Justification Approval T2COM HRCO 26QA026_26-HRCO-31 AFC_signed Final 24 Mar 26.pdf

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Control Number: 26-HRCO-31

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JUNE 2025

JUSTIFICATION REVIEW DOCUMENT

FAR Part 12 Justification and Approval for Other than Full and Open Competition

Program/Equipment: G-1/4 Surgeon Cell Support, U.S Army Transformation and Training Command (T2COM formerly TRADOC)

Authority: Title 41 United States Code (U.S.C.) §1901 as implemented in Federal Acquisition Regulation (FAR) 12.102(b), restricting competition for acquisitions valued over the Simplified Acquisition Threshold Government that is not expected to be recovered through competition.

Amount: $1.03 million

Prepared by:

Rey S. Salinas Phone: 210-872-5184 Contract Specialist Date: 23 MAR 2026 E-mail: rey.s.salinas.civ@health.mil

Contracting Officer:

Clifton M. Wells Phone: 210-295-4528 Contracting Officer Date: 23 MAR 2026 E-mail: clifton.m.wells.civ@army.mil

Technical:

Gerald A. Forest Phone: 757-501-5631 Medical Operations Specialist (COR) Date: 23 MAR 2026 Surgeon’s Office E-mail:gerald.a.forest.civ@army.mil

Requirements:

LTC Tyler Mark Phone: 757-501-5383 Executive Officer, Surgeon’s Office Date: 23 MAR 2026

T2COM

E-mail: tyler.j.mark.mil@army.mil

Controlled By: USAHCA Controlled By: HRCO CUI Category: General Procurement & Acquisitions Limited Dissemination Control: FED ONLY POC: Clifton M. Wells, (210) 295-4528 mailto:rey.s.salinas.civ@health.mil mailto:clifton.m.wells.civ@army.mil mailto:gerald.a.forest.civ@army.mil mailto:tyler.j.mark.mil@army.mil

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Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager/Program Executive Officer:

COL Dennis M. Sarmiento Command Surgeon, T2COM E-mail: dennis.m.sarmiento.mil@army.mil

Phone: 757-501-5384

Legal Counsel:

Thomas P. Hineman Attorney-Advisor (Contracts and Fiscal Law) U.S. Army Medical Command

Phone: 571-644-0154 E-mail: thomas.p.hineman.civ@Army.mil mailto:dennis.m.sarmiento.mil@army.mil mailto:thomas.p.hineman.civ@Army.mil

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FAR Part 12 Justification and Approval for Other than Full and Open Competition

1. Requiring Activity: G- 1/4 Surgeon Cell Support, U.S. Army Transformation and Training Command (T2COM) Headquarters (HQ), 210 W. 7th Street, Austin, TX, 78701-2903.

2. Contracting Activity: U.S. Army Health Contracting Agency (USAHCA), Health Readiness Contracting Office (HRCO), 2199 Storage St. Building 4197, Joint Base San Antonio (JBSA) – Fort Sam Houston, TX 78234-5074.

3. Description of Action: Request approval for a new Firm-Fixed Price (FFP) contract in support of T2COM Headquarters Contract Service Providers (CSP), management and service. This award is a noncompetitive contract (six-month base with option to extend services IAW FAR 52.217-8 for six months) to Potawatomi Training, LLC, CAGE: 4RRK1, 3115 W State ST STE 309D Milwaukee, WI 53208-3364.

4. Description of Supplies/Services: This is a non-personal service contract to provide all CSP, management, and services necessary to support T2COM’s current organic medical structure to enable an extensive medical readiness oversight across the enterprise.

Period Period of Performance (POP) Estimated Value Base 25 March 2026 through 24 September

$510,701.40

52.217-8 25 September 2026 through 24 March

$526,008.60

Estimated Overall Total Price

$1,036,710.00

5. Authority Cited: Title 41 United States Code (U.S.C.) §1901 as implemented in Federal Acquisition Regulation (FAR) 12.102(b) and 10 U.S.C. §3204.

