I.A.02 Limited Competition Justification_2FEB26 printed (SCO).pdf

SEPTEMBER 23, 2025 CUI//SP-SSEL 1 of 4SEPTEMBER 23, 2025 CUI//SP-SSEL 1 of 4

CUI//SP-SSEL

JUSTIFICATION REVIEW DOCUMENT

NATIONAL GUARD BUREAU

111 South George Mason Drive Arlington, VA 22204-1373

1. OVERVIEW

a. Program/Equipment Name b. Estimated Price

Full Food Service for Camp Ashland Regional Training Institute (RTI) DFAC $4,500,000.00

c. Authority

10 U.S.C. 2304(a)(5) or 41 U.S.C. 3304(a)(5) as implemented in FAR 6.302-5 Authorized or required by statute.

d. Technical Representative

Name Title Email Phone Date

LTC Joseph Eggen Administrative Officer joseph.a.eggen.mil@army.mil 402-309-7131 January 20, 2026

e. Contracting Officer

Name Title Email Phone Date

Jeremy Rupprecht Chief of Contracting jeremy.m.rupprecht.civ@army.mil 402-309-8280 January 20, 2026

Requirements Representative (If different from Technical Representative.)

Prepared by (If different from Contracting Officer.)

Name Title Email Phone Date

Patti Lee-Smith Contracting Officer patricia.h.lee-smith.civ@army.mil 402-309-8294 January 20, 2026

2. REVIEWS

I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager (If applicable.)

Program Executive Officer (When item is Program Executive Officer managed.)

Controlled by: National Guard Bureau

Controlled by: Local Office

CUI Category: SOURCE SELECTION

Limited Dissemination Control: FEDCON

POC: Jeremy Rupprecht 402-309-8280 (Populates from the 1.e. Contracting Officer.)

SEPTEMBER 23, 2025 CUI//SP-SSEL 2 of 4SEPTEMBER 23, 2025 CUI//SP-SSEL 2 of 4

Justification for Other than Full and Open Competition Guidance

Local Control Number NGB Control Number (if applicable)

26-001 25-17

1a. CONTRACTING ACTIVITY b. Requiring Activity c. POC

USPFO for NE P&C 2-209th RTI Camp Ashland LTC Jospeh Eggen

2a. NATURE OF ACTION

Other - Authorized or Required by Statute

b. Contract Action

New Contract

c. Contract Type

Firm Fixed Price

d. Fund Type

O&M, Army

3a. ESTIMATED PRICE

$4,500,000.00

4a. Name of Requirement

Full Food Service for Camp Ashland Regional Training Institute (RTI) DFAC

b. Description of Requirement

Full Food Service (FFS) is required at the Camp Ashland Regional Training Institute (RTI) in Ashland, NE which directly provide flexible, cost efficient, and cost effective meals for individuals training at Camp Ashland. The services for this requirement include, but are not limited to, food service management functions, food receipt, delivery and storage, food preparation, food serving, remote site feeding to support field operations (if applicable), and facility sanitation/janitorial duties. The outcomes to be satisfied include providing FFS to the Army that promotes a healthier and stronger Army, sustaining high quality standards of food and cleanliness.

c. Demonstrate, in Detail, Why This Specific Item or Service, is the Only One That Meets Your Requirements

Based upon information contained in the Federal Register dated 23 December 2025, the Justification of Limitation as it relates to the Randolph Sheppard Act, was justified based upon higher costs, arbitration delays, and performance issues specifically discussed in the Department of Education’s decision. While Nebraska recognizes the Department of Education’s findings, prior to 2018, the Camp Ashland DFAC was operated by the State Offices; Division of the Nebraska Commission for the Blind and Visually Impaired. Contract W91243-15-D-0001 was made to the State Offices and a Justification for Other Than Full and Open Competition indicated the State Offices provided meals that met the requirements of the Performance Work Statement and a fair and reasonable determination was made using utilizing the State Office's proposed pricing, and pricing from other states with similar requirements.

