ID07180059_Justification_for_Exception_to_Fair_Opportunity.pdf

Justification for an Exception to Fair Opportunity Task Order: ID07180059

ID07170030: Justification for Exception to Fair Opportunity

Justification for an Exception to Fair Opportunity

1) Identification of the Agency, Contracting Activity, and Document being approved:

Contracting Activity: GSA / AAS Region 7 Agency: GSA acting on behalf of US Army IMCOM Task Number: Bridge Task Order ID07180059 Description of Requirement: Bridge Task Order for Mission Assurance support on behalf of the US Army Installation Management Command (IMCOM)

Document being approved: Justification for an Exception to Fair Opportunity

Contractor Name: Booz Allen Hamilton, Inc. (BAH), 8283 Greensboro Dr., McLean, VA 22102

GSA GWAC Contract Number: (OASIS Contract) GS00Q14OADU108

2) Description of action being approved:

This Justification for an Exception to Fair Opportunity is in support of a bridge task order consisting of a six-month Period of Performance (POP) with one (1) three-month option (nine (9) months in total) to allow for the continuance of critical Mission Assurance contractor support currently being provided by BAH on Task Order GSC0015AJ0047 (also known as GTMP). The current task order was competitively awarded by GSA FEDSIM via the OASIS (Unrestricted) GWAC. In July of 2018 AAS Region 7 was notified that US Army IMCOM in San Antonio, TX (Fort Sam Houston) would not be able to continue on the GTMP Task Order into FY 19.

GSA Region 7 AAS has begun actions to compete a new contract action for IMCOM; however, the aggressive pre-award milestones, require approximately six to nine months for acquisition planning, solicitation, vendor evaluation and award. This timeline, though aggressive, will not result in an award before IMCOM loses service through GTMP, which in turn will cause a protracted loss of critical support for US Army IMCOM. By putting a bridge task order in place, these critical support services can be maintained during the solicitation and award timeframe.

The bridge task order is being issued with a six-month base period of performance and one (1) three-month option period to allow GSA to end the bridge task order as soon as possible after award of the competitive task order. BAH under the GTMP Task Order has workers who are currently in-place who can continue to support IMCOM Mission Assurance requirements and provide unbroken service. As such, the US Army IMCOM requests these services be provided by BAH in order to prevent any loss of service or increase risk to any installations or military personnel.

3) Description of Services Required:

This Justification for an Exception to Fair Opportunity is to support a bridge task for a six-month base period of performance and one (1) three-month option period, on a sole source basis to BAH, to provide mission Assurance for the US Army IMCOM.

IMCOM oversees all Army-wide installation management and related planning, programming, and budgeting activities. IMCOM requires contracted professional, technical, management, and analytical support services to support this mission at all locales. This includes project management and analytical support services to Headquarters (HQ) IMCOM specifically for the HQ IMCOM Provost Marshal/Protection which includes planning, coordinating, resourcing and executing installation Base Operations Mission Assurance protection Program requirements. In this capacity, Contractors shall coordinate with Army

ID07180059: Justification for Exception to Fair Opportunity

Staff, Army North and Army Major Subordinate Command counterparts as required, as well as the IMCOM Directorates.

Through this Task Order BAH will continue to provide vital security, protection, and risk management expertise or results that further the goals of Mission Assurance. Mission Assurance consists of the following 12 “Pillars”:

a. Antiterrorism:

AT is defined as defensive measures used to reduce the vulnerability of individuals and property to terrorist acts, to include limited response and containment by local military and civilian forces. The AT Program is a collective, proactive effort focused on the prevention and detection of terrorist attacks against DOD personnel, their families, facilities, installations, and infrastructure critical to mission accomplishment, and the preparation to defend against and planning for the response to the consequences of terrorist incidents. Commanders of ACOMs, ASCCs, and DRUs; and the CAR and the CNGB are responsible for incorporating AT into their plans and operations.

b. Computer Network Defense:

CND is defined as actions taken to protect, monitor, analyze, defend, and respond against unauthorized activity within Army and/or DOD information systems and computer networks. CND actions include protection, monitoring, analysis, detection, response (to include restoration), and capability sustainment.

