Leavenworth JA 2025_25_REDACTED (1).pdf

Control No: MICC 2025-25

JUSTIFICATION REVIEW DOCUMENT

FAR 6 JUSTIFICATION AND APPROVAL FOR OTHER THAN

FULL AND OPEN COMPETITION

Program/Equipment: U.S. Army Combined Arms Center, Fort Leavenworth, Kansas, Mission Command Training Program (MCTP) Support Services

Authority: 10 U.S.C. 3204(a)(1) as implemented by FAR 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Amount: $ 83,537,363

Prepared by:

Contracting Officer: Ruth N. Austin DSN:

Contracting Officer Date:

Technical:

Requirements:

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

Program Manager:

Small Business Professional:

2/13/25

Local Legal Counsel:

Director, MICC-Fort Leavenworth:

MICC Office of Counsel:

Director, Field Directorate Office – Fort Eustis:

Director, Small Business Program:

Alternate Advocate for Competition:

FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Contracting Activity: U.S. Army Mission and Installation Contracting Command (MICC-Fort Leavenworth), 535 Kearny Avenue, Building 338, Fort Leavenworth, Kansas 66027

2. Description of Action: The U.S. Army Combined Arms Center (CAC) requests a modification to extend the period of performance of contract W911S0-18-C-0004 with Northrop Grumman Corporation (NGC), Inc., 2411 Dulles Corner Park, Suite 600, Herndon, VA 20171-3430, that supports the Mission Command Training Program (MCTP). This modification will extend the performance period for one seven-month base period and one, five-month option period (15 April 2025 to 14 April 2026) at an estimated value of $83,537,363. This extension ensures the continuation of essential exercise planning and support services to allow the Army sufficient time to award the follow-on MCTP contract competitively, no earlier than May of 2025, and allow for the orderly transition to that contract without disrupting ongoing mission essential services.

Upon award of the new contract, this extension will support the 90-day transition period as dictated by the current contract and the re-procurement’s solicitation. Fiscal year 2025, Operations and Maintenance funds will be used for the base period and Fiscal year 2026, Operations and Maintenance funds would be used if the option is exercised which has a 15 November 2025 start date.

The source selection plan and draft solicitation are currently in staffing for final approval. Though acquisition planning for the re-procurement was initiated well in advance of the estimated acquisition lead time (ALT) for this procurement, multiple reviews revealed additional opportunities to enhance competition. These reviews and the resulting refinements to the requirements package and acquisition strategy are a contributing factor in the timeline for the competitive re-procurement. Historically, the time between publication of the solicitation and announcement of award has exceeded 24 months. This contract extension continues services while the competitive re-procurement is in progress.

3. Description of Supplies/Services: Fort Leavenworth is the U.S. Army’s center for excellence in combined arms education, doctrine, and leadership development. The MCTP supports the collective training of U.S. Army units as directed by the Chief of Staff of the Army (CSA) and scheduled by Forces Command (FORSCOM) in accordance with the Regionally Aligned and Modernization Model (ReARMM) process at worldwide locations in order to train leaders and provide commanders the opportunity to train on mission command in Unified Land Operations. The MCTP performs this mission by conducting five basic types of exercises: Warfighter Exercises (WFX); Joint Task Force (JTF)-Enabled WFX; US Army Service Component/Joint and Combined Staff Training Exercises (ASCC); Mission Readiness Exercises (MRX) and Contingency Operations. Key aspects of these exercises are summarized below. On average, the MCTP conducts five WFXs annually in support of Corps and Division training audiences and support units up to five Combatant Command or US Army Service Component

Commands exercise annually. Each WFX requires about 10 weeks of planning and support over a period of nine to twelve months; at any one time, the MCTP is developing between five and seven exercises each year.

The MCTP designs and executes multi-echelon, multi-tiered WFXs that provide expeditionary-focused, realistic demanding training, and leader development opportunities, in decisive action scenarios, to commanders and their staffs on the unit’s approved training objectives. The WFX program is the CSA’s exercise program and a significant training event within the ReARMM, which emphasizes the interdisciplinary specialties of individual brigades in the context of Corps and Division formations. The MCTP, when directed, supports ASCCs, field armies, corps, or divisions designated as an Army Force command as part of an ASCC or geographic combatant command exercise. MCTP, when directed, supports U.S. Army units identified as a Deployment Expeditionary Force by executing a culminating training event as part of Chairman Joint Chiefs of Staff (CJCS) UNIFIED ENDEAVOR-series exercise program. The MCTP, when directed, provides staff assistance to U.S. Army units allocated in support of contingency operations.

The MCTP consists of a headquarters, and four Operation Groups (OPSGRPs). The organization consists of service members, Army civilians (including Highly Qualified Expert Senior Mentors), and support contractors enabling the design and execution of exercises. The MCTP's military Observer Coach/Trainers (OC/Ts) are military education level four branch-qualified officers, warrant officers, and non-commissioned officers (NCOs) who have successfully completed the MCTP OC/T training and certification requirements within the standards established by the U.S. Army Training and Doctrine Command (TRADOC).

