JA part16_ATT_21 Apr 2026 Final_Redacted.pdf

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DCMA Unclassified Wireless Devices and Services - AT&T

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Controlled By: Defense Contract Management Agency

Controlled By: Information Technology Directorate

CUI Category: PROCURE

Distribution/Dissemination Control: FEDCON

POC: Derrick Vining, derrick.vining.civ@mail.mil, (908) 296-4811

JUSTIFICATION & APPROVAL (J&A) FOR FEDERAL ACQUISITION

REGULATION (FAR) SUBPART 16.5 ACQUISITIONS

EXCEPTION TO FAIR OPPORTUNITY

Multiple Award Schedule/Multiple Award Contract (MAC)

Orders under MAC/ Fair Opportunity – FAR 16.507-6(b)

Contract Number: N0024424D0005

Task/Delivery Order Number: HC108425F0270

Procurement Title: Defense Contract Management Agency (DCMA) Unclassified Wireless

Devices and Service – AT&T

Estimated Value:

Statutory and Regulatory Authority: 10 U.S.C. 3204(a) and FAR 16.507-6(b)(3).

Exception to Fair Opportunity Number: Not Applicable (N/A).

Upon the basis of the following justification, I, as the Contracting Officer, hereby approve this exception to fair opportunity pursuant to the authority of FAR 16.507-6(b)(3).

1. REQUIRING AGENCY AND CONTRACTING ACTIVITY

Requiring Agency:

DCMA

3901 Adams Avenue

Fort Lee, Virginia 23801-1809

Contracting Activity:

Defense Information Systems Agency (DISA)/Defense Information Technology

Contracting Organization (DITCO)/PS8414

2300 East Drive, Building 3600

Scott Air Force Base, Illinois 62225-5406

2. NATURE/DESCRIPTION OF ACTION(S):

(a) The nature of this action is a sole-source contract modification to increase the quantity of existing services. This modification will procure an additional 2,127 Unlimited Data Only

(with MiFi (Hotspot) or Internet Device) plans under Exhibit Line Item Number (ELIN)

XB03 over the next three option periods. This action modifies the existing AT&T

Mobility, LLC (AT&T) wireless service task order issued against the Department of Navy

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(DoN) Spiral 4 Indefinite Delivery Indefinite Quantity (IDIQ) Multiple Award Contract

(MAC). This increase will ensure continuous operations of unclassified wireless devices and services, providing priority service data plans and reliable nationwide coverage, including strong service in rural and hard-to-reach areas.

(b) This modification will be executed as a firm-fixed-price (FFP) action. The estimated value of this modification , which increases the total task order ceiling from

. The services will be funded utilizing Fiscal Year 2026

Operations and Maintenance funds.

3. DESCRIPTION OF SUPPLIES/SERVICES:

(a) DCMA employs Quality Assurance (QA) personnel who travel to various contractor facilities to inspect products and ensure they meet the Department of Defense (DoD) standards. To do this job effectively outside a traditional office, these inspectors are being issued newly procured, cellular-enabled rugged Windows laptops. These laptops do not support voice calls; they rely exclusively on mobile data to access the internet.

This modification action is to procure Unlimited Data (with MiFi (Hotspot) or Internet

Device) plans necessary to connect these rugged laptops to the internet. These service plans will allow QA personnel access to mission-critical access to DoD applications, databases, and communication networks in real-time while working in the field. To support DCMA’s global mission these data services must provide coverage across all 50 states within the continental United States, and in over 90 international countries and territories.

(b) The existing AT&T task order (HC108425F0270) provides Unlimited Data (with MiFi

(Hotspot) or Internet Device) plans for DCMA personnel. However, it currently only provides the plan for a total quantity of 192.

This modification procures a significant increase in the number of Unlimited Data (with

MiFi (Hotspot) or Internet Device) plans. This expansion is exclusively driven by the recent and planned deployment of the new rugged laptops for QA staff. Because the laptops require specialized mobility and uninterrupted network access, the current capacity of 192 plans is insufficient. This modification adds an additional 2,127 plans

(phased over three option years) to ensure QA personnel can perform their essential duties outside the office.

(c) The period of performance (PoP) for this modification aligns with the current DCMA task order under the DoN IDIQ MAC, Spiral 4. Service activation will occur upon the exercise of the options and continue uninterrupted. The total anticipated performance period spans from May 7, 2026, through May 6, 2031.

