A15 JA (FAR Part 6)_Redacted.pdf

JUSTIFICATION AND APPROVAL

For Other Than Full and Open Competition

FAR Part 6

Acquisition and Technology Transformation and NBIS Integrated Master Schedule

1. Agency and contracting activity:

The Defense Counterintelligence and Security Agency (DCSA), Procurement Solutions (PRS) Directorate, is the procuring activity for this action. The PRS Directorate proposes to enter into a contract action on an other than full and open competition basis with KPMG, LLC, (CAGE Code 7QEG9) on behalf of DCSA Acquisition and Technology (AT). DCSA has an urgent requirement for contractor support to assist the AT Operating Component in its organizational transformation. This organizational transformation is foundational to establishing the optimized organizational structure, streamlined processes, and agile governance required to successfully execute the National Background Investigation Services (NBIS) critical path. This work is a direct prerequisite for ensuring the people and processes are in place to deliver on the urgent congressional mandate for the NBIS program.

2. Description of action being approved:

This justification and approval authorizes and approves the use of other than full and open competition to issue a new, standalone, sole-source letter contract (also known as an undefinitized contract action or UCA) to KPMG. This action is for non-commercial services with an estimated value of . The contract type will be determined during the definitization period. DCSA Working Capital Funds will be used. DCSA has an urgent congressional mandate for the NBIS program. The urgency of initiating this organizational transformation is directly tied to the NBIS program's critical path and immutable deadlines.

Delaying the effort to establish an optimized and agile AT operating component will create unacceptable schedule delays and cascade into a high risk of failure for the entire NBIS implementation. The use of a letter contract is essential to allow the contractor to start work immediately upon receipt of the letter contract. A fully functional organizational structure must be put in place without delay to support the complex demands of the NBIS schedule and prevent the kind of systemic programmatic breakdown described in Head of Contracting Authority (HCA) feedback. Waiting for a definitized contract would mean losing critical time and momentum, directly and negatively impacting DCSA's ability to meet its congressional mandate. This is not a divisible requirement that could be partially awarded or delayed without significant programmatic harm.

3. Description of Supplies/Services:

DCSA requires immediate, expert services to complete two inextricably linked tasks: (1) the development of the NBIS Integrated Master Schedule (IMS) with a critical path and risk analysis, and (2) a comprehensive assessment of the NBIS parent organization (DCSA AT) to ensure it is optimally structured to manage the NBIS implementation and support the agency’s broader mission. These tasks must be performed concurrently, as the viability of the IMS is directly dependent on the capabilities of the organization executing

J&A for AT Transformation

it. Therefore, this represents a single, integrated requirement to ensure NBIS program success. The total estimated value of this procurement is $4,000,000. This action is for expert advisory and assistance services to support the DCSA AT Operating Component's organizational transformation. These services are critical for the successful execution of the NBIS program. The work is divided into two primary phases over a seven-month period of performance:

Phase I (Assessment & Planning): The contractor shall assess AT's current processes, technologies, and performance metrics to develop a roadmap for creating a unified and agile organization. Key tasks include:

o Lifecycle Optimization: Analyzing and streamlining the "buy, build, run" lifecycle for capability delivery.

o Technology Assessment: Evaluating the current technology landscape and developing a 5-year technology plan and roadmap.

o Performance Measurement: Establishing a framework to measure transformation success and developing a consolidated NBIS IMS with an identified critical path, to be delivered by no later than April 2, 2026.

Phase II (Implementation Planning Support): The contractor shall provide program management, technical expertise, and change management support to guide the implementation of the recommendations from Phase I. This includes developing project charters, designing new governance processes, and creating a change management and communications plan.

4. Authority cited:

The statutory authority permitting Other Than Full & Open Competition for this action is 10 USC 3204(a)(2), as implemented by RFO 6.103-2, “Unusual and compelling urgency.”

Specifically, RFO 6.103-2(b) provides that agencies may contract without providing for full and open competition when the agency’s need for the services is of such an unusual and compelling urgency that the Government would be seriously injured, financially or otherwise, unless the agency is permitted to limit the number of sources from which it solicits bids or proposals. This authority is exercised in accordance with the principles of RFO 1.102(a)(1) to meet the agency’s mission efficiently and effectively first.

5. Reason for Authority Cited:

This justification is based on an unusual and compelling urgency that materialized upon the Acting DCSA director’s testimony before the House Committee on Oversight and Government Reform (HOGR) in February 2026. This testimony established a new, non-negotiable deadline of April 2026 for the delivery to HOGR of a comprehensive NBIS IMS, complete with a critical path and risk analysis. This timeline was not previously anticipated and has created a compressed and urgent timeframe for performance that precludes the use of full and open competition.

A competitive action, which would require a minimum of 70 days in accordance with DCSA’s procurement administrative lead time, would make it impossible for DCSA to meet the April 2026 deadline to provide information to HOGR. This failure would constitute a significant injury to the Government, resulting in unacceptable programmatic and mission risks:

1) Reputational Damage and Loss of Credibility: Failure to meet this deadline would severely damage the agency’s credibility with Congress and other stakeholders in its management of the critical NBIS program.

2) Programmatic Disruption and High Probability of Failure: The NBIS IMS is the foundational document for the entire system deployment and ensure alignment with TW 2.0 IMS. A delay in its creation would cascade, jeopardizing the implementation timeline and DCSA’s ability to meet both its NBIS delivery timeline and its TW 2.0 delivery timeline. Additionally, the concurrent organizational assessment is necessary to ensure DCSA has the capability to execute the NBIS, IMS, and is not hampered by a potentially flawed and inefficient management structure. This introduces a high probability of compounding delays, significant cost overruns, and potential mission failure.

