Justification_Fair_Opportunity_AF DCGS_Sgned.pdf

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

UNDER IDIQ CONTRACTS (FAR 16.505)

The General Services Administration (GSA) makes this Justification for the issuance of an Exception to Fair Opportunity order pursuant to Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(C)

1) Identification of Agency and Contracting Activity:

Requesting Agency:

USAF/Air Force Distributed Common Ground System (DCGS) Requirements Section Chief, Lisa M. Smith 235 Byron Street, Suite 19A Robins AFB GA 31098-1670 Email: lisa.smith.39@us.af.mil Phone: 478-468-5954

Servicing Agency/Contracting Activity:

GSA AAS Region 10 Office of Professional Services and Human Capital Categories (PSHC) 400 15th Street SW Auburn, WA 98001

NOTE: The Servicing Agency identified herein is responsible to procure the required services in support of the DSS CDSE. In accordance with the Interagency Agreement, the Servicing Agency shall act in the capacity of contracting activity for the resultant acquisition. As a result, this justification is hereby prepared and approved by the Servicing Agency Contracting Specialist (CS) and Contracting Officer (CO) responsible for the execution of the services required.

2) Nature and/or Description of Action Being Approved:

The proposed eight (8) month logical follow-on will be a time and material task order, based upon an Exception to Fair Opportunity as defined in FAR 16.505(b)(2)(i)(C), and as further detailed below. The task order award will be made to Booz Allen Hamilton, Inc, under their OASIS IDIQ contract, GS00Q14OADU108.

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3) Description of Supplies/Services and Estimated Value:

The current task order was competitively awarded as a Time and Materials (T&M) task order on September 29, 2017 to Booz Allen Hamilton Inc. under OASIS contract GS00Q14OADU108 in the amount of $29,762,199.03. The Period of Performance (POP) of this task order is as follows:

● Base: 9/29/2017 – 3/31/2018

● OPT 1: 4/1/2018 – 3/31/2019

● OPT 2: 4/1/2019 – 3/31/2020

● OPT 3: 4/1/2020 – 3/31/2021

● OPT 4: 4/1/2021 – 3/31/2022

The United States Air Force Distributed Common Ground System (AF DCGS) is the Air Force Life Cycle Management Center (AFLCMC)/HBGB weapon System Program Office (SPO) at Robins AFB, GA, providing Command and Control Intelligence, Surveillance, and Reconnaissance (C2ISR) support to a variety of Air Force Major Commands and Department of Defense (DoD) customers. To support this global enterprise, AF DCGS manages a challenging sustainment weapon system which has critical dependencies on a complex and constantly evolving Information Technology (IT) infrastructure. The weapon system and associated applications, software, firmware, and hardware requires that there is no gap in services because it would directly impact mission critical software. The AF DCGS weapon system is represented by tightly coupled Sensor-to-PED Integration forming the basis for a multi-spectral data processing environment.

AFLCMC/HBGB/XR/XP specifically addresses these challenges and charts a path forward to improve efficiency and effectiveness for the AF DCGS enterprise.

The support provided by the SPO includes acquisition, oversight of Contractor provided systems and process engineering, integration, and sustainment - all of which are governed by existing laws, regulations, instructions, policies, and procedures. Over time these complex activities have become increasingly complex and stove-piped, limiting unified effort, and thereby increasing risk, cycle time, and cost. In response, AF DCGS implemented process studies and tool development projects resulting in better integrated, enterprise-wide, clearly defined sustainment processes supported by ongoing continuous process improvement.

The estimated value for this eight (8) month task order, covering the period from April 1, 2022 through November 30, 2022 is $6,114,831.00

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4) Identification of the Exception to Fair Opportunity and Rationale:

This Exception to Fair Opportunity is based upon the following FAR 16.505(b)(2)(i)(C) statutory exception and rationale:

The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

Rationale:

The original request for proposal (RFP) was sent to all OASIS Pool 1 contractors under the Unrestricted OASIS contract utilizing NAICS 541611. As a result of the RFP, only two contractors responded and Booz Allen Hamilton was the awardee of the task order. The second contractor was determined not qualified since they did not meet all the required evaluation factors. The existing task order GSQ1017EC0034 was awarded as Time and Materials (T&M) on September 29, 2017 under the GSA OASIS Unrestricted Pool 1 contract, GS00Q14OADU108.

