DITMAC_Specialized_Consulting_Services__J A_-_Redacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

Sole Source

DITMAC Specialized Consulting Support and Research Support Services

HS0021-16-RFQ-DITMAC

Control Number: 16-008JA

FOR OFFICIAL USE ONLY

PROCUREMENT SENSITIVE

SOURCE SELECTION SENSITIVE

REFERENCES:

In accordance with FAR 6.303, for acquisitions of commercial items exceeding simplified acquisition threshold the contracting agency is required to prepare a sole source justification using the format at FAR 6.303-2, as provided below.

DOCUMENTATION:

(1) Identification of the agency and the contracting activity.

Requiring Activity:

Defense Security Service (DSS) Defense Insider Threat Management and Analysis Center (DITMAC) 1550 Crystal Drive, Suite 201 Arlington, VA 22202

Contracting Activity:

DSS Office of Acquisitions (AQ) 27130 Telegraph Road Quantico, VA 22314

(2) Nature and/or description of the action being approved.

The purpose of this document is to obtain necessary approvals for a sole source acquisition in accordance with FAR 6.302-1(a)(2)(iii)(A). Competition is limited to only one responsible source and no other supplies or services will satisfy agency requirements.

The procurement strategy is to issue an open market Request for Quote in accordance with FAR Part 12 Acquisition of Commercial Items and FAR 13.5 Simplified Procedures for Certain Commercial Items.

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The objective of this effort is to acquire essential specialized consulting and research support to enable the DITMAC to achieve its vital mission as defined by Office of the Under Secretary of Defense for Intelligence (OUSD(I)). This support will position the DITMAC to navigate from provisional initial operating capability (IOC) to IOC and finally full operating capability (FOC). The Vendor shall provide specialized consulting and research support services for the DITMAC, to include the following six major areas of focus: 1) Strategic Communications Support; 2) Strategic Plan Implementation; 3) Leadership Development; 4) Tabletop Exercises; 5) Decisional Analysis Risk Tool (DART) Implementation; and 6) DITMAC System of System (DSoS) program support.

DITMAC will provide the Department's first truly quantitative and qualitative analytic overview of insider threat related risk trends, which will significantly inform future decision-making. The DITMAC follows an analytics-driven approach to assessing risk and endeavors to employ a rigorous science-driven approach to addressing risk and risk mitigation as it pertains to Insider Threat in the Department. The Vendor shall provide critical specialized consulting and research support services, to include relevant subject matter expertise to enable the DITMAC to achieve its mission.

The Firm Fixed Price (FFP) contract will be for a period of performance of July 15, 2016 to July 14, 2017;

the estimated cost is $4,127,018.45.

DITMAC Specialized Consulting Support and Research Support Services

HS0021-16-RFQ-DITMAC

Control Number: 16-008JA

FOR OFFICIAL USE ONLY

PROCUREMENT SENSITIVE

SOURCE SELECTION SENSITIVE

(4) An identification of the statutory authority permitting other than full and open competition.

10 U.S.C. 2304(c) authorizes the Department of Defense (DoD) to contract without full and open competition under certain circumstances. For this acquisition, other than full and open competition is permitted per FAR 6.302-1(a)(2)(iii)(A) and (B).

(5) A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Deloitte Financial Advisory Services LLP (Deloitte) is the only source that can satisfy the DITMAC’s requirements without cost duplication or unacceptable delay during the required period of performance, based on the following:

