IT IM DF 22 May 25 Final (002) Redacted.pdf

CUI

DETERMINATION AND FINDINGS

CONSOLIDATION OF INFORMATION TECHNOLOGY -INFRASTRUCTURE

MAINTENANCE (IT-IM) SERVICES

FA8055-25-Q-000X

Contracting Activity: 771 ESS/EGCB

Regulation/Authority: This Class Determination and Findings (D&F) was prepared in accordance with (IAW) the Federal Acquisition Regulation (FAR) 1.704, FAR 7.107-2, Department of Air Force Federal Acquisition Regulation Supplement (DAFFARS) 5307.107-2, and 15 U.S.C. 657q. This D&F supports the determination to consolidate DAF wide requirements previously performed under various contracts, orders, and stand-alone awards as detailed below.

Requirement: The 771st Enterprise Sourcing Squadron, Information Technology Contracting Flight (771 ESS/EGCB), intends to consolidate the legacy Base Operating Service- Information Technology (BOS-IT) maintenance and sustainment requirements into strategic enterprise, multiple awards, decentralized commercial Blanket Purchase Agreements (BPAs) supporting Air Force Installation and Mission Support Center, Cyber Systems Support Branch (AFIMSC/A531). This acquisition effort is known as IT-IM. This consolidation will standardize the levels of service across the DAF while increasing accountability for the infrastructure systems.

Consolidation under multiple award acquisition which consists of multiple Firm Fixed Price (FFP) BPA commercial contracts is in the best interest of the Government to support standardization and accountability of the IT-IM infrastructure, standardizing processes, performance and award standards and data within the DAF. Consequently, consolidation is necessary and justified because the above-referenced expected benefits are critical to mission success and, as described below, the strategy provides for maximum practicable participation by small business.

FINDINGS

1. Background:

IT-IM is the telecommunication architecture that allows video, voice, and data to be transmitted from user to user on and off AF installations. There are six (6) major equipment systems that require sustainment and maintenance services within the existing telecommunications architecture: Digital and Internet Protocol (IP) - based Voice Systems, Giant Voice, Cable Infrastructure, Antenna, Microwave systems, and Land Mobile Radio (LMR) back haul (routers and switches). The Base Operating Support-Information Technology (BOS-IT) legacy systems (Base Telecommunication Support (BTS) contracts have significantly increased above the original scope over time and with technological advancements, have grown to become more IT centric (server/software/hardware) and moving into an Enterprise IT as Service (EITaaS) architecture.

IT-IM is intended to capture all the work outside of the EITaaS realm. Currently, the majority of BOS-IT management and sustainment for legacy BOS-IT infrastructure are disparately resourced and managed by five (5) major organizations; ACC, SAF/CN, AFIMSC, AFCEC, and AFLCMC. Each organization is responsible for different elements of sustainment and maintenance of the equipment for BOS-IT. This spread across organizations does not allow for the development of an enterprise strategy to maintain the systems. Gaps in communication, funding shortfalls, lack of standardized guidance/policy drives excess spending, burdened administration costs and fragments the longevity of the system’s lifecycle.

Historically, the disparate purchases for these requirements have been conducted at the MAJCOM or installation level which has resulted in the issues discussed in the above paragraph related to the spread in responsibility across organizations. Further information about prior acquisition efforts is described in Paragraph 3, Market Research.

2. Description of Procurement Action:

The purpose of this acquisition is to standardize levels of sustainment and operational readiness of common core communication systems across the DAF ensuring serviceable mission systems that meet technical orders or commercial manual standards. Systems to be maintained include Digital and Internet Protocol (IP)-based Voice Systems, Giant Voice, Cable Infrastructure, Antenna, Microwave systems, and (LMR) back haul covering all DAF Installations both CONUS and OCONUS.

Required services include routine maintenance, Preventative Maintenance Inspections (PMI), sustainment, troubleshooting and repairing system faults, replacing faulty components, and installing infrastructure based on emerging mission requirements or refreshing capability. Additional services include special projects which are one-time requirements that fall within the overarching scope of the Performance Work Statement (PWS) and contribute to mission effectiveness.

The approach to standardize services is to establish a commercial Firm Fixed Price DAF wide vehicle for services which also standardizes the maintenance and sustainment verbiage for services acquired.

The ability to establish a central source to procure services will also assist in appropriate data collection for future inventory management development.

The DAF does not have an official Program/Product office for this effort and therefore does not currently have a centralized point of data collection to determine DAF wide quantities. Currently, efforts have been made through Installation Assessment Visits (IAVs) and Installation Health Assessments. However, due to the lack of organic resources, the various assessments have not been sustainable to execute throughout the enterprise within reasonable timelines to determine the total magnitude of infrastructure across the DAF. Historical purchases have been the predominant determinant for establishing estimates rather than basing spend on the infrastructure inventory.

