Justification and Approval for Other than Full and Open Competition CompAdv_090926 SJsigned (1) (1) (2).pdf

SOLE SOURCE JUSTIFICATION UNDER FEDERAL SUPPLY SCHEDULE

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING

ACTIVITY

Department of State Contracting Activity

IX Acquisition Management

□ Foreign Service Institute

□ Office of Foreign Missions

□ U.S. Mission to the United Nations

□ Overseas Post

Requiring Activity GA/AM/PASS

SECTION 2: NATURE AND/OR DESCRIPTION OF THE ACTION BEING

APPROVED

GA requested to place a sole source, firm fixed unit price Federal Supply Schedule (FSS) order with Nakupuna Federal LLC (UEI PTH7Z5BD9GK5; CAGE 9HEC4) under GSA Multiple Award Schedule contract 47QTCA26D003Q. The order will acquire the professional services described in Section 3. This is a new procurement. The program seeks approval solely under the unusual urgency exception. Sections 4, 6, and 7 address the urgent circumstances, the market research supporting the proposed source, and the steps for restoring competition.

Requirement title: Federal Administrative and Operational Support Services.

NAICS / PSC: 541611 - Administrative Management and General Management Consulting Services / R707 - Support-Professional: Acquisition/Contracting

SECTION 3: DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET

THE AGENCY’S NEEDS

The order described in Section 2 will provide the Bureau of Global Acquisitions (GA) with professional support needed to sustain its acquisition and federal assistance operations while the Department conducts the replacement competition described in Section 7. The requirement consists of 65 contractor positions organized under ten task areas. Its principal purpose is classified under NAICS 541611 and PSC R707.

The ten task areas under the statement of work (SOW) collectively encompass the following principal service areas:

• Acquisition lifecycle and procurement advisory support, including acquisition planning, market research, solicitation and evaluation support, negotiation and award preparation, contract administration, closeout, and liaison support for Department customers and requirements owners.

• Federal assistance lifecycle and grant audit support, including pre-award due diligence and risk assessment, award preparation, administration, monitoring, financial report and audit review, Federal Audit Clearinghouse analysis, corrective action support, termination support, closeout, and funds reconciliation.

• Procurement and federal assistance policy, training, and acquisition workforce support, including regulatory impact analysis, policy and template development, audit analysis and response support, workforce certification support, compliance and case management analysis, and suspension and debarment support.

• Cost, price, accounting system, and audit support to contracting officers, including cost and price analysis, cost realism, DCAA coordination, forward pricing and indirect rate analysis, Cost Accounting Standards administration, accounting system adequacy analysis, analysis of audit findings, and support for Inspector General, GAO, and other oversight reviews.

• Program management, enterprise operations, human capital and training support, performance measurement, quality assurance, process improvement, and transition in and transition out services.

Performance requires access to Department facilities, systems, information, and, for designated positions, classified material. Some contractor personnel will require Secret or Top-Secret personnel security clearances. The contractor must maintain the Secret or Top- Secret facility clearance specified in the DD Form 254, as applicable. Because the work also involves procurement sensitive, proprietary, and source selection information, contractor personnel will be subject to applicable procurement integrity, nondisclosure, and organizational conflict of interest safeguards. Work will be performed principally at

Department facilities in Arlington, Virginia, and Charleston, South Carolina, with Government approved remote work when consistent with security, operational, and contract requirements.

The services will augment, but will not replace, Government decision making authority.

Contractor personnel may prepare analyses, draft documents, develop recommendations, and provide administrative and operational support. They will not sign awards or modifications, obligate Government funds, or make final source selection, responsibility, award, termination, or federal assistance decisions. Contractor personnel will not serve as contracting officers, grants officers, source selection authorities, make policy decisions, or supervisors of federal employees.

The contractor will remain responsible for recruiting, assigning, directing, managing, and supervising its employees. All discretion, judgment, and authority associated with inherently governmental functions will remain with authorized federal officials.

