JEFO 21F0043 DMDC Enterprise PMO Final 31 AUG 26_Redacted.pdf

CUI//SP-SSEL

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JUSTIFICATION FOR AN EXCEPTION

TO FAIR OPPORTUNITY

UNDER INDEFINITE

DELIVERY/INDEFINITE QUANTITY

(IDIQ) CONTRACTS

Task Order 47QFMA21F0043

Enterprise Program Management Support in support of:

Defense Manpower Data Center (DMDC)

United States (U.S.) General Services Administration (GSA) Federal Acquisition Service (FAS)

Assisted Acquisition Services (AAS) Army

Interagency Agreement PIID 47QFMA10S0001

Controlled by AAS Contracting Officer Steven Nerenberg: steven.nerenberg@gsa.gov

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The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this Justification for the issuance of an Exception to Fair Opportunity order pursuant to Federal Acquisition Regulation (FAR) 16.5 (GSA Class Deviation RFO-2025-16).

a. Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of:

Defense Manpower Data Center (DMDC) 400 Gigling Road Seaside, CA 93955

Contracting Activity:

GSA AAS Contracting Office (FABCD) 1800 F Street, NW Washington, D.C. 20405

b. Nature and/or Description of Action Being Approved:

The Government intends to issue a modification to extend Task Order No.

47QFMA21F0043, awarded to Deloitte Consulting LLP, against their OASIS Unrestricted Pool 1 Government-wide Acquisition Contract (GWAC) No: GS00Q14OADU113, for twelve (12) months with a value of , to support the current needs of the Defense Manpower Data Center’s (DMDC) Enterprise Program Management (PMO) support services requirement from September 29, 2026 to September 28, 2027.

The TO was originally awarded on 27 September 2021 in the total amount of consisting of one (1) 12-month base period and four (4) 12-month option periods, with a combination of Firm-Fixed Price (FFP) and Time and Materials (T&M) type Contract Line Item Numbers (CLINs). As explained in further detail below, the extension is needed to: (1) allow DMDC to continue to support its essential mission with no break in service, and (2) provide critical transition out support.

c. Description of Supplies/Services and Estimated Value:

The scope of this extension is to continue providing the full range of IT-related program management support services as detailed in the Performance Work Statement of Task Order No: 47QFMA21F0043. The contractor supports DMDC’s mission-critical operations, which include maintaining the central authoritative store of personnel, manpower, training, and security data for the Department of War (DoW). Key support areas include, but are not limited to:

● IT Capital and Strategic Planning

● Portfolio and Investment Management

● Business and System Requirements Management

● Policy and Program Management (including expertise in Identity Credential Access

Management (ICAM), DHRA restructuring, and modernization of the Federal Wage System (FWS))

○ Data Governance and DHRA Restructuring Support

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○ Systems Engineering and Policy Support for critical DMDC systems and initiatives, including:

○ ICAM architecture

○ Modernization of the Federal Wage System (FWS)

○ Real-Time Automated Personnel Identification System (RAPIDS)

○ Defense Biometric Identification System (DBIDS)

○ Personnel accountability systems (e.g., Synchronized Predeployment and

Operational Tracker (SPOT), Noncombatant Evacuation Operations Tracking System (NTS))

Period of Performance: The period of performance for this twelve (12) month extension will be from September 29, 2026 to September 28, 2027.

Estimated Value: The value of this action is estimated to be This amount is based on the continuation of the existing level of effort required to support DMDC’s complex and ongoing strategic initiatives and will increase the TO ceiling from to

d. Identification of the Exception to Fair Opportunity and Rationale:

This TO Justification is being prepared as required by FAR 16.507-6 (GSA Class Deviation RFO-2025-16) Exceptions to Fair Opportunity.

