Justification for Exception to Fair Opportunity_OFDA FINAL.pdf

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Version 06/14/19

General Services Administration

Federal Systems Integration and Management Center

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

UNDER IDIQ CONTRACTS

SOLICITATION 47QFCA20K0032

INTERAGENCY AGREEMENT NUMBER 2020033ID

The General Services Administration (GSA) makes this Justification for the issuance of an

Exception to Fair Opportunity order pursuant to Federal Acquisition Regulation (FAR)

16.5.

a. Identification of Agency and Contracting Activity:

Agency:

General Services Administration (GSA)

Federal Systems Integration and Management Center (FEDSIM)

Acting in support of: United States Agency for International Development (USAID)

Contracting Activity:

GSA FEDSIM Contracting Office (QF0B)

1800 F Street, NW

Washington, D.C. 20405

b. Nature and/or Description of Action Being Approved:

The USAID is undergoing a complex organizational restructuring and what is known as the Office of Foreign Disaster and Assistance (OFDA) today will become the Bureau for

Humanitarian Assistance (BHA) after merging with sister entity Food for Peace. This reorganization is impacting the ability to develop requirements and outline a Performance

Work Statement (PWS) that meets the needs of the future organization prior to the expiration of the current task order. This sole source TO will have a 12-month Period of

Performance (PoP) which will allow time for requirements to be solidified, and for

FEDSIM to complete sufficient market research in advance of a competitive acquisition while maintaining continuity of operations during the transition to the competitively awarded Bureau for Humanitarian Assistance (BHA) TO.

The Government’s competitive strategy must include mechanisms for transition of functions supported by GDIT, provision of deployed personnel and resources, and an entirely new set of requirements. While considering the complexity of the current environment, schedule hindrances and OFDA’s unique mission, multiple meetings were held with the client that drove FEDSIM to begin planning for a sole source acquisition.

During these meetings, FEDSIM documented a shift in executive priorities which precluded the Government’s ability to fully develop requirements as a reason for not pursuing a competitive solicitation at that time. OFDA requires support for the management of information technology (IT) inventory for deployments, and for the rapid deployment, installation, and management of IT field operations centers directly in response to multiple concurrent and ongoing disaster response operations. These

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The incumbent contractor can continue to perform these duties without interruption to

OFDA’s mission and ability to respond to ongoing and future potential crises worldwide.

GDIT (the predecessor awardee was Alliant Solutions, LLC, which was acquired by

GDIT in January 2019, the referred to as GDIT) was awarded a hybrid Firm Fixed Price

(FFP) and Cost Plus Fixed-Fee (CPFF) Task Order on February 17, 2015 consisting of a one-year base period and four, one-year option periods with a total value of

$81,404,134.00. All Option Periods were exercised, including the utilization of the FAR

52.217-8 clause to extend services for an additional six months from March 2, 2020 -

September 1, 2020.

The Alliant 2 GWAC vehicle was selected for this action under the exception to fair opportunity (Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(b). The contract type determined to be most appropriate for this acquisition is a hybrid of FFP and CPFF Task

Order (term). CPFF allows flexibility in responding to the dynamic and changing mission environments. A FFP Contract Line Item Number (CLIN) will be used for Project

Management because the scope and requirements are well defined.

c. Description of Supplies/Services and Estimated Value:

OFDA requires support for the management of information technology (IT) inventory for deployments, and for the rapid deployment, installation, and management of IT field operations centers directly in response to multiple concurrent and ongoing disaster response operations. These responses often occur in remote and austere areas of the world with limited infrastructure. Task Areas of the task order (TO) should include: Program

Management, Operations and Maintenance, Application Development and Maintenance, ICT Response Readiness Operational Support, ICT Equipment Management, and the

Execution of Transition-Out. Details of the individual Task Areas are as follows:

Task 1: Provide Program Management: This includes program management support and all necessary personnel, administrative, logistical, financial, and managerial resources. This includes the management and oversight of all activities performed by contractor personnel, including subcontractors, to satisfy the requirements identified in this SOW.

Task 2: Provide Operations and Maintenance: This includes operations and maintenance support, including network support, information security, systems operations support, and user support/help desk support to enable OFDA to accomplish its foreign disaster assistance mission. In addition to normal daily operations, the contractor shall support this task during periods when the OFDA is operating multiple disaster response activities.

Task 3: Provide Application Development and Maintenance: This includes application development, enhancement, maintenance and management services, as well as program management for the application portfolio. This also includes support for modernizing the application environment, as needed, to seek efficiencies and keep the application portfolio aligned with the business needs of the organization.

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Task 4: ICT Response Readiness Operational Support: This includes all IT and communications services and support necessary for OFDA to maintain response readiness and operational capacity at all times in response to international disasters. This encompasses both the activation of Washington, D.C.-based RMTs, as well as the deployment of field operations support through DARTs and/or field assessment teams.

Task 5: ICT Equipment Management: This includes procurement services and inventory storage and management, and equipment lifecycle management to ensure availability, utility, and accessibility of necessary equipment for OFDA’s ongoing ICT operations and maintenance, as well as for RMTs and field responses.

Task 6: Transition Out: The Transition-Out Plan shall facilitate the accomplishment of a seamless transition from the incumbent to an incoming contractor/Government personnel at the expiration of the TO. The contractor shall provide a Transition-Out Plan no later than (NLT) 120 calendar days prior to expiration of the TO.

The cost of the 12 month bridge contract is estimated to be a total of $29,676,802.00.

d. Identification of the Exception to Fair Opportunity and Rationale:

This TO Justification is being prepared as required by FAR 16.505, Exception to Fair

Opportunity Process.

The rationale is the agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays (FAR 16.505(b)(2)(i)(A)).

