Justification and Approval-Janus Transition Contract-Redacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY

Department of State Contracting Activity

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

Requiring Activity Diplomatic Technology/Enterprise Infrastructure/Network Technologies/Installations Division

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

Approval is requested to solicit and award a base year and three option years IDIQ contract to ensure completion of ongoing work of the Janus III and Janus IV programs, program management support and identified new work on behalf of Diplomatic Technology/Enterprise Infrastructure/Network Technologies/Installation Division (DT/EI/NT/ITL) to AT&T Technical Services Company’s (AT&T), the incumbent contractor.

This action will enable DT to complete projects of the Janus IV program (task order 19AQMM21F0420) and Janus III program (task order SAQMMA14F1811) issued under AT&T’s Connections II Contract (GS00Q12NSD0004), which expires on January 18, 2026, to support the ongoing vital services for Overseas Buildings Operations (OBO), new construction projects, embassy and consulate telecommunications systems, Information Processing Center (IPC) OpenNet and ClassNet relocations, and the installation of Transport Only Network (TrON) infrastructure. AT&T has been providing these critical services under the previous contract and possesses the institutional knowledge and expertise necessary to ensure seamless continuity of operations. This approach will enable the Department to continue support while working towards awarding a competitive follow-on contract, ensuring long-term cost-effectiveness and operational efficiency.

This sole-source contract is essential for meeting congressionally mandated schedules and maintaining the functionality of critical embassy and consulate telecommunications systems, including telephone systems, Microsoft (MS) Teams phone systems, Enterprise Wi-Fi, and critical cabling infrastructure impacting life safety, as well as establishing OpenNet and ClassNet systems at new embassy facilities.

Janus III - SAQMMA14F1811 and Janus IV - 19AQMM21F0420 are task orders that were issued against the General Services Administration’s (GSA) Connections II Governmentwide Acquisition contract (GWAC) which expires on January 18, 2026. GSA has mandated that all funds obligated against any Connections II task order must be fully accounted for by that date. GSA did not effectively communicate this limitation when the Janus IV task order was awarded. This sole source definitive contract will continue work set forth in the current Janus III and Janus IV task orders and identified new work until the new competitive contract is awarded.

These ongoing modernization efforts improve responsiveness, increase safety, and deliver significant value by optimizing productivity, bolstering security, and positioning the Department to thrive in a dynamic and more prosperous global environment. These services are indispensable for ensuring effective communication, secure network operations, and the overall functionality of U.S. embassies worldwide.

Diplomatic Technology/Enterprise Infrastructure/Network Technologies/Installation Division (DT/EI/NT/ITL) (ITL) is naming the follow-on “Janus Transition Contract”, as the logical follow on to Janus III and Janus IV task orders.

SECTION 3: DESCRIPTION OF SUPPLIES/SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

The Janus Transition Contract will require the contractor to complete ongoing projects by providing turn-key integrated multi-vendor original equipment manufacturer (OEM) worldwide telecommunication solutions and support expanded projects on short notice. Key program requirements include:

• Voice/Telephone and Teams Phone System (TPS) Solutions: Provision of hardware, software, and associated services (e.g., site surveys, acquisition, site preparation, engineering, equipment configuration, delivery, installation, training, and maintenance) to replace or upgrade current systems at existing posts and install new systems at new posts.

• Telecommunication Infrastructure Services (cabling): Provision of hardware and associated services to install, upgrade, or remediate telecommunication infrastructure at posts. Known by the Department as Information Technology Infrastructure Remediation (ITIR).

• Information Program Center (IPC) Relocation Services: Integrated relocation of IPC telecommunication equipment and services, including site surveys, acquisition, site preparation, engineering, equipment configuration, delivery, and installation.

• Wi-Fi Solutions: Provision of Enterprise Wi-Fi hardware, software, licensing, and associated services to install, upgrade, or remediate Wi-Fi systems at posts.

• Transport Only Network (TrON) Solutions: Provision of TrON hardware, software, licensing, and associated services to install, upgrade, or remediate TrON infrastructure at posts.

• Distributed Antenna Services (DAS): Provision of hardware, software, and associated services to install, upgrade, or remediate DAS service at posts.

