JA_EC-Council_Redacted.pdf

Control No.: Gordon 2020-9

FAR Subpart 13.5 Simplified Procedures for Certain Commercial Items –

Sole Source Justification and Approval

1. Contracting Activity: Mission and Installation Contracting Command (MICC) – Fort Gordon, GA.

2. Description of Action: The US Army Cyber School, has a requirement to purchase virtual training labs, reading materials, videos, and certifications vouchers for the 170A Warrant Officer Basic Course (WOBC) and the 17A Cyber Captains Career Course.

Nature: New Requirement Follow-on Requirement Mod to Existing Purchase Order/Contract Number

Pricing: Firm-Fixed Price Time & Materials Cost

Funds: OMA Other Funds:

An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d) (i) (B).

Name of Proposed Contractor(s): International Council of E-Commerce Consultants

(EC-Council) Street Address: 101C Sun Avenue NE City, State, Zip: Albuquerque, NM 87109 Phone:

3. Description of Supplies/Services:

a. The US Army Cyber School has a need to purchase virtual training labs, reading materials, videos, and certifications vouchers for the 170A Warrant Officer Basic Course (WOBC) and the 17A Cyber Captains Career Course:

170A WOBC materials access will be provided for the Certified Network

Defender, Certified Ethical Hacker, Computer Hacking Forensic Investigator, and Certified Incident Handler, Certified Security Administrator, and Certified Chief Information Security Officer certifications. FY20:

17A Cyber Captains Career Course, materials access will be provided for the Certified Ethical Hacker, Computer Hacking Forensic Investigator, Certified Security Administrator, and Certified Chief Information Security Officer certifications. FY20:

b. The total estimated dollar value of the proposed action is:

4. Authority Cited: 10 USC 2304, 41 U.S.C. 1901, FAR 13.5 (a) (2) -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Unusual and compelling urgency Exclusive licensing agreements Industrial mobilization Other: Sole Source

5. Reason for Authority Cited: International Council of Electronic Commerce Consultants (EC-Council) is the only supplier of the required training materials and certifications which will allow military instructors to be certified to train and adapt the materials to meet the Cyber School’s needs. SANS, GIAC, and other vendors require their in house instructors to teach the material, which diminishes relevancy and the synthesis of military operations experience into the training; the customization of vendor training to a military audience is degraded or not feasible. Also, teaching materials with in house instructors will allow the Cyber School to further customize the timelines for instruction which vendor-taught programs are unable to provide.

The Cyber School is an accredited training center (ATC) with EC-Council. EC-Council owns the trademark and copyrights to all information, including the certifications and their associated standards for Certified Network Defender, Certified Ethical Hacker, Computer Hacking Forensic Investigator, Certified Incident Handler, Certified Security Administrator, and Certified Chief Information Security Officer certifications and related training material.

The previously identified course materials are the only ones which align with the 170A Warrant Officer Basic Course and 17A Captains Career Course critical task site selection board knowledge, skills, and behaviors list in their entirety. Other vendor and brand name options do not fully support the identified training requirements. Contact with other vendors has resulted in correspondence showing existing materials and brand name materials cannot be modified to meet the current requirement.

Alternatives. Alternatives that were discussed included:

a) Do not procure the identified training requirements. This alternative is unacceptable because the Cyber School requires the training materials and resources as part of the effort to meet the CCoE’s core mission. The CCoE is the U.S. Army's force modernization proponent for Cyberspace Operations, Signal/Communications Networks and Information Services, and Electronic Warfare (EW), and is responsible for developing related doctrine, organizational, training, materiel, leadership/education, personnel, and facility solutions. The CCoE's mission is the training, education, and development of highly skilled Signal, Cyber, and EW professionals supporting operations at the strategic, operational, and tactical level.

b) The use of in-house personnel/expertise to create internally developed content was explored but this alternative was ultimately rejected due to the developer hours required for technical training. listed the average time to design Instructor-Led Training at 34:1 and 4rd party courseware at . For the 181.5 academic hours required by the U.S. Army Cyber School, this would take between hours of development, or between week to complete. With the current cadre assignment cycle of weeks to the organization, training would never be completed. Similarly, collaborating with University of Maryland Baltimore County for training content is estimated at greater than 18 months. This would create a minimum delay for classes and current training for 18 months, resulting in an unacceptable lack of training time as required to support ongoing military accessions and operational missions.

c) Failure to procure the materials will result in a direct mission failure for the continued training of students, and cancellation of further courses until other options become available. This delay will further prevent global Army cyberspace operations, and unduly provide a strategic advantage to adversaries.

d) The minimum requirements of the government are designated through knowledge, skills, and behaviors as found within the 170A and 17A critical task site selection board results.

e) Requirements for Cyber Mission Force certification is directed by DoDI 8570.01M and DoDI 8140. International Council of Electronic Commerce Consultants (EC- Council) is a validated requirements solution within both documents.

6. Actions to Increase Competition: Market research was conducted to ensure there were no other vendors that can provide the requirement. To increase competition the MICC-Fort Gordon issued a sources sought and one response was received but the vendor was deemed unacceptable. The Government will issue a sole source synopsis and address any responses accordingly. MICC Fort Gordon contacted the vendor and currently they have no distributors or resellers.

7. Market Research: Market research was conducted and revealed that the requirement could only be fulfilled through a Sole Source. A Sole Source Vendor Letter and a Sole Source Justification was provided. A Sources Sought was posted to www.beta.SAM.gov on 30 June 2020. One vendor did respond to the Sources Sought but, was deemed technically unacceptable. Although the NAICS is on the WOSB Set- Aside list this requirement cannot be fulfilled through a WOSB vendor. An Intent to Sole Source will be issued and MICC Fort Gordon will respond accordingly. This requirement will be awarded as a Sole Source to International Council of Ecommerce Consultants (EC-Council), 101C Sun Ave NE, Albuquerque, NM 87109. CAGE Code:

5C6W0.

8. Technical Certification: I certify that the supporting data under my cognizance which are included in the J & A are accurate and complete to the best of my knowledge and belief.

9. Fair and Reasonable Cost Determination: As Contracting Officer, I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable.

Heather M. Woodward Contracting Officer

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

Heather M. Woodward Contracting Officer