To align with the rollout schedule of the new rugged laptops, the modification will procure 2,127 additional plans according to the following schedule:

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Option Period PoP Quantity

Increase

Total

Sustained

Quantity

Base Contract May 7, 2025 –

May 6, 2026

No change 192 plans

Option Year 1 May 7, 2026 –

May 6, 2027

Increase by 613 plans

805 plans

Option Year 2 May 7, 2027 –

May 6, 2028

Increase by 757 plans

1,562 plans

Option Year 3 May 7, 2028 –

May 6, 2029

Increase by 757 plans

2,319 plans

Option Year 4 May 7, 2029 –

May 6, 2030

No change 2,319 plans

Option Year 5 May 7, 2030 –

May 6, 2031

No change 2,319 plans

(d) The estimated life-cycle cost for the additional Unlimited Data (with MiFi (Hotspot) or

Internet Device) plans, inclusive of all option periods, is This modification will increase the total task order lifecycle amount . Cost breakdown per period:

Option Period PoP Original Cost Modification Increase

Base Contract May 7, 2025

– May 6, Option Year 1 May 7, 2026

Option Year 2 May 7, 2027

Option Year 3 May 7, 2028

Option Year 4 May 7, 2029

Option Year 5 May 7, 2030

4. SUPPORTING RATIONALE, INCLUDING A DEMONSTRATION THAT THE

PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR THE NATURE OF THE

ACQUISITION REQUIRES USE OF AN EXCEPTION TO FAIR OPPORTUNITY:

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(a) Exception to Fair Opportunity. The following exception applies to this action in accordance with FAR 16.507-6(b)(3): The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

(b) Justification.

(1) In May 2025, DCMA awarded wireless task orders under the DoN IDIQ MAC, Spiral

4 through a fair opportunity competition among all eligible vendors. This ensured that all qualified carriers had an equal chance to compete, resulting in initial awards to both AT&T (HC108425F0270) and a secondary provider, Verizon

(HC108425F0271). These awards established the framework for providing DCMA with reliable wireless services, enterprise support, and nationwide coverage.

In February 2026, DCMA received an initial delivery of 1,115 new procured, cellular-enabled rugged Windows laptops to serve as primary computing devices for

QA personnel in the field. Over the next two years, the agency plans to acquire an additional 2,754 rugged tablets to support its distributed workforce. The requirement for a massive increase in Unlimited Data (with MiFi (Hotspot) or Internet Device) plans was unforeseen at the time of the original May 2025 task order competition.

(2) While full and open competition is generally preferred, the timing and complexity of this sudden hardware deployment makes a separate competitive procurement impractical. The current base year for the AT&T wireless task order expires on May

6, 2026, with the first option year beginning May 7, 2026. Modifying the existing

AT&T task order to act as a logical follow-on for these additional data plans is required in the interest of economy and efficiency. Transitioning these specific QA data plans to a new provider would require substantial phase-in and phase-out activities, establishing new billing, network integration, and support processes, which could disrupt connectivity for business-critical applications. Leveraging the existing contractual alignment with AT&T ensures continuity of service, minimizes administrative overhead, and allows for the immediate activation of devices upon deployment. To prevent similar challenges in the future, DCMA will proactively identify hardware procurement schedules in advance and align subsequent wireless service needs with task order option periods.

(c) Minimum Government requirements. The verified minimum requirements of the

Government for wireless mobility under this task order include:

• Voice, Text and Tether/Hotspot Capability

• Broadband Data Devices (*Portable MiFi)

• Tablets, iPads (*iOS) with Data service capability

• Broadband Data Device service

• Data services in the 50 continental United States, and territories.

(d) Proposed sole source contractor and demonstration of unique source.

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The proposed contractor for this modification is AT&T. AT&T is the only source capable of seamlessly executing this requirement without causing unacceptable delays or substantial duplication of costs to the Government.

(1) DCMA already maintains established agreements, integrated billing structures, and IT support processes with AT&T under the existing task order. Introducing a different contractor to solely support these laptops would require duplicating these systems. Additional duplicated costs would include new system integration engineering, dual billing transitions, redundant operational support setup, and hundreds of administrative hours to manage a subdivided service environment for QA personnel.

(2) QA personnel are currently receiving these rugged laptops and require immediate internet connectivity to perform mission-critical inspections at contractor facilities.

Any delay in maintaining data services to onboard a new vendor would disrupt real-time communications and access to enterprise applications.

(3) AT&T has demonstrated consistently strong network performance across DCMA’s operating areas, including high bandwidth, low latency, and exceptional uptime.

