Limited Source Justification_FAR Part 8_W9124J-20-F-0110_FASOR IT Sustainment_final III_100720_Redacted.pdf

Control No: MICC 2020-82 Contractor: Three Wire Systems, LLC

Program/Equipment: FASOR IT Sustainment & Modernization

Version – September 2018 FOR OFFICIAL USE ONLY

JUSTIFICATION REVIEW DOCUMENT

FAR 8.405-6 LIMITED SOURCES JUSTIFICATION

UNDER THE GENERAL SERVICES ADMINISTRATION

FEDERAL SUPPLY PROGRAM

Program/Equipment: Family Advocacy Program (FAP) Family Advocacy System of Records (FASOR) IT Sustainment and Modernization

Authority: Title III of the Federal Property and Administrative Services Act of 1949 (41U.S.C. 251, et. Seq) and Title 40 U.S.C 501, Services for Executive Agencies, as implemented by FAR 8.405-6.

Amount: $12,437,524.00

Reviews: I have reviewed this justification and find it adequate to support limiting competition.

Program Manager:

Control No: MICC 2020-88

Program/Equipment: FASOR IT Sustainment & Modernization

Version – September 2018 FOR OFFICIAL USE ONLY

Small Business Specialist, Small Business Program:

MICC Legal Counsel:

Contracting Office Mission Division Chief:

Director, MICC-Fort Sam Houston:

Assistant Director, Small Business Program:

FAR 8.405-6 Limited Sources Justification Under the General Services Administration

Federal Supply Schedule Program

1. Contracting Activity: U.S. Army Mission and Installation Contracting Command (MICC) - Fort Sam Houston, Mission Support Division, 2205 Infantry Post Road, Fort Sam Houston, TX 78234.

2. Description of Action: Family Advocacy Program (FAP), Behavioral Health Division, Healthcare Directorate, Headquarters (HQ), U.S. Army Medical Command (MEDCOM) requests a firm-fixed price task order under the General Services Administration (GSA) Federal Supply Schedule (FSS) Program with Three Wire Systems, LLC, 3130 Fairview Park Drive, Suite 425, Falls Church, Virginia 22042. The Government will execute this action against FSS contract GS-35F-0300T. Projected award is August 2020 and fiscal year 2020, Research, Development, Test & Evaluation (RDT&E) and Operations and Maintenance (OMA) funds will be used.

An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d)(i)(B).

3. Description of Supplies/Services: This requirement is for the sustainment and modernization of the FASOR IT system. FASOR is the authoritative data source for Army child and adult abuse incidents that are referred to the FAP. This effort will procure IT software development expertise to translate a legacy FASOR IT system from a proprietary language to a non-proprietary platform; migrate current FAP data from the legacy system to the modernized system; move the system into a cloud environment;

develop new components to meet FAP requirements/mandates; obtain a .mil accreditation (Authority to Operate/ATO) in the cloud environment; sustain and support Cyber Security of the legacy system until all users are moved off of it and onto the modernized FASOR system; and sustain and support Cyber Security of the modernized system. Specifically, the contractor shall provide the following services:

a. Sustainment of the legacy/existing FASOR version for approximately 2 years;

b. Translation of FASOR’s proprietary platform and code into a standard platform (e.g. Windows .NET);

c. Re-hosting of FASOR from a physical, .org environment, to a virtual, .mil cloud environment;

d. Provide Cyber Security expertise to use the Risk Management Framework (RMF) process to obtain a new FASOR ATO in the Cloud environment;

e. Modernization of FASOR to add new modules/components needed to comply with DoDI 6400.01 and its related volumes;

f. Data migration from the legacy system to the modernized system;

g. Deployment of the modernized system and train FAP personnel worldwide on the modernized system;

h. Change management expertise to track requirements and changes to the legacy & modernized systems; and

i. Sustainment and information assurance services to sustain the modernized

FASOR along with its new ATO.

Items a – d above should occur during the base and Option Period 1 provided the contractor has the required Xtendable Server technology expertise. Planning and storyboarding for item e can begin during the performance of the first four (a - d) items, and will occur continuously over 5 phases, with the first phase starting during the base year and the last phase occurring in Option Period 4. Items f and g above will occur at the conclusion of items a – d. Item h must occur throughout all phases and across the whole contract period of performance. Item i will begin after items f and g above and will continue indefinitely. Ultimately, successful completion of these items depends heavily on a contractor with the required Xtendable Server technology and FAP expertise.