The period requested of performance and approval amount are as follows:

Base period: September 16, 2026 through March 15, 2027.

Base-period estimated value: $7,487,183.60.

Potential FAR 52.217-8 extension: Two 6-month option periods from March 16, 2027 through September 15, 2027, and 2nd periods from September 16, 2027 through March 15, 2028.

Maximum extension estimated value: $15,157,336.40.

Maximum potential value (18-month performance): $22,866,716.40

SECTION 4: AUTHORITY AND SUPPORTING RATIONALE

Authority: This action is an order under the Multiple-Award Federal Supply Schedule Program. The Department's FAR Part 8 class deviation adopts RFO FAR 8.401, which directs ordering activities to follow the FSS procedures in GSAR 538.71. GSAR 538.7104- 3(b)(1)(i) permits an FSS order above the simplified acquisition threshold to be placed on a sole source basis when the need is of such unusual urgency that following the competitive Schedule procedures would result in unacceptable delay. The statutory basis is 41 U.S.C.

3302(c)(1)(A)(i), which incorporates the order level urgency exception in 41 U.S.C.

4106(c)(1).

Development of the urgent need: In mid-July 2026, the Department determined that the remaining viable option periods on existing contractor coverage for these functions would end on September 16, 2026, even though GA's need for substantially increased acquisition and federal assistance support would continue. The coverage gap emerged during an agency-wide restructuring involving retirements and other workforce departures. The number and timing of the retirements exceeded the agency's projections, reducing the federal workforce available both to execute the existing workload and to absorb the functions supported by the expiring coverage. At the same time, the integration of former USAID procurement and assistance functions changed the volume and distribution of work that GA must support.

Until the actual workforce losses and workload effects became known, the Department could not reasonably define the revised requirement for 65 contractor positions or the associated skill mix.

Government response and required start: Once the coverage risk was confirmed, the Department defined the revised requirement and conducted focused market research from August 1 through August 6, 2026. Beginning performance on September 16 provides allows continued work at the same level of effort required for critical GA support services. Staffing reductions also limited the personnel available to identify and address the coverage issue. That circumstance contributed to the compressed response, but it is not the basis for the requested exception. The exception rests on the unforeseen magnitude and timing of the workforce reduction and the resulting risk of a service interruption, not on expiring funds or administrative convenience.

Operational consequences of delay: GA supports an annual portfolio of approximately $12 billion through about 25,000 procurement transactions and approximately $4.7 billion through about 1,200 federal assistance awards. Fewer than 300 federal employees support this workload. The integration of former USAID functions is expected to add approximately $3 billion to $4 billion in annual procurement and assistance activity. The September coverage deadline also falls during the end of fiscal year period, when acquisition and assistance offices must process a high concentration of time sensitive awards, modifications, funding actions, proposal and cost analyses, audit and compliance responses, administrative actions, and closeouts. Contractor personnel will not make final decisions or obligate funds, but warranted federal officials rely on the requested analytical, drafting, systems, and administrative support to process this volume of work within required timeframes.

A lapse in coverage would remove the supporting capacity associated with 65 positions at the point of highest operational demand. The immediate result would be delays in preparing, reviewing, and administering procurement and federal assistance actions. Those delays would affect domestic and overseas programs involving information technology, professional services, diplomatic security support, real property, and foreign assistance.

Because bureaus and posts worldwide depend on these actions to execute mission requirements, the disruption would extend beyond GA and could increase operational and personnel safety risks for U.S. activities abroad as well as endanger the nation’s political activities abroad. The immediate harm would not only be the loss of mission support capacity during a critical period but also the greater impact to US personnel worldwide and US foreign policy.