The work for the logical follow-on task order is a continuation of mission critical work. The current task order was modified to extend services in accordance with FAR 52.217-8 Option to Extend Services on September 30, 2021 to allow the contractor to finish several tasks/projects currently in progress. The end date of Option Period 4 was extended through March 31, 2022.

During the market research phase of the recompete it was identified by the GSA Region 10 (R10) Contracting Officer that a similar Request for Information (RFI) had been posted to SAM.GOV. The contracting activity was GSA Federal Systems Integration and Management Center (FEDSIM), who also provides assisted acquisition services (AAS) within GSA. The FEDSIM PM, after consultation with their CO, identified overlap between the two requirements. The FEDSIM PM and CO also indicated they received feedback from industry through their own market research that there was another requirement being competed that was similar to theirs.

Once the PWS concerns were identified, the two contracting offices discussed the portion of the overlapping requirement with the customer. The customer identified minimal overlap within the current task order. However, there was some overlap between the recompete documents provided to GSA AAS R10 and the requirements documents provided to GSA FEDSIM for a new acquisition. It was then determined that the recompete effort by GSA AAS R10 needed to stop so that both GSA AAS R10, GSA FEDSIM, and the customer can deconflict the requirements.

Based upon an Exception to Fair Opportunity, the Government intends to issue

Version 6/28/19 Page 3 an order IAW FAR 16.505(b)(2)(i)(C) which states the order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order. A logical follow-on task order is required as a gap in service directly impacts AFLCMC/HBGB mission critical software capability development and enhancement for a vital national security level weapon system while two contracting activities work to address industry concerns about duplicative requirements being recompeted.

A lapse in service would halt all cybersecurity engineering and help desk support for integrating the Explosive Ordnance Disposal Information Management System (EODIMS) onto the NIPR, SIPR, and JWICS cloud environments that provide critical explosive ordnance and intelligence data for the entire DoD community (USAF, USMC, USA, and USN) and some State agencies. The EODIMS system requires constant maintenance and support that ensures its compatibility, interoperability, optimization, availability, and maintainability on the DOD network. As real word problems arise, data and information must be passed onto needed personnel without undue delay and/or interruption. To preclude or interfere with the transfer/availability of this information to necessary stakeholders would cause a serious mission degradation that would have a negative impact on the security and safety of personnel this system is designed to protect.

Additionally, there would be a domino effect down range that could affect other systems thereby further endangering national security.

If the functions on the existing task order ceased, the EODIMS platform could also lose its authority to operate. This would cause operational issues for AFLCMC/HBGB in executing its mission critical functions. Specifically, lack of support would directly impact the ability to develop solution sets due to loss of integrated evaluation of requirements against current capabilities. It would also impact future year’s projections for the Program Objective Memorandum, which provides AFLCMC/HBGB with the ability to get appropriated funds for the operation and maintenance of the EODIMS system. Should any technical issues arise that causes EODIMS to lose its authority to operate, AFLCMC/HBGB will not be able to submit their requirements for consideration of timely funding until all systems are online, properly functioning, and meet all required DOD systems and network requirements. Any delay incurred could result in a lapse of funding being provided to AFLCMC/HBGB, which would result in not being able to submit another request until the next budget cycle. These requirements/budget requests are to be submitted during a preset designated time frame not set by

AFLCMC/HBGB.

DOD Instruction 5000.88, Engineering of Defense Systems, requires AFLCMC/HBGB to maintain a digital engineering implementation plan to include model elements, element relationship diagrams, activity diagrams, block definition diagrams, and use case diagrams. The plan must include the evolution

Version 6/28/19 Page 4 of a continuous end-to-end digital representation, or integrated set of digital representations, of the system being produced and the establishment of a digital authoritative source of truth (i.e., configuration controlled digital baseline). The program office will make the relevant digital model(s) accessible to the Office of the Secretary of Defense (OSD), Joint Staff stakeholders, and interdependent programs, throughout the life of the program and will maintain configuration management. AFLCMC/HBGB relies heavily on contractor support to meet these policy requirements and specific mission objectives. The government does not have the expertise and manpower in-house to ensure compliance with all DOD policies.

In addition to losing EODIMS authority to operate, failure to comply with policy mandates creates undue risk to the government. If AFLCMC/HBGB is unable to create and maintain a model-based systems engineering environment, it will take longer to analyze, test, and detect issues that, as mentioned prior, impact the ability of specific systems to deliver information meant to ensure the safety of stakeholders reliant on the information the EODIMS platform provides. It also means should there be any known defects within the system, support services can only be provided in person at the affected location. The affected location would have to agree and schedule system downtime for any defects to be remedied. This will dramatically increase costs to conduct developmental and integration testing onsite due to the need to conduct live testing using the weapon system. Live testing impacts mission execution and causes schedule delays due to the need to minimize interruption of operational mission execution.

