LSJ.pdf

Version 12/27/18

Department of Transportation Federal Highway Administration (FHWA)

Information Technology (IT) Acquisition Center of Excellence (ACE)

SOLE SOURCE JUSTIFICATION

Logical Follow On GSA Task Order

The Department of Transportation (DOT) makes this Justification for orders pursuant to Federal Acquisition Regulation (FAR) 8.401(b) and Revolutionary Far Overhaul General Services Acquisition Manual (GSAM) 538.7104-3(b)(1)(iii).

i.) Identification of Agency and Contracting Activity:

Program Office:

DOT, Office of the Secretary (OST) Office of the Chief Information Officer (OCIO) 1200 New Jersey Avenue, SE Washington, D.C. 20590

Contracting Activity:

Federal Highway Administration (FHWA)

IT ACE

1200 New Jersey Avenue, SE Washington, D.C. 20590 ii.) Nature and/or Description of Action Being Approved:

The OCIO has a need to extend the cybersecurity management support services using a bridge task order solicited on a sole source basis to Criterion to support OST's applications and information systems. The Order is currently expired and this request is to procure levels of support for an additional twelve months while a new contract vehicle is procured on a competitive basis.

Description of Supplies/Services Required to Meet Agency’s Need:

The Government requires continued cybersecurity support services to maintain the security, integrity, and operational continuity of its information systems and networks. These services include, but are not limited to, Information Assurance, Disaster Recovery & Continuity, Cyber Security Technical Support, Policy & Training Support, Assessment & Authorization Support, Security Engineering & Administration.

iii.) The Authority and Supporting Rationale:

• This sole source justification is conducted in accordance with GSAM 538.7104-3 (b)(1)(iii), permitting limiting sources for Federal Supply Schedule orders when the order is a logical follow-on to an original order that was competitively awarded. The rationale for the sole source for this action is:

• Continuity of Critical Cybersecurity Operations: The incumbent possesses unique institutional knowledge of the agency’s systems, architecture, security posture, and ongoing risks. Transitioning to a new contractor at this time would introduce unacceptable delays, inefficiencies with on-ramping and transitions, and increased risk to mission-critical cybersecurity operations.

• Avoidance of Unacceptable Performance Gaps: Cybersecurity services require uninterrupted, or limited, execution. Any lapse during transition increases FHWA’s exposure to vulnerabilities, threats, or non-compliance with federal security mandates.

• Efficiency and Cost Effectiveness: The incumbent contractor has already established tools, processes, and personnel familiar with the environment. Introducing a new contractor would require duplication of effort, additional onboarding costs, and potential inefficiencies.

• Bridge to Competitive Task Order: This action is a task order to allow sufficient time for the Government to establish a competitive task order for long-term cybersecurity services. The new task order is currently in development and will be competed in accordance with applicable regulations.

iv.) Determination by the Ordering Activity Contracting Officer that the Order

Represents the Best Value:

The price obtained by the Contractor in response to FHWA’s solicitation will be reviewed for its fair and reasonableness. The Government intends to complete a price analysis that will examine the GSA Federal Supply Schedule contract labor rates, labor hours quoted, historical pricing, and the IGCE.

v.) Description of the Market Research Conducted Among Schedule Holders and the Results of the Research:

Market Research was not conducted among Schedule Holders but based on the program office knowledge of the marketplace Criterion Systems, LLC is the only contractor that can provide these services within the time required.

vi.) Any Other Facts Supporting the Justification:

N/A.

vii.) Statement of the Actions the Agency May Take to Remove or Overcome any Barriers that Led to the Restricted Consideration Before Any Subsequent Acquisition for the Supplies or Services is Made:

OCIO is currently developing a new contract to provide the requirements for cybersecurity support. This task order would enable OCIO to continue services while the new contract effort is finalized and awarded.

viii.) Contracting Officer Certification that the Justification is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

I hereby certify that this justification is accurate and complete to the best of my knowledge, and I determine based on the findings above that the sole source approach is in accordance with the requirements and is in the best interest of the Government.

Josephine Helms Contracting Officer

HCFA-32

Office of Acquisition Services ix.) Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for sole source) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel:

Supporting data provided by technical or requirements personnel has been certified as complete and accurate as demonstrated by reasonable technical review and adherence to current task order rates.

x.) Written Determination by the Approving Official(s):

I hereby certify that this justification is accurate and complete to the best of my knowledge, and I determine based on the findings above that the sole source approach is in accordance with the requirements and is in the best interest of the Government.

Dante Winslow Division Chief of IT Compliance HATS-50, IT Compliance Division