An Independent Government Estimate (IGE) was completed by the AFIMSC/A53I team and the total value for the five-year ordering period is approximately $390M. To determine the magnitude of effort, A53I completed a review of historical spend data for the last 5 years of validated requirements data. The data was obtained using AFIMSC's FM Tool BEAST, IAVs, and Advocate Category Intelligence Report Events (ACE) for Cable, Antenna, and Microwave. A 3% inflation rate was applied to each subsequent year. The assumption was made that future costs would not exceed current/known costs by greater than 20%. A53I identified external price drivers such as new and emerging technologies that are anticipated on this agreement and will be identified as Special Projects or Modernization.

3. Market Research:

Market research was collected from 15 Aug 2023 to present. Market research was collected from the following resources: three (3) contract data requests using FPDS contract reporting data, data call information collected from the installations, researching GSA, two Requests for Information (RFI) posted through SAM.gov, agency interviews, and industry interviews. All information was consolidated into the Market Research Report dated 18 Apr 2025.

Contract Data Reports - Key term descriptions were researched based upon the following North American Industry Classification System (NAICS) codes identified as 517311,517110, 517312, 517210, 541513, 515210, 238210, 541512, 811213, 541330, 541511, 517810, 344290, 334110,237130,443120, 811210, 551120, 517112, 517111, 517121, 517410. After the data collection findings were reviewed, it was noted there was a significant gap between the contract report data and the IGE which was developed utilizing the BEAST data system. The gap appeared to be over $100M. Additional key terms were utilized to further define the gap between what was contractually reported and what was in the database from the requiring activity. Those additional key terms were found to reduce the gap by over $20M. The Government team finds that the methodology used to report the acquisitions in FPDS is severely disparate and assumptions in the development of the IGE are made to account for this disparity.

Contract Spend Data for IT-IM - Multiple spend data reports were collected using targeted keyword terms, NAICS/PSC Codes, and socioeconomic status. The requirements owner provided spend data from their internal system BEAST as well. It is noted that there was a significant delta between the customer spend data and the contract data reporting. Factors attributing to this gap are related to how the contract/order actions were reported, the key terms used to search for data, and services versus equipment purchases for installations with gaps in the services procured. The terms of the data collection were from FY22-FY24 for the first two reports and the final report from FY21-FY24. The acquisition team relied on the contract data while taking the BEAST reporting into consideration of the team’s total estimates. The following are the findings from those reports:

• Total spending from FY21 -FY24 is $221M. 57% of all actions were awarded to small business (inclusive of socioeconomic category SB). Total small business set aside spend totaled 15%. The average spend per month across the enterprise is approximately $18M.

• The contract data showed $188.7M was not directly set aside; however, of that 49% was reported as small business inclusive of various small businesses with one or more socioeconomic statuses. There were 14 MAJCOMs supported over the course of the researched fiscal years. The average total number of actions historically is 345.

• Key Terms - The descriptions and terms utilized in reporting on IT-IM are disparate and the size of spend varies significantly based on what words are used to search. The terms can provide a yard stick estimate and were not as accurate as anticipated.

• NAICS Codes - NAICS and PSC codes were considered in the development of spend reporting for this effort. Over 20 codes combined were utilized to describe the services included in this scope over the three-year period. This reaffirms the disparate nature of procurement and how the varied spend can be attributed to which codes are used.

• Businesses Size and Socioeconomic Status - From FY21 -FY24 approximately 15% of the services were reported as small business. Approximately 50% of the industry spend was on small business with the majority, 72% top spend in the SB categories combined with various socioeconomic statuses. This is sufficient to set aside 100% for small business.

FY21-FY24 total dollars awarded to SB whether set-aside or open award is $126,287,203.44 as demonstrated in the above two charts.

$188,702,608.01, 85%

$23,988,321.76, 11%

$7,532,638.93, 3% $1,427,048.33, 1% $4,420.00, 0%

$0.00, 0%

Obligation by Type of Set-Aside, FY21-FY24

NO SET ASIDE USED/REPORTED

SMALL BUSINESS SET ASIDE -

TOTAL

8(A) SOLE SOURCE

HUBZONE SET-ASIDE

SDVOSB SOLE SOURCE

8A COMPETED

Additional Small Business and Socio-economic Historical Data

FY21-FY24 historical data identified 101 small business and small business socioeconomic vendors who participated in various procurements. The table below demonstrates the breakout of socio-economic status of those vendors;

Internal Research This tool is used by all installations for requirements validation for services that are outlined in the IT-IM contract. The estimated spend over five years was based on a 5-year history of validated requirements. It also accounts for a 3% rate for inflation. CONUS and OCONUS costs were considered as well.

