A02 Signal University Extension JA_CCoE Signed - REDACTED FINAL.PDF
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- JA-20-B-017
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Control Number: JA-20-B-017 Contractor: Leidos, Inc.
Program/Equipment: (C4ISR) Systems Training and Cyber Support
FOR OFFICIAL USE ONLY
JUSTIFICATION REVIEW DOCUMENT
FAR PART 6 JUSTIFICATION AND APPROVAL FOR OTHER THAN
FULL AND OPEN COMPETITION
Program/Equipment: The Regional Signal Training Sites (RSTS), U.S. Army Signal School, U.S. Army Cyber Center of Excellence (CCoE)
Authority: 10 U.S.C. 2304(c)(2) as implemented by FAR Part 6.302-2 -- Unusual and Compelling Urgency.
Amount: $13,493,925.20
Prepared by: DSN:
Contract Management Officer Date: 15 Nov 2019
Contracting Officer: Allison A. Gregory DSN:
Contracting Officer Date: 15 Nov 2019 Allison.a.gregory2.civ@mail.mil
Technical: COM:
Deputy Director, RSTS Date: 15 Nov 2019
Requirements: DSN:
Director, RSTS Date: 15 Nov 2019
Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.
Director, Regional Signal Training Sites Typed Name:
DSN:
Signature:
Legal Counsel Typed Name:
DSN:
Signature:
FAR Part 6 Justification and Approval for Other than Full and Open Competition
1. Contracting Activity: U.S. Army Contracting Command - Aberdeen Proving Ground (ACC-APG), ATTN: CCAP-CCB, 6565 Surveillance Loop, Bldg. 6001, Aberdeen Proving Ground, MD 21005-1846
2. Description of Action: The United States Regional Signal Training Sites (RSTS), U.S. Army Signal School, U.S. Army Cyber Center of Excellence (CCoE) requests a Period of Performance (PoP) extension modification to Cost-Plus- Fixed-Fee (CPFF) and Cost Task Order W15P7T-10-D-D414 KX01 with Leidos, Inc., 3000 Lincoln Drive E Suite G, Marlton, NJ 08053-1500, for continued Command, Control, Communications, Computers, Intelligence, Surveillance and Reconnaissance (C4ISR) Systems Training and Cyber Support. This task order extension will have a Period of Performance of six 6-months from 21 December 2019 through 20 June 2020 with two (2) three 3-month option periods from 21 June 2020 to 20 September 2020 and 21 September 2020 - 20 December 2020 respectively. Fiscal Year (FY) 2020 Operations and Maintenance, Army (OMA) will be used to fund this effort. The anticipated award date of this action is on or before 20 December 2019.
Due to the time constraints associated with this extension, a Statement of Urgency was drafted by the Contracting Officer, on 27 November 2019. The Statement of Urgency was reviewed and approved by, Command Advocate for Competition on 27 November 2019. This approval permitted the Contracting Officer to issue the extension in advance of the approved J&A. This J&A will be completed and approved by the Command Advocate for Competition within thirty (30) days of the signature of the contract award.
3. Description of Services: This requirement supports the mission of the U.S.
CCoE which is the U.S. Army's force modernization proponent for Cyberspace Operations, Signal/Communications Networks and Information Services, and Electronic Warfare (EW). CCoE is responsible for developing doctrine, organizational training material, leadership/education, personnel, and facility solutions in support of Signal and Cyberspace operations. A major aspect of the CCoE's mission is the Contiguous United States (CONUS) and Outside the Contiguous United States (OCONUS) training, education, certification, development and support of world-class, highly skilled Signal, Cyber, and EW professionals supporting operations at the strategic, operational, and tactical level.
These trainings and support services are required for Soldiers to stay current with the equipment and fielding requirements for the newest Command, Control and Communication, Computers, Intelligence, Surveillance and Reconnaissance (C4ISR) Systems in the Army, both CONUS and OCONUS, to include the Kuwait and Afghanistan Areas of Responsibility (AoR).
The current effort is being performed by Leidos, Inc. under contract number W15P7T- 10-D-D414 Task Order KX01. The follow-on requirement is being competed under the Responsive Strategic Sourcing for Services (RS3) Multiple Award (MA) Indefinite Delivery Indefinite Quantity (IDIQ) contract vehicle. The day before proposals were due on 02 August 2019, the Contracting Officer was made aware of a potential organizational conflict of interest (OCI). After a discussion with the legal counsel, it was determined that the Request for Proposal (RFP) should be immediately placed on hold.
The IGE was developed by Program Manager (PM) engineers utilizing the historical pricing data from the initial 12-month base period and 6-month option period and the previous extension that was processed on this Task Order. This action will add additional Level of Effort (LOE) in the amount of hours.
TASK ORDER SUMMARY
4. Authority Cited: 10 U.S.C. 2304(c)(2) as implemented by FAR Part 6.302-2 -
- Unusual and Compelling Urgency.
5. Reason for Authority Cited: The proposed action must be accomplished through other than full and open competition in accordance with FAR Part 6.302-2 because the Army’s need for the services is of such an unusual and compelling urgency that the Government would be seriously affected unless the Army is permitted to extend the current task order. If this task order extension is not executed, the Warfighter will be without appropriate training and certification which is mandated for Soldiers in accordance with (IAW) DoD 8570.1 - Information Security Education requirements.
Soldiers that do not receive and maintain required certifications for their Military Occupational Specialty (MOS) are considered to be “non-qualifiied” in their MOS. This not only impacts unit readiness which affects unit deployability and undermines Mission Command, but it also subjects the Warfighter to potentially adverse career actions such as re-classification or involuntary separation. Not awarding this extension modification to W15P7T-10-D-D414 KX01 will result in unacceptable delays in supporting the Warfighter, both CONUS and OCONUS, thus requiring the urgent need for this extension to be awarded by 20 December 2019.