Option Period 6: 15 APR 2025 to 14 NOV 2025 Value: $44,184,368 Option Period 7: 15 NOV 2025 to 14 APR 2026 Value: $39,352,995 Total Value: $83,537,363

The Government intends to award the follow-on contract no earlier than mid-May 2025.

The Government will exercise the option period 7 if the competitive re-procurement is further delayed, or it is required for implementation of FAR 52.237-3, Continuity of Services, in support of the successor contract.

4. Authority Cited: 10 U.S.C. 3204(a)(1), as implemented by FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. Reason for Authority Cited: As described at FAR 6.302-1(a)(2), when the supplies or services required by the agency are available only from one responsible source, or for DoD, NASA and the Coast Guard, from only one or a limited number of responsible sources, and no other types of supplies or services will satisfy agency requirements, full and open competition need not be provided for. NGC, the incumbent contractor, is the only contractor that is capable of meeting the Army’s needs and performing this extension pending award of the follow-on effort for the reasons noted below.

a. Background.

NGC is uniquely positioned to immediately provide a workforce, and has demonstrated through their past performance record that they have the capability to conduct required tasks without a break in service. Based on contract history, the incumbent contractor has been providing a supporting staff

NGC provides expertise, training, and has been successful in meeting the MCTP cost, schedule, and performance requirements.

It is not feasible, nor is it in the best interest of the Government, for another Contractor at this point to develop/perform the current tasks and services. The follow-on contract includes a mandatory 90-day phase-in period that is essential to ensure the smooth transition between support contractors and to avoid any disruptions to the training mission. The prospect of a new contractor for this bridge contract would also raise the potential of two transitions within a short period of time. The upcoming competition will provide for a transition, but it is unreasonable to incur the expense and efforts for two such transitions within this short period of time. The benefits of competition will not offset the expense and efforts of multiple transitions within this short timeframe. During the phase-in period, the incoming contractor is required to train its workforce, to oversee the transfer of a substantial volume of Government furnished property (GFP), and to observe the mission command training events and other exercises conducted by MCTP. The latter point is particularly important given the integrated and iterative nature of exercise planning and execution. Over 4,900 GFP items, valued at approximately $8.8 million, are currently in the possession of the contractor. At the end of this contract (14 April 2025), a significant amount of GFP will be in transit to WFX 25-4 locations and will not be available for inventory by a successor contractor.

On average, MCTP conducts 73 exercises annually in support of brigade and other units up to and including ASCCs. Each exercise requires about 10 weeks of planning and support over a nine-to-twelve-month period; at any one time, the MCTP is developing between five to seven exercises. Although the MCTP conducts four types of exercises, no two are the same when planned or executed. Instead, each one is tailored to meet the training needs and time available of the supported unit. In addition to the tailoring of each exercise, real world events often cause no-notice adjustments to exercise audiences and locations. For example, the WFX 25-3 division level training audience was assigned a Southern Border Mission and pulled from the exercise 6 days prior to the start of the exercise. The Government and the Contractor had to execute and implement significant changes (i.e. location, training audience) in a very short amount of time. As a result, it is simply not reasonable to expect another contractor to mobilize their workforce and install a management structure for an abbreviated performance period that will only involve seven months of full performance. Even if it were possible to compete the extension, transitioning to a new contractor under that compressed timeline creates significant operational risk and enhances the possibility that the Army will experience disruptions in the performance of these essential exercise planning and execution services. That potential disruption would be magnified by the potential transition to yet another contractor to perform the follow-on MCTP contract three to six months after the extension is awarded.

The following events are scheduled during this extension period. Travel and site setup begins approximately 15 days prior to the start date of the event. The period of performance dates associated with the two option periods illustrated above in paragraph 3 are selected to ensure contract transition will occur in between exercise events (November 25 to January 26 and End of March 26 to May 26), rather than in the middle of a training exercise or during a travel and setup period.

b. Alternatives.

1) Suspended Operations. Suspending operations of the current services is not a viable alternative. This would result in a significant disruption of the MCTP’s training mission which is mandated by Army Regulation (AR) 350-50, Combat Training Centers and TRADOC Regulation 350-50, Mission Command Training Program. If this request is not approved the MCTP will be unable to provide / conduct this Department of Army directed training which could have an adverse impact on the supported unit’s readiness.

The services procured by the MCTP requirement are tied to mission accomplishment and cannot cease without major change to the Army’s mission of combined arms training. MCTP conducts and supports combined arms training that replicates joint-interagency-intergovernmental-multinational operations in a decisive action environment at worldwide locations for Brigades, Divisions, Corps, ASCCs, Joint Force Land Component Commands, and Joint Task Forces in order to create training experiences that enable the Army’s senior commanders to develop current, relevant, campaign-quality, joint and expeditionary mission command instincts and skills. Most, if not all, of today’s general officers have participated in a MCTP exercise at some point in their careers. Disruption of support will not only seriously jeopardize the MCTP’s ability to provide mission essential services but will also have far reaching negative consequences that will impact the entire preset training schedules.

