LSJ -NTIA Cybersecurity Services_FY24-29_Redacted.pdf

Limited Sources Justification Enterprise Services Office of Acquisition

1401 Constitution Avenue NW Washington, D.C. 20230

FY24-29

(1) Identification of the agency and the contracting activity:

Program Office: National Telecommunications and Information

Administration (NTIA)

1401 Constitution Ave, NW

Contracting Activity Department of Commerce

Enterprise Services –

Acquisition 1401 Constitution

Ave, NW Washington, D.C.

20230

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

This is a limited source justification is to modify the existing task order as a logical follow-on to increase the value of Cyber Security Services being provided under task order No.

1331l522F13350294. The labor hour task order was issued competitively under the General

Services Administration (GSA) Multiple Award schedule (MAS) Category Number 54151S, Information Technology (IT) Professional Services to International Business Sales and

Services Corp (IBSS) under GSA Schedule contract No. 47QTCA19D00D9 for

Technological Infrastructure Transformation and Adaptive Networking Services.

Approval is requested to modify the award to IBSS to allow for unforeseen increases to the level of effort (LOE) that will occur for option period two. The current order period of performance for Technological Infrastructure Transformation and Adaptive Networking

Services expires on June 30, 2024, with option period two starting on July 01, 2024, through

June 30, 2025. It is the intention of Enterprise Services (ES) to award a logical follow-on modification to increase the option year value by $5,130,074.57.

This modification will increase the current total value of $3,699,686.00 by $5,130,074.57 to $8,829,760.57 when option period two is exercised.

(3) A description of the supplies or services required to meet the agency’s needs:

To meet NTIA's mission and align with federal appropriations and initiatives, several IT and cybersecurity services are needed. Cybersecurity support involves ongoing monitoring, threat analysis, and the implementation of defense strategies to reduce risks, ensuring compliance with the Federal Information Security Modernization Act (FISMA) and other mandates. This includes the ability to promptly identify, contain, eliminate, and recover from cybersecurity incidents, adhering to directives such as the Department of Homeland

Security’s Binding Operational Directive 18-02 and OMB Memorandum M-19-03.

IT system administration and network support are necessary to manage the lifecycle of servers and workstations, providing design, deployment, configuration, maintenance, and troubleshooting. This supports NTIA’s mandate to maintain its IT infrastructure and sustain communications and broadband initiatives, such as the Internet For All initiative. Cloud support includes managing cloud resources, ensuring scalability, availability, and data integrity in line with the Federal Cloud Computing Strategy (“Cloud Smart”) and OMB directives. Service desk operations provide end-user support, ensuring timely resolution of technical issues across multiple NTIA sites.

Program management and IT architecture support are needed for project planning, goal setting, and progress tracking, ensuring alignment with NTIA’s strategic goals. This includes developing and maintaining NTIA’s IT architecture to support its role in managing the nation’s airwaves and broadband expansion. Web application and database support ensure the efficient delivery of NTIA’s online services and data integrity. Qualified personnel with the necessary experience in system administration, network support, cloud management, cybersecurity, and program management are crucial for complying with federal standards and delivering high-quality services.

(4) An identification the statutory authority, FAR title and FAR citation permitting other than full and open competition.

FAR 8.405-6(a)(1)(i)(C): In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order was not issued under sole-source or limited-sources procedures.

(5) A determination that the order represents a best value consistent with FAR 8.404(d):

GSA has already determined the prices of services as fair and reasonable, and the order was issued based on competition and a resultant determination of fair and reasonable pricing.

Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing. However, in accordance with FAR 8.404(d) and 8.405-2(d), the

Contracting Officer will conduct a price evaluation in order to determine the pricing remains reasonable and provides the best value. In addition, in accordance with FAR 8.405-4, the

Contracting Officer will seek additional discounts prior to increasing the value of the current task order.

(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:

The following Market Research activities were explored:

• Review of Historical Acquisition Information

• Consideration of Personal Knowledge in Procuring Services of the Type

A special notice of intent to sole source was posted on SAM.Gov on 6/10/2024 with a closing date of 6/25/2024 describing the initial strategy to award this increase as a new contract award on a sole source basis as a 12-month logical follow-on. Two responses were received but deemed not technically acceptable due to either the lack of historical context and breadth of expertise necessary to support NTIA’s complex and diverse IT infrastructure; or the potential gaps in the immediate availability of skilled personnel, prime performance, and security/clearance processing and the need for a rapid-fire transition plan and expedited onboarding process poses significant challenges to the Government.

(7) Any other facts supporting the use of other than full and open competition, such as:

Leveraging the expertise of the current contractor, IBSS Corporation, ensures continuous service delivery and supports NTIA’s strategic goals while complying with federal mandates. IBSS

Corporation has demonstrated a thorough understanding of NTIA’s unique operational environment and has a proven track record of delivering high-quality cybersecurity and IT services. Their familiarity with NTIA’s systems, processes, and security requirements minimizes the risks associated with transitioning to a new contractor. By continuing with IBSS Corporation, NTIA can maintain continuity in critical operations, avoid disruptions that could compromise security and efficiency, and ensure that ongoing projects and initiatives are completed on time and within budget.

Moreover, the specialized nature of the required services, including advanced cybersecurity measures, IT infrastructure support, and adherence to federal guidelines and mandates, necessitates a contractor with specific expertise and experience. IBSS Corporation’s prior engagements have shown their capability to meet these stringent requirements effectively. The time and resources required to onboard a new contractor would not only delay crucial projects but also incur additional costs, potentially jeopardizing NTIA’s compliance with federal initiatives and cybersecurity mandates.

IBSS Corporation’s established relationships with NTIA stakeholders, in-depth knowledge of the agency’s operational challenges, and proven ability to deliver against the specified requirements underscore the rationale for limiting competition. This approach aligns with the

Federal Acquisition Regulation (FAR) criteria for other than full and open competition, ensuring that NTIA’s needs are met efficiently and effectively while safeguarding national cybersecurity interests and promoting continuity in service delivery.

By leveraging IBSS Corporation’s expertise, NTIA ensures alignment with federal appropriations and initiatives aimed at enhancing national cybersecurity, modernizing IT infrastructure, and promoting digital inclusion. This strategic decision supports the agency’s mission-critical operations and upholds the integrity and security of NTIA’s information systems in an increasingly complex digital landscape.

(8) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplier or services required:

This acquisition is for limited, specialized support services with the objective of ensuring no gaps in service and meeting NTIA’s requirements until the NTIA’s strategic plan is implemented to transition these services onto the new DOC CIO-wide vehicle, Commerce Acquisition for

Transformational Technology Services (CATTS). This is a targeted effort that is not anticipated to have a follow-on or subsequent acquisition requirements.

(9) Program Official’s and Contracting Officer’s Certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief:

Based on the above information, it is determined to be in the Government’s best interest to do a logical follow-on modification to the existing order No. 1331l522F13350294 under GSA MAS schedule holder IBSS contract No. 47QTCA19D00D9. I certify this justification is accurate and complete to the best of my knowledge and belief.

Program Official Date

Danielle Green Date

Contracting Officer

(10) Pursuant to FAR 8.405-6(d)(2) and ES-A 16-02 rev2, approval by the Operation Unit

(OU) Competition Advocate is for any actions over $750K, but do not exceed $75 million:

APPROVAL/DISAPPROVAL

Christopher Wallis Date

Operation Unit (OU) Competition Advocate