While the Nebraska Army National Guard is no longer required to give priority to the State Offices, prior contract information indicates the State Offices were successful in providing a nutritious, quality meal at a reasonable price through 2018. Additionally, the State Offices' current contract with Offutt Air Force Base (AFB) in Omaha, Nebraska outlines multiple areas the State Offices must provide freshly prepared, nutritious, and quality food items which are in compliance with the revised U.S. Dietary guidelines and approved industry standards. Contract FA255026C0001 (Schriever AFB) in Colorado outlines similar requirements and all contractual data reviewed thus far would indicate the Colorado Department of Labor and Employment are in compliance with the terms and conditions set forth in the Performance Work Statement; specifically the requirement to offer a nutritious, quality meal at a reasonable rate.

Therefore, based upon all available information, the NEARNG has a reasonable assumption that the State Offices will be able to provide a nutritious, quality meal at a fair price.

It is the intention of the NEARNG to engage in direct negotiations with the State Offices and its subcontractor(s); which will allow State Offices the opportunity to provide pricing for each CLIN in the solicitation and once pricing is received, the Contracting Officer will be able to ascertain price fair and reasonable and ensure the contractor can provide meals as outlined in the Performance Work Statement and NEARNG IDIQ Mandatory Ordering Guide.

5a. HAS THIS BEEN PREVIOUSLY PROCURED?

Yes, details are below. No.

6a. AUTHORITY CITED

10 U.S.C. 2304(a)(5) or 41 U.S.C. 3304(a)(5) as implemented in FAR 6.302-5 Authorized or required by statute.

b. Reason for Authority Cited ?

While the Nebraska Army National Guard is no longer required to give priority to the State Offices, prior contract information indicates the State Offices were successful in providing a nutritious, quality meal at a reasonable price through 2018. Additionally, the State Offices' current contract with Offutt Air Force Base (AFB) in Omaha, Nebraska outlines multiple areas the State Offices must provide freshly prepared, nutritious, and quality food items which are in compliance with the revised U.S. Dietary guidelines and approved industry standards. Contract FA255026C0001 (Schriever AFB) in Colorado outlines similar requirements and all contractual data reviewed thus far would indicate the Colorado Department of Labor and Employment are in compliance with the terms and conditions set forth in the Performance Work Statement; specifically the requirement to offer a nutritious, quality meal at a reasonable rate.

SEPTEMBER 23, 2025 CUI//SP-SSEL 3 of 4SEPTEMBER 23, 2025 CUI//SP-SSEL 3 of 4

Therefore, based upon all available information, the NEARNG has a reasonable assumption that the State Offices will be able to provide a nutritious, quality meal at a fair price.

7. POSTING REQUIREMENTS

Post the justification within 14 days after contract award on SAM.gov (GPE) for a minimum of 30 days (FAR 6.305).

8. CONTRACTING REQUIREMENTS

a. Efforts to Obtain Competition ?

In accordance with FAR 5.202(a)(4), this action will not be synopsized. The USPFO-NE Purchasing and Contracting office will conduct direct negotiations with the State Offices Division of the Nebraska Commission for the Blind and Visually Impaired.

a. Effective Competition: Because this is a sole source action, effective competition is not applicable.

b. Subcontracting Competition: In accordance with FAR 52.219-9(d)(9), federal contractors are required to develop and maintain an acceptable subcontracting plan if they are other than a small business and the estimated dollar value of the base contract and all option periods exceed or is expected to exceed $750,000. The Government will require a plan from the State Offices Division of the Nebraska Commission for the Blind and Visually Impaired in support of this action unless there is an appropriate justification for the Contracting Officer to waive the requirement.

b. Actions to Increase Competition ?

While competitive contracting processes are often the norm in public procurement, direct negotiations with the State Offices Division of the Nebraska Commission for the Blind and Visually Impaired in this instance, is an expedient approach ensuring individuals are provided a high quality meal with a reasonable assumption that the State Offices will provide fair and reasonable pricing that is in line with the current marketplace.

c. Market Research ?

Market research conducted in SAM.gov; utilizing prior contract information, and a site visit with the State Offices Division of the Nebraska Commission for the Blind and Visually Impaired and its subcontractors, confirmed they can meet the needs of the NEARNG RTI.

d. Interested Sources ?

