IA Extension - FINAL_Redacted.pdf

Limited Sources Justification (FAR Part 8)

PR 21-20-G30PWS272

Information Assurance (IA) and Security Program Support Services

Pursuant to the authority of Section 201 of the Multiple-Award Schedule Program 41 U.S.C. 251, this justification is prepared in accordance with the requirements of Federal Acquisition Regulation (FAR) 8.405-6(c) for the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3. The circumstance justifying restriction is FAR 8.405-6 (a)(1)(i)(C), through the following facts and rationale:

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Command, Control, Communications, Computers, Cyber and Intelligence Service Center (C5ISC) Contracting and Procurement, Kearneysville Division (CG-9142), located at 408 Coast Guard Drive, Kearneysville, WV 25430 prepared this justification for an exception to fair opportunity.

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

(a) Nature of the action: USCG intends to limit competition in order to award a sole source task order for existing Information Assurance (IA) and Security Program support services to the incumbent contractor, TestPros Incorporated. The Information Assurance (IA) and Security Program support services will ensure that United States Coast Guard (USCG) Information Systems (IS) have access to the services required to maintain compliance for confidentiality, integrity, availability, authentication and non-repudiation.

(b) TestPros Incorporated 46090 Lake Center Plaza Suite 306 Sterling, VA 20165

(c) Contract Type: Firm-Fixed-Price

(d) Estimated total value (including options):

Performance Period Dates Amount

Base Period 01 July 2020 - 31 July 2020 Option Period One 01 August 2020 – 31 August 2020 Total Potential Value

(e) Type of funding: AFC-42

(f) Year of funding: Fiscal Year 2020

(g) Solicitation number: RFP IAEXPWS272

(h) Background information about this requirement: These services are currently being performed under Task Order HSCGG3-17-J-PWY039, Contract HSHQDC-13-D-E2003, which was competitively awarded on 28 July2017, under EAGLE II Functional Category 3 Small Business Track. The incumbent contractor is TestPros Incorporated and the current period of performance expires on 30 June 2020.

(3) Description of Supplies/Services.

The USCG requires continuation of IA and Security Program support services in order to ensure that USCG IS have access to the services required to maintain compliance for confidentiality, integrity, availability, authentication and non-repudiation. The Cybersecurity and Information Assurance support services, tasks and management required to support Department of Homeland Security (DHS) and USCG IS developed and

Limited Source Justification (FAR Part 8) maintained at multiple geographical locations. These systems support missions that include, but not limited to Protection of Natural Resources, National Defense, Maritime Safety, Mobility, Security, Financial Management, IT Support, and Administration of Mariner Credentials.

(4) Identification of the justification and the rationale.

This acquisition is being conducted under the authority of the General Services Administration (GSA) Multiple Award Schedule (MAS) Program in accordance with FAR 8.405-6 limited sources justification and approval.

The statutory authority permitting exception to fair opportunity is 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 provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

A sole source to the incumbent, TestPros Incorporated, is required as TestPros Incorporated is the only company capable of continuing to support IA and Security Program Services at this time due to the COVID 19 pandemic which has caused a delay in the efforts to competitively award a follow-on contract via DHS Strategic Source Chief Information Officer-Solutions and Partners 3 (CIO-SP3) Woman-Owned Small Business set-aside.

TestPros Incorporated is the only company capable of continuing to provide IA and Security Program services at this time without a disruption of IA services. The current IA contract supports 40+ Coast Guard systems that align to the 11 Coast Guard Missions. Transitioning from TestPros Incorporated to a new service provider is estimated to take approximately one (1) month, which would mean award must be made by 1 June 2020 to prevent a lapse in service and the current contract expires on 1 July 2020. USCG is in source selection for the follow-on contract. However, the delay to the pre-award schedule created by the COVID-19 pandemic will not provide sufficient time to complete the pre-award steps and make an award by 1 June 2020 in order to conduct the transition. Due to the need to conduct a transition, it is not in the best interests of the USCG to conduct a source selection for the two-month time period while also engaging in the source selection process for the follow on.

The only reasonable option to ensure continuation of these critical services with no disruption is to issue a sole-source task order to the incumbent, TestPros Incorporated. Failure to award this sole-source task order puts the USCG at serious risk of a break in service and disruption of critical services, including but not limited to IA/Information System Security Officer (ISSO)/Cyber services to the C5ISC Commander and CGCYBER Commander.

TestPros Incorporated has the experience and knowledge required to provide IA/ISSO/Cyber services. The incumbent has the competence and required skill sets to complete this effort without a loss of efficiency to the components of the USCG’s many systems. TestPros Incorporated has been able to show the technical proficiency needed to ensure that the 40+ Systems located at the Operations Systems Center (OSC) and FINCEN data centers maintain Cybersecurity and Federal Information Security Management Act (FISMA) compliance oversight for DHS and Department of Defense (DoD) reporting. Not maintaining Cybersecurity compliance could potentially put systems in jeopardy of being compromised and susceptible to potential disconnect notice from Joint Force Headquarters-Department of Defense Information Network (JFHQ-DODIN). The Chief Financial Officer (CFO) systems are currently in the midst of an Office of Management and Budget (OMB) Circular A-123 and DHS CFO Audit. TestPros supports the effort with daily coordination between the audit entities to ensure no overlap occurs and OSC CFO Systems are able to pass the audits.

The USCG does not have the federal staffing or the federal expertise to perform the technical support necessary for ensuring FISMA and Cybersecurity compliance for 40+ systems. The six Government staff are heavily engaged with C5ISC Organization Modification Request (OMR), FY21 budget, and other Government led initiatives. To fill this gap, it is necessary to contract for support services with the needed skill sets to maintain and implement an enterprise-wide commercial software product. The USCG requires the uninterrupted support for IA/ISSO/Cyber services for all USCG systems which is why a sole source to the incumbent is in the best interests of the USCG.

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

The Contracting Officer hereby determines that this action represents the best value to the Government in accordance with FAR 8.404(d). The contracting Officer will compare the proposed rates for the extension to the current rates, which were previously determined to be fair and reasonable. Additionally, the Contracting Officer will perform a price evaluation as required by 8.405-2(d) to make a final determination of fair and reasonable pricing.

(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.

Market research was conducted for this sole-source task order for the singular purpose of validating the use of Federal Supply Schedules as the best contract vehicle in which to reach the incumbent, TestPros Incorporated.

(7) Any other facts supporting the justification.

None.

(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that preclude the agency from meeting the requirements of 8.405-1 and 8.405-2 before any subsequent acquisition for the supplies or services is made.

The USCG is concurrently in source selection for the follow-on contract. It is being competed under the DHS Strategic Source CIO-SP3 SB as a Woman-Owned Small Business set-aside.

(9) Contracting Officer’s Certification.

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

Date CG-9142 Contracting Officer, C5ISC

(10) Technical/Requirements Personnel Certification.

I certify this requirement meets the Government’s minimum need and that the supporting data, which form a basis for this justification, are complete and accurate.

Date

Branch Chief, OSC

(11) Legal Review and Concurrence:

I have reviewed this justification and deem it legally sufficient.

Procurement Law Attorney

APPROVAL:

Command Procuring Activity Competition Advocate (CPACA)