The statutory authority for this action is FAR 16.507-6(b)(2) (GSA Class Deviation RFO- 2025-16), only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized. The incumbent, Deloitte, is the only source capable of continuing to provide these critical services without interruption. It is impossible to re-compete the current requirement by the task order expiration date of September 28, 2026, and avoid a lapse in the critical services required by DMDC. A competitive procurement would have an estimated procurement lead time of nine to twelve months, which exceeds the time remaining on the current task order.

DMDC is a component under the Defense Human Resources Activity (DHRA), a Department of War (DoW) Field Activity. DMDC maintains the central and authoritative store of personnel, manpower, training, and security data for the DoW. The objective of this task order is to acquire a full range of information technology related program management support services, to assist in establishing and maturing the DMDC service delivery model by implementing program management best practices that reduce the cost and complexity of IT systems and applications, to increase the resiliency, adaptability and agility of DMDC’s systems and to improve collaboration and cooperation with the Lines of Business, while achieving DMDC’s strategic mission objectives.

The extension will provide continuous program management and technical support for several critical, ongoing initiatives within the DHRA and DMDC, aligned with DoW schedules and priorities. The need for a twelve (12) month extension is necessary to support the following four (4) key modernization and rationalization initiatives for an extended period of time while a competitive follow-on contract is procured.

● Human Resources Management (HRM) Portfolio (system) Rationalization (now through September 2027)

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● Portfolio and program support needed to implement Office of Personnel Management’s (OPM) federal Human Resources (HR) solution and rationalize systems (now through July 2027)

● Support for the My DoW Identity Solution (MYDS) alpha/beta test sites (September 2026 - September 2027)

● Program Management (PM) support for myAuth onboarding of DoW components prior to audit 2028 (now through September 2027)

The current task order ends on September 28, 2026. There has been a fundamental, unforeseen shift in the DoW’s strategic requirements that significantly changed DMDC’s approach to a competitive follow-on effort. Specifically, the issuance of the June 2026 SecWar Memorandum, "Advancing Defense Business System Rationalization" (“2026 Rationalization Memo”) completely redefines the scope, metrics, and timeline of the required support that DMDC provides the DoW. The planned competitive follow-on effort, Strategic Technical, Engineering, and Operations Support (STEPS), to be issued against the DMDC DEHRADS Multiple-Award BPA is a new requirement that will incorporate the forward looking DoW rationalization efforts mandated in this Memo.

The first 120 days of this extension will be used to support the Functional Sponsors in defining the new FY28-FY31 rationalization plan. The outputs of this plan will directly influence the Performance Work Statement (PWS) for the competitive follow-on contract (STEPS). In order to maintain essential support during this period of uncertainty, a twelve

(12) The twelve (12) month extension will provide continuous program management and technical support for the four aforementioned critical initiatives (as further defined below) within the DHRA and DMDC portfolio.

This extension ensures team stability and continuity, minimizing risks and aligning execution with strategic goals while preventing any service interruptions during the transition.

1. HRM Portfolio Rationalization (Now through September 2027) The DoW is executing a high-risk initiative to eliminate over 170 of its 342 Human Resource Management (HRM) systems, driven by the 2026 Rationalization Memo.

Supported by a $242M funding supplement (a 50% baseline increase) for FY27, the DHRA must decommission these systems while protecting the fragile, legacy Defense Civilian Personnel Data System (DCPDS), which is concurrently undergoing a emergency remediation. Contractor support under the PMO task order is required to: assess legacy environments by analyzing system functionality, cybersecurity postures, and technical requirements, formulate transition paths through consolidation recommendations and business case analyses for system retirement, drive stakeholder alignment by developing a communication strategy to secure DoW buy-in, and monitor program execution by tracking and reporting rationalization progress against mandated milestones. A twelve (12)-month extension is required to meet the strict FY26–FY27 retirement schedule and avoid statutory funding cutoffs under 10 USC §2222. Even if it were possible to timely award a competitive follow-on effort, potentially replacing Deloitte risks triggering a 90-to-120-day knowledge transfer period, introducing unacceptable volatility. This extension ensures baseline stability, protects the DCPDS remediation, and prepares the program for a secure, competitive follow-on contract.

