J&A-PEOEIS_FINAL,_Redacted.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

AUTHORITY: FAR 16.505(b)(2)

PR/SOL/CONTRACT # D15PD01218

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for an Exception to Fair Opportunity.”

This document is a Justification for an Exception to Fair Opportunity for the Department of the Interior, Interior Business Center, Acquisition Services Directorate, Division 1, Branch 3, on behalf of the Department of the Army, Program Executive Office, Enterprise Information Systems Chief Information Officer (Army PEO EIS CIO).

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

Approval is requested in order to modify the existing task order, D15PD01218, off Army CHESS ITES- 2S to extend the current period of performance for up to two years. The two years will be separated into two, one-year option periods. The current Contractor on this order is CSRA LLC.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

PEO EIS CIO Support Services provides program management support services to the U.S. Army Program Executive Office (PEO) Enterprise Information Systems (EIS), Director G6, Chief Information Officer (CIO), Fort Belvoir, VA, in the execution of responsibilities to support the Enterprise Architecture Division, the Cyber Security Division, Network Operations Division, and other Army initiatives to meet mission requirements of PEO EIS. The PEO EIS has been tasked with addressing priority requirements of Chief of Staff of the Army (CSA) and to rapidly deliver solutions that present the CSA with the information required to assess Army forces status and to facilitate in making informed force utilization and distribution decisions. These activities are supported by critical engineering staff supplied by CSRA LLC under the subject task order and continued to be required by PEO EIS beyond the current task order expiration date. It is anticipated that these activities continue for at least the next 24 months, with the staff to be stabilized during this period to reduce loss of specialized skills and knowledge related to this specific effort.

Additionally, with the establishment of the Army Futures Command, this PEO and Assistant Secretary of the Army (ASA) Acquisition, Logistics, and Technology (ALT) have been advised that some PEO EIS capability and functionality will transition to the new command. To facilitate the rapid establishment of the command and make it functional to meet the intent of the CSA, members of the PEO EIS staff, to include contract personnel, will aid in successful execution of these efforts. The PEO EIS G6 has been advised that personnel covered by this contract will be utilized to support the Futures Command efforts due to CSRA’s specialized expertise and knowledge of Army programs and systems, and institutional knowledge required to assist in the transition of offices.

In order to meet the mission mandates the above support requirements levied against the subject task order, PEO EIS cannot afford to have a transition of support contractor vendors and the loss of the existing contractor support staff during the period specified. To do so would be detrimental to the ability of this command to meet the requirements and would have an unacceptable and significant negative

PR/SOL/CONTRACT # D15PD01218

impact to schedule and performance for both activities.

The estimated value of this extension is . This estimate is based on the actual price of performance for the task order and the current awardee’s Army CHESS ITES-2S contract labor rates.

4. Identification of the exception to fair opportunity (see 16.505(b)(2)) and the supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited. If the contracting officer uses the logical follow-on exception, the rationale shall describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value).

Identify only one of the following.

□ 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.

□ FAR 16.505(b)(2)(i)(B) – Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized (to include brand name in accordance with 16.505(a)(4)).

X FAR 16.505(b)(2)(i)(C) – The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

□ FAR 16.505(b)(2)(i)(D) – It is necessary to place an order to satisfy a minimum guarantee.

□ FAR 16.505(b)(2)(i)(E) – For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

CSRA LLC has been performing the tasks for the past six years under two task orders. Both task orders were awarded using the Fair Opportunity procedures found in FAR 16.505 and were limited to three years of performance due to limitations of the parent IDIQ’s period of performance. At the conclusion of the first task order, the parent IDIQ period of performance had been extended three years, through 2018. At that time, the Contracting Office competed the requirement to the Army CHESS ITES-2S contract holders and received two responses from CSRA LLC (formerly CSC), the incumbent, and Booz Allen Hamilton (BAH). BAH was evaluated to not fully understand the scope of work for the PWS and to present significant performance risks. The second task order was limited to three years of performance in accordance with the updated parent IDIQ performance and ordering period. The current task order expires September 17, 2018.