While other MAC holders may be competitive in select areas, splitting this specific hardware deployment away from the established AT&T enterprise environment would introduce unacceptable operational risks and administrative burdens.

(e) Procurement discussion.

(1) The requirement is strictly constrained by the need for uninterrupted connectivity and enterprise-grade security across DCMA’s operational areas to support business-critical applications (e.g., real-time communications, secure data transfer, and access to secure systems).

(2) This action modifies the quantities for the option years of the existing task order, with the first option period beginning May 7, 2026. The minimum period of performance aligns with these option years to maintain continuity while DCMA executes its planned rollout of the rugged laptops over the next two years.

(3) Wireless data services were previously acquired through competitively awarded task orders under Spiral 4 in May 2025. This follow-on requirement represents a direct, logical continuation of that existing effort with AT&T. This exception has not been overused; it is based solely on the unforeseen surge in laptops requiring immediate, integrated network connectivity.

(f) Impact. Disapproving this logical follow-on modification would create substantial operational risk. QA personnel rely on these rugged laptops to conduct surveillance, submit reports, and access contract systems from remote contractor facilities.

Transitioning to a new provider for these data plans would require significant lead time to establish billing, support, and network integration, resulting in immediate gaps in mission-essential services. Interruptions in wireless connectivity would directly delay

DoD product evaluations and inspections, crimpling DCMA’s ability to meet operational, Page 6 of 10 Pages

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safety and compliance objectives. Continuing with AT&T ensures seamless continuity and maintains the operational readiness of DCMA personnel across the agency’s distributed footprint.

5. COST/PRICE FAIR AND REASONABLE DETERMINATION:

(a) All prices set forth in the DoN IDIQ MAC, Spiral 4 contracts and utilized on individual task orders were based on full and open competition. A comprehensive price analysis was accomplished by the DoN at the IDIQ level. Through that process, the DoN has already determined the prices of the supplies and services to be fair and reasonable, and these prices have been formally established within the basic DoN IDIQ MACs.

(b) In May 2025, the initial task order (HC108425F0270) was awarded to AT&T through a fair opportunity competition among all eligible Spiral 4 vendors, which established fair and reasonable pricing at the task order level. To determine that the cost for this modification is fair and reasonable, the Contracting Officer will compare the proposed prices for the additional 2,127 Unlimited Data Only (with MiFi/Hotspot or Internet

Device) plans directly against the prices currently being paid for those exact same service plans under the existing AT&T task order.

(c) Proposed order prices will be verified to ensure they do not exceed the basic contract prices established in the DoN IDIQ MAC, Spiral 4 and are consistent with the competitively established rates currently being executed on the task order. Based on this comparison to current contract pricing and the established IDIQ rates, the Contracting

Officer will ensure the final negotiated price of the modification, estimated at a lifecycle cost of is fair and reasonable to the Government.

6. MARKET RESEARCH:

(a) DCMA conducted meaningful market research, within the past 12 months, to identify all qualified sources for unclassified wireless devices and cellular services. The purpose of this research was to support a 1-year option extension under task order HC108425F0270

(May 7, 2026 – May 6, 2027) and the immediate need to expand Unlimited Data (with

MiFi (Hotspot) or Internet Device) plans to support the newly procured rugged laptops.

Multiple strategic sourcing vehicles and repositories were reviewed, including:

• DoN IDIQ MAC, Spiral 4,

• General Services Administration Information Technology Multiple Award

Schedule (MAS) Category 517312

• DISA Market Research Report repository

• DISA DITCO Contracts Catalog

• Commercial offerings and rates from major telecommunications providers

(b) The market research revealed that no DISA Premier contracts provided the suitable combination of required enterprise mobility services. Furthermore, comparisons of pricing across the DoN Spiral 4 IDIQ MAC, GSA MAS, and commercial rates confirmed that competitively established rates currently residing on the DoN Spiral 4 MAC

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represents the most advantageous pricing for the Government. Based on the market research finalized on March 10, 2026, it was determined that only the aforementioned broadband data service provided by AT&T, under the current task order, can fully meet the Government’s immediate need without causing unacceptable delays or duplicated integration costs. This ensures continuity of mission-critical wireless services while maintaining fair and competitive pricing. Alternative strategies, such as recompeting the requirement, would introduce unnecessary delays, administrative burden, and operational risk, demonstrating a good faith effort to consider all viable options prior to determining continuation with the current task order and contractor is the best solution for the

Government.