The follow-on requirement is being competed under the RS3 MA IDIQ contract vehicle.
Due to the potential OCI , the RFP was placed on hold.
Prior to the standdown, the source selection was on schedule for award before the existing Task Order ended on 20 December 2019.
Furthermore, a break in service of
W15P7T-10-D-D414 Task Order KX01 will result in significant costs to the Government; and will harmfully impact the Warfighter to an unacceptable level of security and physical risk by not providing suffificent and proper training along with certifications that is required.
If training is not available through the RSTS, individual units will be forced to send their Soldiers to non-RSTS Army, Joint, and Inter-Agency schools and centers in order to receive this required training. At an average cost of $2,000 per Soldier (includes registration/tuition fees, materials, travel, lodging, and per diem), the 12-month cost to the Government is estimated to be $24,000,000.00, approximately twice the cost of executing this extension. The two (2) 3-month option periods have been included in the event that there are additional delays beyond 6-month base period.
The training outlined above is conducted at 11 different locations and results in approximately 12,000 Soldiers being trained/certified on a yearly basis. Due to the complex nature of the training, it is typically planned and resourced the year prior to execution. Scheduled delays caused by the expiration of the incumbent task order, without another contractual vehicle in place, will leave major CONUS and OCONUS mission partners without the ability to provide their Warfighters with the key training they need to operate critical and essential communications systems.
In addition to individual training and certification, this effort is responsible for training, certifying and supporting Major Army Commands (MACOMs) for Department of Defense (DoD) Signal and Cyberspace operations. Constantly emerging Cyber requirements of data communication training include network interface, virtualization, threat detection and network management. The growth of the Cyber threat to the Armed Forces is mandating that the cybersecurity and tactical network management efforts for Program Executive Offices (PEOs) and MACOMs continue without interruption. A lapse in service will severely impact and delay several deployment transitions which will result in increased costs to the Government as well as the risk for potential loss of life during operational deployments.
6. Efforts to Obtain Competition: In accordance with FAR 5.202(a)(2), this action will not be synopsized.
a. Effective Competition: Because this is a sole source action, effective competition is not applicable.
b. Subcontracting Competition: The Contractor has subcontracted 20% of the current Task Order to small businesses. This meets the stated objective(s) contained within the Task Order and it is expected that the Contractor will continue subcontracting at this level under the extension.
7. Actions to Increase Competition: The Government has continually conducted market research over the past four (4) years for this requirement, as it was included in other Integrated Logistics Support Center - Fielding Support Directorate (ILSC- FSD) requirements. The Government currently has a competitive solicitation, RS3-18-0056, which has been set aside for small business prime contractors under the RS3 MA contract vehicle.
It is unknown at this time if the Government will be able to proceed with the procurement from where it left off, or if the requirement will need to be resolicited.
fair opportunity would result in unacceptable delays. It was signed by the Senior Contracting Official (SCO) (formerly the Principal Assistant Responsible for Contracting (PARC) on 17 August 2017, with an approved amount of
The total negotiated task order ceiling (base and option) was awarded at $86,733,307.00.
On 19 March 2019, a J&A, JA-19-E-132, was approved by the Command Advocate for Competition for W15P7T-10-D-D414 Task Order KX01 to extend the period of performance from 20 March 2019 for 3-months with two 3-month option periods. As a result of executing this J&A, some of the FSD requirements were de-scoped, reducing the not-to-exceed value of some of the CLINs. Because of this, a ceiling increase was not required. The authority cited was 10 U.S.C. 2304(c)(2) as implemented by FAR Part 6.302-2 -- Unusual and Compelling Urgency. This J&A was required due to poor requirements development for the follow on Task Order to be awarded under RS3-18- 0056.
c. Market Research (upcoming follow-on requirement)
The following actions were undertaken as part of market research for the next task order for these services.
On 14 January 2019, the Government sent out a Draft RFP to the RS3 contract holders. Questions and comments in response to the Draft RFP were due on 22 January 2019. The Draft RFP included a copy of the PWS, Draft Task Order and all of the Task Order attachments. The Government received and responded to a total of forty (40) questions in response to the Draft RFP.
The Government released the final RFP to the RS3 contract holders on 14 March 2019.
From 14 March 2019 to 24 July 2019, there were numerous questions received from RS3 contract holders regarding the RFP. Multiple correspondences with the requiring activity and responses to questions, resulted in significant changes to the PWS and manpower estimates. The Contracting Officer released two revisions to the RFP on 30 May 2019 and 23 July 2019.
11. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.
Typed Name: Date:
Title: Deputy Director, RSTS Signature:
12. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.
Typed Name: Date:
Title: Director, RSTS Signature:
13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost and price to the Government for this contract action will be fair and reasonable, based upon comparison to the Independent Government Estimate, Cost analysis, and negotiations. Additionally, certified cost or pricing data will be obtained.
Typed Name: Allison A. Gregory Date:
Title: Contracting Officer Signature:
14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.
Typed Name: Allison A. Gregory Date:
Title: Contracting Officer Signature:
Approval
Based on the foregoing justification, I hereby approve the modification to contract W15P7T-10-D-D414 Task Order KX01 for a six (6) month extension with two (2) three (3) month option periods, for the continued procurement of Information Technology Training and Certification Support at the estimated value of on an other than full and open competition basis pursuant to the authority of 10 U.S.C. § 2304(c)(2) as implemented by FAR Part 6.302-2 Unusual and Compelling Urgency, subject to the availability of funds, and provided that the services or property herein described have otherwise been authorized for acquisition.
Date:
Command Advocate for Competition Signature:
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