Deloitte has supported the establishment and incubation of the DITMAC since March 2014 under two contracts awarded by the United States Air Force. The first phase was from March 25, 2014 and was completed on March 24, 2015 for the amount of $2,223,167.00 and was initiated prior to DSS’s assumption of the DITMAC incubation mission and supported via an Air Force contract (FA8240-13-D-2750-0006) per OUSD(I) direction. This first phase focused on the initial establishment with organizational assessments to identify operational gaps, development of a concept of operations and conducting a business process review with process mapping. The second phase of Deloitte support to the DITMAC was continued on the Air Force contract (FA8240-13-D-2750- 0015) and runs from July 15, 2015 to July 14, 2016 in the amount of $3,995,579.00. The three (3) major areas of focus within the two (2) Air Force Task Orders (TO) listed above were: 1) Risk Modeling; 2) Internal Process Development; and 3) Outreach and Change Management. During the period of performance, work was initiated on the development of standard operating procedures, strategic planning, external risk assessment and risk model development. Whereas, within the proposed contract there are six (6) main focus areas: 1) Strategic Communications Support; 2) Strategic Plan Implementation; 3) Leadership Development; 4) Tabletop Exercises; 5) DART implementation and 6) DITMAC DSoS Program Support. Although the Government has now broken out the major focus areas from three (3) major areas to six (6) more distinct areas, each of the six (6) main focus areas map back to the initial three (3) major areas of the previous two (2) TO’s as follows: 1) Risk Modeling is tied to the new focus area of DART Implementation; 2) Internal Process Development is tied to the new focus areas of Strategic Plan Implementation, Leadership Development, and Tabletop Exercises; and 3) Outreach and Change Management is tied to the new focus areas of Strategic Communications Support and DITMAC DSoS Program Support.

Deloitte has provided critical support to the DITMAC under the previous two (2) contracts through the Air Force TO. The Air Force made an unplanned decision to discontinue support the DITMAC’s requirement utilizing their contract vehicle. The DITMAC still has a requirement for the completion of the work already started and developed by Deloitte and has requested the DSS Office of Acquisitions to provide the contract vehicle for continuation of the required DITMAC support. If the critical support for the DITMAC were prematurely ended before completion, the impact of a delay in procuring the required services in a competitive environment would greatly demise the operational tempo and mission of the DITMAC. Without a continuation of these efforts by Deloitte, the DITMAC would realize an immediate and significantly detrimental impact on DITMAC operations and a significant work stoppage at a critical juncture. As DITMAC approaches IOC with the final approval of the System of Record Notice (SORN) and Exemption Rule, it is estimated it would take another vendor three (3) to six

(6) months to become fully operational based on the contracting office’s historical knowledge of transitioning from one vendor to another in order to complete the tasks identified in the PWS and provide the necessary deliverables.

Based on the above information, any delay in acquiring the necessary services for the DITMAC would cause an unacceptable delay in fulfilling their requirements and mission.

The DITMAC is approaching a critical point with the finalization of the SORN and Exemption Rule Circa July 20, 2016, allowing the DITMAC and the 43 DoD Component Hubs to become operational. Without the support provided by Deloitte during this critical juncture, the mission of DITMAC would be greatly diminished and the momentum DITMAC has had towards reaching IOC and FOC on schedule would not be achievable. Some of the

DITMAC Specialized Consulting Support and Research Support Services

HS0021-16-RFQ-DITMAC

Control Number: 16-008JA

FOR OFFICIAL USE ONLY

PROCUREMENT SENSITIVE

SOURCE SELECTION SENSITIVE

more critical elements of this support that Deloitte has started under the current TO but has yet to finish include the following:

a) Finalization of the DITMAC Strategic Plan: Under the current period of performance, Deloitte began to develop the DITMAC Strategic Plan as part of their larger support to internal process development. It is critical now for that plan to be brought to fruition especially since the DITMAC is scheduled to be operational in less than a month and there will be the first DITMAC Director. The draft Strategic Plan must be refined, finalized and implemented in a timely fashion and the performance measurements must be developed and implemented to ensure the DITMAC is meeting its strategic goals and objectives. Losing any traction in this regard would be detrimental to the DITMAC’s mission. The DITMAC will be required to produce this plan in response to Congressionally directed language in the fiscal year 2017 National Defense Authorization Act.

b) Continuation of the Tabletop Exercises: Under the current period of performance, Deloitte drafted Tabletop Exercises that are critical to the DITMAC mission and have gained the interest of senior OUSD(I) and DoD leaders as a critical tool in training and education for not only the DITMAC but the 43 Component Hubs. The DITMAC and the DoD components will be fully operational as of July 20, 2016.