U.S. federal laws mandate all military Services to implement the Office of Secretary of Defense (OSD) FAP in accordance with Department of Defense (DoD) directives.

These directives and U.S. Army regulations require FAP data collection and retrieval for historical checks, child and adult abuse incident management, and reporting to Congress, DoD and Army. The National Defense Authorization Act (NDAA) has mandated FAP requirements since 1981. Current proposals in the U.S. House of Representatives and the U.S. Senate require an expansion of FASOR tracking/registry system (see FY 2021 HR 6395 Sec 537 & 538 AND S4049 Sec 575). There is no substitute system that can track the data in order for the Army to produce the required reports for Congress.

Period of performance:

Base Year: 28 August 2020 – 27 August 2021 Option Period 1: 28 August 2021 – 27 August 2022 Option Period 2: 28 August 2022 – 27 August 2023 Option Period 3: 28 August 2023 – 27 August 2024 Option Period 4: 28 August 2024 – 27 August 2025 FAR Clause 52.217-8: 28 August 2025 – 27 February 2026

Total Value: $12,437,524.00

4. Authority Cited: Title III of the Federal Property and Administrative Services Act of

1949 (41U.S.C. 251, et. Seq) and Title 40 U.S.C 501, Services for Executive Agencies, as implemented by FAR 8.405-6 and substantiated by 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.

5. Reason for Authority Cited: FASOR IT system is the Army’s IT system of record used by FAP to execute DoD FAP policy and directives. Three Wire Systems, LLC is the sole owner and authorized user of the aging and proprietary Xtendable Server technology (platform and language) which comprises the FASOR IT system, as well as the only company possessing the required level of knowledge and experience with the aforementioned technology to successfully perform the required services. As a result of owning the licenses and rights to the technology used to develop the FASOR IT System source code, no other contractor may have access to the system and its source code, much less work on the system, without prior authorization from Three Wire Systems, LLC. Three Wire systems, LLC has not authorized any third party resellers to have access to this proprietary system and source code. Therefore, Three Wires Systems, LLC due to exclusive rights to the proprietary source code and the only one with the ability to work on the FASOR system, is the only source capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

a. Background.

Defense Web Technologies, the original designer/developer of the FASOR IT System, began building the Army FASOR using their proprietary Xtendable Server technology in 2005. They continued to work on FASOR through 2014, when Humana acquired Defense Web Technologies. At that time, Humana decided to drop all Federal Information Technology projects, to include FASOR, prompting Defense Web Technologies to identify Three Wire Systems, LLC as the exclusive Xtendable Service provider to continue support, maintenance, and eventually retire the proprietary Xtendable Server platform. Outside of Defense Web Technologies and Three Wire Systems, LLC, no other contractor has worked on the FASOR IT system. Because of this, when Georgia Tech Research Institute (GTRI) was awarded contract W31P4Q-18- D-0002 in 2018, they have been forced to limit their involvement with performing translation of the source code to meet new standard requirements. Subsequently, GTRI has subcontracted all work to Three Wire Systems, LLC relating to the sustainment of the FASOR IT system and the modification/updating of the source code. Defense Web Technologies issued the Government a perpetual licenses for the Xtendable Server core and the libraries that existed at the time, including everything related to the FASOR IT system. The Xtendable Server core includes everything needed to set up a basic web site. Three Wire Systems, LLC has continued to develop additional FASOR IT system libraries and features, which are their intellectual property. No other contractor has access to these libraries and, therefore, the full FASOR IT system code suite.

Presently, the FASOR IT system exists on Xtendable Server technology and this requirement will move the system from this proprietary language to a non-proprietary platform. However, the Xtendable Server platform is quickly becoming obsolete technology that does not meet .mil domain compliance requirements or support the Army’s IT data sharing strategy of the future. As a result, it is extremely difficult to find experienced and qualified technicians. Personnel currently with Three Wire Systems, LLC were initially hired for key positions in 2014 from their previous positions with Defense Web Technologies. These personnel developed the FASOR IT system and currently work to sustain and update it to meet Government requirements, as well as maintain a compliant cyber posture. Three Wire Systems, LLC is the only company with the required level of knowledge and experience with the proprietary Xtendable Server technology, access to the full source code suite, and the familiarity of the day-to-day duties of Military Family Programs, to include the FAP.

