JA IPV6_Redacted.pdf

Control Number VA-22-00099791

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: This proposed action is for a Time and Materials (T&M) task order (TO) that will be issued under the Transformation Twenty-One Total Technology Next Generation (T4NG) Program, indefinite delivery, indefinite quantity (IDIQ) Contract Number 36C10B21D1032 with Aptive Resources, LLC to provide Internet Protocol version 6 (IPv6) Transition Services.

3. Description of the Supplies or Services: The proposed action is for VA Office of Information and Technology (OIT), Infrastructure Operations (IO) support to migrate hardware, operating systems, applications and other elements of its Information Technology infrastructure from Internet Protocol version 4 (IPv4) to IPv6. This includes all documentation, configurations, inventory management remediations, security, network monitoring, support desk, testing, training, migrations, associated strategies, network setups including new Domain Name Services (DNS), Dynamic Host Configuration protocol (DHCP), networking to include Open Shortest Path First (OSPF) and Border Gateway protocol (BGP) configurations, architecture support and engineering solutions. The Period of Performance shall be one 12-month base period with two 12-month option periods, followed by one six-month option period. The total estimated value of the proposed action is , inclusive of all option periods.

4. Statutory Authority: The statutory authority permitting an exception to fair opportunity is Section 41 U.S.C. 4106(c)(4) as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(D order to satisfy a minimum guarantee.

5. Rationale Supporting Use of Authority Cited Above: The proposed source is Aptive Resources, LLC (Aptive), 421 King Street, Suite 200, Alexandria, VA 22314. Solicitation 36C10B19R0046 was issued by VA, Technology Acquisition Center (TAC) on November 12, 2019, soliciting offers pursuant to the On-Ramp Clause of the T4NG contract. On February 25, 2021, nine offerors were chosen for an award in accordance with the criteria set forth in the Basis for Award of the solicitation. Due to four post award protests filed with the US Court of Federal Claims (COFC) by unsuccessful offerors, VA agreed to a voluntary stay of performance and orders could not be awarded to any of the nine On-Ramp awardees until COFC rendered its decisions on the protests. On March 1, 2022, COFC rendered its decisions denying each of the four protests. Due to the aforementioned litigation delays, the original contract effective date of February 25, 2021, had to be modified to reflect a date following the COFC decisions.

Subsequently, modifications were executed on each of the nine On-Ramp contracts to re-establish the contract effective dates to March 21, 2022. Included in the solicitation was FAR clause 52.216-22, Indefinite Quantity, which stated the minimum guarantee that would be satisfied for each resultant contract award under the T4NG contract. This order is being issued to Aptive to satisfy the minimum guarantee. Aptive has been

IPv6 transition services requirements. The determination included a review of the selected

In addition to the base 12-month period of performance, the proposed TO includes two 12-month option periods and one six-month option period. The Scope of Work for this order is for high-level engineering support services and programmatic support to the VA IO team to enable the successful completion of work which is related to IPv6 transition services from the current IPv4. In the VA memorandum dated May 19, Internet Protocol 6 (IPv6) Transition Period, VA Management established a goal to transition 100% of IP-enabled assets on the VA network to IPv6 by the end of FY 2025.

In addition, Office of Management and Budget (OMB) memorandum M-21-7 mandates all VA endpoints (servers, desktops, laptops, mobile devices, network equipment, applications etc.) must be migrated from IPv4 to IPV6 no later than September 30, 2025.

After completion of the IPv6 transition by September 30, 2025, VA a document refinement, to include updates, reviews, edits and approvals, to continue for a six-month period, which is why the Government is including a six-month option period following the FY 2025 deadline. To accomplish this IPv6 transition task, the Scope of Work is to provide high-level IT engineering resident services necessary to provide architecture oversight to develop and implement an enterprise wide IPv6 transition plan. All of the work under this TO is very complex, which includes a level of high technical risk that could disrupt patient care. In order to successfully accomplish this work, contractor resources will be responsible for obtaining very VA-specific domain knowledge that will be gained through performance in the early phases of the effort and will be instrumental and built upon in later phases to successfully meet the required OMB deadline, to include proper document finalization. At no point during this effort, could a transition of contractor support occur without significantly delaying the project. Due to the ramp-up requirements to get the Contractor onboarded, up to speed on the technical infrastructure and processes of VA, and have them survey the environment, there is not sufficient time to allow VA to use multiple contracts to meet this need. The OMB mandate is very aggressive, and VA will have to work incredibly hard to meet this deadline.

VA requires program management, technical, engineering and guidance support for the transition from IPv4 to IPv6. To this end, IO seeks professional services necessary to design an enterprise wide IPv6 transition plan and manage its implementation on-premises and in the cloud. The Contractor will implement development testing environments and develop implementation procedures for both Azure and Amazon Web Services along with a wide variety of on-premises equipment, including routers, switches, firewalls, wireless access points and controllers, servers, storage devices, end user devices, network services (including DNS and DHCP) and applications. The

Contractor will provide IPv6 transitional help desk support, technical writing and project management services necessary to deliver a successful IPv6 transition.

