Justification and Approval (JA) - RightDirection IDIQ - 19AQMM20D0138.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING

ACTIVITY

Department of State Contracting Activity

Acquisition Management Foreign Service Institute Office of Foreign Missions U.S. Mission to the United Nations Overseas Post

Requiring Activity

Ceiling increase for IDIQ 19AQMM20D0138 RightDirection Technology Solutions Human Resource Bureau (HR), formerly PERT

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

APPROVED

Approval is requested to modify the ceiling of IDIQ 19AQMM20D0138 to RightDirection Technology Solutions, LLC, located at: 300 E Lombard St, Ste 840, Baltimore, MD 21202;

for the supplies and/or services described in Section 3 on behalf of the Requiring Activity.

Offered to the 8(a) program – September 27, 2020 Acceptance provided by SBA’s District Office on September 27, 2020 IDIQ Contract # 19AQMM20D0138 SBA Requirement #: 0373/20/ZA1600008305Z Last day for current J&A: March 27, 2026

The requested modification will increase the IDIQ ceiling by $1,200,000.00, from $4,000,000.00 to $5,200,000.00 due to an increase in estimated hours under the Task Orders necessary to address evolving operational needs. This is an IDIQ for Administrative Services (Time and Materials (T&M)/Labor Hour).

This modification is solely to increase the contract ceiling from $4,000,000 to $5,200,000.

This increase is necessary to allow the continuation of critical administrative services through current open four (4) task orders issued in this IDIQ ending on September 18, 2026, ensuring uninterrupted support while the Department conducts a full and open competition for a follow-on contract before September 18, 2026. No changes to the scope of work, period of performance, or terms and conditions are being made to the IDIQ.

SENSITIVE BUT UNCLASSIFIED

SECTION 3: DESCRIPTION OF SUPPLIES/SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS

The Department of State requires ongoing administrative support to maintain uninterrupted operations for the Bureau of Human Resources front office. Support includes program management, clerical assistance, data entry, records management, and related administrative functions.

SECTION 4: IDENTIFICATION OF THE STATUTORY AUTHORITY PERMITTING

OTHER THAN FULL AND OPEN COMPETITION

This acquisition is conducted under the authority of 41 USC 3304, as implemented by FAR 6.103 and substantiated by the following:

FAR 6.103-2 – Unusual and compelling urgency.

SECTION 5: DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S

UNIQUE QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES

USE OF THE AUTHORITY CITED

RightDirection Technology Solutions, LLC is uniquely qualified to provide these services based upon the following:

a. Experience and Knowledge:

RightDirection Technology Solutions, LLC has provided consistent, high-quality administrative support under the current IDIQ. Their personnel possess the required security clearances, institutional knowledge, and familiarity with Department of State processes and systems.

b. Unusual and Compelling Urgency:

The current contract ceiling will be reached before the end of the required period of performance. Without this ceiling increase, there will be a lapse in critical administrative services, which would disrupt essential Department operations. The requested ceiling increase is strictly limited to the amount necessary to maintain uninterrupted service through September 18, 2026. This extension is critical to allow the Bureau sufficient time to complete a new competitive contract, therefore allowing sufficient time for a thorough process before the end of FY26.

SECTION 6. DESCRIPTION OF EFFORTS TO ENSURE THAT OFFERS WERE

SOLICITED FROM AS MANY POTENTIAL SOURCES AS IS PRACTICABLE,

INCLUDING WHETHER A NOTICE WAS OR WILL BE PUBLICIZED AS

REQUIRED BY FAR SUBPART 5.2 AND, IF NOT, WHICH EXCEPTION UNDER

FAR 5.201 APPLIES

Per FAR 5.201 – EXCEPTION 5.202(4) Small Business Administration (SBA) using the authority of the Section 8(a) of the Small Business Act. The local small business office provided approval to modify the contract as requested with no change is scope, to be exercised by the “Procurement Contracting Officer”. This approval was granted on 03/12/2026. Approval letter on file.

SECTION 7. DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT IS FAIR AND REASONABLE

The Contracting Officer has determined the anticipated $1,200,000.00 to the Government of the services covered by this J&A will be fair and reasonable based on the proposed labor rates and level of effort estimated by the requestor for the remaining period of performance for the Task Orders. The proposed additional level of effort was reviewed in the form of an IGCE in consultation with the technical team and found to be realistic and appropriate for meeting the Governments’ requirements. No changes to the hours or new labor categories were added. The cost structure reflects a reasonable relationship between the current labor mix, hours, and the technical approach. Nothing changed. This is the best value to the Government given the circumstances.

SECTION 8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED (SEE

PART 10) AND THE RESULTS OR A STATEMENT OF THE REASON MARKET

RESEARCH WAS NOT CONDUCTED

No additional market research was conducted for this action because the modification is strictly limited to increasing the ceiling of the existing IDIQ contract. The scope of work, period of performance, and contract terms remain unchanged. The purpose of this increase is to allow the continuation of services through September 18, 2026, ensuring uninterrupted support while providing sufficient time to conduct a new recompete process before the end of FY26. As no new requirements or changes to the nature of the work are being introduced, further market research was not warranted for this modification.

SECTION 9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER

THAN FULL AND OPEN COMPETITION

The original contract was competed under the 8(a) program as a sole source. This justification is not for a new requirement, but solely to increase the contract ceiling only to allow the current contractor to continue providing essential services until September 18, 2026. This will prevent a disruption in mission-critical support and provide the necessary time to conduct a full and open competition for a new contract before the end of FY26. Attempting to re-compete the requirement immediately would risk a gap in service and would not allow for a thorough and competitive procurement process.

SECTION 10. LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN

WRITING, AN INTEREST IN THE ACQUISITION

To date, no other sources have written to express an interest in this acquisition.

This action is limited to increasing the ceiling of the existing IDIQ contract with RightDirection Technology Solutions, LLC. No new solicitation or market research was conducted, as the scope and contractor remain unchanged. No additional sources were contacted or considered for this modification.

SECTION 11. STATEMENT OF THE 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

The Department is committed to full and open competition for future requirements. The requested ceiling increase is a temporary measure to ensure continuity of service while the Department prepares and executes a new competitive procurement. The recompete process is expected to be completed before the end of FY26, with the new contract in place immediately following the expiration of the current IDIQ on September 18, 2026.