ITOPS_JA Limited Source Justification GSA 20222807_.pdf

Department of Health & Human Services Centers for Medicare & Medicaid Services 7111 Security Boulevard, Mail Stop B3-30-03 Baltimore, Maryland 21244-1850

OFFICE OF ACQUISITION AND GRANTS MANAGEMENT

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Cloud IT Operations and Maintenance (ITOPS)

Agency: Centers for Medicare and Medicaid Services (CMS) Acquisition Year: 2022 Author: Katherine Brewer

1. Description of Action:

Nature

• ____ New Requirement

• ____ Follow-On Order

• _X_ Modification of Existing Purchase Order / Contract Number

Contract Type

• ____ Firm-Fixed Price

• __X__ Time and Materials

• ____ Cost Plus Fixed Fee (CPFF)

• ____ Term

• ____ Completion

• ____ Cost Plus Award Fee (CPAF)

• ____ Other: ___________

Projected Cost / Price: $8,457,887.00 Funding Source (s):

000752 Exchange Prog Ops - Exchange Cloud Computing 0511: Federal Exchange_Direct:Disc

000752 Exchange User Fees - Exchange Cloud Computing 0511: Federally-Facilitated Exchange_Reimb:Mand

000010 Prog Ops - Hosting Operations and End-User Support 0511: Program Operations_Direct:Disc

000753 Enterprise Architecture Support 0511: Federally-Facilitated Exchange_Reimb:Mand

000753 Enterprise Architecture Support 0511: Federal Exchange_Direct:Disc (Prgm Mgmt)

Name of Proposed Contractor(s): NAVA PBC Corp

Street Address: 1 Thomas Circle NW

City, State, Zip: Washington, DC 20005

2. Description of Supplies or Services:

The Centers for Medicare and Medicaid Services (CMS) Cloud service offerings consist of Amazon Web Services (AWS) commercial, AWS GovCloud, and Microsoft Azure for Government (MAG) and the current cloud infrastructure hosts over 100 applications. Currently, the ITOPS contractor is responsible for the design, build, operation, maintenance, refinement, modernization, and evolution of all cloud services, software and network infrastructure, products and services required to deliver OIT cloud services.

CMS anticipates extending the current Cloud ITOPS contract with a period of performance of 6-months followed by one optional additional six-month period of performance. The first period of six months will enable the transition of all of the services ITOPS currently supports. The remaining six-month option is merely optional, and will only be exercised if CMS finds there is a need to extend to ensure a successful transition of services.

The services to be provided under the contract extension are:

o DevSecOps support, enablement, and testing as a service (TaaS). This specifically includes pipeline services, repository management, static code analysis, functional testing, load testing and security testing. The goal for these items is to start the transition of services prior to the end of the current contract, so there is a lower level of support needed during the extension period to finish the transition.

o Platform operations support, access management, and operating systems related services. This specifically includes authentication services, patching, mail relay services, and data backup services. The transition of these services will begin during the extension period.

o Networking operations and support, which specifically includes name resolution (DNS), NTP, WAN and WAN network services, cloud networking, and secure access to the cloud (CloudVPN). The goal is to have the majority of these services transitioned prior to the end of the current contract, so only minimal support is needed during the extension period to ensure the new contractor supporting networking is able to fully and successfully take over the support o Operations support and management, change management and Tier 2 Helpdesk. This specifically includes release management, change management, incident management, and on call support.

The transition of these services will begin during the extension period.

o The 24x7 Open Enrollment (OE) 10 support for the Center for Consumer Information and Insurance Oversight (CCIIO).

The estimated value of the proposed action, including all options, is $8,457,887.00

Two 6-month options:

o POP: 09/12/2022 – 03/11/2023: $6,814,767.00 o POP: 03/12/2023 – 09/11/2023: $1,643,120.00

3. Authority:

X_: ORDER AGAINST FSS: Authority of the Multiple Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501, Services for Executive Agencies;and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6. Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405-6(c)(2)(iv).

