Limited-Sources Justification (LSJ) SMTD 2-15-24 signed -_Redacted.pdf

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Advanced Interdiction and Counter Terrorism Instructional Support
Solicitation number
70Z02323FSMTC0001P00001
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About this file

This document is a Limited-Sources Justification (LSJ) for a federal contract opportunity. The Department of Homeland Security, United States Coast Guard (USCG), is procuring continued Advanced Interdiction and Counter Terrorism Instructor Support services for a 4-month period to ensure continuity of training for the Maritime Security Response Teams. The incumbent contractor is RMGS, Inc., and the estimated value of the modification is an increase from the current contract value of to . The justification cites FAR 8.405-6(a)(1)(i)(B) as the basis for the limited sources, noting that RMGS, Inc. provides unique and highly specialized instructors/trainers as subject-matter experts to facilitate the required high-risk training. A follow-on competition for a 5-year contract is currently in process, with the requirement set aside for Service-Disabled Veteran-Owned Small Businesses (SDVOSBs). The new contract is expected to be awarded by June 25, 2024.

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Limited-Sources Justification

Pursuant to the Multiple Award Schedule Program (as authorized by 40 U.S.C. § 501), this justification is prepared in accordance with the requirements of Federal Acquisition Regulation (FAR) 8.405-6(c) for the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3. The circumstance justifying restriction is FAR 8.405- 6(a)(1)(i)(B) through the following facts and rationale:

(1) Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Office of Contract Operations (CG-912), Formal Contracts Division I, on behalf of FORCECOM, prepared this justification on the basis of a limited-sources justification.

(2) Nature and/or description of the action being approved.

Address the following information:

(a) Nature of the action: Force Readiness Command (FORCECOM) requires continued service for Advanced Interdiction and Counter Terrorism Instructor Support for four (4) months to ensure continuity of services for delivering high risk readiness and capability training of all aspects of Counter Terrorism (CT) and Advanced Interdiction (AI) operations to two Maritime Security Response Teams

(MSRT).

(b) Name and address of the contractor:

RMGS, Inc.

500 VIKING DR, STE 302,

VIRGINIA BEACH, VA 23452, US

(c) Contract type: Firm-Fixed-Price

(d) Estimated total value (including options): The current value of the contract is . The estimated modification value is increasing the value from to .

Period Unit Price Total 52.217-8 4-month extension

Total

(e) Previously awarded under: 70Z02319APFC00100 RMGS Inc.

Period of Performance: 3/26/19-3/25/24

(f) Type of funding: Operations and support funds

(g) Year of funding: Fiscal Year 2024

(h) Solicitation number: 70Z02319QPFC00100

(i) Background information about the requirement:

CG 9121-1 is currently procuring these services; however, the need for continued support is needed to meet mission requirements while ongoing competition for the follow-on acquisition is being completed. The four-month option will extend the current period of performance through July 25, 2024. The current period of performance ends on March 25, 2024.

(3) Description of Supplies/Services.

The United States Coast Guard (USCG), Force Readiness Command, Special Missions Training Center, and Special Missions Training Detachments (SMTDs) in particular, deliver a broad range of initial, proficiency, and sustainment training that is deemed high risk, to the two Maritime Security Response Teams (MSRT) to enhance readiness and capability in all aspects of Counter Terrorism (CT) and Advanced Interdiction (AI) operations. This includes but is not limited to advanced individual weapons marksmanship; Close Quarters Combat (CQC); tactical insertions and extractions; Precision Marksmanship; and support of exercises that encompass Department of Homeland Security, USCG, Department of Defense, and other Federal Law Enforcement agencies. This training is mandated by several USCG policies, governed by Tactics, Techniques, and Procedure (TTP) publications, and associated training plans developed specifically for the USCG’s Deployable Specialized Forces (DSFs) of which the MSRTs are a member. This training delivery and oversight is predominately delivered by USCG active duty and civilian personnel, however, as the MSRTs mature and increase in size and operations, the Coast Guard has a requirement for contract trainer supplementation.

(4) Identification of the justification and the rationale.

• 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 statutory authority permitting extension of services is FAR clause 52.217-8. FAR clause 52.217-8, Option to Extend Services, provides the Government the option to extend contracts (or orders) for services for up to an additional six months. Consistent with FAR 37.111, it is appropriate to use FAR Clause 52.217-8 when the Government experiences a delay in awarding a subsequent follow-on contract that is outside of the control of the Government.