6. Reason for Authority Cited: The procurement process for the G-1/4 Surgeon Cell Support at T2COM Headquarters was impacted by several unforeseen factors that were beyond planning control. The merger of U.S. Army Training and Doctrine Command (TRADOC) to form the new T2COM major command required a headquarters relocation from Fort Eustis, Virginia to Austin, Texas. This necessitated a complete re-validation of all procurement documents by the new command to ensure compliance. A significant overhaul of the Federal Acquisition Regulation (FAR) occurred, changing the classification of the required items from non-commercial to commercial. This forced the contracting office to shift its strategy from FAR Part

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13 to FAR Part 12, which is now commercial, causing further delays. A federal government shutdown halted all contracting activities for a period of time. These uninterrupted services are vital for the U.S. Army's mission. They are essential to support and address capability and capacity gaps, and to manage and oversee the anticipated growth of 253 organically assigned medical staff across T2COM.

Competition during the transition of command structure, relocation and onboarding new personnel would create unacceptable delays in fulfilling the agency’s requirements.

This action meets the SBA “new requirement” test of 13 C.F.R. §124.504(c)(1)(ii)(C) as the contract magnitude has decreased by more than 25 percent.

a. Background: Potawatomi Training, LLC. is the incumbent contractor providing support to the T2COM under contract W911S020P0047. The contract is currently in its final six-month option period, authorized under FAR 52.217-8, with a period of performance ending on March 24, 2026. A follow-on action was intended to be awarded before the current contract's expiration. These delays have postponed the completion of the requirements package and subsequent contracting procedures, creating a high risk of a service gap after March 24, 2026. To prevent disruption of services, a six-month base with option to extend services IAW FAR 52.217-8 for six months is requested.

This period will ensure continuity of operations and allow sufficient time for the award and phase-in of a new contractor under the follow-on contract.

b. Alternatives: With appropriate timelines and new levels of reviews, this requirement could be competed in an 8(a) program, such as OASIS Plus. The intent for follow-on is to use this vehicle to procure an 8(a) competitive service requirement once enough timeline for acquisition process is available. Although this alternative exists in theory, with our current timeline, above acquisition strategy is not feasible without jeopardizing the G-1/4 Surgeon Cell Support,T2COM’s required services.

c. Impact if not approved: The mission impact if this contract is disapproved a break in service will occur and cause a negative impact for the T2COM, G-1/4 (Surgeon Office), Headquarters (HQ), 210 W 7th Street, Austin, TX 78701-2903. The contract action will imitate the current contract’s Performance Work Statement (PWS). There is a Fully Funded purchase request available on this action and ready to award. Due to the shortage of time required to get a competitive solicitation through GSA OASIS and based on the deadline, it will be a lengthy process to effectively execute the requirement complete without break in service. The support staff services purchased as part of this purchase order comprises of the following: growth of 253 organically assigned medical staff across the T2COM Training Enterprise to include: 56 Basic Combat Training (BCT)/One Station Unit Training (OSUT) Brigades (BDE) and Battalions (BN), 4 Reception BNs, and 19 Advanced Individual Training (AIT) BNs. If there’s break in service, the lack of service being provided could result in harm and affect the continuity of quality for U.S. Army Transformation and Training Command (T2COM), G-1/4 (Surgeon Office). The above facts are the reasons for requesting the one-year duration minimum to be covered under this action. This contract has the capability to ensure that there will be no break in service for requested services.

7. Efforts to Obtain Competition: A sole source HUBZone contract with Potawatomi Training LLC is necessary to avoid a break in service for the T2COM

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requirement until HRCO Contracting can get the follow-on contract in place. J&A will be posted to SAM.gov within 14 days after award.

a. Effective competition: Potawatomi Training, LLC, is the only vendor capable of fulfilling the government's specific requirements within the given timeframe as the incumbent contractor. Their continuous performance of this work since September 25, 2020, ensures their employees possess the necessary familiarity with the requirement.

b. Subcontracting competition: Potawatomi Training, LLC is a small business concern. In accordance with FAR 19.109(b), a subcontracting plan is not required.