Commanders of ACOMs, ASCCs, and DRUs; CNGB; CAR; and direct reporting program managers responsibilities include ensuring their units, activities, and installations develop and implement an IA program to support Army CND efforts.

c. Continuity of Operations Program:

COOP is defined as policies, plans, procedures, and capabilities that provide for the continued execution of critical missions and functions across a wide range of potential emergencies, including localized acts of nature, accidents, technological, and/or attack related emergencies. The COOP responsibilities of commanders of ACOMs, ASCCs, and DRUs include developing and maintaining a COOP program and maintaining a COOP operations plan (OPLAN) that identifies and prioritizes MEFs.

d. Critical Infrastructure Risk Management:

CIRM is the Army program to implement Defense Critical Infrastructure Program responsibilities by conducting the Critical Asset Identification Process with ACOMs, ASCCs, and DRUs; USAR; and ARNG to identify Task Critical Assets; nominate Defense Critical Assets; and conduct risk management activities.

The CIRM responsibilities of the commanders of ACOMs, ASCCs, and DRUs; USAR; and ARNG include maintaining awareness of infrastructure risk and implementing required risk mitigation strategies.

e. Emergency Management:

The EM function serves as the single, comprehensive, and integrated EM program on Army installations, facilities, and activities. The Army EM Program is responsible for all activities and operations related to preparing for, mitigating the potential effects of, preventing, responding to, and recovering from all multi-agency and/or multijurisdictional emergencies on or impacting Army installations worldwide. The Army EM Program functions within an all-hazards environment consisting of all natural, technological (man-made), and terrorism hazards. The EM responsibilities of senior commanders include the implementation of EM program training, standards, and National Incident Management System procedures; all-hazard preparedness; and ensuring Army installations comply with EM requirements, participate in the EM planning process, and provide personnel support as specified in host installation EM Plans.

f. Fire and Emergency Services:

F&ES is defined as the program that ensures public safety by providing response capabilities and medical services during emergencies. The F&ES Program provides policy formulation, strategy development, enterprise integration, program analysis and integration, requirements and resource determination, and best business practices for services, programs, and installation support to Soldiers, civilians, and family members, and of an expeditionary Army in a time of persistent conflict.

g. Health Protection:

HP is defined as medical and public health activities and measures that identify, prepare for, and respond to health hazards and emergencies, resulting in Army mission accomplishment and protection of the Army Family. HP includes: medical emergency readiness (preparedness, response, and special teams); health promotion (risk communication, occupational health, and community resilience); medical therapeutics (for emerging and continental United States threats and distribution capability); medical prophylaxis (vaccines, pretreatments, and protective measures); medical intelligence (medical information, global health engagements, and medical analysis); and medical surveillance (risk, reports, and impact on the force).

h. High-risk personnel:

Senior Army civilian and military leadership serve as an extended symbol of our nation’s Army, making them attractive and accessible targets. Some personnel are at a greater risk than the general population by virtue of their rank, assignment, symbolic value, vulnerabilities, location, or a specific threat requiring additional security to reduce or eliminate risk. These individuals are formally designated as HRP.

Additional protection may be provided to HRP through progressive levels of training, equipment support, facilities improvement, and/or personnel protective services detail support.

i. Information Assurance:

The IA Program is the protection of systems and information in storage, processing, or transit from unauthorized access or modification; denial of service to unauthorized users; or the provision of service to authorized users. It includes those measures necessary to detect, document, and counter such threats.