The FAP mission is military unique in its efforts to prevent, manage, and treat victims and offenders in child maltreatment and domestic abuse in the Army. The FAP operates under the authority of U.S. laws for child abuse and victim advocacy and implements the program in the military services in compliance with the Army Regulation 608-18, The Army Family Advocacy Program, and DoD Instruction 6400.01 Family Advocacy Program, which govern the service-unique capabilities that FAP and FASOR must provide. Parts of the FAP mission include, but are not limited to, Child and Adult Abuse prevention, management and treatment, Domestic Abuse Victim Advocacy, New Parent Support Program and Problematic Sexual Behavior-Child and Youth. FAP mission requirements are specific to the military, operate globally on U.S. military installations, and require annual reporting to Congress. FASOR is the information system used to manage incidents of adult and child abuse referred to the Army.

Knowledge of the FAP mission and its unique requirements would be highly difficult for a contractor not currently aware of Congressional, DoD and Army mandates for the FAP. Three Wire Systems, LLC has extensive knowledge of the FAP programs and mandates.

FAP has a complex clinical decision-making algorithm (decision tree algorithm) as well as regulations that come from the National Defense Authorization Act, the DoD, the Department of the Army, and MEDCOM; all of which can change from year to year.

Some of the FAP subprograms intersect and are interdependent at times. One of these subprograms shares data with the other applications on the platform on which it resides.

Various levels of hierarchy within the FAP (e.g. FAP Manager, FAP Chief, FAP supervisor, FAP Administration & Command), and across organizations from Medical Treatment Facilities, to MEDCOM Regions, to Headquarters MEDCOM, require their own rules, roles, and access to FASOR for data release, data analyses, and reports.

The release of information varies from Health Insurance Portability and Accountability Act (HIPAA), to Personally Indentifiable Information (PII), to third party, or a combination thereof.

The FASOR IT system supports four essential tasks related to Army readiness:

Adult and child incident management (required by federal law and DoDM 6400.01/FAP and its related volumes);

Army Central Registry (ACR) abuse data collection for reporting to

Congress, DoD and Army (required by DoDM 6400.01 Volume 2 and Army Regulation 608-18/Army FAP);

Installation records checks (required by DoDM 1402.05/Background Checks on Individuals in DoD Child Care Services); and

Hosting of the Case Review / Incident Determination Committee algorithm to comply with DoD definitions of abuse, which is used by Army installation garrison commanders to manage the Case Determination Committee (CDC)/ Incident Determination Committee (IDC) committee processes (required by DoDM 6400.01 Volume 4).

The FASOR system is the authoritative source for adult and child abuse incidents and is on the Army's High Value Asset list. High Value Assets are those assets, Federal information systems, information, and data for which an unauthorized access, use, disclosure, disruption, modification, or destruction could cause a significant impact to the United States' national security interests, foreign relations, economy, or to the public confidence, civil liberties, or public health and safety of the American people.

HVAs may contain sensitive controls, instructions, data used in critical Federal operations, or unique collections of data (by size or content), or support an agency's mission essential functions, making them of specific value to criminal, politically motivated, or state sponsored actors for either direct exploitation or to cause a loss of confidence in the U.S. Government. The FAP’s business processes and requirements include, but are not limited to:

Record keeping by DoD and Army standards.

Record management processes for a "family record" involving multiple individuals (open, monitor, manage, transfer, close, re-open).

Case management meeting regulatory guidance (high-risk severe cases require contacts that are more frequent).

Fatality data collection, management and reporting.

Reports generation for local prevention and treatment management.

Problematic sexual behavior of children and youths incident data collection, management and reporting (all Army installations).

Intimate partner adult abuse and child abuse data collection, management and reporting.

Background checks for Childcare and Criminal Investigation Department.

Electronic Health Record documentation.

HIPAA and Privacy Act processes tailored to the military.

Data collection requirements for Congress, DoD, Army, researchers and other vested agencies.

Transitional Compensation eligibility.

Training requirements for FAP and Commanders.

The FAP has complex business rules unlike traditional case management. A typical case management system (CMS), such as the Army ACS Client Tracking System or medical Case Management System, is based on adding a person or case to the system and then adding events that happen to the person throughout the tracing history. The case can be associated with other cases in the system or collateral contacts, which are not cases. FASOR however is completely different and is unlike any other system.