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2. OPM Federal HR Solution Implementation (Now through July 2027) OPM is implementing a cross-government Core Human Capital Management (HCM) platform to drive system efficiencies. In doing so, OPM is transitioning agencies away from a fragmented legacy HR environment toward a common government operating model based on more standardized processes and data models. This massive transition requires DoW-wide coordination and strategic gap analysis with OPM to mitigate risks. DHRA requires support under the PMO task order to:

● Identify rationalization opportunities by comparing OPM capabilities against the DoW Business Enterprise Architecture.

● Update senior leadership (SecWar, DoW CIO, USW P&R, and DHRA) on program status, risks, and issues.

● Execute critical technical activities, including fit-gap analysis, testing, and validation.

A twelve (12)-month extension is essential to maintain momentum without interruption.

This period directly covers critical implementation phases, from initial preparation to final cutover and legacy system decommissioning.

3. Support for the My DoW Identity Solution (MYDS) alpha/beta test sites (September 2026 - September 2027) MYDIS is a modern identity management and credentialing solution scheduled to replace the legacy Real-Time Automated Personnel Identification System (RAPIDS) starting in Fiscal Year (FY) 2027. To ensure a seamless transition, a 12-month contract extension to the PMO task order is required to provide uninterrupted site support for critical beta testing from September 2026 to September 2027.

● Execute field testing by developing and running test activities in live operational environments.

● Maintaining parallel environments by managing a functioning MYDIS production site to facilitate comparison and transition

● Developing test plans, schedules, and procedures

● Manage software quality by tracking error reporting, resolution, and system software changes The year-long beta testing phase is non-severable; a contractor cannot deliver a functional evaluation report without observing the entire testing cycle. Even if it were possible to timely award a competitive follow-on effort, potentially replacing Deloitte risks disrupting baseline stability, delaying vital operational feedback, and stall the decommissioning of RAPIDS, forcing the DoW to incur substantial duplicate system maintenance costs.

4. Program Management (PM) support for myAuth onboarding of DoW components prior to audit 2028 (Now - September 2027) MyAuth, DoW’s modern, cloud-based identity and multi-factor authentication system built to replace the legacy DS Logon, which is a component of ICAM, a critical-path requirement mandated by the DoW CIO for the Department to achieve a clean financial audit by 2028. The program is experiencing rapid growth, onboarding twenty (20) customer applications in FY26 with twenty-five (25) more planned for FY27. To manage

Version 02/28/2025 Page 6 this complex integration and secure the platform, DHRA requires continuous program management support under the PMO task order to:

● Drive application onboarding through direct customer engagement, program documentation (user guides) development and application integration

● Provide audit and Service Organization Control (SOC)-1 program documentation and governance

● Maintain program oversight through automated dashboards, performance metrics, and leadership reporting

A 12-month extension is vital to prevent an onboarding disruption during this critical expansion. Even if it were possible to timely award a competitive follow-on effort, potentially replacing Deloitte risks diverting specialized resources to a 60 to 90-day knowledge transfer, halting application integrations. This delay would push key migrations past the FY27 deadline, fail to remediate access control deficiences, and directly threaten the Department’s statutory 2028 audit readiness mandates.

Additionally, allowing a service gap will result in:

● Halting Critical Initiatives throughout the DMDC portfolio: A lapse in PMO services would immediately halt high-priority mandates, including DHRA restructuring, Federal Wage System (FWS) modernization, and the ICAM architecture. The PMO provides the essential strategic planning, policy development, and implementation oversight for these multi-year efforts. A service gap would impede progress, delay the realization of strategic benefits, and disrupt mission-critical timelines.

