Justification and Approval Redacted.pdf

CUI

SOURCE SELECTION INFORMATION – SEE FAR 2.101 AND 3.104

Justification for Other Than Full and Open Competition

Defense Civilian Personnel Advisory Services - Web Development, Sustainment and Cloud Hosting, DCPAS.FY21-984

Choose the funding level for this J&A Document:

☐ < $900K ☐ > $900K and < $20M ☐ > $20M and < $150M ☐ > $150M

Contracting Activity: Personnel Readiness Management Agency (PRMA) Acquisition Management Directorate

(AMD)

Center/Office/Requirement Title: Defense Civilian Personnel Advisory Service (DCPAS), Web Development, Sustainment and Cloud Hosting (RTD ID#: DCPAS.FY21-984) Authority (include full title): 10 U.S.C. 3204(a)(1) – Use of Procedures other than Competitive Procedures, FAR 6.103-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Estimated Contract Cost (including options): $460,851.12 (for 6-month extension period)

COORDINATION & APPROVALS: (<$900K)

Date COR / Program Mgr / Requiring Activity

Eric Lind

PRMA-DCPAS

Signature

Date Technical/Requirements Certification Scott Rogers

PRMA-DCPAS

Signature

Date APPROVED BY: Contracting Officer Matthew C. Poole

PRMA - AMD

Signature

Controlled by: PRMA AMD CUI Category: SSEL Dissemination Control: FED ONLY POC: Tameka Laws, Tameka.j.laws.civ@mail.mil

I. Agency/Contracting Activity.

Agency: Defense Civilian Personnel Advisory Service (DCPAS), 4800 Mark Center Dr, Alexandria, VA 22350.

Contracting Activity: Personnel Readiness Management Agency (PRMA) Operations Acquisition Management Division, 4800 Mark Center Dr, Alexandria, VA 22350.

II. Nature and/or description of the action being processed.

DHRA requires the extension of a firm-fixed-price contract awarded to Eminent IT, LLC (H9821021C0009). The extension will provide continued web development, sustainment, and cloud hosting services for a period of up to six (6) months. This modification is being executed in accordance with Federal Acquisition Regulation (FAR) Clause 52.217-8, Option to Extend Services, which was included in the contract award and will include the necessary Contract Line-Item Numbers.

The exercise of FAR Clause 52.217-8 is required to prevent a critical lapse in the ongoing mission support services. This requirement is driven by an unavoidable delay in funding availability, as follow-on funds for procurements were restricted until PRMA successfully fulfilled Unfunded Requirements (UFR). These UFRs were critical to secure the necessary funding for the core cloud hosting and system sustainment costs required to keep the system operational; without this approval, the program lacked the baseline funding required to initiate a follow-on solicitation. Specifically, the program office did not receive the final UFR funding decision and allocation until the fourth quarter of the fiscal year. To mitigate this delay, the Government actively sought internal hosting and maintenance support from the Defense Media Activity (DMA) and the Defense Manpower Data Center (DMDC). However, it was determined that neither agency possessed the capacity to meet these requirements. As a direct result of this funding delay, there is insufficient procurement lead time remaining to execute a new contract award prior to the expiration. Furthermore, the current timeline is structurally inadequate to support a safe and effective transition period for a new awardee without posing significant operations risk.

Additionally, the sheer volume of technical work required to successfully transition these complex web development and cloud requirements to a new provider could not be safely accomplished within such a compressed timeframe. Executing the six-month extension clause of the contract will provide the necessary continuity of operations while affording the Government sufficient time to finalize the new solicitation, execute the follow-on award, and ensure a structured, low-risk transition of services. The value of the current contract is $4,389,122.76.

The six-month extension has a total estimated and fully certified value of $460,851.12, which will result in a new estimated contract value of $4,849,973.88. The preceding period of performance ends on September 20, 2026. This short-term extension is necessary to prevent a critical break in service while the competitive follow-on procurement is finalized and awarded.