These table top exercises allow the exchange of information, flushing out of processes, ironing out how critical information will flow up from the DoD components to the DITMAC to Senior leaders and potentially to other Federal Agencies that are a critical dependency. Any delay in the training and awareness created through these tabletop exercises and their related reports would have a detrimental impact for the DITMAC and the DoD components to be successful at accomplishing their missions and may delay the DoD in closing the gaps and seams across the DoD that can be exploited by insider threats.

c) Risk Modeling Accomplishment: Most importantly is the refinement and maturing of the risk modeling accomplished under the current period of performance through the next phase of DART Implementation.

Although Deloitte started these basic risk modeling activities under the current TO, this effort has gained traction and acceptance amongst DoD senior leaders and is being looked towards as a risk assessment model that can be leveraged by the entire Insider Threat enterprise to more efficiently and effectively assess risk as it pertains to insider threats. These basic risk models, established by Deloitte, are currently nascent models that require refinement, socialization and testing. These risk models will serve as the engine behind the future automation of this capability as a tool. Developing these risk models into a more usable and mature state is critical to the ability for the DITMAC to assess risk and provide recommendations to the DoD components in a timely and efficient manner, which will be critical in just a few short weeks. Any delays, setbacks or switches to alternate Contractors would possibly negate the critical work developed in the initial risk modeling effort that has been presented to the DoD components, DSS leadership, OUSD(I) as well as other DoD seniors.

Deloitte is the only vendor positioned to complete the required tasks in the PWS in a timeframe that allows the DITMAC to maintain schedule and meet its mission mandates. Deloitte is the only vendor that has the background and historical information necessary to continue the required tasks from day one without a learning curve that has the potential to derail the DITMAC mission and achieving IOC and FOC as scheduled. The tasks identified in the PWS are a continuation of the tasks Deloitte has already started under the current Air Force TO (as identified above) and a new vendor would need to go back to the beginning to gain a full understanding of all of the items completed in order to continue to provide the necessary specialized consulting and research support services.

Based on the Government’s subject matter expert and the Contracting Officer’s (CO) historical knowledge, the possibility that a new vendor may move in a different direction to complete the required tasks would invalidate the work already completed and delivered to the Government. This change in direction would cause unacceptable delays in fulfilling the core mission of the DITMAC. The tasks required within the PWS are to be provided to the Government within the one-year period of performance, there is insufficient time for a new vendor to complete the tasks required to support the DITMAC’s transition from provisional IOC to FOC.

DITMAC Specialized Consulting Support and Research Support Services

HS0021-16-RFQ-DITMAC

Control Number: 16-008JA

FOR OFFICIAL USE ONLY

PROCUREMENT SENSITIVE

SOURCE SELECTION SENSITIVE

The DITMAC is aggressively working toward IOC, and eventually FOC, aided by the specialized consulting and research support services provided by Deloitte. These specialized consulting and research support services have positioned the DITMAC to navigate from initial establishment through provisional IOC in an expeditious fashion. Under the TOs awarded by the Air Force, Deloitte has provided the necessary support services and deliverables to allow the DITMAC to move from establishment to provisional IOC in a condensed timeframe in order to meet the DITMAC mission. Deloitte has the institutional knowledge and has shown they have the capability to ensure the DITMAC moves from provisional IOC to FOC during the compressed period of performance to allow the DITMAC to meet their mission as defined by the OUSD(I). Deloitte’s specialized consulting and research support services have played a critical role in enabling the rapid establishment of the DITMAC. The work started by Deloitte is not complete and prematurely ending this support, specifically at the same time the DITMAC is moving to IOC would be significantly disruptive and have a significant impact on the DITMAC operations leaving many of the critical ongoing efforts incomplete that tie directly back to the DITMAC core mission areas. All aspects of DITMAC development are intricately related such that a change in one area of development will affect all efforts, from standard operating procedures to exercise development to strategic planning. Any delays resulting from contractual shifts or delays would greatly increase the period between now and IOC, continuing to exacerbate the DoD’s known vulnerabilities to insider threats. Until DITMAC reaches operational capability DoD remains vulnerable to threats the DITMAC is designed to identify and mitigate, delays in reaching operational capability are unacceptable.