(c) The Government made a good faith effort to consider viable alternative strategies before determining that an exception to fair opportunity was necessary.

(1) Alternative 1: Recompete the Additional Laptop Data Plans. The primary alternative strategy was to issue a new, separate fair opportunity solicitation strictly for the 2,127 new Unlimited Data plans required for the QA rugged laptops. However, this strategy was rejected. Awarding a separate task order to a different carrier solely for the laptops would require DCMA to engineer redundant network integrations, manage dual billing portals, and establish bifurcated IT support workflows. This would introduce unnecessary administrative burdens, substantial duplicated costs, and severe operational risk due to deployment delays.

(2) Alternative 2: Modify the Existing Task Order (Chosen Strategy). Exercising the existing option and modifying the current AT&T task order to accommodate the expanded quantity of data plans represents the most advantageous approach. This strategy leverages the highly competitive rates already established under Spiral 4, ensures immediate continuity of mission-critical wireless services for the QA personnel, and avoids the duplication of enterprise integration costs.

7. ANY OTHER SUPPORTING FACTS:

None.

8. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME BARRIERS

THAT LED TO THE EXCEPTION TO FAIR OPPORTUNITY:

(a) Procurement History. The DoD and the Office of Management and Budget (OMB) mandate the use of centralized mobility vehicles (such as the DoN IDIQ MAC, Spiral 3 and the current Spiral 4) for all unclassified wireless services. The overarching enterprise mobility requirement has been successfully competed multiple times. The following table summarizes the last several awards and bridge actions for DCMA's wireless requirements leading up to the current Spiral 4 task order:

Contract/Task Order PoP Contractor (Size) Competitive Status

& Vehicle

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GS00Q13NSA3000/

S5121A14A0009

Sept 30, 2014 –

Sept 29, 2019

Verizon (Large) Competed (GSA

FSSI Wireless BPA)

GS00Q13NSA3000/

S5121A16A0006

Jan 1, 2017 – Apr

1, 2019

AT&T (Large) Competed (GSA

FSSI Wireless BPA)

GS00Q13NSA3000/

S5121A19F0011

Apr 1, 2019 – Jul

1, 2019

AT&T (Large) Sole Source

Extension (Bridge to Spiral 3)

N0024418D0003/

HC108419F0186 &

N0024418D0001/

HC108419F0188

Jul 2, 2019 – May

6, 2024

AT&T (Large) &

Verizon (Large)

Competed (DoN

IDIQ MAC, Spiral

3)

N0024418D0001/

HC108424F0171 &

N0024418D0003/

HC108424F0178

May 7, 2024 –

May 6, 2025

AT&T (Large) &

Verizon (Large)

Sole Source

Extension (Logical

Follow-on via

JA24-046)

N0024424D0005/

HC108425F0270 &

N0024424D0010/

HC108425F0271 (Current

Task Orders)

May 7, 2025 –

May 6, 2031

AT&T (Large)

Verizon (Large)

Competed (DoN

IDIQ MAC, Spiral

4)

(b) DCMA successfully took action to remove previous barriers by fully competing the overarching wireless requirement under the DoN Spiral 4 MAC in May 2025, which resulted in the current AT&T task order. However, a temporary sole-source environment currently exists specifically for the additional 2,127 Unlimited Data plans required by this modification. This barrier was created by an unforeseen, out-of-cycle procurement of cellular-enabled rugged laptops for QA personnel.

To avoid the need for similar limited-source modifications in the future, DCMA will implement stronger integrated acquisition planning. Specifically, the agency will proactively align the forecasting and procurement schedules of mobile hardware (e.g., laptops, tablets) with the lifecycle of the enterprise telecom task orders. By forecasting these hardware surges earlier, DCMA can ensure that the required data plans are bundled into the base quantities of future competitive task order solicitations, rather than added incrementally via exception to fair opportunity.

(c) As noted in the history above, the base requirement for enterprise mobility was recently competed under Spiral 4. The changed circumstance necessitating this specific exception is not a failure to compete the base requirement, but rather a sudden internal hardware deployment (the rugged laptops). Because these laptops must integrate seamlessly with

DCMA's existing network infrastructure and billing portals without operational delay, they must be added to the established AT&T task order. When this current Spiral 4 task order approaches the end of its lifecycle, the total aggregated quantities (including these laptop data plans) will be re-baselined and competed fully under the next iteration of the DoN mobility MAC (e.g., Spiral 5).

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