GSA Research – The following is a summary of the potential GSA Vehicles to determine if the IT-IM scope was aligned to one of the likely similar Government Wide Acquisition IT centric Contracts (GWACs). Four GWACs appeared to potentially be in scope of the requirements for the DAF.

POLARIS GWAC- The anticipated award for the Polaris contract was 2023. The contract is a multiple award indefinite-delivery/indefinite-quantity (MA-IDIQ) GWAC. Services are Information Technology (IT) and IT service-based solutions from small businesses. After researching what was included as part of the Polaris scope, it was determined that it did not align to the scope of the DAF IT-IM PWS. The services were focused strictly on IT not inclusive of the six (6) major elements of this effort.

8(a) STARS III - The scope for this GWAC is centered around a product or commodity rather than a service and does not include support for the six (6) major elements of this effort.

2GIT- The description of this GWAC appeared to not be in line with the requirements of this effort. As stated above the team found the contract to be commodity based as well and did not support the services necessary.

ALLIANT 2 - This acquisition meets commercial needs; however, the DAF does not meet the funding requirements of this contract. IT-IM is too small of an acquisition to use this contract.

Industry – Based upon the RFI and information collected from vendor interviews, DoD constitutes an average of approximately 60% of the consumer market within IT-IM services. The Government is one buyer among many that utilize the various descriptions of services available in the marketplace. Market research indicates that the required items are of a type customarily used by the public or by non-governmental entities for purposes other than governmental purposes and have been sold, leased, or licensed to the general public. As commercial services, they are not designated as military unique services or under configuration of the Government; however, the Government does appear to have moderate leverage of this type of service acquisition.

Historically, many of the service procurements of IT-IM have been with small businesses. The research supports a 100% small business set aside. Prior to obtaining the results of RFI, the historical data found that 20 current contracts/orders support Base Telecom Services (BTS) maintenance and sustainment. Of those 12 are small business contracts, eight(8) of them are 8(a) contracts. It is noted that the 20 current contracts are not inclusive of the entire DAF, but it is our sample size that we received from the bases and/or AFIMSC/A531.

Request for Information – After a review of historical and existing contracts, it was determined that most of the contracts executed for sustainment and maintenance for legacy and BOS-IT have been awarded to small business vendors and small business vendors with various socioeconomic statuses. There is reasonable expectation that two or more responsible small businesses, competing independently, would submit offers in response to an Invitation to Establish a BPA (IEBPA). Each installation is unique regarding the infrastructure due to installation size and mission and therefore services and what is required to be serviced on each base may vary significantly. Currently there is no existing contract or vehicle that would support the entirety of the DAF and offer a strategic solution with the capability to also standardize various aspects of the processes, communications and workflow of the systems of this effort.

On 05 September 2024, a Request for Information notice was posted on SAM.gov. This RFI response date was extended to 04 October 2024. A survey of potential sources was identified, and details are provided below. The total number of responses from the RFI was 12. Of the potential sources, 11 are small businesses and 1 large business.

A second RFI was posted on 14 January 2025 and closed on 30 January 2025. A survey of potential sources has been identified, and details are provided below. The total number of responses from the RFI was 7. Of the potential sources, 6 are small businesses and 1 large business.

In total, 2 large businesses and 17 small businesses submitted responses to the Government's RFIs. Of those small businesses, 16 were identified with one or more socioeconomic statuses.

Both RFIs included a draft of the PWS to ensure the requirement was understandable and clear to industry.

Findings from the RFIs show that there are many vendors with niched specialties but no one vendor to perform the entirety of the scope of the PWS. The Government would require a network of vendors to cover the entire enterprise maintenance needs. Vendors found the PWS to be clear and understandable regarding the AF need.

Additional Findings – No one business can perform maintenance and sustainment against the totality of the scope. Based on the contract data history, there are many contractors who have various capabilities aligned to the scope of the PWS and a network of contractors used to sustain and maintain the various functions for the systems architecture. The research shows that there is a sufficient number of small businesses and small businesses with socioeconomic status to support the mission. To maximize small business utilization, the Government's vehicle would require a network of vendors leveraging their distinct and complementary capabilities as a multi-vendor approach.

IT-IM services have typically been procured as commercial services using commercial procedures.

Installation level activities have previously determined the services to be commercial for a type of service

IAW FAR 2.101.

4. Benefit Analysis and Rationale for Rejection/Acceptance of Alternatives:

It has been determined through a benefits analysis that consolidating this procurement is necessary and justified as the expected benefits are critical to mission success. The following strategies were considered:

Alternative #1: Business as Usual “Status Quo”. This approach involves continuing to procure maintenance and sustainment services at the MAJCOM and/or Installation level.

The benefits of this approach include:

• The various contracting departments are familiar with this approach resulting in little to no administrative churn associated with shifting procurement strategies.

