JOFOC 89243221CNE000020.pdf

JOFOC 89243221CNE000020

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

For Contract 89243221CNE000020

1. Agency and Contracting Activity:

The U.S. Department of Energy- Idaho Operations (DOE-ID), under the Office of Nuclear Energy (NE-31), plans to contract by means other than full and open competition. This document sets forth the justification and approval of the use of one of the exceptions to full and open competition allowed under the Competition and Contracting Act (CICA) of 1984.

2. Nature and/or Description of the Action Being Approved:

This justification provides the rationale for awarding a sole-source modification to extend the period of performance for contract 89243221CNE000020 with Montech, Inc. The modification extends the contract for a period of six months, from June 30, 2026, to December 31, 2026. This action is a bridge to ensure the continuity of critical Personnel Security Support services at the Idaho National Laboratory (INL) while a competitive follow-on contract is solicited and awarded.

3. Description of Supplies/Services Required to Meet the Agency's Needs:

The services required are for comprehensive Personnel Security Support for the DOE-ID program at the INL. The INL is the nation's lead laboratory for nuclear energy research and development, and much of the work involves classified information vital to the defense and security of the United States.

The contractor provides the specialized expertise necessary to implement the DOE-ID Personnel Security Program. This includes, but is not limited to:

Adjudication: Reviewing investigative reports, evaluating derogatory information, and making recommendations on security clearance eligibility for approximately 4,500 clearance holders and 440 individuals in the Human Reliability Program (HRP).

Information and Records Management: Utilizing and managing sensitive data across multiple government database systems, including the Central Personnel Clearance Index (CPCI) and the Defense Counterintelligence and Security Agency (DCSA) systems.

Clearance Processing: Assisting applicants, processing clearance packages, and ensuring compliance with all applicable federal regulations and DOE directives.

Personal Identity Verification (PIV): Managing the processing of paperwork and fingerprints for identity credentials in accordance with Homeland Security Presidential Directive 12 (HSPD-12).

All contractor personnel are required to possess and maintain an active DOE “Q” security clearance to perform these duties. The total estimated value of this six-month extension is $450,000.

4. Statutory Authority Permitting Other Than Full and Open Competition:

41 U.S.C. 3304(a)(1), as implemented by Federal Acquisition Regulation (FAR) 6.302-1, "Only one responsible source and no other supplies or services will satisfy agency requirements.".

5. Demonstration that the Contractor's Unique Qualifications or the Nature of the Acquisition Requires the Use of the Authority Cited:

Montech, Inc. is the incumbent contractor and is uniquely qualified to provide these uninterrupted services for the following reasons:

Prevention of Unacceptable Delays in Mission-Critical Work: The Personnel Security Program is an essential function that ensures only trustworthy individuals are granted access to classified information and facilities at the INL. A lapse in these services would create an immediate backlog in clearance processing and adjudication, directly impacting the INL's ability to staff critical national security missions. A new contractor would require a significant transition period to hire cleared staff, learn DOE-ID specific procedures, and gain proficiency in the required government security databases. This would cause unacceptable delays and disrupt ongoing operations.

Incumbent's Specialized Knowledge and Experience: Montech’s personnel possess extensive, in-depth knowledge of the DOE-ID security program, local procedures, and the specific needs of the INL population. They have established working relationships with federal employees and investigative agencies. Their expertise in applying complex adjudicative guidelines (e.g., DOE O 472.2, 10 CFR 710, IRTPA) to the INL workforce is critical for making consistent and defensible recommendations. This level of specialized experience cannot be immediately replicated by another source.

Security Clearance Requirements: The Statement of Work requires all contractor personnel to hold an active DOE "Q" clearance. Montech’s staff currently possess the required clearances. A new contractor would face a lengthy timeline, potentially exceeding one year, to obtain these clearances for their proposed staff. During this period, the new personnel would be unable to access the classified files and systems necessary to perform the work, rendering them ineffective and resulting in a complete stoppage of security processing functions. For a short-term, six-month bridge contract, it is impractical and unfeasible for a new source to meet this requirement.

Avoidance of Duplication of Costs: Awarding this short-term bridge to another source would result in a significant duplication of costs for the government. These costs would include the recruitment and training of new personnel and the loss of productivity during the extensive learning curve. The government would essentially be paying for a new team to gain the expertise that the incumbent, Montech, Inc., already possesses and applies effectively.

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable:

A notice of intent to award a sole-source modification will be published on SAM.gov in accordance with FAR 5.201. Due to the justifications outlined in Section 5—specifically the unacceptable delays and the time required for a new contractor's personnel to obtain "Q" clearances for a short-term requirement—soliciting offers for this six-month bridge action is not practicable. The primary purpose of this action is to prevent a break in service while the government prepares a full and open competition for the long-term follow-on requirement.

7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable:

The Contracting Officer will determine that the anticipated cost for this action is fair and reasonable. Costs will be negotiated based on the previously negotiated firm-fixed-price rates in the existing contract, which were determined to be fair and reasonable at the time of award. The government will conduct a price analysis of the independent government cost estimate and the contractor's proposal to ensure the final negotiated price for this extension is fair and reasonable.

8. Description of the Market Research Conducted and the Results:

Market research confirms that while other firms may exist in the marketplace that can provide security support services, no other source could meet the requirements of the SOW within the short transition period without causing a severe degradation of service. The primary barrier, confirmed by market research, is the mandatory DOE "Q" clearance requirement which takes a substantial amount of time to obtain and cannot be met by a new contractor in time to perform a six-month bridge contract without mission failure. Therefore, Montech, Inc. is the only responsible source capable of fulfilling the agency's needs without interruption.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition:

The work performed under this contract is integral to the Department of Energy's national security mission. Failure to provide seamless personnel security support would jeopardize the operational readiness and security posture of the Idaho National Laboratory. This six-month bridge contract is the most prudent course of action to ensure mission continuity while preserving the government's commitment to future competition.

10. Listing of Sources, if any, that Expressed an Interest in the Acquisition:

No other sources have expressed written interest in this specific requirement. Any interest expressed as a result of the synopsis will be evaluated.

11. Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition Before Any Subsequent Acquisition for the Supplies or Services Required:

This sole-source bridge contract is the action being taken to allow time for the agency to conduct a full and open competition for the long-term requirement of these services. This will ensure maximum competition is obtained for the subsequent acquisition.

Certifications and Reviews can be found on the next page…

12. Certification

The information contained in this Justification for Other than Full and Open Competition is certified accurate and complete to the best of my knowledge and belief.

X_________________ Carrie Hall Acquisition Initiator

X_________________ Jeffrey Fogg Contracting Officer

CARRIE HALL

Digitally signed by CARRIE

HALL

Date: 2026.06.24 13:20:01 -06'00'