JA26-022 Expiring CSA Class JA redacted_Redacted.pdf

CUI

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Controlled By: DISA Controlled By: PSD/PS82 CUI Category: PROCURE Distribution/Dissemination Control: FEDCON POC: Tara.D.Whitaker2.civ@mail.mil

JUSTIFICATION FOR OTHER THAN FULL AND

OPEN COMPETITION (OTFAOC)

Federal Acquisition Regulation (FAR) Part 6 Justification & Approval (J&A), Supporting Procurements under FAR Part 12, FAR Part 15, or FAR Part 13.5.

Purchase Request Number: Expiring Communications Service Authorizations (CSAs) Contract Number: Multiple CSAs on Appendix A of this J&A Task/Delivery Order Number: Not Applicable Procurement Title: Class J&A for Expiring CSAs Estimated Value:

Regulatory Authority: 10 U.S.C. § 3204(a)(1) and FAR 6.302-1 /Defense Federal Acquisition Regulation Supplement (DFARS) 206.302-1, Only One Responsible Source

Class Justification for OTFAOC Number: FY26-022

Upon the basis of the following justification, I, as Head of Contracting Activity, hereby approve the use of other than full and open competition of the proposed contractual action pursuant to the authority of FAR 6.302-1.

1. REQUIRING AGENCY AND CONTRACTING ACTIVITY:

a. Requiring Agency:

Defense Information Systems Agency (DISA)/Procurement Services Directorate

(PSD)

2300 East Drive, Building 3600 Scott AFB, IL 62225-5406

b. Contracting Activity:

DISA/Defense Information Technology Contracting Organization (DITCO)

Telecommunications Division (PS82) 2300 East Drive, Building 3600 Scott AFB, IL 62225-5406

2. NATURE/DESCRIPTION OF ACTION(S): DITCO contracts for long haul telecommunications services with United States (US) regulated/non-regulated and foreign contractors on behalf of various Military Departments (MILDEP), the Department of Defense (DoD), and other federal agencies at locations within the 48 Contiguous United States (CONUS), Hawaii, Alaska, US Territories and Possessions, and international locations. DITCO acquires

Class J&A for Expired/Expiring CSA’s-JA26-022

Page 2 of 7 Pages these telecommunications services using the streamlined Inquiry/Quote/Order (IQO) process.

The IQO process is a method for acquiring telecommunication services not available or unobtainable under an existing Indefinite Delivery contract. The IQO process is for the acquisition of telecommunication services, which may include associated equipment and special construction. All IQO CSAs must be firm-fixed-price or tariffed as authorized by the Federal Communications Commission (FCC) or other regulatory bodies such as a state Public Utility Commission.

Under the IQO process, DITCO receives mission partner’s (MP) Telecommunications Service Requests and Telecommunications Service Orders from DISA via a Web service. DITCO’s responsibility is to establish CSAs with contractors to satisfy the requirements of its MPs.

DFARS Subpart 239.7407 authorizes the use of the CSA for procuring telecommunications. A CSA is an order for a telecommunications service incorporating a Basic Agreement (BA), a written instrument of understanding that includes applicable terms and conditions, that constitutes a binding contractual obligation upon acceptance by the contractor. CSAs operate on a month-to-month basis, for which the Government must notify the contractor 30 days in advance of discontinuing service.

Throughout the life of the CSA, and especially prior to the expiration of the original estimated service life of a CSA, MPs are required to notify DITCO if the service is still required by taking steps to submit their new follow-on procurement requirements. This review and revalidation requirement is required of all owned/leased telecommunications in accordance with the Chairman of the Joint Chiefs of Staff Instruction 6211.02D, Defense Information Systems Networks (DISN) Responsibilities, dated 24 Jan 12. If the MP still requires the service, a re-award action is processed. If the MP no longer requires the service, a discontinue action is accomplished via modification and the telecommunications service ends.

Through the years, DITCO has improved the IQO process to more effectively communicate with its MPs prior to CSAs expiring to determine if the service is still required or should be discontinued. DITCO ensures CSAs are modified to extend expiration dates prior to expiration.

Therefore, this J&A addresses the extension of the expiring CSAs listed in Appendix A projected for the period of March 14, 2026, through March 13, 2027. These CSAs must be extended to allow DITCO time to either determine from its MP whether the telecommunications service is required and to re-compete the service, if appropriate, or if services should be discontinued.

The total ceiling of this class J&A is based on the current monthly recurring charges of each CSA outlined in Appendix A. Operations and maintenance funding will be provided for these extensions. The applicable North American Industry Classification Code is 517- Telecommunications.

3. DESCRIPTION OF SUPPLIES/SERVICES: CSAs consist of a wide spectrum of long-haul telecommunications services such as: business lines and dial tone services for government administrative operations, local area access, Intrastate and Interstate point-to-point services, switched services, domestic and international long-distance services, 800 Services, Packet Switched Data Services, video services, Integrated Switched Digital Network (ISDN) services, etc. Analog services are typically 3-kilohertz voice grade circuits, while digital services range

Page 3 of 7 Pages from 9.6 kilobytes (narrowband) to Optical Carrier -N (wideband) circuits.