Following are a few examples of complex FAP business rules:

Example 1: FASOR is actually an incident tracking system. Rather than all incidents revolving around a person/case, it is all persons revolving around an incident.

Example 2: There is significant complexity in FAP incident roles and Army Regulations/Uniform Code of Military Justice (UCMJ) definitions of roles. Within an incident (case) there are victims who may be sponsors, family members, sponsors who may be offenders, victims or neither, and offenders who may be sponsors, family members or neither or unknown persons. There are also victims, offenders and sponsors related to government childcare situations. Complications arise in defining the code and the outcomes when there are blended families and when there are cross-accusations (two family members accuse each other of abuse) of family maltreatment, as well as in dual military families where the sponsor may be mom for one child and the dad may be a sponsor for the other child (because that child is from a previous marriage), or the sponsor may be neither the victim or the offender because the father and step mother have been accused of maltreatment for his child of a previous marriage, but his military ex-wife is the sponsor. Significant complexity exists for the criteria for substantiation of maltreatment – physical abuse, sexual abuse, emotional abuse or neglect. Periodically, there are changes to policy or laws and these changes affect many places in the FASOR IT system. A FASOR modernization will magnify these changes without a complete understanding of their effects. For example, if a criterion is added to a form of abuse or even one (1) word is changed, this will affect how the rules engine deals with the selection of this criterion. If a new exclusion is added, it is not as simple as adding it to the list on a form. Understanding where it is wired in throughout the code to affect the rules engine, the CRC, the reports, the background check and the way Xtendable holds data in the cache rather than writing it to the database, is essential to making it work.

Example 3: Significant complexity occurs when transferring incidents. If an incident requires a transfer to another Army installation, it is imperative for accurate Congressional reporting that the FASOR IT system records the incident properly so that it is not under or over reported by duplication. If the incident occurs on installation A, but then requires a transfer to installation B, the proper reporting must be made for how many incidents occurred. An incident cannot be completely removed from installation A, nor can it be added to installation B, implying that the incident occurred there. This is especially a concern with regard to the Xtendable code, as the database is the primary mechanism for this function. The Xtendable technology database is not a traditional relational database in that it does not write data directly to the database. It holds in it cache until the system finds it convenient to do the task. Only the Xtendable database knows the status and content of all FASOR data. Three Wire Systems is the only contractor that fully knows and understands this.

Example 4: The Background Check functionality and accuracy is essential to preventing a known or suspected offender from having additional opportunities to offend by becoming a youth coach or other role where they may have access to vulnerable populations. Sister services also utilize the background check when dealing with cross service situations. Errors in this process risk the safety of Army Families or improper accusations if someone who is actually a victim, or the sponsor of a victim, shows positive in the background check. For example, if somebody codes or changes this module improperly, a service member whose child was spanked improperly at an Army daycare could be denied being a chaperone for a field trip because he is positive on the background check as an offender.

The DoD FAP, and by extension the FASOR IT System, is congressionally mandated to prevent and respond to reports of child abuse/neglect, domestic abuse, and problematic sexual behavior in children and youth in military families. Army Regulation 608-18, The Army Family Advocacy Program, and DoD Instruction 6400.01 are unique to the DoD FAP. They receive periodic updates as well as new guidance with imposed implementation suspenses. FASOR is currently non- compliant with changes made to FAP directives requiring IT system updates since 2016 – some changes are critical and require immediate implementation.

Per Army Directive 2016-38 (Migration of Army Systems and Applications to Approved Hosting Environments and Consolidation of Data Centers), FASOR must move to a .mil domain hosting environment to become compliant with DoD and Army Cyber requirements. It is currently on an .org hosting site and requires an extensive technical effort to move to a .mil hosting site. This involves a complete translation of the current proprietary code to non-proprietary code without any loss of functionality or performance. It also involves other IT technology enhancements (e.g. DOD Active

Control No: MICC 2020-88

Example 3: Significant complexity occurs when transferring incidents. If an incident requires a transfer to another Army installation, it is imperative for accurate Congressional reporting that the FASOR IT system records the incident properly so that it is not under or over reported by duplication. If the incident occurs on installation A, but then requires a transfer to installation B, the proper reporting must be made for how many incidents occurred. An incident cannot be completely removed from installation A, nor can it be added to installation B, implying that the incident occurred there. This is especially a concern with regard to the Xtendable code, as the database is the primary mechanism for this function. The Xtendable technology database is not a traditional relational database in that it does not write data directly to the database. It holds it in cache until the system finds it convenient to do the task. Only the Xtendable database knows the status and content of all FASOR data. Three Wire Systems is the only contractor that fully knows and understands this.