A typical FEDSIM acquisition of this size and complexity ranges from seven to nine months from kickoff to award therefore, if we were to have started a competitive acquisition in March 2020, an award wouldn’t be made until roughly October 2020.

Factoring in a transition period of 120 days, the new TO Period of Performance (POP) could not begin until February 2021. Given that the current POP expires on September 1, 2020 that would result in a five month gap in service. An immeasurable loss would be realized including a gap in service that is necessary to international disaster relief.

As stated previously, OFDA and Food for Peace are being merged into a new bureau, BHA. The BHA structure will fully integrate one, single bureau to consolidate core capabilities of the same humanitarian assistance challenges while streamlining policies, processes, systems, tools, and staffs for a more effective approach to managing complex crises and natural disasters. At the outset of the acquisition planning in April 2019, it was unclear as to what BHA would look like, what its mission would entail, what the scope of work would include and what client stakeholders would be responsible for capturing requirements.

OFDA also communicated that network responsibilities would be shifting and OFDA.gov would no longer be owned, operated, and maintained by the future BHA and existing network capabilities would be absorbed by USAID’s OCIO. At the time FEDSIM began planning for the re-compete, no future-state architecture had been developed and BHA’s roles and responsibilities were unclear.

Amidst this uncertainty, Hurricane Dorian hit the Bahamian Islands and the ensuing relief effort impacted progress on the acquisition. In September 2019, OFDA activated a

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Disaster Assistance Response Team (DART) and stood up a Response Management

Team (RMT) while coordinating with the U.S. Government during the catastrophe. Those efforts continued while coordinating relief with local Bahamian authorities, U.S.-based search and rescue teams and Washington D.C.-based USAID.

Congressional approval for the BHA was formalized in January 2020 however the future-state architecture was still in flux, as was the delineation of roles and responsibilities within this new organization

By March 2020 the COVID-19 pandemic dealt an unexpected blow to the already strained acquisition schedule and presented additional performance constraints, increasing the likelihood of a lapse in service. In the wake of the COVID-19 pandemic, OFDA made the decision to stand up a RMT to be positioned for an immediate DART or field assessment deployment. If implemented, OFDA’s Senior Management Team would require increased support, which only a sitting contractor would have the ability to respond to in an urgent fashion. The current contractor has hands on experience providing all IT and communications services and support necessary for OFDA to maintain response readiness and operational capacity 24 hours a day, 7 days a week when responding to global disasters (such as the Ebola pandemic). A gap in service would result in an unacceptable lapse in OFDA services critical to international disaster response. This would cause humanitarian relief disruption, compromise, or failure, and more importantly, possible loss of aid to those in need. A new contractor would be at a severe disadvantage in assuming full operational duties within the required timeframe.

A sole source is needed for making a timely award while avoiding unacceptable delays prior to the current TO expiration, and therefore no other contractor would be able to come up to speed and obtain the necessary clearances required before September 1, 2020.This sole source TO will have a 12-month Period of Performance (PoP). This PoP will allow time for FEDSIM to complete sufficient market research for the competitive action and maintain continuity of operations during the transition to the competitively awarded BHA TO.

GDIT currently provides all IT and communications services and support necessary for

OFDA to maintain response readiness and operational capacity at all times in response to international disasters. This encompasses both the activation of Washington, D.C.-based

Response Management Teams (RMTs), as well as the deployment of field operations support through Disaster Assistance Response Teams (DARTs) and/or field assessment teams. GDIT’s highly specialized response personnel are currently ready to deploy in the wake of a disaster and go to the most austere areas of the world for months at a time.

Given the substantial training, institutional knowledge transfer and ramping up that would be required for an incoming contractor undergo, these unique capabilities uniquely position the contractor to execute their duties in a timely fashion.

It is the intention of FEDSIM to award a follow on competitive action by May 2021 to afford the successful offeror a full 90 to 120-day transition in period to ensure there is no interruption to the continued operation of the mission critical networks and systems.

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e. Determination That the Anticipated Cost is Fair and Reasonable:

The Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable. The expectation of reaching a fair and reasonable price was determined through analysis of a preliminary cost estimate for the 12 month sole source bridge effort, which the Contracting Officer requested from GDIT. This preliminary estimate was developed by GDIT using actual cost data (labor rates, labor mix and level of effort) from the current OFDA ICT TO, and is predicated on the assumption that the scope of support reflected in the current order will remain unchanged and carry forward into the sole source bridge TO. GDIT’s preliminary estimate was also compared to an

Independent Government Cost Estimate for the bridge TO which was jointly developed by FEDSIM and USAID. The results of that comparison were favorable and it was determined that the GDIT estimate appropriately aligned with the government’s expectations. Further cost and price analysis will be conducted to ensure fair and reasonable pricing upon GDIT’s formal cost proposal submission in response to the forthcoming sole source Task Order Request. The total amount of funding required for the total estimated period of 12 months is approximately $29,676,802.00.

f. Other Facts Supporting the Justification:

There are no other facts.

g. Statement of Actions:

A subsequent competitive acquisition is anticipated, once the sole source is awarded. The

TO award resulting from this acquisition is targeted to occur in May of 2021. A signed

Interagency Agreement has been received from the client agency guaranteeing FEDSIM support for future competitive acquisition planning, solicitation release and contract award.

h. Certification by Technical or Requirements Personnel:

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

Courtney Loy Date

Acquisition Project Manager

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i. Signature of Authorized Official:

I hereby certify that the Justification is accurate and complete to the best of my knowledge and belief, and I 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.

Brendan McDonough Date

Contracting Officer

Christopher Hamm, SES Date

HCA Designee

Christopher Bennethum Date

HCA, Acting Assistant Commissioner, AAS