Justification for an Exception to Fair Opportunity Acquisition Support Bridge Logical Follow-on Redacted.pdf

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JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

10 U.S.C. § 3205

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by Federal Acquisition Regulation (FAR) 16.507-6(d)(2) (FAR Class Deviation 26-04 Rev.

11), this justification for an exception to fair opportunity is supported as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Headquarters

Contracts Division 3 (HCA-COCO-31) proposes to enter into a task order with an exception to fair opportunity.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the action: USCG intends to procure on a sole source basis

(b) Name and address of the contractor: OCT Consulting, LLC

8260 Greensboro Drive, Suite 435

McLean, VA 22102

(c) Contract Type: Firm Fixed-Price Task Order

(d) Estimated total value (including options):

Period Unit Price Total

Base Period

2 Months

(03/29/2026 –

05/28/2026)

$700,000.00

$700,000.00

Total $700,000.00

(e) Type of funding: Operations and support funds

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: 70Z02326Q91200002

1 In this document, citations to RFO Parts 6, 10, 15, 16, and 25 are citations specifically to FAR Class Deviation 25-

11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 Rev. 1 for FAR Part

15, FAR Class Deviation 26-04 Rev. 1 for FAR Part 16, and FAR Class Deviation 25-09 Rev.1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order

14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

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(h) Background information about the requirement: Firm Fixed Price Contract No.

47QRAD20D8119 Task Order No. 70Z02320FACS01300 for USCG

Headquarters Acquisition Support was awarded to OCT Consulting, LLC. on 29

September 2020 and expired on 28 September 2025. The USCG exercised FAR

52.217-8 for a total of six (6) months with an ultimate completion date of 28

March 2026.

3. Description of Supplies/Services.

The USCG has a requirement to provide contractor support services for non-inherently governmental contracting tasks (pre-award, contract administration, closeout, data migration, mandated financial and procurement processes, and centralized contract filing inventory), and support services to assist with the (FPDS-NG), USCG Contract Writing

Systems, and Invoice Processing Platform (IPP).

4. Exception to Fair Opportunity.

The exception to fair opportunity is:

• RFO 16.507-6(b)(3) – The new work is a logical follow-on to an original order, and the order was placed in accordance with the fair opportunity process and was not issued under sole-source or limited-sources procedures.

5. Identification of Exception to the Buy American Statute.

N/A

6. Supporting Rationale of the Exception.

The previous task order with OCT Consulting, LLC. was originally competed among 8(a) contract holders under GSA OASIS in accordance with the fair opportunity process under

FAR Part 16.

The relationship between the initial order and the follow-on bridge order is logical for several reasons:

Scope:

The follow-on order maintains the same scope of services as the initial order, covering pre-award, contract administration, closeout, data migration, and systems support. Continuity in scope ensures that ongoing operations, processes, and institutional knowledge are preserved, preventing disruption to mission-critical contracting activities.

Period of Performance:

The follow-on contract is limited to the minimum period necessary to complete the competitive acquisition process and facilitate a seamless transition to new contractors. This short period is directly tied to the timeline required for a competitive procurement, Last Updated 03/05/26 3 demonstrating a clear and logical extension of the initial order without unnecessary prolongation.

Value:

The value of the follow-on contract is proportional to the limited period and scope of services required to maintain continuity. It avoids excessive or duplicative costs by only covering the essential support needed during the transition, ensuring fiscal responsibility and alignment with operational needs.

This action is necessary to ensure continuity of contractor support services for USCG contracting operations. The complexity and integrated nature of the required services, including pre-award, contract administration, closeout, data migration, and systems support, means that any gap in contractor support would jeopardize mission-critical operations. OCT Consulting, LLC provides essential support that cannot be interrupted without significant risk to mission execution. OCT Consulting, LLC has supported this mission for over five years and currently provides 27 FTEs to support the Coast Guard

Head of Contracting Activity (CG-HCA) and Office of Procurement Policy and Oversight

(CG-HCA-PPO).

Due to the integrated nature of the services provided, segregating portions of the work for competition is not feasible without risking loss of institutional knowledge and operational continuity. To ensure the effective period of this order is no longer than the minimum time necessary to enter into a competitive contract, USCG has established clear milestones for the follow-on competitive procurement. A competitive solicitation has already been issued, vendor responses are actively being evaluated, and transition planning is underway. The bridge contract with OCT Consulting, LLC will be limited to two (2) months, which is the minimum period required to complete the competitive acquisition process and facilitate a seamless transition to new contractors.

Other alternatives considered included:

• Transitioning to a new contractor without a bridge period.

• Segregating tasks to allow for partial competition.

• Utilizing internal USCG resources to cover the gap.