Based on the above, competing this requirement would result in untenable delays and an inability to complete ongoing critical efforts resulting in the potential loss of the approximately $6,000,000.00 already invested in these efforts. Consequently, the renewal of the existing services sole source to Deloitte represents the most cost effective approach for DSS, ensuring continuity of operations without interruption.

(6) A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies.

The CO will follow the procedures in FAR 5.201 and FAR 6.305 in ensuring a Synopsis and the Justification required by 6.303-1 are properly completed. A Request for Quote (RFQ) will be issued to Deloitte in accordance with FAR Part 12, Acquisition of Commercial Items, and FAR Part 13.5, Simplified Procedures for Certain Commercial Items.

(7) A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

In determining a fair and reasonable price, the CO will evaluate the proposed price against the formal Independent Government Cost Estimate (IGCE). The detailed estimate provides a breakdown of what the Government believes is the potential labor categories, as well as estimated labor rates and the estimated fixed monthly price for providing the required services. The estimated monthly price will be compared to established pricing on other Government contracts, such as the General Services Administration’s (GSA) Federal Supply Schedule (FSS) for the same types of services. Additionally, price comparisons will also be accomplished from as many other sources as possible, including commercially as well as any Government-Wide Acquisition Contracts

(GWAC).

These services are available from one vendor. Based on market research, it is anticipated that a fair and reasonable price will be determined and agreed to.

Leveraging DSS’ current use of the vendor services, along with open market price comparison, the CO is confident in obtaining the best value for DSS.

DITMAC Specialized Consulting Support and Research Support Services

HS0021-16-RFQ-DITMAC

Control Number: 16-008JA

FOR OFFICIAL USE ONLY

PROCUREMENT SENSITIVE

SOURCE SELECTION SENSITIVE

(8) A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

Availability and pricing information was sought from Booz Allen Hamilton, SRA International, and Deloitte. Market research was conducted for the purpose of seeking as many potential sources as possible.

Although Deloitte is the sole provider of the service, there are not multiple providers with the required support available on the open market to meet the Government’s current requirement. An RFQ will be provided to Deloitte in accordance with FAR Part 12, Acquisition of Commercial Items, and FAR Part 13.5, Simplified Procedures for Certain Commercial Items.

(9) Any other facts supporting the use of other than full and open competition, such as:

Nothing to add to this section that has not already been articulated within this justification document.

(10) A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

Deloitte Financial Advisory Services LLP

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

Future requirements for the DITMAC for Specialized Consulting and Research Support Services will be processed using full and open competition based on market research and adequate time to complete the appropriate acquisition planning required to remove or overcome all barriers to competition.

DITMAC Specialized Consulting Support and Research Support Services

HS0021-16-RFQ-DITMAC

Control Number: 16-008JA

FOR OFFICIAL USE ONLY

PROCUREMENT SENSITIVE

SOURCE SELECTION SENSITIVE

Requiring Activity/Program Management Office 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.

Printed Name: Delice-Nicole S. Bernhard

Title Assistant Director, Operations Organization Code DSS-DITMAC

Signature:

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: Stephen M. Heath

Title Contracting Officer Organization Code DSS-AQ

Signature:

Activity Competition Advocate ($650,000 - $12,500,000)

Printed Name: Tara L. Petersen

Title Chief, Office of Acquisitions Organization Code DSS-AQ

Signature:

BERNHARD.DELICE-

NICOLE.SCOTTO.1258008703

Digitally signed by BERNHARD.DELICE-NICOLE.SCOTTO.1258008703 DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=DSS, cn=BERNHARD.DELICE-NICOLE.SCOTTO.1258008703 Date: 2016.07.07 10:36:17 -04'00'

Digitally signed by HEATH.STEPHEN.M.1265803683 DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=DSS, cn=HEATH.STEPHEN.M.1265803683 Date: 2016.07.07 11:40:11 -04'00'

PETERSEN.TARA.L.1157925497

Digitally signed by PETERSEN.TARA.L.1157925497 DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=DSS, cn=PETERSEN.TARA.L.1157925497 Date: 2016.07.07 11:43:14 -04'00'