Limited Source Justification for SMOC-ISSO Bridge

Limited Source Justification

This acquisition is 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), Title 40 U.S.C. 501, Services for Executive Agencies, and is justified by the following facts and rationale required under FAR 8.405-6(a)(1 ).

1. Agency and Contracting Activity:

U.S. Department of Homeland Security (DHS), U.S. Immigration and Customs Enforcement (ICE), . Office of Acquisition Management (OAQ), Illformation Technology Services Division

2. Nature and/or description of action being approved:

The ICE Office of the Chiefinformation Officer (OCIO) Information Assurance Division (IAD) has a requirement for Information System Security Officer (ISSO) services and Security Management and Oversight Compliance (SMOC) support services.

The name of the proposed vendor is:

Knowledge Consulting Group (KCG)

11710 Plaza America Dr. Ste 520

Reston, VA 20190-4741

DUNS: 007232429

The Government proposes to issue a task order against KCG's GSA contract no. GS-35F- 0448N for this requirement.

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

The services needed are Information System Security Officer (ISSO) services and Security Management Oversight and Compliance (SMOC) support services estimated at for the three (3) month base period and three (3) one month option periods.

The services include program management support, security program management and integration support, security authorization and risk management, Information Assurance Governance (lAG), program reviews, and transition support in support ofiAD's mission to coordinate the development and implementation of computer and network security policies, products, and services across ICE (See Attachnient 1- Revised Bridge SOW).

The period of performance is one (1) three month base period plus three (3) one month option periods as follows:

Period of Performance Estimated Total Base Period 05/0112012 to 07/31/2012 Option Period 1 08/01}2012 to 08/3112012 Qption Period 2 09/0112012 to 09/3112012 Option Period 3 10/01/2012 to 10/3112012 Grand Total:

4. Identification of the justification rationale and demonstration of the proposed contractor's unique qualifications to provide the required supply or service:

Under the authority ofF AR 8.405-6(a)(l )(i)(B), only one source is capable ofproviding the services required at the level of quality required because the services are highly specialized.

The federal government and the Department of Homeland Security have made information protection a matter of national security, and that is not limited to just government information. Access to private data and sensitive business details could create security problems. Therefore, despite any downturns in the information technology economy, the market for information assurance and other computer security personnel is likely to remain strong. Currently, there is a severe shortage of qualified people to take on the roles of information assurance.

Contractor personnel serving on this contract have a highly specialized set of skills to assist the U.S. Immigration Customs Enforcement, Office ofthe Chieflnformation Officer protect the information networks ofthe second largest investigative agency in the federal government from cyber threats. These personnel have extensive knowledge in intrusion detection and control, which is the art of discovering. if an inappropriate activity has occurred, the ability to recommend and support systems that provide user authorization and authentication, and equally important, they have knowledge of the National Institute of Standards and Technology (NIST) guidelines for information security and experience with Federal Information Systems Management Act (FISMA) reporting. While there are other companies that have personnel with information assurance skills they would not be able to operate with the same type of efficiency and effectiveness on May 1 '1 because they would need to acquire a significant amount of institutional knowledge from the incumbent, establish new business relationships with stakeholders within and outside of ICE, and a new vendor would need to understand the ICE information security policies and procedures which may not be immediately available after contract award.

The reason for not having a competed requirement in place is that in February of this year, significant portions of the ICE budget for the Office of the Chieflnformation Officer (OCIO) had not been released yet so the Information Assurance Division (lAD) within OCIO was unable to accurately estimate the scope of services needed for the new effort. In April, when prospective budget changes were more clearly defined, the ICE OCJO determined a reduction in the level of effort for ISSO and SMOC support services was necessary to align with ICE funding limitations. These budget constraints resulted in a significant change in the acquisition planning process thereby delaying and affecting the execution of the internal ICE Balanced Workforce Assessment (BWA) and other essential acquisition documents.

The impact of not approving this sole source contract for continued ISSO services and SMOC support services will result in the degradation of the lAD's ability to fulfill information security mission requirements as follows:

• The award of a contract to the incumbent contractor (KCG) is necessary to avoid a break in service for mission essential programs;

• KCG has corporate knowledge and critical information that needs to be transitioned to the new contractor;

• The mission will experience major setback or unacceptable delays without sufficient overlap with the incumbent contractor; and

• KCG is the only contractor that can ensure continuity and a smooth transition of these services during these critical periods at a fair and reasonable price for the Government without associated new contract start up costs and a potential degradation of services.

5. A determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d):

The Contracting Officer has determined that the anticipated price will be fair and reasonable based on an analysis performed by the program office to ensure that the level of effort is reasonable to achieve the work outlined in the SOW. Further, the Contracting Officer will compare quoted pricing to KCG's GSA contract, which GSA has already determined pricing to be fair and reasonable and that the Contracting Officer is not required to do a separate determination. The CO will seek additional discounts from the GSA schedule pricing.

6. Description of Market Research:

ICE OCIO and ICE OAQ have completed market research through a Request for Information (RFI) and a review of multiple websites of GSA Schedule vendors. ICE has found multiple GSA Schedule vendors that are capable of performing the requirements; however, ICE needs at least 3-6 months to complete a competition among vendors for the required services. The current KCG task order that provides ISSO and SMOC support services expires on 30 April 2012 and due to changes in requirements based on budget constraints, the new contract award is not anticipated until the fourth quarter of fiscal year (FY) 2012.

7. Any other facts supporting the Justification:

Transitioning to a new contractor other than the incumbent while the new requirement is solicited and a subsequent competitive award is made would negatively impact the Government in terms ofthe mission, time, and costs. The mission ofiCE OCIO/IAD is to coordinate the development and implementation of computer and network security policies, products, and services across ICE. The support services being provided by KCG are critical to this part of the ICE mission. Since 2008, KCG has been providing SMOC support services to support lAD's mission and is responsible for the implementation of the structure and model of the ICE ISSO Services Program. KCG has the inherent knowledge to continue providing ISSO and SMOC support services in a consistent manner at a price that is considered fair and reasonable until a competitive award is made.

8. A statement ofthe actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made:

ICE OAQ is in the process of completing market research and the acquisition strategy for a competitive award. It is anticipated that the new ISSO contract vehicle will be awarded within three (3) to six (6) months. The new requirement will be competed among multiple vendors rather than issuing a single award BPA and/or task order on a limited sources basis.

9. Technical Representative's Certification

I certify that this requirement meets the Government's minimum need and that the supporting

· data, which forms a basis for the justification, is accurate and complete.

Sc Townsend Date Technical Representative/COTR

10. Contracting Officer's Certification

I certify that the data supporting the recommendation for the use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Alexander K. Roberts Contracting Officer

11. Office ofthe Principal Legal Advisor

Date

Oi lui zo 1 z I I

I reviewed this Limited Source Justification and find it to be legally sufficient.

Song Kim Date

:5. Willi einberg Date ICE C mpetition Adv