Directory linkage) before going through the Cyber Security Risk Management Framework (RMF) process to obtain an Authority to Operate (ATO) that authorizes the FASOR IT system to be on a .mil network, in accordance with DODI 8510.01 Risk Management Framework (RMF) for DoD IT. It also involves maintaining the legacy FASOR IT system and code while concurrently standing up a refreshed (recoded/ translated) FASOR IT system in a virtual, .mil environment. Three Wire Systems, LLC is the only company that knows and owns the full FASOR code suite, and the only company capable of accomplishing this extensive requirement within acceptable schedule and cost estimates.

The current FASOR IT system’s technology is obsolete and remains non-compliant with Cyber Security requirements (e.g., .mil compliance and virtual/Cloud hosting). The FASOR IT system has Cyber Security’s conditional approval to continue operating only because the Program Management Office (PMO) is showing efforts to make the FASOR IT system compliant (e.g., awarding this contract). At present, FASOR has until 06 September 2020 to become compliant. However, the FASOR PMO is seeking to obtain a 12 to 18-month extension. Successfully executing this contract and all tasks will satisfy the FASOR PMO’s requirement to become FAP and Cyber Security compliant.

If the FASOR IT system is not available, the Army FAP mission will fail. The FASOR IT system is required to operate without interruption 24x7 under Congressional mandate. The system is used by the FAP to track and handle cases of adult and child abuse (approximately 12,000 Army incidents are captured annually), incidents of which can occur at any point during the day, so a fully functional system operating continuously is paramount to ensure all incidents may be reported and recorded, as well as to avert mission failure. The FASOR IT System’s data collection for child abuse and domestic violence incidents is equivalent to any medical treatment incident requiring an automated system for data capture. Without the FASOR IT system, FAP caseworkers will have to resort to collecting information by hand using pen and paper, which would create detrimental impacts to the FAP mission, including:

Nullify real-time management of offenders due to lack of visibility of all parties to the paper-based record.

Nullify real-time reporting of childcare background checks from FASOR required for federal employment (applicants and current personnel).

Nullify data integrity for accurate reporting to Congress, DoD and Army due to mistakes, non-standardized data collection, and inconsistent reporting of information.

Create inefficiency, variance and de-standardization of the FAP program processes (incident data collection, management, and reporting) due to the number of personnel required to hand document into the FAP record.

Impede incident management by FAP personnel due to only one paper-based record being available when multiple personnel require the FAP record.

Decrease efficiency and timeliness of incident notifications to commanders, offenders, victims, sponsors and family members (such as FASOR auto-generated letters).

Decrease efficiency of the IDC/CRC committee incident determination process due to use of a paper-based algorithm instead of the automated version in FASOR.

Impact the FAP budget and allocation of funds, as additional personnel would be needed to hand record incidents (requiring increases to funding).

Decrease response time to Freedom of Information Act requests due to having to hand-type letters and information in forms.

Create a safety risk to victims and impede active support to victims of abuse due to non-visibility of current or past incidents by FAP personnel.

Create an undue administrative burden on FAP personnel due to the high volume of handwritten notes required to manage an incident (intake, referral, risk assessment, safety plans, clinical assessment, incident summaries, treatment plans, case management notes and plans, transfer summaries, letters, incident status determination summaries and meeting minutes).

Medical and FAP staff who manually capture critical incident information must then find time to enter information manually into an automated system. Further, if the FASOR IT system remains offline for any period of time, the FAP leadership will not have access to processed data and therefore, cannot accurately report abuse incidents in the mandatory quarterly and yearly Congressional reporting requirements. This will result in the Army becoming non-compliant with DoD mandates.

b. Alternatives.

