JA CCSS 1.0 for Signatures_Redacted.pdf

Corporate Consolidated Support Services 1.0

Control Number VA-25-00077947

JUSTIFICATION

FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed action is for a modification to the Task Order (TO) 36C10B21N10110004 issued under Transformation Twenty-One Total Technology Next Generation (T4NG) Indefinite Delivery Indefinite Quantity (IDIQ) Contract Number VA118-16-D-1011 on a hybrid Firm-Fixed-Price (FFP) and Cost Reimbursement (CR) for Travel only basis to Civitas DX LLC (Civitas), 9920 Pacific Heights Boulevard Suite 150, San Diego, CA 92121. The purpose of this modification is to extend the period of performance of Option Period 3 and Optional Tasks Seven, Eight, and Nine for up to three months to continue Consolidated Corporate Support Services (CCSS) for the Corporate (CORP) portfolio. This extension will serve as a bridge of support until a new competitive TO is awarded.

3. Description of the Supplies or Services: The subject TO provides CCSS for continuous sustainment of Congressionally mandated mission critical products that provide benefits to Veterans such as disbursements, 1099’s for Vendors, Treasury, Office of Management and Budget (OMB) and Congressional reporting, consolidation of Veterans’ loans, identification of payroll discrepancies, and more. In broad terms, this TO supports systems that provide acquisition and performance management activities, human capital management, complex needs of legal, congressional, and regulatory affairs, and financial management activities. Specific supported products include, but are not limited to, the Financial Management System for Veterans & Vendor payments, PayVA for Veterans debt reconciliation, and Human Resource-Payroll Application Services, providing critical payroll data to the financial applications. This TO provides VA with dedicated teams of cross-functional staff to design, build, operate, and maintain legacy mission critical IT Applications and DevSecOps for CORP Portfolio Product Lines and various Products. This TO provides specialized IT skills to ensure that CORP products meet the Veteran- intended outcomes they are required to deliver. These IT skills include Common Business-Oriented Language (commonly referred to as COBOL) and Statistical Analysis System (commonly referred to as SAS) programmers, Mainframe IT specialists, Hyperion (a suite of business performance management and financial planning software), and Cybersecurity specialists. These services streamline the systems, improve scalability, increase availability of services, and enable more efficient delivery of services. Specific technical support provided under this TO includes system monitoring, incident analysis and resolution, system administration, application updates, database updates, business report generation, help desk/end user support, Section 508 accessibility remediation, Authority to Operate (ATO) maintenance/renewal, and security vulnerability remediation and resolution for which

Civitas updates security plans and standard operating procedures (SOP). Civitas maintains the ATO on the VA network, ensures software updates in order to comply with VA’s Technology Reference Model (TRM), and addresses Section 508 accessibility requirements. Furthermore, Civitas evaluates and remediates any defects that are identified in the Legacy product and DevSecOps Systems as well as analyzes and implements any approved enhancement requirements. Civitas triages issues to determine if the problem is traceable to requirements, design, configuration, testing, code defect, documentation deficiency, or knowledge gap, and determines whether further analysis is required.

These services, if interrupted, will severely degrade the operational capabilities of CORP products.

On September 28, 2021, Civitas was awarded this TO on a competitive basis for a 6-month Base Period with three 12-month Option Periods and 11 Optional Tasks. This TO is currently in Option Period 3, which was previously extended by three months from March 29, 2025 to June 28, 2025. The period of performance for this proposed action is another overall 3-month extension for the period of June 29, 2025 through September 28, 2025, to be executed on a monthly basis, to allow sufficient time for a competitive follow-on TO award and to provide a seamless transition, if needed. The previous modification did not properly account for two months of transition which should have extended the ultimate completion date out for additional 2 months. As such, this action would extend the overall period of performance from 47 months to 50 months. The total estimated value of the proposed action is , inclusive of options, which will increase the total value of the TO from to .

4. Statutory Authority: The statutory authority permitting an exception to fair opportunity is Section 41 U.S.C. 4106(c)(2) as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(B), entitled “Only one awardee is capable of providing the supplies or services required at the level of quality required because of the supplies or services ordered are unique or highly specialized.”

5. Rationale Supporting Use of Authority Cited Above: VA is in the process of competitively awarding a new TO. The requirement for the competitive TO began in the middle of Fiscal Year (FY) 2024. However, delays ensued after a CORP Portfolio leadership review in February 2025 that led to further updates to the CCSS follow-on Performance Work Statement (PWS) and Evaluation Plan. The required updates have taken longer than anticipated due to the breadth of products that fall under the CORP Portfolio. Due to these delays, the solicitation release for the follow-on is projected for mid-June 2025 with award projected in late July 2025. Once the competitive TO is awarded, there is also a need for at least 60 days of overlap to support a seamless transition of the services to a new vendor, if needed, and as originally planned under the CCSS TO. For these reasons, CCSS requires support provided by Civitas beyond its current end date of June 28, 2025 until the follow-on TO is awarded.