Measures that protect and defend information and information systems (IS) ensure their availability, integrity, authentication, confidentiality, and nonrepudiation. This includes providing for restoration of IS by incorporating protection, detection, and reaction capabilities. Commanders of ACOMs, ASCCs, and DRUs; ARNG; and USAR; program evaluation offices (PEOs); and direct reporting program managers (PMs) responsibilities for IA include ensuring their units, activities, or installations develop and implement an IA program with hardware, software, tools, personnel, and infrastructure.

j. Law Enforcement:

LE is defined as directing, developing, and monitoring implementation of HQDA policies pertaining to LE, military working dogs, police intelligence, military police investigations, military police offense reporting, U.S. Army Deserter Information Program, and other provost marshal activities.

k. Operations Security:

OPSEC is a process of identifying critical information and subsequently analyzing friendly actions attendant to military operations and other activities to: identify those actions that can be observed by adversary intelligence systems; determine indicators that hostile intelligence systems might obtain that could be interpreted or pieced together to derive critical information in time to be useful to adversaries;

and select and execute measures that eliminate or reduce to an acceptable level the vulnerabilities of friendly actions to adversary exploitation. Commanders at all levels are responsible for ensuring that their units, activities, or installations plan, integrate, and implement OPSEC measures to protect their command’s critical information in every phase of all operations, exercises, tests, or activities; and issuing orders, directives, and policies to protect their command’s critical and sensitive information in order to clearly define the specific OPSEC measures that their personnel should practice.

l. Physical Security:

The PS Program is defined as the interrelationship of various components that complement each other to produce a comprehensive approach to security matters, including PS plans; PS inspections and surveys;

participation in combating terrorism committees and fusion cells; and a continuing assessment of the Installation’s PS posture. The PS program prescribes policies for the protection of certain assets: arms, ammunition, explosives, biological select agents and toxins, unclassified Army property, nuclear reactors and special nuclear materials, and chemical agents. The program prescribes policies for the protection of Army sites, specifically controlling access to installations and standalone facilities and restricted area controls. The program also prescribes policies for Army civilian police and security guards. The commanders and directors of ACOMs, ASCCs, DRUs, USAR, and ARNG PS responsibilities include establishing a PS program to plan and coordinate PS matters

To support this mission the contractor will provide a number of FTE’s ranging from Junior to Senior levels at US Army IMCOM locations both CONUS and OCONUS. These individuals will directly support IMCOMs mission.

Estimated Dollar Value: $47,569,314.00

Six-Month Period of Performance (base) (9/21/2018 – 3/21/2019) | $31,712,876.00 Option 1 (Three-Month) (3/22/2019 – 6/21/2019) | $15,856,438.00

4) Identification of Exception to Fair Opportunity and Supporting Rationale:

This acquisition is conducted under the authority of FAR 16.505(b)(2), entitled Exceptions to the fair opportunity process, specifically FAR 16.505(b)(2)(i)(A): The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays. After September 21, 2018 US Army IMCOM will no longer be able to get these services through the GTMP Task Order GSC0015AJ0047. There is insufficient time to allow for competition and contractor selection, as well as time to transition services without losing critical services.

If IMCOM loses these critical support services it will greatly reduce their ability to Prevent, Protect, Mitigate, Respond and Recover (P2MR2) from threats and incidents. Higher Headquarters Assessments (HHA) are mission assurance assessments of the 12 non-warfighting pillars and 3 enablers on IMCOM Installations IAW DoDI-O 2000.16, AR 525-13 and the DoD Vulnerability Assessment Benchmarks. Loss of this capability will remove command oversight from critical programs. An investigation into the Washington Navy Yard shooting, that took place in September of 2013, found that loss of command oversight was a factor in the government failing to identify or stop this threat.

Critical Infrastructure Risk Management (CIRM) is executed IAW DoDI 3020.45 and AR 525-26 assuring that critical infrastructure assets are available to support national security through the process of identification of public, private, and governmental (Federal and military) infrastructure assets both cyber and physical; the conduct of vulnerability assessments; the determination of risk; and the management of risk. Loss of this capability will critically degrade or possibly cease capabilities vital to National Security.

The decision to award this sole source bridge task to BAH takes into account the Government's need for continuity of operations and the potential costs of disrupting operations and losing these critical services.