There are no alternatives to an award to Three Wire Systems, LLC. The FASOR PMO does not have internal expertise to perform the work. Costs to expand the FASOR PMO would require authorization of many new civilian positions, which is not feasible with all the reorganizations and budget reductions. This contract will essentially extend the PMO’s resources to accomplish the FASOR system modifications. The FASOR PMO cannot suspend operations because, as previously stated, the FASOR IT System is congressionally mandated to run 24x7 to meet operational and accessibility requirements, as abuse incidents can occur at any time.

c. Impact if justification request is not approved.

Failure to award to Three Wire Systems, LLC will cost the government more money and time for an upfront transition of software/hardware that will cause mission interruption of approximately one (01) year delay in the product development and an additional $1 million in costs. Potential disparities in functionality between the legacy and modernized FASOR IT systems are likely to occur due to the vendor not having access to the full FASOR source code suite. Three Wire Systems, LLC currently performs required Cyber Security activities that support the existing ATO-C. Awarding to them would not require a new ATO and would save one (01) to two (02) years of labor and Independent Verification and Validation (IV&V) efforts that the RMF process requires, as well as approximately $150 thousand. Additionally, there is a high probability the FASOR IT system will be forced to shut down, and notifications to high-level leadership (DoD, HQDA, DHA, OTSG/MEDCOM Command, Acquisition Command, etc.) of the complete failure to provide 24/7 continuous operation of the FASOR IT system. Current FASOR operations include a primary data center (currently in San Diego), a disaster recovery site (currently in Arizona) and all the firewalls and other required hardware, to set up and operate. Three Wire Systems, LLC, has a complete operational FASOR sustainment infrastructure. This includes the capabilities for development, testing, staging, training and production environments managed with robust change and configuration management tools and processes. This also includes 24/7 server monitoring, daily Cyber Security information flow regarding threats and patches that they must apply to the servers, a code repository and sprint documentation system as well as the history and documentation for ten (10) years of tickets and code.

All personnel have the required training certificates, CACs and tokens to access the FASOR servers. Awarding to Three Wire Systems, LLC will save nine (09) or more months of procurement and setup time and will eliminate the high risk of losing critical FASOR code and data, Cyber Security compliance, etc. Three Wire Systems, LLC sustains and operates these environments for FAP, which would continue uninterrupted, saving extensive delays and additional costs if Three Wire Systems, LLC received this sole source contract.

6. Actions to Increase Competition: The FASOR PMO is taking steps to foster competition in the future by having the FASOR proprietary code that is based upon Xtendable Server technology, translated to open source code software as part of this contract. This will allow more companies to compete for FASOR’s future technical requirements.

7. Market Research: Market research has been ongoing since the inception of this requirement and continuing during the drafting of this document, conducted by both the requiring activity and contracting office.

a. Initially, The FAP and MEDCOM worked with Communications-Electronics Command (CECOM) for this procurement action. CECOM was functioning as a liaison

Program/Equipment: FASOR IT Sustainment & Modernization

Version – September 2018 FOR OFFICIAL USE ONLY between MEDCOM and the Army Contracting Command – Aberdeen Proving Ground (ACC-APG). ACC-APG publicized a Request for Information (RFI) in 05 December 2019 seeking companies with the technical ability to perform under the PWS, while also holding an 8(a) status. The RFI closed on 11 December 2019, with six (06) respondents submitting their capability statements for review.

b. The six (06) respondents, included two (02) 8(a) contractors, two (02) small business, and two (02) large businesses; among these was Three Wire Systems, LLC.

ACC-APG performed an analysis of the information and sent it to CECOM and the MEDCOM. It was determined that the requirement was not only unsuitable for inclusion in the Small Business Administration’s (SBA) 8(a) program, but unsuitable for competition as well. The analysis concluded that Three Wire Systems, LLC was the only contractor company technically qualified to perform the work based on the information provided. None of the other respondents were considered technically capable. This conclusion was supported by ACC-APG, in part because Three Wire Systems, LLC is the sole owner and authorized user of Xtendable Server technology (platform and language) which comprises the FASOR IT system.

c. Once the requirement was submitted for procurement to the MICC, as part of internal procedures a second RFI, under Solicitation PANMCC-18-P-0000 008525, was posted to the beta.SAM.gov government-wide central website, on 26 March 2020 with responses due no later than 08 April 2020. The Sources Sought indicated that the Army was seeking information for planning and informational purposes only and requested all firms to submit a capabilities statement demonstrating their experience in the computer services field. A total of nine (09) contractors responded and provided their capabilities statement. After the requiring activity completed their review of the capability statements, only that submitted by Three Wire Systems, LLC was determined to have the capacity and experience to perform the required services. In addition, the PWS was submitted to GSA points of contact for an in scope review to determine compatibility within the Alliant 2 program, VETS 2GWAC or Schedule 70.