The delays associated with finalizing the new CCSS PWS were driven by CORP leadership’s decision to implement lessons learned from a separate TO for similar services. In general, the program team was required to reevaluate multiple tasks in the

PWS in order to take out certain labor categories/tasks that were identified by leadership as non-technical support tasks. Furthermore, in mid-April 2025, additional reviews and audits of the CCSS program/products were conducted, this was a result of the recent newly enacted requirements to implement additional cost efficiency procedures as required by Executive Orders. All of these new reviews led to numerous changes to this requirement and necessitated updates to the documentation which has impacted the timeline.

Civitas is currently meeting the requirements of the TO and performing satisfactory or better in all areas. If another vendor is selected, additional risk would be incurred as the new contractor’s staff may not fully understand the intent and context of the complex requirements included in this application. Furthermore, another source would require a steep learning curve while gaining familiarity with the VA systems, which is in addition to basic onboarding requirements for vendor staff such as background checks, security clearances, systems access, mandatory training, establishing communications plans, readiness reviews, etc. Overall, if another vendor is selected, completion of onboarding requirements is anticipated to take at least 30 days.

Without this continuation of services, VA faces a gap in service for the critical support described in Section 3. These services, if interrupted, will degrade the operational capabilities of CORP’s 130 products and jeopardize VA's mission. For example, Veterans may not be able to receive payments on-time, make their loan payments, or receive Canteen Services. Additionally, VA may be unable to furnish financial reports to Treasury, OMB, and Congress. Lastly, CORP and downstream reporting applications will be unsupported with a risk of failure and significant delays and security management for all products would go unsupported, leaving the VA Enterprise vulnerable. Only the current incumbent, Civitas, is capable of providing the highly specialized technical services at the level of quality required under the current time constraints, without serious degradation of services/systems resulting in direct negative impacts to Veterans. The proposed overall 3-month extension will ensure continuity of VA’s CORP portfolio, programs and sustainment activities to assists in a seamless transition to a new vendor.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this document. This effort did not yield any additional sources that can meet the Government’s requirements. There is no competition anticipated for this acquisition. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Contracting Opportunities website, SAM.gov, and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: No barriers to future competition are anticipated. A competitive contract is anticipated to be awarded in July 2025 and all future acquisitions are planned to be awarded on a competitive basis.

8. Market Research: The Government technical experts continuously perform market research by conducting internet searches and staying abreast of the current technologies and market outlook. This requirement is leveraging market research conducted in November 2024 as part of the competitive procurement. On November 5, 2024, the Government issued a Request for Information (RFI) to gather information from potential vendors about their services and capabilities, as well as to research industry trends and market conditions to collect information to develop a plan to meet business changes and/or objectives. The RFI resulted in 23 responses received from the industry, of which nine were Service-Disabled Veteran Owned Small Businesses (SDVOSB). All 23 responses were reviewed by CORP Portfolio technical representatives. As a result of the analysis, which was based on the capability statements provided by the vendors, the Government determined that eight vendors, six of which are SDVOSBs, are capable of successfully performing the requirements of the PWS. Furthermore, two of the capable SDVOSBs, Veterans EZ Info Inc. and Thunderyard Liberty JV LLC, are T4NG SDVOSB primes. While it is clear that the two aforementioned T4NG SDVOSB primes are capable of providing the specialized technical support services that meet VA’s needs, neither are capable of providing staffing for the required CORP Portfolio critical services at the level of quality required by the current need date of June 28, 2025. Only Civitas can immediately provide already familiar and properly badged and equipped personnel to meet the CORP Portfolio’s critical operational and mission needs without adversely affecting services to programs and projects that support Veterans. The competitive TO is currently projected to be awarded in July 2025. This extension will provide for the timely continuance of this critically needed support in order to ensure there is no gap in service.

9. Other Facts: None

10. Technical and Requirements Certification: I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this TO action will be fair and reasonable based on a comparison with the Independent Government Cost Estimate and price analysis.

12. Procuring Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

6/10/25

Office of General Counsel (OGC) Review

I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The Competition Advocate’s approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of an extension to continue the Consolidated Corporate Support Services, on an other than fair opportunity basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.