LSJ - AICS Logical Follow-on Redacted.pdf

LIMITED-SOURCES JUSTIFICATION

FOR FEDERAL SUPPLY SCHEDULE (FSS) AWARDS

(FAR SUBPART 8.4)

IDENTIFICATION NUMBER (CONTRACT NUMBER): GS-35F-

0542P/89303018FAU400001 MOD TBD

Edgewater Federal Solutions, Inc.

1. IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY

The Department of Energy (hereafter referred to as “DOE”, “Agency” or “Department”) Office of Headquarters Procurement Services (MA-64), located in Washington, D.C., proposes to issue a Federal Supply Schedule (FSS) task order modification above the simplified acquisition threshold (SAT) by limiting the number of sources. This action is in support of the Office of Environment, Health, Safety and Security (EHSS). This document sets forth the justification for limiting sources in accordance with the circumstances described under FAR 8.405-6(a)(1)(i)(C), which states in part: “[i]n the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order.”

This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C. § 152(3) and 40 U.S.C. § 501).

2. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

The purpose of this sole source action is to issue a hybrid firm-fixed price and time-and-material modification to extend the performance period and add additional funding to GSA Schedule Task Order No. GS-35F-0542P / 89303018FAU400001. As a result of this proposed modification, the period of performance will be extended by an additional fifteen

(15) months, consisting of a base extension period of twelve (12) months, and one (1) three-month optional extension period. This will adjust the period of performance from November 23, 2018 – April 22, 2024 to November 23, 2018 – July 22, 2025. In addition, this proposed modification will increase the total value of the subject Task Order by approximately

Proposed Awardee Information:

Awardee Information:

o Name: Edgewater Federal Solutions, Inc.

o Address: 5280 Corporate Drive, STE C130, Frederick, MD 21703-8502 o Unique Entity Identifier (UEI): DA71PM1JFL51

GSA Schedule Number: GS-35F-0542P Task Order Number: 89303018FAU400001 NAICS: 541512 Computer Systems Design Services Estimated Value of Action:

DEMONSTRATION OF THE CONTRACTOR’S UNIQUE QUALIFICATIONS

Logical Follow-On FAR 8.405-6(a)(1)(i)(C) – In accordance with this authority, the new work is a logical follow on to an original FSS order. The original order was placed in accordance with applicable FSS ordering procedures, and the original order was not previously issued under sole source or limited sources procedures.

This action is a logical follow-on contract modification to extend services under an existing GSA Schedule Task Order that was competitively issued in accordance with the applicable GSA E-Buy ordering procedures. Solicitation No. DE-SOL-0010923 was competed amongst ten (10) Small Business FSS schedule holders on GSA E-Buy under SIN 54151S – Information Technology Professional Services. Seven (7) quotes were received and EHSS selected Edgewater Federal Solutions, Inc. (Edgewater) as the awardee under order number

89303018FAU400001.

EHSS, in conjunction with the Contracting Officer, have determined that it is in the best interest of the Government to award a logical follow-on extension to the incumbent contractor, Edgewater, as they are currently performing DOE’s complex and specialized IT systems security requirements successfully, and they possess all the requisite certifications, registrations, and resources to continue supporting several ongoing projects that have critical completion schedules. Award of a logical follow-on extension will capitalize on time and financial investment already committed to these projects. Transitioning tasks from the existing contract to a new vendor before these ongoing projects are completed would cause serious disruption to EHSS’s mission and would result in increased cost to achieve the end goal.

Below are examples of ongoing projects with critical completion schedules and performance challenges, whereby transitioning these to an alternate vendor would introduce substantial, avoidable cost risk and performance inefficiencies:

Name of Project

Project Start Date

Estimated Project Completion Date

Project Risks

OneEnrollment Application

September 1, Final Operating Capability Oct. 10, 2024, then continuation as operations and maintenance

Project provides an enhanced capability for identity management for DOE federal employees and contract employees. Delays in the project will impact the ability to meet cyber requirements for multi-factor authentication and enhanced identity management in zero trust. E.O.14028.

eDISS Trusted Workforce

(TW)

Upgrades

Oct 2022 TBD 2025 – Dependent on Office of the Director of National Intelligence (ODNI) and TW milestones

Project ensures that DOE will be able to meet TW requirements for continuous vetting of the DOE federal and contractor population.

eDISS O&M On-going On-going Ensures the secure operating configuration for the DOE Personnel

Security System application (eDISS).

eDISS is a high value asset within the DOE for the issuance and maintenance of DOE security clearances.

Transition to

NNSA

ESNHub Infrastructure

October 2022 June 2024 Project to unify classified networks across the DOE complex and DOE- HQ. This project will transition responsibility for the classified network and end user workstations from EHSS to NNSA. NNSA has been directed to provide a unified classified network for the Department.

Cyber Security On-going On-going Provides reviews, assessments, and approvals for EHSS managed networks, systems, and applications.

Ensures that EHSS managed IT is safe and secure for use by DOE and other federal agencies. Ensures that EHSS maintained IT does not pose a risk to other DOE networks and systems.

As indicated in the chart above, DOE has several critical projects that are in-process, and, collectively, maintain the overall integrity of the Department’s cyber security infrastructure.

Each of these projects are multi-faceted in nature; include numerous steps for successful completion (e.g. continuing operations support of multi-factor authentications and transitioning classified networks across DOE & NNSA workstations); and involve multiple rounds of preliminary assessments, plan submissions, reviews, and approvals between both the contractor and DOE prior to final implementation. Transitioning any of these critical tasks midstream from the incumbent contractor to a new contractor would essentially halt any progress under these tasks and would greatly increase the likelihood that significant Government and contractor resources would be spent reworking steps previously completed, resulting in avoidable cost duplication and scheduling delays in implementing these critical security upgrades.

