DEPARTMENT OF WAR

WASHINGTON HEADQUARTERS SERVICES

1155 DEFENSE PENTAGON

WASHINGTON, DC 20301-1155

JUSTIFICATION FOR

OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

ACQUISITION DIRECTORATE

WHS-2026- 2178-JA

UNDER FEDERAL ACQUISITION REGULATION FAR SUBPART 6.103

1. AGENCY AND CONTRACTING ACTIVITY: The Department of War (DoW), requiring Agency is the Defense Security Cooperation Agency (DSCA), Ted Stevens Center for Arctic Security Studies (TSC). The contracting activity is Washington Headquarters Services (WHS), Acquisition Directorate

(AD).

2. DESCRIPTION OF ACTION: WHS/AD is awarding a sole source contract to the incumbent contractor, ACT1 Federal LLC (ACT1), for a follow-on contract for support services and technical assistance to the TSC. This will be a hybrid firm-fixed price, time and materials contract that will be funded with Fiscal Year (FY) 2026 funding.

3. DESCRIPTION OF SUPPLIES/SERVICES: This requirement is for support services and technical assistance for the TSC at TSC’s offices and other sites as designated by program needs. Unless otherwise specified, support will take place at the TSC, 8414 McGuire Ave., Joint Base Elmendorf-Richardson, Anchorage, Alaska. The technical, academic, logistical, and administrative support services will support the TSC mission, including the development and execution of seminars, conferences, symposia, and other academic events as well as extended and quick-turnaround analytical research materials as defined in the Performance Work Statement (PWS). The Period of Performance (PoP) will be per the table below:

Performance Periods Performance Period Dates Amount Base Period 28 Sep 2026 - 27 Sep 2027 $ Option Period I 28 Sep 2027 - 27 Sep 2028 $ 6-month extension IAW 52.217-8 28 Sep 2028 – 27 Mar 2029 $ Base + All Options 28 Sep 2026 – 27 Mar 2029 $

4. AUTHORITY CITED: This sole source action is authorized under regulatory authority FAR 6.103-1

(c)(2).

5. REASON FOR AUTHORITY CITED: The uninterrupted continuation of services by ACT1 is critical during the Ted Stevens Center for Arctic Security Studies’ (TSC) and the Asia-Pacific Center for Security Studies’ (APCSS) transition toward Full Functional Capacity (FFC). FFC is the operational state where TSC and APCSS possess the permanent staff, IT infrastructure, cybersecurity posture, and workflows needed to independently execute 100% of their regional security cooperation missions without temporary build-out support. Disrupting ACT1’s support during this Pre-FFC phase, stand-up window where critical IT baselines and cloud environments are actively deployed and integrated, would jeopardize operational capability deadlines currently fulfilled by ACT1 under its incumbent contract, which expires on September 29, 2026. Additional rationale justifying this sole source award is below.

Severe Network & Security Risks: ACT1 is currently migrating TSC from an Impact Level 4 (IL4) to an Impact Level 2 (IL2) GovCloud system. Transitioning to a new vendor at this time would disrupt this delicate build and authorization pipeline. A new vendor's lack of historical network knowledge risks revocation of the Authority to Connect (ATC) from the Joint Base Elmendorf-Richardson (JBER) network, potentially disconnecting the TSC completely.

Substantial Duplication of Taxpayer Costs: Due to TSC's small, non-redundant IT and administrative infrastructure, transitioning to a new contractor would result in a lengthy phase-in period with parallel operations. The program office estimates this transition would result in $ million in unrecoverable, duplicated taxpayer costs.

The timeline required to fund, audit and execute this dual-yielding transition phase directly delays the immediate fulfillment of urgent DSCA requirements. The duplicated transition costs would not be recovered through the competitive process. The $ million in unrecoverable duplication of costs represents the minimum mandatory dual-operating window required to prevent a total mission blackout.

Of the estimated duplication costs, $ million reflects 3 months of ACT 1 support to transition a complex, active IT system and maintain 100% of steady-state operations including ongoing and planned mission events. Simultaneously, $ during the 3 months, reflects paying a new, incoming, contractor to onboard and undergo background checks, system familiarization, and training before full performance can start. Compressing this 3-month transition window introduces operational risk, including critical system failures and event cancellations.