• Telecommunication Services: Provision of hardware, software, and associated services to install, upgrade, or remediate telecommunication service at posts.

• Spare Parts Provisioning: Supply of spare parts to support the maintenance and functionality of systems.

• Engineering and Maintenance Support: Ongoing engineering support, troubleshooting, and maintenance for current and legacy systems.

The critical requirement is to continue support provided under Janus III and Janus IV task orders (Construction projects, embassy and consulate telecommunications systems, IPC relocation, Enterprise Wi-Fi, ITIR, and TrON installations.) These modernization efforts improve responsiveness, increase safety, and deliver significant value by optimizing productivity, bolstering security, and positioning the Department to thrive in a dynamic and more prosperous global environment. Each discipline plays a vital role in ensuring the Department meets its operational, safety, and congressional mandates.

The contractor will support the program areas listed below:

1. Janus IV Program Support Personnel:

o Janus IV tasks involve specialized project management, technical expertise, and operational support for ongoing initiatives critical to the Department’s mission. These tasks include managing complex workflows, coordinating with stakeholders, and ensuring compliance with federal regulations and standards. The vendor’s familiarity with Janus IV ensures seamless continuity and avoids delays in mission-critical activities.

2. OBO New Construction Projects:

o OBO is responsible for the design, construction, and maintenance of U.S. diplomatic facilities worldwide. This contract supports OBO’s new construction telecommunications projects, ensuring compliance with congressionally mandated schedules while upholding high standards for safety, security, and functionality.

o The scope of the contract includes the installation of essential telecommunications infrastructure, such as:

Telephone Systems MS Teams Phone Systems Wi-Fi Networks IPC Relocation to facilitate the deployment of OpenNet and ClassNet systems o These services are critical to enabling seamless communication, secure network operations, and the overall effectiveness of new embassy facilities.

3. Embassy Telecommunications Systems:

o Embassy telecommunications systems are the backbone of communication and operations at

U.S. embassies. This contract supports the installation, maintenance, and enhancement of critical systems, including:

Telephone Systems: Ensuring reliable voice communication for diplomatic and administrative functions.

MS Teams Phone Systems: Supporting modern, cloud-based communication platforms for collaboration and coordination across global missions.

Wi-Fi Networks: Providing secure and high-speed wireless connectivity for embassy personnel and operations.

Critical Cabling Infrastructure: Maintaining and upgrading cabling systems that support telecommunications, IT networks, and life safety systems, such as fire alarms and emergency communication.

Distributed Antenna Services (DAS):Providing enhanced signal coverage and reliability within embassy facilities, supporting critical communication needs.

4. Information Processing Centers (IPC) Relocation Addressing OpenNet/ClassNet Stand-Up:

o The relocation of IPCs and the establishment of OpenNet/ClassNet systems are essential for embassy telecommunications operations. This contract supports the installation, configuration, and testing of these systems to ensure secure and functional network connectivity.

OpenNet: Provides unclassified network access for embassy personnel, supporting administrative and operational functions.

ClassNet: Ensures secure classified communication for sensitive diplomatic activities.

The vendor will ensure compliance with Department-approved hardware, security policies, and coordination

5. Transport Only Network (TrON) Installation:

o TrON is a specialized network designed to securely transport data between Department facilities without direct user access. This contract supports the installation, configuration, and testing of TrON infrastructure to ensure secure and efficient data transport.

6. Spare Parts Provisioning:

Supply spare parts to support the maintenance and functionality of systems. This includes ensuring the availability of replacement components for hardware and infrastructure to minimize downtime and maintain operational continuity.

7. Engineering and Maintenance Support:

Provide ongoing engineering support, troubleshooting, and maintenance for current and legacy systems. This includes addressing technical issues, performing system upgrades, and ensuring the continued functionality of telecommunications systems. Engineering support is critical to maintaining secure and reliable operations at posts worldwide.

These services are essential for maintaining uninterrupted operations, ensuring the safety of personnel, and supporting the Department’s global mission. The vendor’s expertise and familiarity with these disciplines are critical to meeting the Department’s needs efficiently and effectively.