3) Mission Degradation: NBIS is the future of the Government’s personnel vetting enterprise. Delays in its delivery directly impact the Government’s ability to onboard, investigate, and adjudicate personnel. This creates a potential bottleneck that degrades national security and the readiness of the entire Federal workforce.

KPMG is the only source that can perform this integrated requirement. Any other vendor, regardless of general experience with government programs, would need to undertake a significant discovery and data-gathering phase to replicate the knowledge KPMG already possesses. This knowledge is not merely documented; it is largely tacit, comprising the undocumented architectural decisions, stakeholder contexts, and risk trade-offs made during the Trusted Workforce (TW) 2.0 IMS development. This level of experiential knowledge is unobtainable through simple document transfer and would require any other vendor a prohibitive amount of time to reverse-engineer. KPMG's unique capability is twofold:

1) Deep Knowledge of the Required Work: Through their foundational role in authoring the TW 2.0 IMS under the Personnel Vetting (PV) Transformation Other Transaction Authority (OTA) agreement, KPMG possesses an unparalleled, granular understanding of the specific tasks, dependencies, and workflows the NBIS organization will be required to execute. This knowledge is the essential baseline for any credible organizational assessment.

2) Ability to Assess Structure Against Strategy: An organizational assessment is not a generic exercise. It is an analysis of an organization's fitness to execute a specific strategy. KPMG is performing under the PV Transformation OTA, as well as the Financial Management (FM) Transformation requirement. Because KPMG has the deepest understanding of DCSA's intertwined strategic plans (and the Integrated Master

Schedules), they are uniquely positioned to evaluate how the current organizational structure enables or impedes that strategy. A different vendor would lack this critical context and would have to first learn the IMS from scratch before they could even begin to assess the organization, a delay the Government cannot afford.

3) Holistic and Efficient Solution: By utilizing KPMG for both components, DCSA eliminates the significant risk of communication gaps, data silos, and conflicting recommendations that would arise from using two separate vendors. The seamless integration of these two tasks under one provider is the only way to meet the urgent deadline with a coherent and actionable result.

The scope of this proposed sole-source action is strictly limited to providing the integrated services necessary to (1) develop the NBIS IMS for the April 2026 deadline and (2) conduct a concurrent organizational assessment of the NBIS parent organization (DCSA AT). The total period of performance will not exceed seven months, sufficient only to address the immediate urgent requirement for the IMS while also completing the necessary, concurrent organizational assessment to ensure long-term program viability.

6. Efforts to Obtain Competition:

This action is being conducted under the authority of RFO 6.103-2, "Unusual and compelling urgency," which permits limiting the number of sources solicited. As detailed in Section 5, the Government's urgent need to meet a deadline of early April 2026 for the NBIS IMS makes it impractical to solicit offers from any source other than KPMG, LLP. The extensive lead-time required for any other contractor to replicate KPMG's knowledge would result in unacceptable delays and guarantee failure to meet this critical deadline.

The Government's efforts to obtain competition are focused on the long-term. This sole-source action is a tactical, short-term mechanism designed to address the immediate crisis while simultaneously creating the conditions for future competition. The deliverables from this contract, specifically the AT Lifecycle Improvement Plan and Technology Roadmap, are critical drivers for this contract strategy. These documents will codify and define the organizational processes and technical requirements currently understood only by KPMG. By formally documenting these structures, the Government will significantly lower the barrier to entry for potential competitors in future related acquisitions, as the "discovery phase" that only KPMG will have completed will be substantially reduced.

While market research did identify other potential sources capable of providing general management and transformation consulting based on NAICS 541611, these firms do not possess the unique capabilities of KPMG as mentioned in paragraph 5.

As this action is being conducted under the authority of RFO 6.103-2, the requirement for a pre-award synopsis of the proposed contract action at FAR 5.201 is waived in accordance with the exception at FAR 5.202(a)(2). Publicizing a notice of intent and waiting for responses would prevent the agency from meeting its critical mission requirements.

However, in accordance with FAR 5.301, a notice of the final contract award will be published on the Government Point of Entry (sam.gov), and the approved Justification and Approval document will be posted with the award notice.

7. Market research: Pursuant to FAR Part 10, market research was conducted to identify sources capable of providing the required services on this compressed timeline. The research included the following methods:

1. Review of Government-Wide Acquisition Contracts (GWACs): A comprehensive search was performed using the GSA eLibrary and GSA Advantage to identify vendors on the Multiple Award Schedule (MAS) and the OASIS+ contract vehicle.

2. Industry Analysis: A review of the competitive landscape for federal professional services was conducted to identify leading contractors with demonstrated expertise in large-scale organizational transformation for federal agencies.

3. Review of Agency's Existing Contract Portfolio: An internal review was conducted to understand the current landscape of transformation and advisory service contracts within the agency to identify potential synergies and risks.

B. List of potential capable vendors discovered during market research:

Although there are other vendors who perform work within NAICS code 541611, none of these firms would be able to meet the Government’s schedule except for KPMG, given their unique capabilities mentioned in paragraph 5.

8. Other Facts:

a) Procurement History: This requirement is similar to at least two other major, ongoing "transformation" type contracts within DCSA for which KPMG, LLP, is the incumbent prime contractor. This proposed action is a new, standalone contract for Acquisition and Technology to address an urgent and unforeseen requirement that is outside the scope of existing contracts but critically dependent on the knowledge gained from them.

b) Subcontracting Competition: As KPMG, LLP, is an Other than Small Business, the Government will request a small business subcontracting plan.