JA - COMS Extension - Redacted.pdf

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 sole source action is for a six-month extension to the Cloud Operations and Migration Services (COMS) Task Order 36C10B23N10010013 issued under Transformation Twenty-One Total Technology Next Generation (T4NG) with Cognostante MVH, LLC, 3110 Fairview Park Drive Ste 800, Falls Church, Virgina, 22042

3. Description of the Supplies or Services: On August 9, 2023, T4NG Task Order (TO) under fair opportunity procedures amongst all T4NG prime contract holders. The current contract Period of Performance expires on August 8, 2026. The purpose of this extension is to provide six months of support to ensure service continuity until the award of the Application Hosting, Compute, and Storage domain of the new IO competitive Task Order. Due to the complexity and shift in contract approach the award is slated for a February 2027 award date. If this support expires it will significantly impact the VA Enterprise Cloud ( functions such as security monitoring and oversight, as well as cost and performance optimization of the VAEC General Support Systems (GSS).

COMS provides a comprehensive range of support services that include deploying, optimizing, contractor is responsible for continuously deploying, operating, maintaining, monitoring, and and ensuring access to those services in accordance with established Service Level Agreements.

COMS also provides access to new or existing VAECOT capabilities that leverage emerging technologies; provisions VAEC environments and supports the release and deployment of systems and applications; delivers sustainment support to ensure secure and uninterrupted access to hosted systems; provides cybersecurity management support to ensure secure access and ongoing security compliance; and offers cloud and infrastructure training and coaching to help VA develop inter

The Period of Performance shall be August 9, 2026 through February 8, 2026. The total estimated value of the proposed action is

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 Revolutionary Federal Acquisition Regulation Overhaul (RFO) VA Deviation 7-6(b)(2), entitled “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.”

Cloud Operations and Migration Services (COMS) VA-26-

Rationale Supporting Use of Authority Cited Above: The proposed source for this action is Cognosante, 3110 Fairview Park Drive Ste 800, Falls Church, Virgina, 22042. Based on the market research detailed in Section 8 of this document, it has been determined that Cognosante remains the only responsible source capable of meeting VA’s cloud requirements within the required timeframe. No other vendor can provide the required services without disruption, as a

The existing COMS contractor staff can begin performance immediately upon award of this extension, with no learning curve or lapse in support.

The VAEC requirements are being consolidated under a group of s and therefore cannot be awarded as a standalone requirement. VA anticipates awarding this competitive task order under the GSA contract vehicle in February 2027, which will encompass the services outlined in Section 3. Unanticipated changes to the contract award approach between October award. the original award was planned for June 2026. The approach evolved in part due to the responses from the Request for Information (RFI).

The original plan called for one large contract covering six domains; however, this was later revised to distribute the six domains across multiple contracts to ensure the appropriate knowledge and skill sets are aligned with each domain.

Cognosante’s knowledge of the VAEC spans more than eight years, beginning with the original development of the environment. Extending the contract period of performance for six months ensures there are no gaps in support prior to the award of the new contract. A structured contract transition period is essential to ensuring a new vendor’s success and maintaining continuity of operations. The current contract does include transition support; however, the transitional optional task cannot be exercised until a new vendor has been identified.

6. Efforts to Obtain Competition: Market research was conducted and concluded that there are multiple vendors with the capability to provide support, but none would be able to provide the support within the required timeframe without creating service disruptions and delays. In

RFO -6(f), the award notice for this action will be synopsized on the Contracting Opportunities website, beta.SAM.gov, and this justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The requirements under this effort were initially competed under a competitive acquisition and VA anticipates awarding a new competitive TO on or about February 8, 2027 under the GSA contract vehicle.

8. Market Research: Market research conducted by Government Subject Matter Experts in June 2026 including internet searches and reviews of vendor responses for similar cloud services, competition, no vendor can assume responsibility immediately without an orderly transition.

Accordingly, this extension is necessary to maintain continuity of operations until the award of the Application Hosting, Compute, and Storage domain portion of the IO contracts is made by February 2027, and the acquisition strategy continues to support full and open competition, maximize small business participation, and align with category management principles such as

9. Other Facts: None

Technical/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.

Fair and Reasonable Cost Determination

I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable based on a comparison with the Independent Government Cost Estimate and price analysis.

Contracting Officer Certification/Approval

I certify that this justification is accurate and complete to the best of my knowledge and belief.

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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.

Advocate for Competition Approval In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of a six-month extension 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 property and services herein described have otherwise been authorized for acquisition.