8. Actions to Increase Competition: To avoid a break in service, establishing additional competition is not feasible, because it would necessitate a protracted and rigorous staffing process for a new contractor. This, combined with the required phase-in period, would inevitably result in a service disruption.

9. Market Research: Market research conducted for the follow-on effort, that closed on December 16, 2025, per FAR Part 10, revealed a competitive market with several seasoned vendors available to fulfill the requirement, when afforded enough time to execute the acquisition strategy. On 20 March 2026 it was decided that since this was a new requirement it would be awarded as a Sole Source under a HubZone Direct Award. (See Market Research Amendment).

10. Interested Sources: Request for Information (RFI) RFI was posted by the contracting team on 14 May 2025 with a close date of 30 May 2025. 20 potential vendors showed interest. Contracting team also reached out to couple of 8(a) ANC vendors for Market Research purposes. Below is a list of some of those vendors who showed interest.

VENDOR

NAME

LOCATION POINT OF CONTACT RESPONSE

KATMAI,

LLC

12001 Science Drive, Suite 160 Orlando, FL

Rober Iezzi GM & Director, 561- 740-8701, riezzi@katmaicorp.com

Yes

Koniag Government Services

Centerpoint Drive, Suite 700 Anchorage, AK 99503

Fiona Barshow Vice President, 571-278-9857, fbarshow@koniag-gs.com

No

Alaka’ina Foundation Family of Companies

Buckeystown Pike, Suite 460, Frederick, MD 21704

Jim Hulbert Business Development Director, Federal Health & Life Sciences 340-236- 9899, jhulbert@alakaina.com

Yes mailto:riezzi@katmaicorp.com mailto:fbarshow@koniag-gs.com mailto:jhulbert@alakaina.com

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Chenega Pro Federal Solutions, LLC

5253 Prue Rd #230 San Antonio, TX 78240

Jeff Rohrbaugh GM 610-513- 8231, Jeffrey.rohrbaugh@chenega.com

Yes

COHO

Integrated Solutions

1577 C Street, Ste 300-C Anchorage, AK

George Bernardy President 907- 360-2692, George.bernardy@cohois.com

Yes

Goldbelt Affiliates

550 Cherokee Ave, Suite 100, Alexandria, VA 22312

Jasmine Stewart President Healthcare Technology & Transformation Group 202-374- 6434, Jasmine.stewart@goldbelt.com

Yes

11. Other Facts: N/A mailto:Jeffrey.rohrbaugh@chenega.com mailto:George.bernardy@cohois.com mailto:Jasmine.stewart@goldbelt.com

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All signature pages are separate from the body of the document.

12. Technical Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Gerald A. Forest Medical Operations Specialist (COR), Surgeon’s Office T2COM

13. Requirements Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

LTC Tyler Mark Executive Officer, Surgeon’s OfficeT2COM

14. Fair and Reasonable Cost Determination:

I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. This determination will be made using price analysis and Independent Government Estimate.

Clifton M. Wells Contracting Officer

15. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Clifton M. Wells Contracting Officer

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Approval

Based on the foregoing justification, I hereby approve the procurement of G-1/4 Surgeon Cell Support, U.S. Army Transformation and Training Command (T2COM) on an other than full and open competition basis pursuant to the authority of Title 41 United States Code (U.S.C.) §1901 as implemented in Federal Acquisition Regulation (FAR) 12.102(b), For acquisitions valued over the SAT, prepare a written justification and obtain approval of the justification as described in 6.104. Cite the following statutory authority, as applicable -restricting competition for acquisitions valued over the Simplified Acquisition Threshold Government that is not expected to be recovered through competition. The estimated total value of the new contract is $1,036,710.00 for a six-month base period (25 March 2026 to 24 September 2026) to include an option to extend services IAW FAR 52.217-8 for six months (25 September 2026 to 24 March 2027). The approval is subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for this acquisition.

CICELY D. SIMMONS-CARROLL

Advocate for Competition