Why competition would cause unacceptable delay: GSAR 538.7103-3 ordinarily requires an acquisition above the simplified acquisition threshold to be competed by publishing an RFQ on GSA eBuy or issuing an RFQ to enough Schedule contractors to reasonably ensure receipt of at least three quotations. Every quotation received in response to the RFQ must be fairly considered. A responsible competition for this 65 position, $22,866,716.40 million professional services requirement would require the Department to complete the solicitation package, provide a meaningful quotation period, evaluate technical capability and total price, document the award decision, verify facility and personnel clearances, confirm staffing commitments, provision Government equipment and systems access, transfer active work, and complete transition activities. The 26 days available after market research concluded are insufficient to complete those steps. Only 16 calendar days of concurrent coverage are available for transition. A competition initiated after August 6 could not produce an award and an operational contractor in time to begin transition on September 1 or maintain continuity after September 16.

Why the proposed source can meet the urgent need: As documented in Section 6, the market research identified Nakupuna Federal LLC as the only Schedule source able to satisfy the complete revised requirement within the available time. The company holds MAS contract 47QTCA26D003Q and NAICS code 541611. The Department verified the entity's relevant experience; facility security clearance; access and clearance posture for proposed personnel; available staffing; familiarity with Department systems and operating requirements; and ability to mobilize for the September 1 start. The Department also verified its ability to maintain the critical functions covered by this justification when existing coverage ends on September 16. Based on these capabilities the agency concluded that Nakupuna Federal LLC is ideally suited for this sole source award.

Transition and duration: While continuity of services is in progress, the contractor must submit its transition in plan within two days after award and complete the planned transfer of active work, access validation, orientation, and related transition activities during that period. The proposed source's verified mobilization approach supports continuity of the critical acquisition and assistance functions when existing coverage ends. The 12 month base period is limited to the time needed to maintain support while the Department conducts and transitions to the replacement competition described in Section 7. The potential FAR 52.217-8 extension, from September 16, 2027 through March 15, 2028, may be exercised only if additional time is needed to complete that competition or transition and prevent another lapse. Its estimated value is included in the approval amount and will be evaluated with the base requirement. This justification does not support performance beyond the six month extension.

SECTION 5: DETERMINATION BY THE ORDERING ACTIVITY

CONTRACTING OFFICER THAT THE CONTRACT ACTION REPRESENTS THE

BEST VALUE CONSISTENT WITH FAR GSAR 538.7102-2(B)(4)

The Contracting Officer has determined the anticipated contract action will represent the best value based on the Contracting Officer’s plan to follow the procedures in GSAR Subpart

538.71. Although approval is requested to contract with one source, the Contracting Officer will not award the planned contract action unless the Contracting Officer evaluates and determines that the resultant price is reasonable.

SECTION 6. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED

AMONG SCHEDULE HOLDERS AND THE RESULTS OR A STATEMENT OF

THE REASON MARKET RESEARCH WAS NOT CONDUCTED

To determine whether another contractual vehicle or Schedule source could meet the compressed schedule described in Section 4, the GA requiring activity and acquisition personnel conducted focused market research from August 1 through August 6, 2026. The team reviewed more than 100 existing Department professional services contracts and IDIQ vehicles and conducted an external review of Schedule contractors holding NAICS code 541611. The objective was to identify a source that could begin transition on September 1 and maintain critical service continuity after existing coverage ends on September 16.

The review considered the actual contractual scope of each existing vehicle. Each potential offeror was evaluated against the principal purpose and complete scope of the revised SOW, facility and personnel security requirements, relevant experience, immediate staffing availability, systems and onboarding requirements, and ability to meet both transition deadlines.

The existing Department vehicles did not provide a viable solution to the immediate need.

Some lacked contractual scope and ceiling to cover the principal purpose and integrated workstreams of the revised SOW. Other potential sources lacked one or more capabilities necessary for timely performance, including applicable Schedule coverage, required security access, relevant Department and functional experience, immediately available staff, or a feasible mobilization plan. The external Schedule review likewise found no other NAICS code 541611 contractor that could satisfy the complete requirement and meet the September 1 and September 16 deadlines without unacceptable delay.