It was decided that executing a bridge task order to keep in place the previous support personnel would be the most advantageous and cost effective option available to the Government, price and other factors considered. In order to maintain continuity of support for the client until the follow-on re-compete task order is awarded, issuing a bridge task order is found to be the most logical and cost effective alternative to the Government.

5) Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable and Represents the Best Value:

A quote will be requested from BAH for the bridge task order, consisting of a six-month base period of performance and one (1) three-month option period. The cost and price will be determined to be fair and reasonable by the Contracting Officer before award is made. BAH will be requested to provide the same levels of services required by US Army IMCOM historically at the same rates for this bridge task order;

these rates were previously approved and found to be fair and reasonable and in accordance with the

GTMP Task Order and the OASIS IDIQ. The GTMP Task Order GSC0015AJ0047 was awarded utilizing fair opportunity ordering procedures for GSA IDIQ Contracts, as identified under FAR 16.505.

This “bridge” Task Order will be a Cost Plus Fixed Fee (CPFF) task order and the Contracting Officer will receive and review Certified Cost and Pricing data to ensure all cost elements are fair and reasonable prior to award. BAH also has indirect rates that are pre-approved by DCAA which will be used for this task order.

6) Other facts supporting the justification:

In order to ensure that this bridge task order is only for the limited and defined period of time described above, GSA is concurrently approving the pre-solicitation documents for the competitive, long-term task order. This means that the GSA has, at the time of issuance of this bridge task order, follow-on re-compete documents. Having these re-compete documents in hand reduces the risk of delays and provides assurance that the bridge task order is truly a temporary measure and that a long-term follow-on task order (one year base and four one year options) will be issued in the very near future.

7) Description of Efforts to Remove or Overcome Barriers that led to this Exception:

Competition was received on GTMP task order GSC0015AJ0047 and there is an urgent and compelling need to limit competition on the bridge task order while the follow-on task order is being solicited. This sole source bridge task order will allow GSA and IMCOM adequate time for market research, communication with industry, and other measures to ensure fair opportunity is provided on the subsequent requirement.

Adequate competition is anticipated for the long-term requirement.

8) Contracting Officer’s Certification

The Contracting Officer certifies by signature below that this justification is accurate and complete to the best of my knowledge and belief.

9) Technical Representatives Certification

By signature below the technical representative with the US Army IMCOM certifies that the supporting data which forms the basis of this justification is accurate and complete.

10) Determination by the Approving Official

Based on the above information, it is hereby determined by the approving official signature below that the circumstance in FAR 16.505(b)(2)(i)(A) applies to this order.

SIGNATURE PAGE

Thomas Leugers Date Antiterrorism Officer HQ, US Army IMCOM

Paul Szymanski Date Contracting Officer

Zach Rich Date AAS Section Chief

Legal Date

Alan Searsy Date Chief, AAS

Shaloy Castle-Higgins Date Acquisition Policy and Program Coordinator

George Prochaska Date FAS Region 7 HCA

8/21/2018

8/21/2018

20180824

LEUGERS.THOMAS.

G.1073649621

Digitally signed by

LEUGERS.THOMAS.G.1073649621

Date: 2018.08.24 06:46:22 -05'00'

PAUL

SZYMANSKI

Digitally signed by PAUL

SZYMANSKI

Date: 2018.08.21 14:22:54 -05'00'

ZACHARY RICH

Digitally signed by ZACHARY

RICH

Date: 2018.08.21 14:25:52 -05'00'

ALAN SEARSY Digitally signed by ALAN SEARSY Date: 2018.08.22 09:59:30 -05'00'

AMY COOK Digitally signed by AMY COOK Date: 2018.08.21 14:58:18 -05'00'

SHALOY CASTLE-

HIGGINS

Digitally signed by SHALOY CASTLE-

HIGGINS

Date: 2018.08.23 14:44:14 -05'00'

GEORGE PROCHASKA Digitally signed by GEORGE PROCHASKA Date: 2018.08.24 08:59:27 -05'00'