JA Limited Source Justification_CPT_final_clean_Redacted.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Cloud Products & Tools (CPT) Agency: Centers for Medicare and Medicaid Services Acquisition Year: 2024 Author: Kimberly Watson (OIT/IUSG) and Patrick Forgione

(OAGM / ITCG)

1. Description of Action:

a. Nature

New Requirement Follow-On Order Modification of Existing Purchase Order / GS-35F-393CA 75FCMC20F0080 –

b. Contract Type Firm-Fixed Price Time and Materials Cost Plus Fixed Fee (CPFF)

Term Completion

Cost Plus Award Fee (CPAF) Other:

c. Total Projected Cost / Price: $188,825,866

d. Funding Source (s): FY 2024 Appropriated Funds using multiple funding sources

e. Name of Proposed Contractor(s): General Dynamics Information Technology (GDIT) Street Address: 3150 Fairview Park Dr. Suite 100 City, State, Zip: Falls Church, VA 22042-4504

2. Description of Supplies or Services:

The purpose of the Cloud Products & Tools (CPT) task order is to deliver all infrastructure needed by CMS Business Owners, and their application teams, to utilize the CMS Cloud Service.

Infrastructure includes, but is not limited to, all the technology used by CMS Business Owners and Cloud program contractors developing and operating applications and services within that hybrid data center environment. The CPT contractor serves as a broker of critical IT infrastructure upon which many CMS applications are built and operated. Infrastructure in this context includes all the following: Infrastructure as a Services (IaaS) or other native services from Cloud Service Providers (CSPs) (e.g., Google Cloud Provider (GCP), Microsoft Azure Government (MAG) and Amazon Web Services (AWS)), software, co-location data center leased space, hardware, tools and training. Furthermore, CPT is responsible for providing asset and financial management services associated with this infrastructure.

CPT plays a critical role in CMS’ physical data center consolidation effort, as it is the contract vehicle that CMS uses to acquire the data center co-location lease where its relatively new hybrid environment is hosted (i.e., physical and cloud). The resources delivered under that lease includes

CLIN SUMMARY

CLIN DESCRIPTION OF SERVICES PERIOD OF

PERFORMANCE

PRICE

0040-

12-Month Extension 7/01/24 - 6/30/25 $188,825,886

3. Authority:

: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).

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

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

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 CMS Office of Information Technology (OIT) provides a vital service to the CMS user community by maintaining the computing Infrastructure that assures the availability of CMS data to the Agency's staff, researchers, contractors, and its beneficiaries. Within this context, OIT is in the midst of a multiple-year data center consolidation effort necessary to improve performance, reduce cost, and establish a disaster recovery solution necessary to ensure the availability of mission critical applications. Several such applications are in the process of migrating to CMS cloud’s modern (hybrid) data center environment from one of several legacy data centers being closed. The two contracts that support the data center consolidation are the Managed Infrastructure Service Provider (MISP) and the Infrastructure as a Service (IaaS). MISP was awarded in the spring of 2022 and IaaS was awarded in the fall of 2023.

The program planners want to avoid managing the complex work under these two highly complex and interdependent contracts (MISP and IaaS) while planning and executing a third complex procurement/award at the same time (i.e., CPT). The CPT contract plays a critical role in this multiple-year data center consolidation effort, as it is the contract vehicle that CMS uses to acquire the lease for spaces where the target environment is hosted. The leases that CPT engages with Equinix includes the cage spaces that house all of the IaaS and MISP workloads, the racks and power for all of the equipment, and all of the backbone network connections. The network connections are quite complex. These connections include cross-connects from one cage to another, metro-connects from one Equinix site to another, Direct Connects to CMS’ AWS environments, Express Routes to CMS’ MAG environments, and connectivity to CMS’ WAN

(CMSNet). These leases are constantly appended to increase cage space, racks, and power as workloads continue to be added to the Equinix data centers. Accordingly, network connections are added, network bandwidth is increased, and redundancy is built in. CPT is currently engaged in many of these additions and has been constantly through the duration of the many migrations.

It is critical that CMS has no interruptions, gaps, or periods of transition of leases and knowledge during the data center migrations.

