ID05210035 JandA - Other than Full and Open - Redacted for Posting.pdf

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Justification for Other Than Full and Open Competition

Solicitation ID05210035

General Services Administration

JUSTIFICATION AND APPROVAL

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION/CONTRACT 47QFLA21K0028 (ID05210035)

The General Services Administration (GSA) makes this Justification and Approval (J&A) for

Other Than Full and Open competition pursuant to Federal Acquisition Regulation (FAR) 6.303.

1. Identification of Agency and Contracting Activity:

This Justification for Other Than Full and Open Competition is being executed by GSA

Region 5, Federal Acquisition Service (FAS), Assisted Acquisition Services (AAS) on behalf of Headquarters Air Combat Control Cyberspace Capabilities Center (HQ ACC CCC/NIX) at Scot Force Base (AFB), IL.

2. Nature and/or Description of the Action Being Processed:

GSA intends to award a new, firm fixed price (FFP), sole source Blanket Purchase

Agreement (BPA) to the Escal Institute of Advanced Technologies, Inc (DBA: SANS

Institute (SANS)) for Global Information Assurance Certification (GIAC) Certified Incident

Handler (GCIH) certification renewal vouchers.

3. A Description of the Supplies/Services Required to Meet Agency Needs:

HQ ACC CCC/NIX provides support to the Air Force information assurance workforce to meet the commercial cyber security certification mandates set forth by the Department of

Defense (DoD). In their capacity, HQ ACC CCC/NIX serves as the Air Force focal point to procure and distribute commercial exam and annual maintenance fee vouchers sanctioned by the DoD.

In accordance with DoD 8570.01-M, Information Assurance Workforce Improvement

Program, and AFMAN 17-1303, Air Force Cybersecurity Workforce Improvement Program, the United States Air Force (AF) is mandated to ensure all personnel assigned to Information

Assurance (IA) positions achieve and maintain commercial certification commensurate with the level of duties associated with their specific position. The GCIH, which validates an individual’s ability to detect, respond, and resolve computer security incidents using a wide range of security skills, is one of the cyber security certifications offered to the IA workforce.

Under the resultant BPA, SANS will provide GCIH certification renewal vouchers in quantities requested by the Government. The total estimated value of the effort for a five-year base ordering period is $XXXXXX.

4. Identification of the Statutory Authority Permitting Other Than Full and Open

Competition:

This J&A is pursuant to FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Demonstration that the Proposed Contractor’s Unique Qualifications or Nature of the

Acquisition Requires Use of the Authority Cited:

The SANS Institute is the governing body for the GIAC certifications. SANS develops and controls the policies and procedures for purchasing certification tests and renewal vouchers.

SANS is the sole provider for these items and does not allow third parties to act as their agent. A disclaimer, found on the GIAC website (https://www.giac.org/about/program-overview), states:

“The GIAC certification program only offers certification attempts to individual candidates, including verification of individual identity at multiple steps. SANS is the sole source for

GIAC certification exams and exam vouchers. GIAC does not permit the resale or transfer of any certification registration or GIAC exam voucher. Each certification attempt purchased is non-transferable and any certification application / registration instance is intrinsically tied to one and only one individual account.”

Accordingly, SANS is the only firm capable of providing exam and renewal vouchers to meet this requirement.

6. Description of Efforts Made to Ensure that Offerors are Solicited from as Many

Potential Sources as Practicable:

The Contracting Officer posted a Request for Information (RFI) to GSA eBuy to solicit responses from Schedule Contractors under the Schedule Special Item Number (SIN)

611420, Training Courses. The RFI was posted on April 5, 2021 with a response date of

April 12, 2021. One company, Mile2, stated that while they cannot provide official SANS

GIAC exams and vouchers, they can offer what they claim to be comparable courses which map to some SANS certifications, allowing students to earn the Mile2 credential and prepare for the official SANS exam. This does not meet the customer’s requirement for official

SANS certification exam and renewal vouchers. No other companies responded to the RFI.

This effort will be synopsized IAW FAR 5.201 indicating the Government’s intent to award a sole source BPA. The approved J&A will be posted to beta.SAM within 14 days of award

IAW FAR 6.305(a).

7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable:

The GSA Contracting Officer will determine prices fair and reasonable IAW FAR 13.106-

3(a)(2), which states “If only one response is received, include a statement of price reasonableness in the contract file. The Contracting Officer may base the statement on –

(i) Market research;

(ii) Comparison of the proposed price with prices found reasonable on previous purchases;

(iii) Current price lists, catalogs, or advertisements. However, inclusion of a price in a price list, catalog, or advertisement does not, in and of itself, establish fairness and reasonableness of the price;

(iv) A comparison with similar items in a related industry;

(iv) The contracting officer’s personal knowledge of the item being purchased;

https://www.giac.org/about/program-overview https://www.giac.org/about/program-overview

(v) Comparison to an independent Government estimate; or

(vi) Any other reasonable basis.”

8. Description of the Market Research Conducted or a Statement of the Reason Market research was not Conducted:

The Contracting Officer reviewed historical acquisitions and found that this requirement was previously met under firm-fixed price (FFP) Blanket Purchase Agreement (BPA)

ID05160012, awarded on a sole source basis to SANS. Award was issued on Jun 9, 2016 for a one-year base period with four one-year option periods. Prior to the issuance of BPA

ID05160012, the client purchased GCIH certifications numerous times using their

Government Purchase Card (GPC), each time from SANS.

Internet searches were conducted to search for potential providers. A query of the SBA

Dynamic Small Business Search (DSBS) tool using NAICS code 611420 (Computer

Training) and keywords “Information Assurance” yielded six (6) small business records, however review of their capabilities narratives showed that they could not meet the needs of the Government.

To further support this justification and ensure adequate market research, the Contracting

Officer posted a Request for Information (RFI) to GSA eBuy, as discussed above, to solicit responses from Schedule Contractors under the Schedule Special Item Number (SIN)

611420, Training Courses.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition:

None.

10. List of Sources, if any, That Expressed Interest in the Acquisition:

See Section 6 above.

11. A statement of the Actions, if any, the Agency May Take to Remove or Overcome Any

Barriers to Competition Before Making Subsequent Acquisitions for Supplies or

Services Required:

There are currently no sources besides SANS that offer the GIAC GCIH certification renewal vouchers. Market research will be performed for any future requirements and the

Government will continue to monitor the marketplace for additional sources of the required vouchers.

12. Certification by the Technical/Requirements Personnel:

I hereby certify that the supporting data is accurate and complete.

Date: _April 30, 2021

Jason Little, CIV

Program Manager E-Learning, Flight RA & COR

HQ ACC CCC/NIX

LITTLE.JASON.PA Digitally signed by

UL.1104664500

LITTLE.JASON.PAUL.1104664500

Date: 2021.04.30 08:27:13 -05'00'

13. Contracting Officer’s Certification that the Justification is Accurate and Compete to the best of the Contracting Officer’s Knowledge and Belief:

I certify that this justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the finding above that an other than full and open competition approach is in accordance with the requirements and is in the best interest of the

Government.

Reagan P. Criddle

Contracting Officer

GSA, FAS R5, Contracting Division

Final Approval:

Date:

4/30/2021

I certify that this justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the finding above that an other than full and open competition approach is in accordance with the requirements and is in the best interest of the

Government.

Evan Port

Supervisory Contracting Officer

GSA, FAS R5, Contracting Division

4/30/2021

Date: _