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 -Other than full and open competition. (FAR Overhaul) and substantiated by the following:

☒ 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements

The incumbent contractor is the only source that can support the on-going projects and the Department’s need to ensure uninterrupted support for critical operations and meet Congressionally mandated schedules as described below.

1. Immediate Need for Continuity:

o The Department faces an urgent requirement to maintain continuity in essential services, including OBO New Construction projects, embassy telecommunications systems, IPC relocation, Enterprise Wi-Fi, ITIR, and TrON installation. Any delay in awarding this contract would result in significant disruptions to mission-critical operations, jeopardizing the Department’s ability to meet congressionally mandated schedules and operational deadlines.

These modernization efforts improve responsiveness, increase safety, and deliver significant value by optimizing productivity, bolstering security, and positioning the Department to thrive in a dynamic and more prosperous global environment.

o Multiple projects are in process with contractor staff onsite at overseas Posts, equipment ordered and delivered to the warehouse, and equipment in transit to Posts for installation.

Changing the contractor for projects already in progress would increase costs and create schedule delays and unnecessary risks by stopping on-going work, bringing contractor personnel back from the Posts, sending new contractor personnel to the posts, briefing the new contractor about on-going projects, moving equipment from one contractor-owned warehouse to another, and managing the transition to a new contractor along with managing the on-going projects. There are currently 20 teams on site at posts throughout the world with travel schedules in place to continue project completion.

o These items above will add significant unnecessary and duplicative costs to the program that could not be recovered through competition. The Government will incur additional costs for contractors to travel back from posts, brief and train new contractor staff and have them travel to the posts. Additional costs will be incurred to have equipment moved from the contractor’s secret cleared warehouse to the new contractor’s secret cleared warehouse, which will need to be approved by Diplomatic Security.

o The transition to a new contractor will cause work to cease, further impacting tight timelines and congressionally mandated schedules. Transition to new contractor introduces a significant risk that schedule delays will occur.

o Several critical factors affect these projects including Diplomatic Security (DS) Construction Plans (CSP) and permit approvals, post-ordered departures for from high threat locations (such as Kiev, Hati, and Baghdad), project site preparation, local government shipment authorizations, COVID-19 travel restrictions, equipment production delays caused by chip shortages, lack of qualified contractor resources in the early stages of the contract, and travel delays, post availability, and OBO schedule adjustments. CSP and DS approvals safeguard personnel and facilities, while local government permits and site preparation ensure compliance with host nation regulations and readiness for construction. Ordered departures and Post availability underscore the fluid nature of diplomatic missions, requiring flexibility in project timelines. Equipment delays and OBO schedule changes further emphasize the need for a contract designed to anticipate and mitigate disruptions.

2. Avoiding Serious Injury to U.S. Government Interests:

o The inability to secure vendor continuity would cause serious injury to the U.S. Government, both financially and operationally. Disruptions in telecommunications systems, including OpenNet, ClassNet, and TrON, would compromise secure communications, impede embassy operations, and potentially impact life safety systems.

3. Critical Nature of Services:

The services covered under this contract—such as voice/TPS/telephone, telecommunications infrastructure installation, IPC relocation, Enterprise Wi-Fi, ITIR, and TrON deployment—are essential for maintaining secure and effective embassy operations worldwide. These services directly support the Department’s global mission and ensure the safety, bolstering security, and functionality of diplomatic facilities.

4. OBO New Construction Projects – Projects must begin on time to ensure the Department can adhere to congressionally mandated schedules.

SECTION 5: DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE AUTHORITY

CITED

The incumbent contractor, AT&T, possesses unique qualifications and expertise that are essential to meeting the Department’s mission-critical needs. The nature of the acquisition and the contractor’s specialized capabilities justify the use of this authority, as outlined below:

1. Specialized Expertise in the Janus Program:

o AT&T has extensive experience managing Janus III and Janus IV tasks, including project management, technical expertise, and operational support for complex workflows. Their familiarity with the program ensures seamless continuity, avoiding delays and disruptions that would otherwise jeopardize mission-critical activities.