The contractor’s unique qualifications and/or specialized capabilities or expertise that are not prevalent elsewhere on the schedules are that RMGS Inc. provides instructors/trainers as authoritative, subject-matter experts, filling instructional and Range Safety Officer (RSO) roles to facilitate high risk training and other Command prioritized training to enhance the Coast

Guard’s Counter Terrorism and Advanced Interdiction operational capability. For another offeror to provide these services, a transition period would be necessary to ensure the new offeror has expertise with the Coast Guard’s requirement for Counter Terrorism and Advanced Interdiction requirements.

Any interruptions in the SMTD/FORCECOM’s instructional and training schedule would severely impact the Coast Guard’s ability to prepare a Mission Ready Total Workforce. The services provided by this contract are instrumental to SMTD/FORCECOM’s training capability and ability to effectively deliver required training programs for mission critical functions.

Specifically, delays could possibly result in loss of operational readiness of Maritime Security Response Team East and West. If the J&A is not approved, the Coast Guard would have USCG wide degraded counter-terrorism capability, and these impacts could be detrimental.

(5) Determination by the ordering activity Contracting Officer that the anticipated order represents the best value consistent with 8.404(d).

The Contracting Officer has determined that issuing the proposed task order to RMGS Inc.

represents the best value and will result in the lowest overall cost alternative, considering price and administrative costs, to meet the Government’s needs.

The contracting officer determines that the anticipated price is fair and reasonable based on prior acquisition IAW FAR 15.404-1(b)(2)(ii).

(6) A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research began in November 2020 and concluded that there are numerous small businesses that fall under the NAICS code 611699. APFS F2023063685 was published 02NOV2023. A search of DHS Strategic Sourcing Vehicles OASIS, PACTS II, and TACCOM II resulted that none were in scope with the required period of performance. A search of the existing Coast Guard Strategic Sourcing Vehicle FORCECOM Omnibus was reviewed and considered, however the instructor description in the PWS does not match the contract requirement. A search of existing intra/inter-agency contract vehicles/Federal Supply Schedules, specifically category 611430ST Security Training yielded no results within scope. A search of the Small Business Association’s Dynamic Small Business Search (DSBS) Quick Market Search showed 36-Economically Disadvantaged Women-Owned Small Business, 56-8(a) Certified or 8(a) Joint Venture, 90-Women-Owned Small Business, 216 Service-Disabled Veteran-Owned Small Business or Joint Venture, 24-Veteran-Owned Small Business or Joint Venture, and 20- HUBZone Certified Contractors under NAICS 611699 in the states of California and Virginia.

The technical office performed a search of the internet and found 9 SDVOSB and 1 Small Business deemed capable to perform the requirements of the contract.

USCG posted a RFI to SAM.gov on 24OCT2023 and received 14 responses. Of those responses, the following were deemed capable by the technical office: 5 SDVOSB, 1 Large Business, 1 Small Business. Based on the largest response which includes the incumbent, it was determined that the government could achieve maximum competition from the Service-Disabled Veteran Owned Small Business (SDVOSB) socioeconomic class.

(7) Any other facts supporting the justification.

None.

(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that preclude the agency from meeting the requirements of 8.405-1 and 8.405-2 before any subsequent acquisition for the supplies or services is made.

The USCG utilizes the Department of Homeland Security’s Acquisition Planning Forecast System (APFS) to notify industry of potential procurement opportunities as early as possible in the acquisition cycle. The APFS record for the current contract for SMTD, F2018043673, was published on 04DEC2018 to alert industry of this opportunity. AFPS Record for SMTD, F2023063685, was published on 02NOV2023 to alert industry of the re-compete opportunity that is currently in process. A Request for Information (RFI) notice 70Z02324QSMTC0001 was posted to SAM.gov on 24OCT2023 to inform the public of the USCG’s upcoming requirement and to gain information and capability from interested Contractors. The RFI explained the SMTD/FORCECOM instructional support requirement and requested interested parties provide a capabilities statement. 14 responses to the RFI were received.

This subsequent effort is being competed amongst SDVOSB for a five-year contract and will be awarded NLT 25June2024.

(9) Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Date Contracting Officer

(10) Technical/Requirements Personnel Certification.

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

Date

Technical Representative/COR

APPROVAL –

Date

Contracting Officer

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