Tasking associated with the follow-on GSA FSS Order modification will be highly integrated with the ongoing projects referenced above and would require the contractor to immediately assume responsibility for all elements of project performance (including any cybersecurity decisions proposed by the prior contractor) to successfully make progress as needed. In serving as the incumbent contractor for the referenced projects and having successfully performed under the existing GSA Task Order, Edgewater stands as a highly qualified source for continuing the follow-on support services required for this effort.

In addition, Edgewater has a number of key and non-key personnel who currently possess the required “Q” security clearances. Obtaining a “Q” clearance can take anywhere from 6 months to a year, so a new contractor would need to hire staff from the incumbent or hire personnel with the appropriate clearances in a short period of time. In past procurements of this nature, contractors have proven to be unsuccessful in their efforts to obtain “Q” clearances quickly, which has caused major performance issues. EHSS cannot take this risk, given the critical nature of these services, which are integral to the security and safety of the Agency’s employees and sensitive materials.

The Government anticipates gaining further economy and efficiency by continuing with the current vendor beyond April 2024 due to the institutional knowledge and intellectual capital gained through performance of the original contract that cannot be transferred to a new contractor without a substantial duplication of time resulting in a duplication of costs, missed milestone deliveries and delays of future projects.

5. DETERMINATION OF THE BEST VALUE

GSA has already determined the prices of the schedule contracts to be fair and reasonable.

Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing. The DOE MA-64 Contracting Officer has determined, using the procedures in FAR 8.405-2(d) and 8.405-4, that the order represents the best value and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government's needs. The Contracting Officer has completed a best value determination ensuring adherence to FAR 8.404(d) which has been incorporated in the contract file.

Also, the Contracting Officer notes that the Government has accumulated significant historical pricing and level of effort data over the past five (5) years for the services required, and that the prices paid to date have remained consistent with historical prices paid for this effort. As such, the Contracting Officer has determined that sufficient information is available to determine the fairness and reasonableness for prices submitted for the prospective follow-on modification to this task order under this justification.

6. DESCRIPTION OF MARKET RESEARCH

Per DOE Acquisition Guide 8.3, Contracting Officers must first consider those sources identified as mandatory in FAR Part 8, required by statute, or specified by regulation. If a mandatory source is not available, FAR 8.004 encourages the use of FSS, GWACs, MACs, and any other procurement instruments intended for use by multiple agencies, including, but not limited to, IDIQs, BPAs, and Enterprise-Wide Agreements. Appropriate consideration must also be given to Small Businesses.

DOE policy requires the Contracting Officer to consider DOE Preferred Solutions (including EWAs) and BICs as mandatory sources. As part of acquisition planning, Contracting Officers must also consider existing contracts before electing to conduct an open market procurement.

• FAR Part 8 sources including Ability ONE and Federal Prison Industries

• DOE Preferred Solutions (e.g., DOE EWAs)

FAR Part 8 Sources Market research was conducted in accordance with FAR Part 10.002. In accordance with Federal Acquisition Regulation (FAR) 8.002(a)(2), Priorities for use of Government supply sources, mandatory sources must be evaluated and utilized, if they can provide the needed services, before seeking open market sources. As required by the previously stated FAR citation, the contracting activity must evaluate the following source, AbilityOne, prior to other sources. The purchasing priority for services is AbilityOne. As stated in FAR 8.703, their procurement list can be accessed at www.abilityone.gov. This list was reviewed to determine whether security services are required services, and they are not. AbilityOne does not provide these types of services.

DOE Preferred Solutions (e.g., DOE EWAs) As required by DOE Policy, the DOE Preferred Solutions (Dated March 2024) listed on Acquisition Answers was reviewed to determine suitability for the requirement. A thorough review was conducted of all sources listed within the DOE Preferred Solutions. The review resulted in a determination being made that none of the preferred solutions were viable options for the Applications Infrastructure and Cyber Security Support Program. This determination was made due to incompatibility between the existing solutions and the scope of this requirement.

Other This action is only for a short follow-on extension until a new award is in place. Market research has already been conducted for the current recompete. Consequently, additional market research was limited due to the urgency of the requirement and because the time required to conduct extensive research would have significant adverse impacts on the Department. Any disruption in the current support could adversely affect DOE’s oversight of safety and security operations and the classification mission support national security objectives. The disruption of service would impact EHSS’ ability to maintain its cybersecurity posture, thereby increasing the potential of EHSS systems being used to provide unauthorized access to other departmental systems and networks, creating additional risk for DOE.

A public notice of this sole source justification to Edgewater Federal Solutions, LLC will be posted by the Contracting Officer on SAM.gov in accordance with FAR 8.405-6(a)(2).

7. ANY OTHER SUPPORTING FACTS

All relevant facts and circumstances have been presented; therefore, there are no additional facts.

8. ACTIONS TAKEN TO REMOVE BARRIERS TO COMPETITION

In an effort to break down efforts to eliminate barriers to competition, this Office will continue to survey the market and publish notices to ensure that it is in the best interest of the Department to acquire this support from Edgewater to satisfy the programmatic needs of the Department. The Department intends to compete this requirement in the future, possibly on a full-and-open basis in order to ensure sufficient competition among qualified vendors. This decision aims to ensure a competitive environment, fostering better quality and value for the Department's needs. To ensure transparency and fairness, the Department plans to implement rigorous evaluation criteria and outreach efforts to attract a diverse pool of qualified vendors. The Department will also develop strategies to successfully transition ongoing projects to a new vendor should Edgewater not be selected under future acquisitions for this requirement.