2. Proven Track Record in OBO New Construction Telecommunications Projects:

o AT&T has demonstrated expertise in supporting OBO’s new construction telecommunications projects, including the installation of telephone systems, MS Teams phone systems, Enterprise Wi-Fi networks, and Transport Only Network (TrON) infrastructure. Their ability to meet congressionally mandated schedules while maintaining high standards for safety, security, and functionality is critical to the success of these projects.

3. Experience with Embassy Telecommunications Systems:

o AT&T has demonstrated expertise in installing, maintaining, and enhancing embassy and consulate ITIR and telecommunications systems, including OpenNet and ClassNet. Their in-depth knowledge of Department-approved hardware, security policies, and ability to collaborate across multiple Department bureaus ensures full compliance with technical and security requirements.

4. Expertise in IPC Relocation and Network Deployment:

o AT&T has unique qualifications in relocating Information Processing Centers (IPC) and deploying

OpenNet and ClassNet systems. Their ability to configure and test these systems ensures secure and functional network connectivity, which is vital for embassy operations.

5. Impact of GSA Connections II Contract Sunset:

o Janus III - SAQMMA14F1811 and Janus IV - 19AQMM21F0420 are task orders that were issued against the GSA’s Connections II Governmentwide Acquisition contract (GWAC) which ends on January 18, 2026. AT&T’s familiarity with the Department’s systems and processes makes them uniquely qualified to step in and provide continued support.

6. Minimizing Risk and Ensuring Continuity:

o AT&T’s unique qualifications minimize the risk of operational disruptions and ensure continuity of services. Their deep understanding of the Department’s telecommunications infrastructure, coupled with their ability to meet urgent deadlines, makes them the only viable option to address the Department’s immediate needs.

AT&T’s specialized expertise, proven track record, and familiarity with the Department’s systems and processes make them uniquely qualified to perform the required services under the authority cited.

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 5.202 APPLIES

The Department will publish a copy of the approved Justification and Approval on SAM.gov in accordance with FAR Part 5.

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 price to the Government of the supplies/services covered by this J&A will be fair and reasonable based on tentative commitment that proposed prices and rates will remain the same as those contained with Janus IV (Contract No. GS00Q12NSD0004; task order 19AQMM21F0420, option year 4) and aligned with the discounted rates proposed by the contractor. Janus IV rates are already determined to be fair and reasonable. The only increase allowed will be project-based labor rates which can increase by no more than 3% per year if the cause of delay is the government. In addition, the Contracting Officer will evaluate the proposed rates for a new contract, by comparing them to 1) the Option Year 4 rates for the current (expiring contract), and 2) rates found using the GSA rate calculator tool. By signing the justification, the Contracting Officer makes a determination that the price to the Government is expected to be fair and reasonable.

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

The Department investigated several alternatives to awarding a sole source contract including:

• Continuing work under the existing contracts – GSA has mandated that all Connections II contracts must have all funds accounted for by January 18, 2026. GSA was not forthcoming with this information when the initial award was made in January 2021 and did not inform the Department until August 2025.

• Using the existing Enterprise Infrastructure Solutions (EIS) task order with AT&T – GSA stated that it would be difficult to reprogram the funds to EIS. The current task EIS order would require modification and extensive on-going administration to manage project billing and completion. In addition, the EIS Contract Access Fee (CAF) is 4.75%. By using EIS, the Department would incur a CAF of $8,550,000.00 in addition to the CAF already paid under the Connections II program, with no value added to the process. The Department would be paying the CAF twice for the same work because GSA would not waive or reduce the CAF as requested by the Department.

• Sole source definitive contract to the incumbent contractor - This approach allows the Department to maintain continuity of critical services for awarded work, avoids additional duplicative costs, and minimizes the risk of schedule delays.

The Department will conduct market research to determine the best approach for a competitive follow-on contract to support future projects.

SECTION 9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION

1. Urgency of Mission-Critical Operations:

o The Department faces an immediate need to ensure uninterrupted support for embassy telecommunications systems, OBO New Construction projects, and IPC relocations. Delays in awarding this contract would disrupt essential services, including OpenNet, ClassNet, and Transport Only Network (TrON) installations, which are critical for secure communication and operational functionality at U.S. embassies worldwide. These modernization efforts improve responsiveness, increase safety, and deliver significant value by optimizing productivity, bolstering security, and positioning the Department to thrive in a dynamic and more prosperous global environment.