N/A_: An urgent and compelling need exists, and following the procedures would result in unacceptable delays (FAR 8.405-6(a)(1)(i)(A));

_N/A_: Only one source is capable of providing the supplies or services required at the level or quality required becausethe supplies or services are unique or highly specialized (FAR 8.405-6(a)(i)(B)); or

__X__: 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 (FAR 8.405-6(a)(1)(i)(C));or

The contracts that support the OIT Data Center service line, including CMS cloud and Virtual Data Center, are evolving in light of CMS” pursuit of two primary goals: Disaster Recovery as a Service (DRaaS) and and CMS Continuous Authorization and Verification Engine (batCAVE). The implementation of these projects has and will continue to drive evolution in the scope and period of performance of existing contracts, including the creation of new contracts and elimination of others. From a purely cloud perspective, batCAVE’s service offerings will supersede many of those provide by ITOPs. Further, CMS is pursuing a goal of centralizing the workstreams across the hosting contracts, in order to reduce overlap and redundancy of support. As a result, CMS envisions a transition of the remaining ITOPS scope of work to one or more other contracts whose scope will support both cloud and on-premise data centers (i.e., hybrid cloud), and in so doing will result in better alignment and consolidation of services across IUSG’s hosting contracts.

It would be inefficient to recompete the ITOPS effort at this time. Transitioning to a new contractor will be costly and result in delays across multiple contracts disrupting the contract realignments across IUSG.

Furthermore, the extension will reduce any risk or impact on Open Enrollment (OE) 10. The OE 10 period will run from November 1, 2022 to January 16, 2023, and the ITOPS contractor provides 24x7 support during this period. Transitioning of these services to a new contractor would put OE 10 at risk.

N/A_: An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. (FAR 8.405-6(b);

4. Market Research:

Due to timing constraints and the need to align services, this extension is being used to support a transition out and not the procurement of services. In accordance with FAR 10.002 (b)(1), the extent of market research will vary, depending on such factors as urgency, estimated dollar value, complexity, and past experience. As previously noted, CMS is not asking for more time to engage in a follow-on procurement, but needing this extension to mitigate the risks to Open Enrollment 10 and to transition out the support to better align contracts.

5. Actions to Increase Competition:

This work is a modification to an original Federal Supply Schedule order whereby the original order was placed in accordance with the applicable Federal Supply Schedule Fair Opportunity ordering procedures and not as sole source or limited source procedures. The modification extension’s purpose is to allow the necessary time for the successfully transition out the support to better align contract and to mitigate the risks to Open Enrollment 10.

6. Any other facts supporting the justification:

None

Approvals:

1. Program Office Certification: This is to certify that portions of this justification have been developed by the undersigned program office personnel, including supporting information and/or data verifying the Government’s minimum needs, schedule requirements and other rationale, which form the basis for this Limited Source Justification.

Contracting Officer Representative (COR) / Date

Program/Project Manager (P/PM) / Date

Best Value Determination. By my signature below, after review of the relevant documents, I have determined that the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d),and constitutes a fair and reasonable price. The basis for my determination is as follows:

Per FAR 8.404(d), “GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. This effort will be a modification under the GSA MAS order for the Nava MAS Schedule Contract. The proposed labor mix and level of effort will be evaluated for price reasonableness.

In accordance with FAR 17.204 (e) Unless otherwise approved in accordance with agency procedures, the total of the basic and option periods shall not exceed 5 years in the case of services, and the total of the basic and option quantities shall not exceed the requirement for 5 years in the case of supplies. By virtue of this extension the total estimated order period of performance is extended from two years to three years.

Therefore, not exceeding the FAR limitation of five years.

2. Contracting Officer Certification: This is to certify that the justification for the proposed acquisition has been reviewed and that to the best of my knowledge and belief, the information and/or data provided to support the rationale and recommendation for approval, is accurate and complete.

Contracting Officer / Date

OAGM Approvals

I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

OAGM Division Director / Date

OAGM Group Director / Date

3. Head of Contracting Activity (HCA) Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

HCA Name / Date

4. CMS Competition Advocate (CA) Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

N/A Name / Date

5. OGC Legal Review

N/A_________________________________________________ Name / Date

6. Office of Small and Disadvantaged Business Utilization

N/A_________________________________________________ Name / Date

7. Senior Procurement Executive (SPE) Approval Based on the foregoing justification, I hereby approve the procurement of (state supplies/services being procured) on an other than full and open competition basis pursuant to the authority of (state the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 253(c)(1)), as implemented by FAR 6.302-1), subject to the availability of funds, andprovided that the services herein described have otherwise been authorized for acquisition.

_N/A________________________________________________ Name / Date

For: