Limited Source Justification.pdf

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LIMITED SOURCE JUSTIFICATION & APPROVAL (J&A)

FEDERAL ACQUISITION REGULATION (FAR) PART 8 ACQUISITIONS

Multiple Award Schedule (MAS)/Multiple Award Contract Orders under MAS/General Services Administration Schedules (GSA)/Federal Supply Schedules

FAR 8.405-6

Purchase Request Number: HC10902300063656 Contract Number: GS-00F-296CA Task/Delivery Order Number: HC104721F4002 Procurement Title: Instructors, Training Support, & Technology Based Instruction Estimated Value of Modification:

Estimated Value of Contract Lifecycle:

Statutory and Regulatory Authority: 10 U.S.C. 3204(a) and FAR 8.405-6(a)(1)(i)(B)

J&A Number: JA23-058

Upon the basis of the following justification, I, as Procuring Activity Competition Advocate hereby approve this limited source justification pursuant to the authority of FAR 8.405- 6(a)(1)(i)(B). The acquisition referenced herein conducted under the Statutory Authority of the Multiple Award Schedule Program, 41 U.S.C. 152(3).

1. REQUIRING AGENCY AND CONTRACTING ACTIVITY:

Requiring Agency:

Contracting Activity:

Defense Information Systems Agency (DISA)/Defense Information Technology

Contracting Organization – National Capital Region (DITCO-NCR)/PL63 P.O. Box 549 Ft. Meade, Maryland 20775

2. NATURE/DESCRIPTION OF ACTION(S):

provides assured global information services to the , ensuring that the is able to communicate with anyone, anywhere, and under any condition. The Instructors, Training Support, & Technology Based Instruction task order GS-00F-296CA/HC104721F4002 with Peraton Services & Solutions Inc provides

JA23-058 Instructors, Training Support, & Technology Based Instruction

Page 2 of 9 Pages with the instructional support and eLearning development services required to train and keep their personnel abreast with the latest and dynamic technology. Over the past years, mission has drastically expanded requiring additional training support. This firm-fixed price modification will expand and increase the current level of instructional support and eLearning development services on the task order to support expanded mission.

Specifically, this modification will provide additional instructional support by increasing the number of positions by , from instructors to instructors. This additional instructional support is necessary as the existing classrooms are currently at maximum capacity while at the same time, the number of personnel that will attend the existing, revised, and new courses is anticipated to increase by . Due to the limited size of the available classrooms and the increased size of the classes, multiple simultaneous iterations of the same course(s) will need to be held concurrently in order to keep the cohort on schedule which exemplifies the need for additional instructors. Furthermore, this will also allow the Training Academy to provide in-person instructional support to via the Training Academy. This modification will also provide additional training support by increasing the number of positions by , from positions. The additional position is needed to peer review the existing/new course material and provide product management control. Peer review and product management control is currently being performed by the existing instructors in conjunction with personnel. With the increase in courses and course frequency, this support will provide a single point of contact that will free up resources while ensuring that the version control is maintained, and course materials are accurate and free of errors. The other position is required in order to increase the Council on Occupational Education (COE) accreditation support. The COE accreditation support is being expanded to include a single point of course scheduling, course administration, and records management for the courses covered by this task order. The COE accreditation support being added via this modification is currently being performed by personnel assigned to the Training Academy. Over the past years, as mission has expanded, so has it’s mission; however, the number of personnel available has not kept up with its mission, requiring personnel assigned to the Training Academy be utilized to support mission. Consequently, this has strained the capabilities of the existing Government personnel assigned to the Training Academy. This modification by expanding the COE accreditation support will reduce the strain on the existing personnel providing full-service COE accreditation support. The Government will be utilizing the Surge CLIN to fund this increased/expanded level of effort.

The Surge CLIN ceiling available on this contract is ; however, it is expected, based on the Independent Government Cost Estimate that the full cost of this expansion will exceed the available surge ceiling by approximately . This modification will be funded with 2023 Operations and Maintenance funds with an anticipated effective date of August 1, 2023.

3. DESCRIPTION OF SUPPLIES/SERVICES:

Under the current effort, the Instructors, Training Support, & Technology Based Instruction task order delivers foundational and advanced level leadership and technology discipline training to personnel via in-person courses that are taught multiple times a year. The task order also provides eLearning development support that focuses on creation and

Page 3 of 9 Pages maintenance of eLearning materials, supporting and supplementing all instructor-led courses as well as providing distance learning courses. Additionally, the task order provides institution accreditation support and media services support.

With this modification, the Instructors, Training Support, & Technology Based Instruction task order will increase the number of courses from worth of courses per year to of courses per year to standardize existing training materials and develop new curricula based on the introduction of new technologies for personnel.

Additionally, this modification will create a single focal point for peer review of existing/new course material and product management control, as opposed to these services being provided by both personnel and contractor instructors. It will also expand the existing accreditation support to include a single focal point responsible for managing daily course enrollments and scheduling, managing the course catalog, managing the administration of testing program, and gathering/presenting data for the COE Accreditation. This focal point will also provide learning management system training and maintenance of official educational files, records and transcripts. By expanding the existing accreditation support services, the contractor will be able to consolidate the above services into a single point of contact (POC), reducing the amount of coordination required from multiple personnel and streamlining the scheduling, instructing, testing, and records management into a single process.

This contract modification will take effect at the beginning of Option Period 2 and last for the life of the task order. The remaining periods of performance are as follows:

Option Period 2 – August 1, 2023 – July 31, 2024 Option Period 3 – August 1, 2024 – July 31, 2025 Option Period 4 – August 1, 2025 – July 31, 2026

The existing contract lifecycle value is . The inclusion of this expanded/increased level of effort covered under this J&A will result in an increase to the lifecycle value by approximately for all the remaining years of performance.

4. IDENTIFICATION OF LIMITED SOURCE AUTHORITY AND DEMONSTRATION OF

CONTRACTOR’S UNIQUE QUALIFICATIONS:

(a) Circumstances Justifying Limiting the Source.

FAR 8.405-6 (a)(1)(i)(B), only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

(b) Description of the Justification.

The incumbent contractor Peraton Services & Solutions Inc is currently providing all the instructional and eLearning development support and will be providing the same instructional and eLearning development support utilizing the surge option contained on the task order. However, the surge ceiling will only allow for coverage for the

Page 4 of 9 Pages expanded services/increased level of support. Due to the level of integration, coordination, and communication required, the Government is unable to breakout the services being added into a separate contract. Specifically, as the courses are taught on an as-needed basis an extremely high level of coordination is required in order to have the appropriate instructional support available. As the courses also utilize e-Learning material developed by the incumbent’s e-Learning development team a high level of coordination, consistent training, and cohesiveness is required between the instructional support team and the e-Learning development team. The product management control services will also need to integrate, coordinate, and communicate with the peer review services and the e-Learning development services that are currently being performed by the incumbent. Additionally creating/maintaining a course catalog, scheduling, enrolling students, and administering the testing program require coordination with the existing instructional support provided by the incumbent to ensure that instructional support is available to the personnel, and that the instruction can take place prior to testing, but without a significant delay. The gathering of data for COE accreditation and maintenance of official files, records, and transcripts also require integration with the testing program and scheduling. As documented above, these services are intricately woven together, which requires a high level of integration, coordination, and communication with the incumbent that the Government will be unable to enforce if broken out into a separate contract. In addition, the time required to compete this as a separate effort and contract personnel that are cleared at the Top Secret/Sensitive Compartment Information level with a screening will negatively impact mission and the services they provide to the .

The current contractor has already demonstrated their successful performance and has a trained and cleared staff that would need minimal additional training to fully support this effort. The current contracted staff is already familiar with the customers, the operational tempo (OPTEMPO), and the training needs required to support mission.

(c) Justification:

(1) Minimum Government requirements. The minimum requirement the Government has for this contract modification is to include providing peer review/product management support and single point of course administration/records management for personnel who take the instructor-led or eLearning courses, instructional support for revised and new courses, and instructional support to via the Training Academy. As detailed above, a significant portion of this effort is covered under the existing surge support CLIN. This justification is solely for the remaining portion of the expanded/increased level of effort which cannot reasonably be extracted into a separate requirement. In addition, all personnel must be TS/SCI cleared with a screening.

(2) Proposed sole source contractor. Peraton Services & Solutions Inc. is the incumbent contractor that is currently providing the instructional and eLearning development support services at the Training Academy. As detailed above, Peraton Services & Solutions Inc. will also be providing the expanded/increased level of

Page 5 of 9 Pages support via use of the Surge CLIN. They are the only vendor that is reasonably postured to provide the additional support not covered by the remaining Surge CLIN.

a. The proposed sole source contractor is Peraton Services & Solutions Inc.

Peraton is currently performing the work and creating the content utilized for instruction.

b. Peraton has performed on this requirement for more than 6 years with satisfactory or above CPARS ratings.

c. Additionally, Peraton uniquely equipped in that they are already familiar with the current requirement. Their familiarity with the requirement and expertise in this field allows a seamless and expedient transition with these new requirements and is beneficial to the Government.

d. Peraton is uniquely positioned to provide the additional course administration/records management support being added to the course accreditation support as it was a component of the student services support that they previously provided on the previous contract, prior to Government taking over that requirement.

e. Peraton possesses the core expertise and personnel to execute the tasks to support mission. Peraton demonstrates the understanding of current workload and are capable of ensuring there will be no degradation in quality of the requirement for the remainder of the PoP.

(3) Discussion regarding cause of the limited source situation. Competition would not be feasible, even if additional time was available to recompete the requirement due to the level of integration, coordination, communication, cohesiveness, and consistent training required for this effort. These requirements make it impossible to extract the portion of the effort being expanded/increased upon to be carved out to allow for competition. In addition, these services are required immediately due to expanded mission requirements and mission re-alignments. This is especially true with the impending . Furthermore, the time it would take to conduct a competitive procurement, coupled with the stringent requirements of the process would put the Government at risk of not meeting the mission requirements.

The level of integration, coordination, and communication necessary for this effort and described above, inherently connects the existing instructors to the increased effort services in such a manner that if the requirement were procured from another contractor, the contractors from each contract would be dependent on the other to create and produce specified deliverables in order to fulfill contractual requirements.

While the Government could compel two separate parties to collaborate, it adds in a significant degree of difficulty and leaves the Government vulnerable to contractual maleficence and unenforceability.

Furthermore, another major constraint is security requirements. All assigned personnel must possess a TS/SCI clearance and go through the stringent requirements of the process. Due to security protocols, this

Page 6 of 9 Pages rigorous process is unable to begin until a contract has been awarded and the period of performance has begun. This leads to significant delays in onboarding and contract performance. This process can take up to for the process itself. This delay will adversely affect both mission due to limited and/or inadequately trained staff.

(4) Demonstration of limited source. As mentioned above, due to the integration, coordination, and communication required to implement these required changes other MAC holders would not be capable of meeting the stated requirements. Peraton Services & Solutions Inc. retains a cadre of vetted personnel and is able to provide the necessary staff immediately. At the same time, Peraton will be able to seamlessly coordinate between the existing instructional support team, the additional position, the additional , and the dedicated slated for peer review of existing class material and product management. In addition, Peraton has prior experience performing the product management, peer review, and COE accreditation services that are being added on similar contracts. Peraton is best situated to take the appropriate actions now to meet this emergent requirement.

Peraton is the only vendor that is reasonably postured to provide the additional support for the expanded/increased mission requirements without endangering the Government to experience any lapse in training, prior to

(5) Procurement discussion.