At the time of the initial award of the CPT contract, CMS anticipated a recompeted award being made at the end of the end of the current period of performance, however the additional complexity brought about by the evolving MISP and IaaS contracts, which are interdependent on CPT have brought about unexpected delays to the migration efforts that could not have been foreseen previously. A major data center migration was scheduled to occur in June 2022. Prior to that cutover CMS encounter issues with some software terms and conditions that hindered the schedule. Specifically, a software provided on a separate contract became a blocker with their terms and not allowing CMS to have a waiver during the migration. As a result, CMS had to postpone the data center migration in question from June 2022 to April 2023 while CMS worked through the issues. Correspondingly, this delayed the migrations of other data center workloads until after April 2023. Consequently, a few migrations still need to be completed, which will occur during the anticipated 12-month extension for CPT. Transitioning the CPT contract in the middle of the data center migration activities would pose a huge risk to the mission critical systems, potentially leading to multiple critical system failures and duplication of costs in support for the aforementioned systems. Any delay or gap in acquiring Equinix services would hinder migration and delay schedules potentially costing CMS tens of millions of dollars.

Given a 12-month extension CMS, the CPT requirement, as well as interdependent requirements such as MiSP and IaaS among others, would benefit greatly by the resolved migration efforts and finished consolidation efforts for the data centers. Therefore, the proposed 12-month CPT extension will result in greater contractual results for a large number of CMS requirements that depend on the services CPT provides. Extending CPT with GDIT will ultimately provide cost efficiencies while providing better quality services.

CMS’s cloud footprint is the largest Federal Civilian (non-DOD) environment known to the acquisition planners, requiring a contractor with the substantial means necessary to purchase large amounts of resources at a time. Due to the size of this environment, the discounts achieved by the current contractor through their agreement with AWS is substantial. Accordingly, the transition of CPT to a new contract vehicle is a time-consuming, complex acquisition. The occurrence of this event within the context of the complex migration activities described previously creates a confluence of activity that poses too great a risk for the planners to accept.

A misstep could cost CMS millions of dollars or create performance problems for mission critical systems.

Meeting the Government’s current requirement with an alternate vendor would require intensive training and a transition period of six (6) months, along with a Procurement Action Lead Time (PALT) of about six (6) months for a competitive award, which results in the need for a twelve

(12) month extension to account for the overall lead time necessary for the new contractor to take over full performance of the CPT requirement. The current period of performance remaining on the CPT task order does not allow for this required timeframe (6-month PALT, plus 6-month transition, 12-months total).

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:

General Dynamics Information Technology (GDIT) is capable of performing this work with no gap in performance following the end of the current contract by virtue of the CPT program experience, which is the primary justification for the sole source acquisition. Market research for this anticipated negotiated extension of the current CPT task order relied on the extensive market research performed before releasing the solicitation for the current CPT task order. It included a review of the US General Services Administration (GSA) Multiple Award Schedule (MAS) to identify capable vendors, publishing a Request for Information (RFI) to capable vendors to collect additional information, and then hosting meetings with vendors to refine the procurement requirements further and to ensure the recent procurement approach was in the best interest of the Government. During CMS’s initial market research, GDIT, an offeror for the CPT solicitation, was determined to be highly capable of fulfilling CMS’s need for this work. Other large business were also deemed capable, but as mentioned throughout this document, a transition to another contractor for this extension at this time is untenable due to the size, criticality, and complexity of the CPT requirement, as well as the time and cost involved with such a transition. Also, the work under this anticipated negotiated extension of the current CPT task order is substantially similar to that under the current CPT task order. CMS did receive adequate competition for the current CPT task order based on the market research CMS conducted. Any new contractor would need to repeat the work already done to get the program to where it is now. Other vehicles were also reviewed but did not contain a pool of large vendors comparable to GSA MAS, as well as none containing the pricing advantages found on GSA

MAS.

A potential CPT contractor must possess the ability to perform to the following overall requirements:

CPT will be responsible for the delivery of all infrastructure needed by ADOs utilizing the CMS Cloud Service as well as that needed by other contractors responsible for delivery of the cloud service to the ADO, i.e., CNS, ITOPS, and SecOps. Infrastructure includes but is not limited to all of the technology used by ADOs and Cloud program contractors in running applications or delivering their services. Essentially it includes all of the following things: Cloud services from CSPs - includes continuing the delivery of Microsoft Azure Government (MAG) and Amazon Web Services (AWS) CSP accounts and procuring CSP compute or native services, software, Equinix data center leased space, hardware, tools, and OEM professional services etc. Furthermore, CPT is responsible for providing basic asset and account management services associated with this infrastructure.

The scope of this Cloud Product and Tools (CPT) work order includes the following overarching product objectives associated with the OIT/IUSG cloud program. Many of these objectives involve coordination and collaboration with the larger integrated CMS Cloud Team: CMS, CPT, ITOPS, CNS, and SecOps.

While focusing on the above requirements, CMS further reviewed various contract vehicles and