In fiscal year 2018, Army PEO EIS initiated the acquisition planning process for the re-compete of the program management support internally against the Army CHESS ITES-3S contract (the Army re-compete for ITES-2S). Army CHESS ITES is mandatory for use for Army service contracts. In early 2018, Army CHESS ITES-3S received another round of pre-award protests, delaying award for an estimated 24 months. As a result, Army Contracting Command (ACC) extended the period of performance on Army CHESS ITES-2S by 24 months to April 13, 2020. Army PEO EIS CIO continues to require the same level of service for the current tasks as well as assistance for the transition to the Army Futures Command.

In order to continue services, the Government would have to either compete and award a limited two-year task order or extend the current task order by two years. It is most advantageous to the Government to extend the current task order for two years through the exception to fair opportunity authority selected above. This sole-source extension would be in the interest of efficiency and economy as an extension to the current task order requires significantly less administrative time and government resources to complete and the possible cost savings provided by issuing a new two-year task order through fair opportunity procedures do not outweigh the administrative costs. Furthermore, extending the current order for two years will ensure the historical knowledge and expertise acquired by the CSRA LLC will be reduce the administrative cost of a transition to a new contractor. A transition to a new contractor is not efficient as the new order would be limited to a two year period of performance (as restricted by the ITES-2S contract) and a portion of this time would be for a potential new contractor to “get up to speed” on supporting the Army PEO-ESI program.

All Army CHESS ITES-2S contract holders were given fair opportunity during the solicitation of task order D15PD01218. At the conclusion of D15PS01218 and upon award of Army CHESS ITES-3S, a five year task order will be competed to contractor holders in accordance with the fair opportunity procedures found in FAR 16.505. Based on this information, extending the current task order by two years to September 17, 2020 is in the interest of the Government.

5. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The estimated costs of are in line with the costs of the current level of performance. The current task order price was determined fair and reasonable at the time of award. Based on this information, the anticipated costs of the extension can be found fair and reasonable. Additionally, the labor rates were established at the IDIQ level and determined fair and reasonable at the time of the IDIQ award. The Contracting Officer will make a separate fair and reasonable determination at the time of the modification award.

6. Any other facts supporting the justification.

Not Applicable.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

When the current Army CHESS re-compete is finished and the transition of PEO EIS capabilities and functions to the Army Futures Command is complete, fair opportunity will be given to all contract holders for any future requirements.

8. The contacting officer’s certification that the justification is accurate and complete 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.

Title (Contracting Officer) Date

9. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for an exception to fair opportunity) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify that the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

Title (Program Office/COR) Date

10. A written determination by the approving official that one of the circumstances in FAR 16.505(b)(2)(i)(A) through (E) applies to the order.

Insert the appropriate circumstance justifying the exception to fair opportunity and FAR reference. Use only one exception. Must match the exception identified in #4 above.

8/21/18

8/21/18

Digitally signed by

Date: 2018.08.21 07:41:06 -04'00'

1065313754 Digitally signed by

1065313754 Date: 2018.08.21 13:54:17 -04'00'

11. Reviews and Approvals

Concur

Title (Branch Chief) Date

(Division Chief approval is required for actions valued from the Simplified Acquisition Threshold up to $700,000)

Concur

Title (Division Chief) Date

(Bureau Competition Advocate approval is required for actions valued from $700,001 up to $13.5 million).

Concur

Bureau Competition Advocate Date

(Head of the Contracting Activity approval is required for actions valued from $13,500,001 up to $68 million.)

Approve

Head of the Contracting Activity Date

8/22/18

8/22/18

Digitally signed by

Date: 2018.08.22 12:31:02 -04'00'

Digitally signed by

Date: 2018.08.22 14:30:37 -04'00'

Digitally signed by Date: 2018.08.23 14:34:33 -04'00'

Digitally signed by Date: 2018.09.11 17:12:40 -04'00'