The results of this review determined that the PWS is compatible under all three (03) groupings: Alliant 2 program; VETS 2GWAC; and 70 schedule under SIN 132-51 (54151S) Information Technology Professional Services. Three Wire Systems, LLC has an active GSA Schedule (GS-35F-0300T) under SIN 132-51 (54141S).

d. The market research confirms that Three Wire Systems, LLC, is the only contractor that can sustain the legacy FASOR due to the Xtendable proprietary code.

Research provided by the requiring activity, along with that conducted by the contracting office, and the results of the sources sought confirmed the services should be available through the GSA 54151S schedule category to Three Wire Systems, LLC as a under their active GSA Schedule (GS-35F-0300T).

8. Other Facts:

a. Procurement History

a. Procurement History

Program/Equipment: FASOR IT Sustainment & Modernization

Version – September 2018 FOR OFFICIAL USE ONLY

Contract: W31P4Q-18-D-0002; W31P4Q-18-F-0130 Contractor: Georgia Tech Applied Research Corporation (GTRI) Period of performance: 26 September 2018 – 25 September 2020 Competitive Status: Full and Open Competition

b. Work on the FASOR IT tracking/registry system under Contract #W31P4Q- 18-D-0002 and Task Order #W31P4Q-18-F-0130 has been sub-contracted out to Three Wire Systems, LLC, which is currently completing performance as the contract reaches the end of the last option period.

c. Three Wire Systems, LLC has worked on other government information technology projects for over 14 years, including the Army and Air Force FAPs and with other DoD agencies, to include the Department of Veterans Affairs and the National Guard. Three Wire Systems, LLC is aware of the specificity and complexity of the FAP requirements in FASOR and can start work right away without a steep learning and training curve.

Control No: MICC 2020-88

b. Work on the FASOR IT tracking/registry system under Contract #W31P4Q-18- D-0002 and Task Order #W31P4Q-18-F-0130 has been sub-contracted out to Three Wire Systems, LLC, which is currently completing performance as the contract reaches the end of the last option period.

c. Three Wire Systems, LLC has worked on other government information technology projects for over 14 years, including the Army and Air Force FAPs and with other DoD agencies, to include the Department of Veterans Affairs and the National Guard. Three Wire Systems is aware of the specificity and complexity of the FAP requirements in FASOR and can start work right away without a steep learning and training curve.

Program/Equipment: FASOR IT Sustainment & Modernization

Version – September 2018 FOR OFFICIAL USE ONLY

9. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

10. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

11. Best Value Determination/Fair and Reasonable Cost Determination: I hereby determine that the order represents the best value to the Government in accordance with FAR 8.405-6(c)(2)(v). Additionally, I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. This determination will be made using Price Analysis and the IGCE. Evaluation of price will be performed using one or more of the price analysis techniques for commercial items in FAR Part 13.106-3(a) to determine price reasonableness. If price reasonableness cannot be determined using price analysis of Government obtained information, additional information in accordance with FAR Part 15.402(a) may be required from the Offeror to support the proposed price.

12. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Program/Equipment: FASOR IT Sustainment & Modernization

Version – September 2018 FOR OFFICIAL USE ONLY

Approval

Based on the foregoing justification, I hereby approve the procurement of FASOR IT Sustainment and Modernization under Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et Seq.) and Title 40 U.S.C 501, Services for Executive Agencies, as implemented by 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. The estimated value of the contract is $12.44 million for a five year period of performance consisting of a base year and four option years, from 28 August 2020 through approximately 27 August 2025. The option of FAR Clause 52.217-8 is also included for an additional six months if exercised. The approval is subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.

SCOTT D. KUKES

Alternate to the Command Advocate for Competition U.S. Army Mission and Installation Contracting Command, JBSA Fort Sam Houston, TX

KUKES.SCOTT.DE

AN.

Digitally signed by

KUKES.SCOTT.DEAN.

Date: 2020.08.26 21:14:50 -05'00'