JOFOC_MCMS_2025_redacted_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

AUTHORITY: FAR 6.302, 41 U.S.C. 3304

SOL # 140D0425Q0092

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by FAR 6.3 and in accordance with the requirements by FAR 6.303-1, the justification for the use of the statutory authority under FAR 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

This document is a justification for other than full and open competition for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division 1, Branch 2, on behalf of the DOI Office of the Secretary, Office of Acquisition and Property Management, Interior Museum Program (IMP).

2. Nature and/or description of the action being approved.

Following two years of configuration and migration of the Museum Collection Management System (MCMS), DOI is looking to award a sole-source contract to continue to provide technical support, training, cloud hosting, and additional migration services. Gallery Systems is the only source for licenses of the existing software configured under DOI Task Order 140D0422F0740 which expires on March 31, 2025.

The requirement will be sole sourced to the current owner of the Software as a Service (SaaS) that is the basis of MCMS.

Gallery Systems 111 Broadway, Suite 502 New York, NY 10006

3. A description of the supplies or services required to meet the agency’s needs

(including the estimated value).

The services required to meet the agencies requirement are to provide any licenses, provisioning, and maintaining the cloud environment services to host the MCMS software, The Management System (TMS) Collections, and the MCMS database. The requirement contains the following requirements:

• FedRAMP Authorization must be maintained.

• Provide ongoing support and maintenance of the software.

• Provide ten live virtual training sessions for new users.

• Execute data migration of data still stored in legacy system.

• Work with DOI to identify and provides estimates to implement additional functionality.

The Contracting Officer (CO) intends to establish a single award contract with a 12-month base period and four 12-month option periods with an estimated total value of $4,157,254.67 with the following period of performance.

Base Period: April 1, 2025 (begins on date of award) Option Period 1: April 1, 2026 – March 31, 2027 Option Period 2: April 1, 2027 – March 31, 2028 Option Period 3: April 1, 2028 – March 31, 2029 Option Period 4: April 1, 2029 – March 31, 2030 FAR 52.217-8 (est): April 1, 2030 – September 30, 2030

4. An Identification of the statutory authority permitting other than full and open competition.

This is an acquisition conducted under the authority of FAR 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. 41 U.S.C. 3304(a)(1).

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The base product is built on TMS Collections, a proprietary SaaS product owned by Gallery Systems, which is the only FedRAMP system that meets the programs requirements. As the owner of TMS Collections, Gallery Systems is the only provider that has the necessary knowledge and experience to support its proprietary software. The configuration of the software to meet MCMS requirements was largely completed and only minor adjustments remain. The previous vehicle with IBM assisted Gallery System in getting their FedRAMP certification, however IBM’s assistance is no longer required and the Government can go directly to Gallery Systems, the product owner.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies.

To ensure that offers are solicited from as many potential sources as practicable, a requirements notification was posted to System for Award Management (SAM) on November 19, 2024 to allow the program office an opportunity to examine the results of industry inquiries and reach a conclusion concerning the potential degree of competition. There were no responses received within 15 days.

7. A determination by the contracting officer that the anticipated cost to the

Government will be fair and reasonable.

The contracting officer determines that the anticipated discounted price(s) will be fair and reasonable based on comparisons with current market prices and the existing FCHS1 Task Order, which provides three years of pricing data.

8. A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

AQD conducted market research by reviewing the acquisition history of the existing order 140D0422F0740 and information from similar recently awarded AQD contract actions. The review of the acquisition history of the current task order concluded that it was competed under the DOI Foundation Cloud Hosting Services (FCHS) Indefinite Delivery/Indefinite Quantity (IDIQ) contracts which consists of eight large businesses. This was a mandatory vehicle for cloud hosting requirements at the time. It was also determined that these are commercially available services and TMS SaaS software is commercially available cloud product. No other products in the commercial environment that has the required capabilities are FedRAMP authorized.

The previous order was successful in its implementation. The Government’s experience with the software owner demonstrated they no longer needed a large business to be a Prime Contractor. Additionally, FCHS2, the successor to FCHS, is not a mandatory source allowing DOI to pursue a direct contract with the software provider.

9. Any other facts supporting the use of other than full and open competition;

such as:

The estimate of the cost to the Government to implement a different system would be a minimum of $7 million which would include sponsoring a new vehicle for FedRAMP certification and configuring it for MCMS requirements. This is based off of the fact that we would have to duplicate efforts that were completed over the past two years.

10.A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

No responses were received.

11.A statement of any 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.