III. Description of supplies/services required to meet agency needs (including the estimated value).

DCPAS has a continuing need for Web Development, Sustainment, and Cloud Hosting services (RTD ID#: DCPAS.FY21- 984). These services provide the technical infrastructure and maintenance required to run DCPAS's public-facing and internal web systems, which distribute vital DoD-wide human resource guidance, policy updates, and operational resources.

To prevent an administrative and technical lapse, PRMA AMD intends to extend these services under Contract H9821021C0009 for up to six months in accordance with FAR Clause 52.217-8. The current contract's option period ends on September 20, 2026. The current contract provided for a one-year base period, and four, twelve-month option periods.

The fourth option period was exercised on 3 September 2025.

The FAR 52.217-8 clause was included in the original solicitation and contract award; however, pricing for the extension period was not evaluated. The lack of prior price evaluation for the extension necessitates this Justification and Approval (J&A). PRMA AMD anticipates that it will need to exercise all of the FAR 52.217-8 to fulfill the requirement for continued web development, sustainment, and cloud hosting services.

The total value of this extension is $460,851.12, which represents six months of continued support at the current contracted pricing. Fiscal Year 2026 Operations and Maintenance (O&M) funds in the amount of $460,851.12 have already been fully budgeted, provided, and certified.

IV. Statutory authority permitting Other than Full and Open Competition.

10 U.S.C. § 3204(a)(1), as implemented by FAR 6.103-1 – "Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements," permits other than full and open competition for this interim extension of services.

The current contract, H9821021C0009, was awarded as a Small Business Administration (SBA) 8(a) direct pursuant to the executed Partnership Agreement U.S. Department of War, an authorized to negotiate directly with the 8(a) Business Development Participant.

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

Eminent IT, LLC is the only source that can perform the necessary web development, database maintenance, and cloud hosting services during this interim period without causing unacceptable, high-risk delays and technical disruptions.

Eminent IT, LLC possesses the specialized system clearances, proprietary knowledge of the DCPAS web architecture, and trained personnel who are already onboarded and operational. Bringing on any other source to fulfill this short-term bridge requirement on a competitive basis would require an extensive acquisition lead time of 250+ days, including a transition and onboarding period of at least 30 to 60 days. This would result in substantial duplication of costs that would not be recovered through competition and would cause an immediate break in service. Consequently, utilizing FAR Clause 52.217-8 with the incumbent is the only viable method to maintain operational continuity.

Extension and continued services under FAR 52.217-8 will support the transition of a competitive follow-on contract.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

Not applicable, as this is a short-term extension of an active contract to prevent a break in service. A competitive long-term follow-on contract is currently being processed by PRMA AMD to ensure robust future competition. This extension serves strictly as a bridge to complete that competitive acquisition.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will determine a fair and reasonable price for the six-month extension utilizing proposal analyst techniques found at RFO FAR 15.404-1, including comparison with historical prices and/or comparison to the Independent Government Cost Estimate .

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Market research was conducted extensively for the long-term, competitive follow-on contract. However, for this short-term bridge extension, it was determined that Eminent IT, LLC is the only source capable of performing the requirements without an immediate and detrimental lapse in mission support due to the technical onboarding and environment transition requirements. The Government anticipates the next contract will be a competitive follow-on small business set-aside.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

Not applicable.

X. List of sources, if any, that expressed interest in the acquisition.

Not applicable. Only the incumbent, Eminent IT, LLC, is capable of maintaining the hosting and web administration environments within this emergency timeframe without causing a service outage.

XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required.

The follow-on competitive acquisition is already underway. This extension is strictly a bridge to complete the evaluation, award, and transition of the competitive follow-on procurement, thereby eliminating any long-term barriers to competition.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by our signature(s) above, we certify that any supporting data contained herein, which is our responsibility, is both accurate and complete.