None of these alternatives are viable as transitioning to a new contractor without overlap would result in delays, loss of critical expertise, and disruption to ongoing programs.

Segregating tasks would dilute accountability where no single entity is responsible for overall outcomes, and it becomes harder to measure and enforce performance standards of the contract. Additionally, this would increase risks by disrupting continuity, complicating coordination among multiple contractors and USCG personnel, and jeopardizing mission-critical operations and compliance. Internal resources are insufficient to absorb the workload, given current operational demands.

If this justification is not approved and the product or service is not provided, the USCG will face unacceptable mission disruption through immediate loss of contracting support where critical contracting actions would cease, resulting in significant delays in awarding, Last Updated 03/05/26 4 administering, and closing out critical contracts. Many high-visibility and essential programs supporting defense, homeland security, and maritime safety missions would be delayed, appropriated funds could go unused or be cancelled, and operational readiness would be degraded at a time of increased geopolitical tension with USCG assets support

U.S. actions abroad. Critical programs, including high-visibility procurements and systems support, would be at risk, jeopardizing compliance with legal and regulatory requirements.

7. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable. The Contracting Officer determines that the anticipated price(s) will be fair and reasonable based on the use of the General Services

Administration (GSA) One Acquisition Solution for Integrated Services Plus (OASIS+) contract vehicle to satisfy this requirement. The pricing under the GSA OASIS+ contracts will be determined to be fair and reasonable by comparing historical contract pricing data and the current GSA FSS rates for OCT Consulting, LLC., which have already been determined to be fair and reasonable.

8. Description of Market Research. Market Research was conducted during March 2026 to determine whether the proposed strategy is the most advantageous to the government. After reviewing all DHS Strategic Sourcing Vehicles (SSV) it was determined that the GSA

OASIS+ vehicle is within scope of this requirement. The proposed contractor was awarded a

GSA OASIS+ 8(a) contract; however, they are not eligible to receive a direct 8(a) award as they do not have the required 8(a) status in the SBA Dynamic Search. As a result, the USCG is completing this justification to award a Task Order off the proposed contractor’s GSA

OASIS+ 8(a) contract.

9. Other Facts Supporting the Use of Other Than Full and Open Competition.

Coast Guard Head of Contracting Activity (CG-HCA) currently awards 22,000 actions for

$3.2B in contracting actions to support the USCG’s defense, homeland security, and maritime safety missions. OCT contractor personnel perform day-to-day contracting functions, supporting the full acquisition lifecycle from requirements development through award, administration, and closeout.

Some critical, high-visibility procurements that are at risk include:

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In addition, OCT provides essential systems support for the Financial System

Modernization Solution (FSMS), the USCG contract writing system, and the Federal

Procurement Data System–Next Generation (FPDS-NG), the federal-wide procurement reporting tools, in direct support of CG-HCA users. Any disruption to the OCT contract will put the USCG’s ability to award contracts, obligate funds, and meet legal and regulatory reporting requirements at unacceptable risk.

The services provided by OCT cannot be interrupted without immediately impairing the

USCG’s ability to execute and report contracting actions, jeopardizing the timely use of appropriated funds, and degrading operational readiness. Award of a sole-source bridge contract to OCT Consulting, LLC is therefore justified as the only responsible means to ensure continuity of critical acquisition and contracting system support while the

Government completes a competitive procurement.

10. Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to

Competition Before Any Subsequent Acquisition for Supplies or Services Required.

The USCG has issued a competitive solicitation for these requirements and is actively evaluating vendor responses. To maximize competition and ensure future acquisitions are fully competitive, the following actions are being taken:

• Comprehensive Market Research: USCG is conducting ongoing market research to identify additional qualified vendors and expand the pool of potential offerors for future requirements.

• Industry Engagement: The agency is engaging with industry through outreach events and Requests for Information (RFIs) to encourage participation and inform vendors of upcoming opportunities.

• Transition Planning: USCG is developing a robust transition plan to facilitate handover from the incumbent to new contractors, minimizing risk and ensuring continuity of operations.

• Multiple Award Strategy: It is anticipated that multiple Blanket Purchase

Agreements (BPAs) will be awarded within two (2) months, increasing competition and providing flexibility for future task orders.

These actions will ensure that any barriers to competition are addressed and removed, enabling full and open competition for subsequent acquisitions of these services.

11. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of an exception to fair opportunity is accurate and complete to the best of my knowledge and belief.

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Ryan Shaughnessy Date

Contracting Officer

12. Technical/Requirements Personnel Certification.

I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Ranford Demontegnac Date

Technical Representative

APPROVAL

Ryan Shaughnessy Date

Contracting Officer