The has a mission critical need to expand and increase the current level of instructional support and eLearning development services on the task order to support expanded mission. The Government will be utilizing the Surge CLIN to fund this increased/expanded level of effort. The Surge CLIN ceiling available on this contract is ; however, it is expected, based on the Independent Government Cost Estimate that the full cost of this expansion will exceed the available surge ceiling by approximately . This modification will be funded with 2023 Operations and Maintenance funds with an anticipated effective date of August 1, 2023.

Major constraints for this procurement are the security requirements, the level of integration, coordination, and communication required for this effort, lack of or inadequately trained personnel. All assigned personnel must possess a TS/SCI clearance and go through the stringent requirements of the process. The security requirement in and of itself significantly reduces the availability of personnel who can fulfill the listed requirements. Recompeting this requirement and awarding to a new contractor would cause a lapse in the quality and continuity of services, given that the Government is not required to make contractors collaborate with each other if the additional work is recompeted and the remaining work stayed as it is currently. Finally, the is fast approaching and the

Page 7 of 9 Pages has a lack of trained personnel to adequately support the mission.

Any lapse in training would be detrimental to the mission.

(6) Impact.

If the source is not appropriately limited, the mission may be detrimentally affected due to a lapse in the quality and continuity of services, as the Government is not required to make contractors collaborate with each other if the additional work is recompeted and the remaining work stays as it is currently. Historically, the OPTEMP for personnel significantly increases

. With the impending it will be detrimental to have an inadequately trained workforce and filling these new training requirements will be crucial in developing a larger pool of sufficiently trained personnel to support the increased/expanded mission.

5. BEST VALUE DETERMINATION:

GSA has already determined that prices of the fixed price services are fair and reasonable for the purpose of establishing the schedule contract. However, the KO is still required to make a determination of fair and reasonable pricing for individual orders using the proposal analysis techniques at FAR 15.404-1. The complexity and circumstances of the acquisition should determine the level of detail and analysis IAW FAR 8.404(d) for acquisitions under FAR 8.405- 2(d).

6. MARKET RESEARCH:

The Training Academy Contracting Officer Representative and the Alternate Contracting Officer Representative conducted market research from March 10, 2023 – May 1, 2023 to support exercising the option year two of the current contract and acquiring the additional support services required by this effort. This market research covers current and new requirements that would start with Option Year Two, with a Period of Performance of August 1, 2023 to July 31, 2024. An informal analysis was performed utilizing the DISA Market Research Repository, Contract-Awarded Labor Category + (CALC+), and Federal Procurement Data System. No additional training contracts could be located that required both highly skilled instructors and eLearning developers that were also cleared at the TS/SCI level with a

. Furthermore, market research was performed on the same Labor Categories (LCATs) that are on the current contract, to ensure that the current contractor could perform them at a fair and reasonable price. The current LCATs obtained from the CALC+ show costs are in-line with LCAT rates obtained during the market research conducted on May 1, 2023 for Option Year Two extension, which is still relevant.

Based on current market research, dated May 1, 2023, it has been determined that only the aforementioned service provided by Peraton Services & Solutions Inc., can fully meet the Government’s need. The Government will continue to conduct market research to determine if there are changes in the marketplace that would enable future competitive actions.

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7. ANY OTHER SUPPORTING FACTS:

Contractors on this requirement must have a TS/SCI clearance with a and level of access prior to performing on this requirement.

8. ACTIONS THE AGENCY MAY TAKE TO REMOVE BARRIERS THAT LED TO THE

RESTRICTED CONSIDERATION: (FAR 8.405-6(c)(2)(viii))

(a) Procurement history.

(1) GS-35F-0323J/HC104715F0016, March 31, 2015, Competitive, Full and Open, Large Business.

(2) GS-35F-146DA/HC106420F0079, July 30, 2020, Competitive, Full and Open, Large Business.

(3) GS-00F-296CA/HC104721F4002, July 29, 2021, Competitive, Full and Open, Large Business.

(b) Any follow-on contracts will be recompeted on a full and open basis capturing all increased/expanded agency training requirements.

(c) Previous awards were issued on a full and open basis. However, new requirements given to have increased/expanded mission. Any future requirements will capture this increased/expanded mission from the offset.