4. IDENTIFICATION OF STATUTORY AUTHORITY: Only one responsible source and no other supplies or services will satisfy agency requirements, 10 U.S.C. 3204(a)(1) (FAR 6.302-

1/DFARS 206.302-1).

5. DEMONSTRATION OF CONTRACTOR’S UNIQUE QUALIFICATIONS:

a. Description of events. The MP of each applicable MILDEP/Agency must make a final determination to re-award CSAs on a competitive basis or discontinue services.

Services must remain operational until these determinations are made, contractual actions completed, and for re-awards, new service is fielded. Continuity of services through these existing CSAs is essential to support various DoD and federal agency operations. DITCO does not have insight into the criticality of the individual circuits and is unable to advise contractors to disconnect CSAs without proper authorization from MPs.

b. Justification.

(1) Minimum Government requirements. This contract action is required to allow for the extension and re-award of expiring CSAs, enabling DITCO time to acquire the needed guidance from all MPs. Some of these leased services knowingly range from providing commercial business lines in support of government administrative operations to critical operations related to national security (e.g., Direct Communication Links; Embassies; defense network missile silos; and military and humanitarian operations in Southwest Asia). Any break or gaps in service would have a significant impact on the mission of the following federal agencies:

Defense Finance and Accounting Services Defense Health Agency Defense Information Systems Agency Defense Intelligence Agency Defense Logistics Agency Defense Personnel Accounting Agency Department of Defense Federal Aviation Administration National Geospatial – Intelligence Agency National Security Agency Nuclear Regulatory Commission Office of Secretary of Defense United States Air Force United States Army United States Coast Guard United States Navy White House Communications Agency

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(2) Proposed sole source contractor. Many different contractors are associated with these CSAs. Appendix A of this J&A identifies the proposed sole source contractor per CSA through the telephone company symbol within the CSA numbers. The contractors' unique qualification is the ability to continue the existing services and extend the continuity of services to avoid a break in service.

(3) Discussion regarding cause of the sole source situation. DITCO is continuously working with the DISA Program Executive Office Services to field an automated tool, which will allow for proactive coordination with MPs to determine if services are still required or should be discontinued. Initial fielding of an automated tool was provided in June 2018 and an “enhanced” fielding of this tool took place in January 2020; however, there are currently data integrity issues that require correction, and the tool is not useful for the mission partners to effectively monitor CSAs. Further corrections and/or enhancements have been halted, as DISA is working to deploy a new entitlement system (DISA MarketPlace) for its MPs. The features required of the basic elements of a useful application will be integrated into the new entitlement system, currently scheduled for deployment in 2030 (note: deployment has been delayed since initial development began). Once deployed, MPs will be able to more efficiently, and within a manageable scale, track the upcoming expiration of active CSAs, allowing for timely submissions of re-award and/or disconnect requests. In the interim, manual efforts are required to track and monitor CSAs and their associated re-award/discontinue actions continuously. Although progress is being made in discontinuing services within their current expiration date, additional CSAs with approaching expiration dates are added, resulting in a constantly changing inventory every year. Given the delayed deployment of an automated tool and the dynamics associated with managing a large volume of CSAs, a J&A is expected to be required until such time the MILDEPs/Agencies are provided with better tools to manage their large volume of expiring CSAs.

(4) Impact. Services must remain operational until these determinations are made, contractual actions completed, and for re-awards, new service is fielded. Continuity of services through these existing CSAs is essential to support various DoD and federal agency operations. DITCO does not have insight into the criticality of the individual circuits and is unable to advise contractors to disconnect CSAs without proper authorization from MPs.

6. CONTRACT OPPORTUNITIES ANNOUNCEMENT/POTENTIAL SOURCES: No solicitation(s) will be posted to SAM.gov to support the modifications to extend the Period of Performance (PoP) on these CSAs; however, re-award actions to replace these CSAs will be synopsized in SAM.gov if required by FAR Part 5. A copy of this approved J&A will be posted to SAM.gov.

7. DETERMINATION OF FAIR AND REASONABLE COST: CSAs were initially competitively awarded with firm fixed prices or tariff pricing of which the prices were determined fair and reasonable. Tariff pricing is determined fair and reasonable as rates by a common carrier for tariffed telecommunications services are prices set by law and regulation

Page 5 of 7 Pages within the provisions of 10 U.S.C. 2306a in accordance with DFARS 239.7406(a). Should any contractor pursue a non-tariff rate increase because of the extension of the PoP on a CSA, the Contracting Officer will determine whether the proposed price is fair and reasonable.