This effort will require substantial experience in cloud, network, storage and platforms engineering to support the challenges of developing both dual-stack IPv4/IPv6 environments and native IPv6 environments within the vast VA enterprise. VA requires consistent, accurate, standardized artifacts and guidance for the IPT team in executing

IPv6 transition goals. Recompeting this requirement would require substantial re-training to include familiarizing a new Contractor with the standards, policies, segmentation, purpose and size of the VA enterprise infrastructure and network and would make it nearly impossible to meet the extremely aggressive OMB mandate to transition to IPV6 no later than September 30, 2025. For these reasons and as long as the vendor is performing satisfactorily, it is critical that the VA maintain continuity of the contractor support staff throughout completion of the IPv6 transition. If the VA is forced to switch contractors at any point prior to completion of the IPv6 transition, it would result in a substantial transition and on-ramping effort that is estimated to take approximately six months to complete. This estimate of time is based on previous transition efforts of similar size and scope. Any shorter period of performance would also mitigate efficiencies that the contractor support is intended to provide, duplicate costs and degrade both the quality of support to complete the tasks in support of transition from IPv4 to IPv6. Therefore, utilizing a single vendor for this work is the only way that will allow VA to meet the required date.

Although the minimum guaranteed value under the T4NG On-ramp contract is $250,000, pursuant to FAR 16.505(b)(2)(i)(D), the Government reserves the right to award initial orders on a sole source basis at amounts which may exceed the minimum guaranteed value.

A minimum guaranteed order under an IDIQ contract must be placed during the same fiscal year as the IDIQ is awarded to avoid a bona fide need violation (31 U.S.C.

Sections 1501, 1502) and until it is placed, there is no enforceable contract. Once the IDIQ contract has been awarded, an obligation is created.

6. Efforts to Obtain Competition: In accordance with FAR 5.301 and 16.502(b)(2)(ii)(D), this action will be synopsized at award on the Contract Opportunities website and the justification will be made publicly available within 14 days after the award. In addition, this justification will be posted with the solicitation to notify all the T4NG vendors.

7. Actions to Increase Competition: There is no competition anticipated for this action as it is being issued to meet the mandatory minimum guaranteed value for this IDIQ contract. It is expected that any future requirements will be awarded on a competitive basis.

8. Market Research: In August 2022, the VA Program Manager contacted three T4NG vendors who were eligible to receive an award in order to meet their minimum guarantee. The Program Manager discussed requirements. The three vendors were DexteriTech Solutions, LLC (DexteriTech), Aptive and Mind Computing, Inc. (Mind Computing).

A detailed summary, including the results, below:

DexteriTech: On August 16, 2022, VA met with DexteriTech who provided a professional summary of its VA IPv6 Implementation Support Capability to meet the requirements of the Performance Work Statement (PWS) for the IPv6 transition, including its . DexteriTech provided relevant past contract performance and demonstrated implementation experience, network engineering and device expertise and its capability to support VA IPv6 transition. On August 17, 2022, Government technical experts determined that the vendor DexteriTech was fully capable of executing ition.

Mind Computing: On August 26, 2022, VA met with Mind Computing who provided a Capability Statement that included past performance that excluded some of the key elements in the PWS. It has extensive experience and capabilities related to software development, design and data management. However, the vendor specified it had no direct experience in implementing IPv6 at an enterprise scale, which is exactly what the vendor would be responsible for under this effort. Based on this information, Mind Computing did not show it could meet the technical tasks in the PWS, nor did it provide information about its capabilities showing that it could likely produce a technically acceptable proposal. Therefore, it was determined that Mind Computing was not capable of meeting all of V

Aptive: VA met with Aptive on August 29, 2022. Aptive asserted it could support the contract requirements, primarily based on its experience, capabilities and past performance. During this meeting, Aptive demonstrated it was qualified to support IPv6 transition planning, design, implementation, operations and maintenance. Aptive has over a decade of experience supporting federal organization and direct experience in addressing challenges presented by IPv6 transitions. The vendor provided a comprehensive capabilities overview for IPv6 and showed a deep interest and

Aptive thoroughly presented how it would address each aspect of the draft PWS, including key elements such as installation and engineering for communication systems, software, components and subsystems. During this discussion, the vendor laid out possible challenges VA would face, its capabilities, examples of past performance, a path toward meeting organizational goals and a high-level initial approach. The vendor provided an illustration showing how VA could successfully transition to IPv6 by identifying tasks and potential scope. Aptive provided evidence of capability and prior experience to support IPv6 transition planning and required activities related to its execution. Moreover, Aptive demonstrated experience with the performance of infrastructure assessments, IPv6 address planning, IPv6 implementation planning, IPv6 test lab setup/management and end-to-end IPv6 deployments. Therefore, technical experts deemed Aptive fully capable of meeting all VA requirements for managing transition from IPv4 to IPv6.

During refinement of VA requirements in September, it was learned that DexteriTech was no longer eligible to receive an award as it has already met its minimum guarantee.

Therefore, Aptive is the only viable source to meet this requirement in accordance with FAR 16.505(b)(2)(i)(D) cited in Section 4 of this document. To avoid a bona fide need violation (31 U.S.C. Sections 1501,1502), the Government will proceed under a sole-source minimum guarantee award under the T4NG contract.

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 contract action will be fair and reasonable based on price analysis and comparison with the Independent Government Cost Estimate.

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

Approval

In my role as Head of the Contracting Activity, based on the foregoing justification, I hereby approve the acquisition of IPv6 Transition 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.