State of Nebraska:Division of the Nebraska Commission for the Blind and Visually Impaired

e. Other Facts ?

The State Offices and its subcontractor(s) participated in an on-site walk through of the DFAC on 16 July 2025. The State Offices subcontractors verified they could meet the needs of the Government and are currently providing DFAC services at OFFUT Air Force Base, Buckley Space Force Base in Aurora, Colorado, and Blackstone Consulting oversees DFAC operations for Army dining facilities across the United States. Multiple DFAC's across the 54 have similar requirements; although the number of students/soliders utilizing the Camp Ashland DFAC is smaller than that of larger Army bases.

f. No justification required if:

(A) Qualified Nonprofit Agencies for the Blind or other Severely Disabled -- 41 U.S.C. 85, Committee for Purchase From People Who Are Blind or Severely Disabled (see Subpart 8.7);

(B) The agency's need is for a brand name commercial item for authorized resale;

(C) When the statute expressly requires that the procurement be made from a specified source. (Justification and approval requirements apply when the statute authorizes, but does not require, that the procurement be made from a specified source);

9. REQUIRING ACTIVITY CERTIFICATION

Technical and Requirements

I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Name Date Title

LTC Joseph Eggen January 20, 2026 Administrative Officer

Phone Email

402-309-7131 joseph.a.eggen.mil@army.mil

10. REVIEW

Contracting Officer (KO)

1. I hereby determine that the anticipated cost to the government for this contract action will be Fair and Reasonable.

2. I certify that this Justification is accurate and complete to the best of my knowledge and belief.

(This certification shall be made by the contracting Officer who will sign the contract resulting from this Justification and Approval.)

Name Date Phone

Jeremy Rupprecht January 21, 2026 402.309.8280

Email jeremy.m.rupprecht.civ@army.mil

Digitally signed by

EGGEN.JOSEPH.ALLEN.1245111912

Date: 2026.01.20 16:47:53 -06'00'

Digitally signed by

RUPPRECHT.JEREMY.MARC.114779

Date: 2026.01.21 09:29:20 -06'00'

SEPTEMBER 23, 2025 CUI//SP-SSEL 4 of 4SEPTEMBER 23, 2025 CUI//SP-SSEL 4 of 4

Legal (Local)

I have reviewed this justification and find it adequate to support other than full and open competition. See comments below. (Field will expand as needed.)

This procurement utilizes authority of 34 C.F.R. 395.33(d) to enter direct negotiations with SLA, and thus is an exception to ordinary competition requirements.

Name Date Phone

MAJ Ben Williams January 21, 2026 (402) 309-8371

Chief of the Contracting Office (CoCO) Acting as.

I have reviewed this justification and find it adequate to support other than full and open competition. See comments below. (Field will expand as needed.)

Approved. Concur with Legal.

Name Date Phone

Jeremy Rupprecht January 22, 2026 402.309.8280

Chief, Acquisition Compliance and Oversight Division (AQ-P Chief) Acting as.

I have reviewed this justification and find it adequate to support other than full and open competition. See comments below. (Field will expand as needed.)

Name Date Phone

Jack K Mylan III February 13, 2026 586-876-3843

11. APPROVAL

Command Advocate for Competition (CAFC) Acting as.

I have reviewed this justification and find it adequate to support other than full and open competition. See comments below. (Field will expand as needed.)

Name Date Phone

Jamaal K Valentine February 13, 2026 (571) 431-2247

12. REDACTION INSTRUCTIONS

After completion and signatures, print to PDF. Then redact items such as, but not limited to:

1. Dollar amounts.

2. Names.

3. Signatures.

4. Proprietary information.

FAR 5.401, FAR 24.1, and FAR 24.2

WILLIAMS.BENJAMI

N.DANIEL.1254732253

Digitally signed by

WILLIAMS.BENJAMIN.DANIEL.1254

732253 Date: 2026.01.21 19:02:17 -06'00'

Digitally signed by

RUPPRECHT.JEREMY.MARC.114779

Date: 2026.01.22 07:19:48 -06'00'