The research confirmed that Nakupuna Federal LLC under MAS contract 47QTCA26D003Q and NAICS code 541611 was the ideal choice. The Department verified the entity's security posture, staffing availability, relevant experience, familiarity with Department systems and processes, and mobilization capability. Considering scope, security, staffing, experience, and schedule together, Nakupuna Federal LLC was the only Schedule source found capable of meeting the complete urgent need within the appropriate period. This conclusion is limited to the present deadlines. If more time for normal competition and transition were available, other Schedule firms would be viable options. However, there is not adequate time to pursue normal competition and consider these options.

SECTION 7. STATEMENT OF THE ACTIONS, IF ANY, THE

AGENCY MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS THAT

LED TO THE RESTRICTED CONSIDERATION BEFORE ANY

SUBSEQUENT ACQUISITION FOR THE SUPPLIES OR SERVICES IS MADE

SECTIONS 8. CERTIFICATIONS

The unusual urgency addressed by this justification is temporary. The proposed order is not intended to displace competition beyond the time needed to maintain services, conduct a responsible competition, and complete transition to the replacement contractor.

The Department will compete the replacement as a firm-fixed-price small-business set-aside among eligible GSA Schedule contractors under the Department's FAR Part 8 class deviation and GSAR 538.7102-2(c)(1) and 538.7103-3. The 6-month base period allows time to complete the competition, security processing, onboarding, knowledge transfer, and transition. The acquisition team will manage to the following target milestones:

• September 2026: validate requirements, refine the SOW, and update market research;

• September/October 2026: complete small business coordination, prepare the RFQ, and establish the evaluation approach;

• No later than October 2026: issue the competitive RFQ to eligible Schedule small businesses;

• October/November 2026: receive and evaluate quotations, conduct exchanges as needed, and complete price and award documentation;

• No later than December 2026/January 2027: award the replacement order; and

• January 2027: complete security, onboarding, knowledge transfer, and transition before the base period ends on March 15, 2027

The requiring activity and contracting office will review these milestones and relevant staffing forecasts at least monthly. Schedule risks will be elevated early enough to permit corrective action before another coverage lapse occurs. The FAR 52.217-8 extension may be exercised only if continued coverage remains necessary to complete the replacement competition or transition despite reasonable adherence to this sched

TECHNICAL AND REQUIREMENTS CERTIFICATION (FAR 6.104(b)) I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

Technical Cognizance:

SIGNATURE:

/S/ 8/18/2026

Abdulaziz Yousuf Date Audit Manager

Technical Cognizance:

/S/ 8/18/2026

Abdulaziz Yousuf Date Audit Manager

LEGAL SUFFICIENCY

This J&A is hereby determined to be legally sufficient.

SIGNATURE:

John W Cox Date: 2026.09.08 08:47:34 -04'00' Digitally signed by John W Cox

CONTRACTING OFFICER CERTIFICATION (FAR 6.104-1(a)(12)) I certify that this submission is accurate to the best of my knowledge, and that it contains complete information necessary to enable other officials to make an informed recommendation for approval or disapproval.

Digitally signed by Stephanie E

Stephanie E Fugate Fugate Date: 2026.09.08 08:59:09 -04'00'

Contracting Officer Bureau of Global Acquisitions

SS

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A p T h

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E n ie E Fugate

Date: 2026.09.08 09:06:01 -04'00' Digitally signed by Stephanie E Fugate

Stephanie Fugate Acting Office Director

SECTION 9. APPROVALS

COMPETITION ADVOCATE

SIGNATURE:

Digitally signed by Anna Urman Date: 2026.09.09 15:19:08 -04'00'

Trena Mills Bureau of Global Acquisition

HEAD OF THE CONTRACTING ACTIVITY

SHARON D Digitally signed by

SHARON D JAMES

JAMES Date: 2026.09.10 16:19:50 -04'00'

Sharon James Date