LSJ__HSCG23-16-F-PCI116__CPIC-IA-ARM_Direct_Access.pdf

Limited Source Justification (FAR Part 8)

HSCG23-16-Q-PCI116

9/27/2016

This acquisition is conducted under the authority of Title 41 U.S.C. 152 (3), Competitive Procedures, and Title 40 U.S.C. 501, Services for Executive Agencies, Federal Acquisition Regulation (FAR) 8.401, and is supported by the following facts and rationale required under FAR 8.405-6 (a)(1)(i)(C): In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply

Schedule order which was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original was not issued under sole-source or limited-sources procedures.

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Assistant

Commandant for Acquisition (CG-9), Office of Contract Operations (CG-912), Formal Contracts

Division III (CG-9123) proposes to issue a task order under a Federal Supply Schedule contract on the basis of other than full and open competition.

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

In support of the USCG Human Resource (HR) and payroll system known as Direct Access (DA), the

USCG is issuing a limited source Task Order (TO) for Contractor Technical and Administrative support services. The USCG has a requirement to support the existing level of effort provided under TO #

HSCG23-11-F-PCI110 for Capital Planning and Investment Control, Information Assurance, and Audit

Risk Management Support for DA. This system provides support services for the active duty, reserve, and retired military components of the USCG. The current TO is administered by the CG-912

Contracting Office and the Contracting Officer’s Representative (COR) duties reside in CG-631. The place of performance for this TO will be USCG Headquarters (HQ).

The period of performance of this Task Order is six months (September 30, 2016 through March 29, 2017), with an additional three month option (March 30, 2017 through June 29, 2017). The estimated price for this Firm Fixed Price (FFP) effort is $1,329,727.50.

The proposed contractor is:

Total Systems Technology Corporation (TSTC)

12400 Rochester Dr

Fairfax, VA 22030

(3) Description of supplies or services.

The purpose of this task order is to obtain Contractor technical and administrative support services for, IT Audit, Capital Planning, Investment Control, Information Assurance, and Audit Risk Management support within CG-63, for Direct Access and the United States Coast Guard’s (USCG) Exchange

Systems (CGES). Contractor tasks shall include, certification and accreditation (C&A) analysis, information technology (IT) security technical assurance, program management support services, independent verification and validation (IV & V), requirements gathering and documenting, and administrative support.

Coast Guard Command, Control, Communications, Computers & Information Technology (C4IT) systems are required to complete a C&A and annual self-assessment. The Coast Guard has selected

National Institute of Standards and Technology (NIST) SP 800-37 for unclassified C4IT systems, Defense Information Technology Security Certification and Accreditation Process

(DITSCAP)/Department of Defense (DOD) Information Assurance Certification and Accreditation

Program (DIACAP) for classified and National Security Systems, and NIST SP 800-26 for annual self-assessments for all systems.

• A robust information assurance (IA) program defends information and information systems by ensuring their availability, integrity, authentication, confidentiality, and non-repudiation. This policy applies to C4IT assets, including systems and products that enable C4IT capability in support of the

Coast Guard’s missions or business functions.

• The Coast Guard Information Assurance Program (IAP) includes periodic assessments of risk, including the magnitude of harm that could result from the unauthorized access, use, disclosure, disruption, modification, or destruction of information and information systems that support the operations and assets of the organization. Policies and procedures that are based on risk assessments cost-effectively reduce information security risks to an acceptable level, and ensure that information security is addressed throughout the life cycle of each organizational information system.

The Office of Management and Budget (OMB) requires federal agencies to establish and maintain a capital programming process that links mission needs and capital assets in an effective and efficient manner. Effective capital programming requires long-range planning and a disciplined budget decision-making process as the basis for managing a portfolio of assets to achieve performance goals and objectives with minimal risk, lowest life-cycle costs, and greatest benefits to the agency's business.

OMB requires that capital requests be captured and submitted electronically in a consistent format known as Exhibit 300. The information reported on Exhibit 300 helps OMB:

• Understand agency capital programming and investment decision-making processes;

• Ensure that spending on capital assets directly supports agency missions and will provide a return on investment equal to or better than alternate uses of funding;

• Identify poorly performing projects, i.e. projects that are behind schedule, over budget, or lacking in capability using earned value management techniques and systems;

• Identify capital assets that no longer fulfill ongoing or anticipated mission requirements or do not deliver intended benefits to the agency or its customers.

• For IT, ensure that strong business cases are provided for IT investments. These business cases should include security, privacy, enterprise architecture, and provide the effectiveness and efficiency gains planned by the business lines and functional operations.

The Program Office has reviewed and the Contracting Officer has determined the above services are neither inherently governmental functions nor personal services.

(4) Authority and supporting rationale permitting use of Limited Sources.

This acquisition is being conducted under the authority of GSA FSS in accordance with FAR 8.405-6

(a)(1)(i)(C): In the interest of economy and efficiency, the new work is a logical follow-on to an original

Federal Supply Schedule order which was placed in accordance with the applicable Federal Supply

Schedule ordering procedures. The original was not issued under sole-source or limited-sources procedures.

Task Order HSCG23-11-F-PCI110 is set to expire on September 30, 2016. As stated above, all USCG networked systems require various types of certification, accreditation, and risk analysis. The USCG determined via acquisition planning and market research that a contract vehicle which could provide these services for all USCG networked systems may be in the best interests of the government. Effort is currently underway to competitively obtain this support.

Through Direct Access, the USCG provides payroll and HR support to the United States Public Health

Service (USPHS) and the National Oceanic and Atmospheric Association (NOAA). Based on the support provided, these organizations provide funding for Direct Access support.

There is a continuing requirement for these critical services supporting Direct Access and CGES; an interruption in these services would severely impair the USCG’s ability to provide human resource support, payroll, and exchange services to its active duty, reserve, and retired military personnel, as well as to USPHS and NOAA.

(5) Determination by the ordering activity Contracting Officer that the anticipated order represents the best value consistent with 8.404(d).

The Contracting Officer will determine that this action represents the best value to the Government in accordance with FAR 8.404(d). All support services are included in the vendor’s GSA FSS contract.

GSA has already determined that schedule prices for these services are both fair and reasonable, and the government requested a discount. Prior to issuing the task order, the ordering activity will conduct a price evaluation IAW FAR 8.405-2(d) by considering the level of effort and mix of labor hours proposed to perform the specific tasks being ordered, in determining that the total price is fair and reasonable.

(6) A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.