2. End of GSA Connections II Contract:

o The previous procurement vehicle, the GSA Connections II contract ends on January 18, 2026 with no possible extension. This creates a gap in the Department’s ability to procure these services through competitive means, necessitating the use of a sole-source contract to address immediate needs.

3. Vendor Familiarity and Specialized Expertise:

o AT&T has unique qualifications and extensive experience with the Department’s telecommunications infrastructure. Their familiarity with Department-approved hardware, security policies, and cross-bureau coordination ensures seamless integration and compliance with technical and security requirements.

4. Minimizing Operational Risk:

o Transitioning to a new vendor under competitive procurement for continuing support would require significant time for onboarding, training, and system familiarization, which is not feasible given the urgency of the Department’s needs. The proposed contractor’s existing knowledge and expertise minimize operational risk and ensure uninterrupted continuity of services.

5. Congressional Mandates and Deadlines:

o The Department is required to meet congressionally mandated schedules for OBO New

Construction projects and embassy telecommunications upgrades. The proposed contractor’s proven ability to deliver services on time and in compliance with these mandates makes them the only viable option for ongoing work under the current circumstances.

6. Critical Life Safety Systems:

o The services provided under this contract include the installation and maintenance of critical cabling infrastructure and telecommunication systems that support life safety systems, such as fire alarms and emergency communication. Any delay in these services could compromise the safety of personnel and facilities, further justifying the need for immediate action.

7. Cross-Bureau Coordination:

o The contractor’s ability to work seamlessly across multiple Department bureaus ensures efficient execution of complex, interdependent tasks. This level of coordination is essential for maintaining operational effectiveness and security.

8. Limited Scope and Duration:

o The proposed contract is limited to a base year and three option years and addresses only the

Department’s immediate needs. This approach allows the Department to meet urgent requirements while preparing for competitive follow-on contracts, ensuring compliance with procurement regulations in the long term.

The end of the GSA Connections II contract, the contractor’s unique qualifications, and the critical nature of the services required support the use of other than full and open competition. This sole-source contract is essential to maintaining uninterrupted operations and meeting the Department’s mission-critical needs.

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.

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 fostering competition in future acquisitions and will take the following actions to remove or overcome any barriers to competition for subsequent contract award of these supplies and services:

1. Transition to a Competitive Procurement Vehicle:

o The Department will conduct market research and assess and pursue suitable competitive procurement options to replace the expiring GSA Connections II contract. This effort will involve utilizing existing General Services Administration (GSA) contracts, other government-wide acquisition contracts (GWACs), internal Department contracts, or creating a new competitive solicitation designed to meet the Department’s specific requirements.

2. Development of a Long-Term Acquisition Strategy:

o The Department will develop a long-term acquisition strategy to ensure future requirements are clearly defined, well-documented, and aligned with competitive procurement practices.

This strategy will include detailed performance work statements (PWS) and technical requirements to facilitate broader vendor participation.

3. Improved Planning and Coordination:

o The Department will enhance internal planning and coordination across bureaus to ensure sufficient lead time for competitive acquisitions. This includes early identification of requirements, streamlined approval processes, and proactive engagement with contracting officers to avoid future urgency-based sole-source procurements.

4. Vendor Transition Planning:

o To mitigate the risks associated with transitioning to a new vendor, the Department will develop a comprehensive transition plan. This plan will include knowledge transfer, training, and phased implementation to ensure continuity of operations while onboarding a new contractor.

5. Utilization of Lessons Learned:

o The Department will conduct a post-award review of this sole-source contract to identify lessons learned and areas for improvement. These insights will inform future acquisition planning and help address any barriers to competition.

6. Compliance with Federal Acquisition Regulations (FAR):

o The Department will ensure compliance with FAR Part 10 (Market Research) and FAR Part 7

(Acquisition Planning) to promote competition and avoid reliance on sole-source contracts in the future.

The Department recognizes the importance of competition in federal procurement and is committed to taking proactive steps to remove barriers to competition for future acquisitions. By implementing these actions, the Department will ensure that subsequent procurements for these critical supplies and services are conducted in a fair, open, and competitive manner.