8. MARKET RESEARCH: This is an extension of approximately 610 existing CSAs to ensure continued support until the MPs can submit discontinue actions or re-award actions against the expiring CSAs and the re-award actions are completed and service fielded. It is DITCOs intent to competitively re-award services to either small or large businesses as required pursuant to a current market research report submitted concurrently with the DD2579 to the DISA Office of Small Business Programs, in accordance with DARS Part 10. Based on current market research, completed from February 2025 through the present, it has been determined that only the telecommunication services provided by the current contractors for each CSA listed in Appendix A, can fully meet the Government’s need.

9. ANY OTHER SUPPORTING FACTS: To prevent this situation from reoccurring, DITCO has taken steps to ensure MPs are notified, via multiple mediums, of when CSAs will be expiring; continuation of a dedicated agency point of contact and regular coordination between the appointee and DITCO; Status of Acquisition Messages (SAMs) reflect contract expiration dates upon initial award of CSAs; the Telecommunication Services Enterprise Acquisition Services Inventory and Billing Information (TIBI) system reflects contract expiration dates for individual CSAs; Bulk Inventory Reports are available on demand within TIBI for MPs to track expiration dates; DITCO sends periodic reports of expiring CSAs to MPs; up to six Expiration Notice SAMs are now issued on Integrated Defense Enterprise Acquisition System CSAs beginning 12 months prior to expiration date; and DITCO-Scott participates in DISA/MP Drumbeats to highlight the need to discontinue or re-award CSAs. The continuous coordination with MPs and other methods listed above has led to the discontinuation of 427 CSA’s, over 53% of the CSAs on last year’s J&A, since March 2025 alone. A significant portion of the remaining CSA’s awaiting discontinuance have an awarded follow-on circuit either in contractor engineering or installation; upon cutover to the follow-on solution(s), those CSAs will be discontinued. The length of time to re-award CSAs and to cut-over services are due in large part to the procurement and installation of new, modernized solutions, versus like-for-like services, as legacy technology is no longer available, or is unreasonably expensive to maintain. Age and value of the CSA is considered when prioritizing the focus of discontinue efforts.

10. LISTING OF INTERESTED SOURCES: Many different contractors are associated with these CSAs. Appendix A of this J&A identifies the potential interested sources through the telephone company symbol within the CSA numbers. Any interested sources will be identified during market research and the competitive acquisition process for the re-awards replacing these CSAs. IAW DFARS PGI 206.303-2(b)(i)(A), the requirement to post a Sources Sought or Request for Information is not required as it was waived by the HCA on 18 November 2025; due to the circumstances identified in this J&A, the Government would not receive benefit from such a posting at this time.

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

THAT LED TO THE EXCEPTION TO FULL AND OPEN COMPETITION: Reviewing officials and the approval authority have reviewed the previous J&A, which was routed with this J&A, and determined any planned actions to remove barriers to competition listed on the

Page 6 of 7 Pages previous justification were considered. DITCO personnel continue to notify MPs of pending expiration dates through multiple mediums, a new order entry tool continues to be developed allowing enhanced abilities for MPs to monitor their expiring CSAs, and significant manual actions continue to be conducted by DITCO personnel, ensuring timely disconnect of expiring CSAs. Additionally, escalation procedures have been implemented; if MPs are non-responsive to DITCO personnel discontinue/re-award submission engagements, CSAs that have been renewed two times, three times, four times or more are escalated for Chief of Contracting Office, Head of Contract Organization, and Head of Contracting Activity respectively. After reviewing the actions taken, it is determined that a sole source environment still exists. CSAs identified by MPs confirming there is a valid continuing need for continued service will be re-awarded competitively as discussed above. The necessity for this action is also set forth above.

Enclosure a/s: Appendix A

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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.

NAME: Dustin (Dusty) Sampson SIGNATURE/DATE: See separate signature page

TITLE/ORGANIZATION: Program Manager/PS82

PHONE: 667-890-4963

REQUIREMENTS 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.

NAME: Dustin (Dusty) Sampson SIGNATURE/DATE: See separate signature page

TITLE/ORGANIZATION: Program Manager/PS82

PHONE: 667-890-4963

CONTRACTING OFFICER CERTIFICATION: I certify that this justification is accurate and complete to the best of my knowledge and belief.

NAME: Tara D. Whitaker SIGNATURE/DATE: See separate signature page

TITLE/ORGANIZATION: Contracting Officer/PS821

PHONE: 667-891-5367

PROCURING ACTIVITY COMPETITION ADVOCATE APPROVAL: I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Since this justification does not exceed $20M, this review serves as approval and my written determination that the aforementioned FAR circumstances apply.

NAME: Andrea L. Horstmann SIGNATURE/DATE: See separate signature page

TITLE/ORGANIZATION: Procuring Activity Competition Advocate/DITCO/PS2

PHONE: (667) 890-0841

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED

TO Tara D. Whitaker at 667-891-5367 or tara.d.whitaker2.civ@mail.mil.