• Each installation can prepare installation specific requirements.

The risks of this approach include:

• Varied levels of services that incur excessive spend and gold-plated services that are unnecessary to maintain the infrastructure

• Varied and delayed upgrades in services which incur excessive costs

• Potential delays in critical services due to restrictions on the manufacturers’ proprietary system

• Deferment of requirements to sustain the system or implement efficiencies

• Inefficient use of resources for procurement - utilizes multiple contracting agencies to procure the same type of services across the enterprise

• Difficulty in accountability and auditability as the services are procured across various

NAICS codes and incorporated with other requirements that can make tracking spend difficult

• Differentiation in requirements definition and NAICS coding can lead to difficulty for small businesses to identify services they can provide to the Government and enter new markets which can decrease competition and drive-up costs

Alternative #2: Consolidation of Requirements- using a multiple award Blanket Purchase Agreement with decentralized ordering – 100% small business set aside This approach involves awards of multiple commercial BPAs which will be set aside for small businesses and provide standard PWS and ordering procedures.

The benefits of this approach include:

• The standardization of the PWS and a single ordering procedure process will provide uniformity to deliverables required of small business vendors and ensure clear and consistent communication of requirements to vendors. This will also provide for accuracy within the accountability and inventory of equipment service.

• Competition and participation by various businesses is critical to mission success as it helps drive down costs while also ensuring that the DAF does not become over-reliant on a small number of contractors to provide services that are essential to installation operations.

• Consolidation of the contracts into one acquisition supports accountability and auditability of these services, providing transparency in spending which is critical to the mission success of the DAF by demonstrating DAF’s responsible stewardship in executing taxpayer dollars. As demonstrated by the market research of prior acquisitions for these services, tracking of spend across numerous and varying acquisition vehicles which utilize a plethora of NAICS is difficult. By consolidating these requirements under a single acquisition program, AFIMSC will be able to easily reference BPA call orders awarded under the Master BPA to track spend and ensure proper use of funds.

Accountability and auditability are critical to the mission success of the DAF as it generates confidence among appropriators that DAF is executing funds appropriately and efficiently.

• The standardization of the PWS requirements across installations will ensure that each installation receives like-services, avoiding gold-plating and potentially unnecessary expense associated with varying and individualized requirement generation. Equally, standardization will ensure that installations receive the level of services necessary and are critical to mission success.

The risks of this approach include:

• Installations will be required to transition from their current method of acquisition to this new vehicle. However, the ease of issuing BPA calls off a vehicle that has predetermined CLINs, a PWS, and ordering procedures should allow for a relatively smooth transition.

• Installations will not have the flexibility of completely altering the requirements in each BPA call. However, to mitigate this risk, flexibilities are being built into the overarching PWS and CLIN structure to ensure installations can meet their installation requirements while also promoting the standardization of requirements and accountability of spend.

5. Any negative impact on small businesses has been identified. It is not anticipated that consolidation of these requirements will impact small business in a negative manner. Rather, as this will be a 100% small business set aside. It is anticipated that the awards will maximize utilization of small businesses and small businesses with socioeconomic status at the order level.

6. Coordination with the Office of Small Business Programs: This determination was coordinated with the Secretary of the Air Force Small Business Office (SAF/SB) as required by 13 CFR 125.2 and FAR 7.107-2, in addition to the AFIMSC/SB. Additionally, the acquisition strategy was discussed with the Small Business Administration.

7. Bundling: This acquisition does not constitute bundling. FAR 2.101 defines bundling as a subset of consolidation that occurs when two or more requirements are performed under separate small contracts are combined into a solicitation for a multiple award contract that is likely to be unsuitable for award to a small business concern. In this case, the Government has determined through the market research and feedback from small business entities that this acquisition is suitable for Small Business participation and small businesses are willing and capable of performing as prime contractors. Specifically, many small businesses have been performing IT-IM efforts, and the intent is to set aside this entire acquisition for small businesses. Therefore, this is not a bundled requirement as defined IAW FAR 2.101, since this approach further demonstrates the consolidated effort is highly suitable for Small Business participation and enhances opportunities for greater capability and capacity.

DETERMINATION

Based upon the findings stated above and pursuant to FAR 7.107-2, I hereby determine the expected benefits of consolidation are critical to the mission success of 771 ESS, AFIMSC/A531and other users, and the procurement strategy for Alternative #2 provides for maximum practicable participation by small business. Consequently, I hereby determine the proposed consolidation of the current and varying contract vehicles into a multiple award program that is set aside is necessary and justified and is in the best interest of the Government.

LANCE R. FRENCH, Brig Gen, USAF Commander, AF Installation Contracting Center

2 Attachments:

1. Market Research Report, 18 Apr 25

2. IT-IM PWS, 18 Apr 25