Depending on the specific system affected, taking the system down may cause other systems to fail down range creating further unnecessary risk to the mission objectives of multiple offices. Model based systems are required as they allow the government to test, analyze, and find solutions virtually with minimal disruption to the end users of those systems and their individual missions.

Lastly, failure to keep mission critical functions working while the next procurement is competed gravely degrades the ability to support Joint EOD (JEOD), Very Important Persons Protection Support Activity (VIPPSA), OCONUS, and CONUS reporting to non-DoD federal and state agencies increasing the risk of national security threats to national leaders. Because EODIMS supports not just DOD but State agencies, failure to keep operations running means AFLCMC/HBGB would no longer be able to meet National, Joint and Service level mandates to integrate/share data across DoD and non-DoD partners.

5) Determination That the Anticipated Cost is Fair and Reasonable:

The task order will be solicited and awarded on a time and materials basis. Price fair and reasonableness will be determined based upon a comparison to historical pricing information, comparison to the Independent Government

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Estimate (IGE), and in consideration of the labor rate ceiling pricing contained within the GSA OASIS IDIQ.

6) Other Facts Supporting the Justification

An analysis was conducted to review the cost impact of not having a task order in place while the recompete of the current task order is completed. As stated above, this task order supports several mission critical functions that under no circumstances can have a lapse in service. Not having contract support coverage would cause AFLCMC/HBGB Weapon System Program Office to seek assistance outside the organization to keep operations running.

If AFLCMC/HBGB were to consider requesting the AF command for staffing to support operations, then AFLCMC/HBGB would need a minimum of 30 military personnel. There is no numerical value that can be placed on the negative impact to other military missions/operations should AFLCMC/HBGB leadership need to consider this option. Additionally, it may not be physically possible to get 30 military personnel, with the needed specialties, by March 31, 2022, as the process to request such an action would require higher level command approval well above the local command’s authority.

Next, AFLCMC/HBGB’s would attempt to direct-hire temporary government personnel. This scenario is also unlikely and untimely since AFLCMC/HBGB would have to attain the ability to direct-hire the required positions through the proper human resource channels and Office of Personnel Management (OPM).

Upon completion of a cost analysis to direct-hire personnel, it was determined that the Government would incur approximately $1.5M in additional costs to cover a gap in service. The additional costs were based on a burdened annual cost of $250K per full time employee (FTE), amortized down to eight (8) months.

The additional costs are mostly attributed to paying for relocation, lodging, and per diem for needed personnel to temporarily relocate. The added costs are not currently paid under the contract nor projected under the recompete contract.

7) Statement of Actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before and subsequent acquisition for the suppliers or services is made:

The awarding of this eight month task order allows for the necessary timeframe for the Government to deconflict multiple ongoing procurements and procure the five (5) year recompete effort under GSA OASIS on a competitive basis, thus providing fair opportunity to all GSA OASIS vendors in accordance FAR Part 16.505.

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8) Certification by Technical or Requirements Personnel:

I hereby certify that the supporting data is complete and accurate and complete.

Requirements Section Chief, Lisa M. Smith 235 Byron Street, Suite 19A Robins AFB GA 31098-1670 Email: lisa.smith.39@us.af.mil Phone: 478-468-5954

9) Signature of Authorized Official:

I hereby certify that the Justification is accurate and complete to the best of my knowledge and belief, and determine on the basis of the findings above that the Exception to Fair Opportunity is in accordance with the requirements, and is in the best interest of the Government.

Evelyn Henderson Acquisition Program Manager Assisted Acquisition Service (AAS) Region 10

Henry

Senior Contracting Officer Office of Professional Services and Human Capital Categories

Kristi Irvin Competition Advocate Office of Professional Services and Human Capital Categories

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SMITH.LISA.M.139549906

Digitally signed by

SMITH.LISA.M.1395499064

Date: 2022.02.28 11:53:16 -05'00'

Sheila Morrison Division Director (C) Office of Professional Services and Human Capital Categories

Keith Jeffries CONOPS Office Director GSA/FAS/PSHC Office of Contract Operations

Assistant Regional Counsel (LD7) General Services Administration

Sheri Meadema Head of Contracting Activity (Acting) GSA/FAS/PSHC Office of Contract Operations

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