2) Use of Government In-House and Expertise. Currently there are no available Government personnel able to supplement this work with the experience required to execute the mission-oriented tasks contained throughout the Performance Work Statement.

3) FAR 52.217-8, Option to Extend Services. The six-month extension period was already exercised and is currently in progress. This temporary measure has equipped the Government with skilled resources required to continue the MCTP mission uninterrupted throughout the interim period.

c. Impact if justification not approved. The impact of not approving the request for a bridge contract would be a break in service, and potentially a work stoppage that would severely impact the performance of the MCTP’s mission. From the period of 15 April 2025 – 14 April 2026 MCTP will have four Warfighter Exercises (WFX), three Brigade Warfighter Exercises (BWFX), and two Army Service Component Command Exercises (ASCC). These exercises require significant Government and contractor involvement in order to facilitate the training of the Army. There is a mandatory 90-day phase-in period that is essential to ensure the smooth transition between support contractors and to avoid any disruptions to the training mission. The lengthy phase-in period is intentional and recognizes the integrated and complex nature inherent in performing this contract.

Awarding to another contractor for this interim period would pressure the government into omitting the 90-day phase-in period, risking mission disruption and potential failure as a result of the time constraints for the incoming contractor to train its workforce, oversee the transfer of Government property, and observe the mission command training events and other exercises prior to the expiration of the current period of performance. The bridge extension will temporarily mitigate risks to mission success and ensure a smooth transition to the new MCTP contract. Considering all of the direct and cumulative impacts to mission and training requirements, MCTP support capabilities to satisfy those requirements will not be met without the continued support of the existing Contractor, on site, and ready to employ the mission essential requirements at the highest level of reliability and effectiveness.

6. Efforts to Obtain Competition: On 22 October 2024, MICC – Fort Leavenworth published a special notice, as required by FAR 5.201, on SAM.gov, announcing its intention to extend NGC’s contract on a sole source basis and seeking any responses from interested vendors. The special notice was active for 30 days and the Government received zero responses from other firms objecting to or indicating a willingness or capability to perform the extension. The competitive follow-on acquisition is currently in progress and will result in an award of a Cost-Plus-Fixed-Fee contract on an unrestricted basis.

a. Effective Competition: Because this is a sole source action, effective competition is not applicable.

b. Subcontracting Competition: The extension for continued services is being requested with the incumbent contractor who is an Other than Small Business concern.

A review of its Electronic Subcontractor Reporting Systems (eSRS) report on the current contract from September 2020 to date, indicates the Contractor makes good faith effort to subcontract in accordance with subcontracting percentages provided in their subcontracting plan. A revised subcontracting plan will be required as part of the proposal submission and negotiated by the Contracting Officer (KO) for the extension period of performance to include KO, Small Business Professional & SBA Procurement Center Representative review. No change is expected in the subcontracting goals for this extension period. The acceptable plan will be incorporated into the contract and monitored in eSRS.

7. Actions to Increase Competition: Due to reasons indicated above in paragraph 5, NGC, Inc. is the only firm that can realistically perform the interim support services. The extension provides the only viable, lowest risk alternative to MCTP’s mission accomplishment in the most effective and efficient manner while MICC completes the solicitation and source selection of proposals for the new follow-on contract. Efforts to maximize competition are a contributing factor to the delays experienced with the competitive re-procurement. For example, software tools required for performance of the current contract have been bifurcated from the re-procurement, eliminating intellectual property barriers to entry.

As stated in paragraph 6 above, a notice of intent was posted on SAM.gov to announce the issuance of a single source contract modification to NGC, Inc. for continuation of the MCTP support services. The new follow-on contract is anticipated to be awarded in May 2025.

8. Market Research: Market research was not conducted for the extension for reasons discussed in paragraphs 6 and 7 above. There is a competitive follow-on action in progress. A sources sought notice was posted on 6 September 2022 for the follow-on action. MICC-Fort Eustis has conducted extensive market research as part of the competitive follow-on procurement. This market research confirms that MCTP support is an intensive effort that requires significant transition efforts.

9. Interested Sources: NGC, Inc. is currently performing the contract and is the only known source that can perform at the required performance level while maintaining continuity of services. As stated in paragraph 6, the Government published a special notice of intent to award a single source contract modification to NGC, Inc. This announcement was active and open to response or submission for 30 days. To date, no other sources have written to express an interest in performing a seven-month bridge contract. All notices required by FAR 5.201 have been published.

10. Other Facts:

a. Procurement History.

1) Contract W911S0-18-C-0004 was competitively awarded on 28 September 2018 and this requirement is currently being re-competed. The competitive follow-on acquisition will result in an award of a single Cost-Plus-Fixed-Fee contract, on an