● Loss of Specialized Expertise and Institutional Knowledge: Over five (5) years of performance, Deloitte has amassed an extensive and highly specialized knowledge base of DMDC’s systems and their complex interconnectivity, DMDC’s strategic initiatives, and complex inter-agency relationships. Additionally, the PMO task order requires Key Personnel with deep experience in DoD identity management and specific DMDC systems. Deloitte has these approved personnel in place and fully integrated, and the loss of this institutional knowledge would hinder program momentum.

● Risk to Operational Readiness: PMO support is critical for time-sensitive DoW operations, including identity verification (DoW ID cards) and personnel accountability via systems like SPOT, NTS, and DBIDS for DoD ID card issuance, personnel accountability, and physical access control. A transition mid-stream would disrupt strategic development and maintenance, directly impacting mission-critical timelines. The PMO provides the essential program management, requirements definition, and systems engineering that ensures the continuity and functionality of these systems. A transition to a new contractor would introduce a period of reduced efficiency and potential disruption to the PMO's ability to manage and support these systems, posing a direct risk to these critical services.

● Delays for Complex Ongoing Initiatives: The contractor is deeply embedded in multi-year strategic initiatives, such as the migration to a multi-cloud environment and the DHRA-wide 508 Accessibility Program implementation. Introducing a new contractor mid-stream would stall progress on these efforts, delaying the realization of their strategic benefits and efficiencies for the DoW. Deloitte’s familiarity with

Version 02/28/2025 Page 7 established governance forums, stakeholder relationships, and technical roadmaps is essential for timely completion of these initiatives.

Based on the analysis above, Deloitte is the only contractor with the in-place cleared personnel, system access, and unique institutional knowledge required to prevent a gap in services while the follow-on STEPS order is competitively procured. Furthermore, the current order is set to expire on September 28, 2026, making the significant startup time required for a new contractor unfeasible.

e. Determination That the Anticipated Cost is Fair and Reasonable:

The GSA Contracting Officer (KO) will complete an evaluation of the contractor’s price submission to ensure the labor mix and hours are appropriate for the work to be performed. In accordance with FAR 15.404-1 (GSA Class Deviation (RFO-2025-15) and 15.404-2 (GSA Class Deviation (RFO-2025-15), a price and cost analysis will be performed including the verification of rates, as well as a comparison to prices currently paid to determine the prices fair and reasonable.

f. Other Facts Supporting the Justification:

There are no other facts supporting the justification.

g. Statement of Actions:

There are no anticipated barriers once the new acquisition is awarded, as the requirement was competed under fair opportunity in accordance with FAR 16.505.

The Government will solicit only Deloitte Consulting, LLP, under their GSA OASIS Unrestricted Pool 1 Contract No: GS00Q14OADU113/ TO 47QFMA21F0043. This action will extend the current order for the twelve (12) month option period from September 29, 2026 to September 28, 2027. No other firm is capable of providing the necessary supplies or services at the level of quality required because the supplies or services ordered are unique or highly specialized. This extension provides the necessary coverage while the expertise within the timeframe required. The Government is currently preparing the STEPS recompete Orders under the DEHRADS BPA, ensuring fully competitive awards are established before the Enterprise PMO extension expires. There are no barriers to competition as the STEPS requirement will be solicited through the DMDC DEHRADS BPA. This vehicle was originally established using best value procedures per legacy FAR 8.405-3(b)(2)(v)(B) and currently includes ten (10) active BPA holders.

h. Certification by Technical or Requirements Personnel:

I hereby certify that the supporting data is accurate and complete.

Date

Project Manager, GSA AAS Army

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i. Signature of Authorized Officials:

I hereby certify that the Justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that the exception to fair opportunity is in accordance with the requirements and is in the best interest of the Government.

Date

Contracting Officer, AAS Army Assisted Acquisition Services (AAS)

AAS Advocate for Competition:

Competition Advocate, AAS Army Assisted Acquisition Services

AAS Contracting Executive:

Contracting Executive, AAS Army Assisted Acquisition Services