Moreover, transitioning to a new vendor would create a 3-to-6-month project delay and add an estimated $ per month in duplicative IT support costs during the transition. A new contractor cannot inherit or assume administrative liability for the existing DSCA system and environmental security posture without DSCA performing a comprehensive re-evaluation of the security architecture. While Authorization to Operate (ATO) work will technically continue, this transition resets the Risk Management Framework timeline, delaying final ATO approval by 3 to 6 months. To prevent a total IT blackout during this transition, the Government would need to fund a dual-contractor footprint. This means continuing to pay ACT1 an estimated $ per month to keep the ATO work and Authority to Connect (ATC) while paying a new prospective contractor to get up to speed.

6. EFFORTS TO OBTAIN COMPETITION: As required by FAR 5.201, synopsis was a Notice of Intent to Sole Source (NOI to SS) was posted on July 24, 2026, via www.SAM.gov. In response to the NOI to SS, one (1) contractor submitted a response. The response was reviewed and DSCA’s findings are summarized in market research paragraph below.

7. FAIR AND REASONABLE COST DETERMINATION: I determine that the anticipated price for this contract action will be fair and reasonable. The techniques identified in FAR 15.404-1(b) will be used to ensure award will be at fair and reasonable prices. Formal pricing for the follow-on contract will be obtained from the incumbent contractor.

8. MARKET RESEARCH: A market research report was completed in May 2026. Based on historical data and an internet query, ACT1 Federal, LLC was identified by DSCA as a qualified employee stock ownership plan (ESOP) employee-owned business and potential supplier for the (sole-source) follow-on contract under provisions of 10 U.S.C. 2304(c) 6.302-5 Authorized or required by statute and DFARS 252.270-7002 Pilot Program to Incentivize Contracting with Employee-Owned Businesses. The Agency submitted an ESOP Pilot award application package was submitted to DPCAP/CP on May 18, 2026, to further determine eligibility. After various exchanges with DPCAP Senior Procurement Advisors, from DPCAP/CP POC, it was verbalized and noted that there was no guarantee the application would receive approval before September 30th thus putting the requirement at critical risk. Moreover, a delay in receiving Defense Pricing, Contracting, and Acquisition Policy, Contract Policy Directorate (DPCAP/CP) approval of ACT1’s ESOP Application would put the subject contract solicitation and award at risk and negatively impact TSC’s mission.

Finally, a System for Award Management (SAM) NOI to SS was posted on July 24, 2026, and the notice closed on July 30, 2026, with one (1) response or capability statement received from Dexis Professional Services LLC. DSCA reviewed the response from Dexis and identified three major risks based on the submission and their experience with Dexis, who currently implements DSCA’s Global Assessment, Monitoring, and Evaluation (GAME) contract. Based on DSCA’s review, there were three (3) major risks identified: Academic Continuity Delay, Potential Catastrophic Network Disconnection and Duplication of costs. Dexis specializes in high-level policy education with tactical training and lacks academic curriculum development experience. The program office estimated this would result in a minimum six (6) month delay in completing academic products threatening TSC’s ability to meet its congressionally mandated deadlines. Dexis lacks experience managing standalone Information Systems and Government Commercial Cloud (GCC) environments. Because TSC has a small, non-redundant IT department, any contractor learning curve or compliance error directly threatens their Authority to Operate (ATO) and risks revocation of the network Authority to Connect (ATC) from Joint Base Elmendorf-Richardson (JBER). The program office estimated $ million in duplicated transition costs required to simultaneously maintain the current operations while phasing in a new contractor.

9. OTHER FACTS: N/A

10. INTERESTED SOURCES: ACT1 Federal, LLC (Incumbent) is an interested source. Also, Dexis

Professional Services, LLC submitted a response in reply to the posted NOI to Sole Source.

Vendor Name Location Point of Contact Capability Assessment

ACT1 Federal, LLC 62C27

Arlington, VA

This is the incumbent contractor.

Dexis Professional Services, LLC

7PN98

Arlington, VA

The contractor was determined not capable due to academic, technical and transition risks.

11. ACTIONS TO INCREASE COMPETITION: The DSCA will continue to assess market research to ensure it remains current with Department of War (DoW) standards. DSCA will monitor the market for other potential sources to increase future competition for this requirement and any associated services.

12. Is this acquisition for a non-competitive follow-on acquisition previously awarded on a non-competitive basis?

☒Yes. A copy of the previous justification is attached. The actions to remove any barriers to competition cited on the previous justification ☒ were ☐ were not completed.

☐ No. The original acquisition was conducted on a competitive basis.

☐ Not Applicable. This is a new requirement.

CERTIFICATION

I, hereby, certify that the supporting data under my cognizance included in this justification are accurate and complete to the best of my knowledge and belief.

APPROVAL

This justification is approved.

, Competition Advocate Date