source, Consulting, Facilitation, Program, and Project Management Services for the Defense Security Service (DSS) Industrial Security Field Office (IO).

Per FAR subpart 8.401, this acquisition is being conducted under the authority of the Multiple

Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.) and Title 40 U.S.C. 501, Services for Executive Agencies.

The procurement strategy is to issue a sole contract modification to extend the current contract order through General Services Administration (GSA) Advantage utilizing the e-Buy tool in accordance with FAR subpart 8.405-6(a)(1)(i)(B) to GS-001F-010CA.

3. DESCRIPTION OF SUPPLIES/SERVICE:

IO supports DSS’ mission to protect classified information and materials in the hands of cleared industry by ensuring compliance with the National Industrial Security Program Operating Manual (NISPOM) and Executive Order 12829. Additionally, IO works in partnership with facility security officers and Industry representatives to ensure the protection of classified information released under contractual obligations or research and development efforts. In order to continue to perform this mission in an evolving and increasingly complex environment, IO must continuously review, analyze, and update processes, procedures, organizational structure, and methods.

Currently, adversaries are successfully attacking cleared industry at an unprecedented rate. This threat is unparalleled in our nation’s history and directly affects everyone in the country. DSS has concluded that maintaining the status quo is simply not an option. In the past, DSS focused on the NISPOM to guide the agency’s oversight compliance actions. However, as a static policy manual, the NISPOM does not identify what national security information needs the most protection; address the methods being used by adversaries; or consider the vulnerabilities inherent in business processes. These reasons, coupled with the unprecedented threat to our national security information and technology, are the driving factors behind the need for change for DSS. Given this, over the past year DSS has been moving ahead with developing a

Consulting, Facilitation, Program and Project Management Services Industrial Security Field Operations (IO) new methodology, DSS in Transition (DiT), which is based on knowing the assets at each facility, analyzing threats to assets, identifying vulnerabilities, and recommending the appropriate countermeasures.

This new methodology will couple NISPOM compliance with a new intelligence-led, asset-focused, and threat-driven approach. It will allow DSS to work more effectively with cleared industry to design tailored security programs with the ultimate goal of helping to ensure that contracted capabilities, technologies, and services are delivered uncompromised.

These services, at this critical point, enable deployment of DiT, are deemed available only from one source in order to maintain the DiT continued development and DSS efforts to deliver the technology advantage uncompromised. Lack of ability to provide subject matter experts in the area of DiT and its major components or any other source would result in DiT deployment delays. Additionally, there would be substantial duplication of cost to the Government that is not expected to be recovered through best value competition; therefore resulting in unacceptable delays in fulfilling the agency’s requirements to deploy DiT early in the 2018 calendar year.

The contract extension is for a three-month base option period, and a three-month option. The estimated cost for the three-month base period extension is $335,196.80; the period of performance:

Base Period: 12/28/2017 through 03/27/2018 3 Month Option: 03/28/2018 through 06/27/2018

4. AUTHORITY AND SUPPORTING RATIONAL AND THE PROPOSED CONTRACTOR’S

UNIQUE QUALIFICATIONS

In accordance with FAR subpart 8.405-6(a)(1)(i), the applicable exception to placing this order on a competitive basis is FAR subpart 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. ICF Incorporated, LLC (ICF), currently is the only source capable of providing the services required at the level of quality required because the services are unique and highly specialized.

Currently, there is no other contract vehicle in place for the purpose of the IO to enable the deployment of DiT. This modification is necessary to continue these services without a break in service.

The modification will allow for continued service while a competitive acquisition is being completed. The current contractor, ICF, has detailed knowledge necessary to continue DiT support for the IO and is best suited to maintain the immediate short-term requirements to be accomplished while the competitive acquisition is completed.

The competitive acquisition is currently in the source selection process, which is why the modification effort is only necessary for a few months. The six-month period of performance will allow the current incumbent to continue DiT support services while the competitive recompete is completed and will provide time for appropriate on ramping and transition. The current contractor has the existing workforce and specialized capability already in place and can ensure continued performance without any delay because of their existing program knowledge, understanding off IO procedures, and access to the current DiT projects being worked. The current contractor’s performance has been deemed acceptable by the Contracting Officer’s Representative.

5. DETERMINATION OF BEST VALUE

A request for quote is being sent to ICF and it is anticipated the pricing will be fair and reasonable as determined under the terms and conditions of the original solicitation, HS0021-12-Q-0100. DSS expects

Consulting, Facilitation, Program and Project Management Services Industrial Security Field Operations (IO) to obtain additional discounts from ICF’s GSA price list, where pricing has already been determined to be fair and reasonable.

FAR subpart 8.404(d) (Deviation) states, “Supplies offered on the schedule are listed at fixed prices. Services offered on the schedule are priced either at hourly rates, or at a fixed price for performance of a specific task (e.g., installation, maintenance, and repair). GSA has determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, to be fair and reasonable for establishing the schedule contract. GSA's determination does not relieve the ordering activity’s contracting officer from the responsibility of making a determination of fair and reasonable pricing for individual orders, BPAs, and orders under BPAs, using the proposal analysis techniques at 15.404-1. The complexity and circumstances of each acquisition should determine the level of detail of the analysis required.” Based on the justification to continue with the current service provider, market research conducted via both open market and GSA’s Federal Supply Schedule, and by utilizing the streamlined procedures under FAR Part 8, the Contracting Officer has determined that the request for quote will result in a modification that represents the best value to the Government at the lowest potential price.

Leveraging DSS’ current use of the services provided by ICF, along with the competitive pricing available through their GSA contract, the Contracting Officer is confident in obtaining the best value for

DSS.

6. DESCRIPTION of MARKET SURVEY / EFFORTS TO OBTAIN COMPETITION

ICF currently is the only source capable of providing the essential DiT services at the level of quality required because the services are unique and highly specialized. The market research demonstrated that similar requirements are commercially available; however, due to the logical nature of this requirement and required consistency, issuing a modification to ICF is in the best interest of the Government.

7. ANY OTHER SUPPORTING FACTS

The current DiT projects that are being completed within IO will be discontinued without the provided support and resources that are needed to continue the critical processes and projects, with would result in undue harm to the DSS and the missions the DSS supports.

8. ACTIONS TAKEN TO REMOVE BARRIERS TO COMPETITION

The Office of Acquisitions is currently undergoing a source selection for a competitive award for the Consultation, Facilitation, Leader Alignment, and Strategic Collaboration support services in support of the DSS. This modification will provide the appropriate time required to fully compete this requirement and provide a transition period.

Consulting, Facilitation, Program and Project Management Services Industrial Security Field Operations (IO)

CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this justification and which form a basis for this justification are complete and accurate.

Requiring Activity/Program Management Office Certification

Printed Name: Matthew D. Roche

Title: Assistant Deputy Director Operations Organization Code: DSS-IO

Signature: Phone: 571-305-6621

Contracting Officer Certification

I hereby determine that the anticipated cost for this contract action will be fair and reasonable. I certify that this J&A is accurate and complete to the best of my knowledge and belief.

Printed Name: Ashley D. Maddox

Title: Chief, Contract Operations Organization Code: DSS-AQ

Signature: Phone: 571-305-6547