M04_JA_HQ0034-20-C-0112__2 Mos Bridge_Signed.pdf

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Acquisition Directorate

DEPARTMENT OF DEFENSE

WASHINGTON HEADQUARTERS SERVICES

1155 DEFENSE PENTAGON

WASHINGTON, DC 20301-1155

Control No. WHS-2025-1624-JA July 4, 2025

JUSTIFICATION FOR

OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

UNDER FEDERAL ACQUISITION REGULATION FAR SUBPART 6.3

HQ0034-20-C-0112, Galapagos Federal Systems, LLC

1. AGENCY AND CONTRACTING ACTIVITY: The Department of Defense (DoD), Washington Headquarters Services, Acquisition Directorate (WHS/AD), Enterprise Office of the Secretary of Defense Division (EOSD), Technical Analysis Branch (TAB) on behalf of the Office of the Under Secretary of Defense for Intelligence and Security (OUSD(I&S)) Counterintelligence, Law Enforcement & Security (CL&S) Office.

2. DESCRIPTION OF ACTION: OUSD(I&S) CL&S has a continuing need for Specialized and Sensitive Administrative, Policy, Operations and Analytic Support Services to support the office. The current contract expires July14, 2025, and the Government intends to extend the current contract period of performance (POP) for continuity of services. The Government recently awarded a competitive long-term;

Blanket Purchase Agreement (BPA) on February 14, 2025, and the concurrent Call Order for EXDIR HQ0034-24-F-0704 and Sensitive Activities & Special Programs (SASP) HQ0034-24-F-0705, were awarded on February 20, 2025. However, on March 6, 2025, a protest was filed against the two Call Order awards resulting in a 100-day stop work order. These two call orders directly affected the work required to award another call order for the effort within this request in May 2025. Therefore, an extension will be required to continue services while the Government worked to resolve the protest and ultimately resolicits the Call Orders amongst the Blanket Purchase Agreement (BPA) holders, if necessary. WHS/AD intends to award the follow-on contract by September 2025. This extension will utilize Firm-Fixed-Price (FFP) Contract Line-Item Numbers (CLINs), with a total estimated value of $119,550.48 using fiscal year (FY) 2025 Operation and Maintenance (O&M) Funds. The period of performance for the bridge contract will be extended from July 14, 2025 – September 13, 2025

DESCRIPTION OF SUPPLIES/SERVICES: The DDI (CL&S) requires policy, operations, and analytic support in various functional areas to fulfill its core functions: (1) developing and managing resources to address intelligence mission and security requirements, (2) policy formulation, (3) conducting outreach to appropriate DoD components and Intelligence Community (IC) elements, (4) industrial partners and providing oversight of counterintelligence, (5) identity intelligence and biometrics, (6) law enforcement, and security activities. To meet these requirements, the CL&S workforce leverages a mix of DoD civilian, military, Joint Duty Assignment (JDA), liaison officers, and contract personnel. Contract personnel perform a variety of tasks alongside government employees in support of CL&S’s mission. The Contractor’s performance and deliverables shall provide wide ranging technical and administrative support and program support at the direction of the Executive Director.

Controlled by: WHS/AD CUI Category(ies): SP-PROCURE

Limited Dissemination Control: FEDCON POC: Syreeta A. Donald, syreeta.a.donald.civ@mail.mil mailto:syreeta.a.donald.civ@mail.mil

Performance Period(s) Performance Period Dates Amount

(2) Month Bridge Extension 14 July 25 – 13 Sept 25 $87,955.02

3. AUTHORITY CITED: This action is authorized under provisions of 10 U.S.C. 3204(a)(1), FAR 6.302- 1(a)(2)(iii)(B), "Only one responsible source and no other supplies or services will satisfy agency requirements." More specifically, “For DoD…services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in [u]nacceptable delays in fulfilling the agency’s requirements.”

4. REASON FOR AUTHORITY CITED: CL&S requires continued, support from the incumbent to fulfill its requirement for professional, technical & administrative support. If not, the Government would experience unacceptable delays in providing the necessary support for CL&S and subsequently within the I&S Enterprise. Only one source can provide the supplies or services required at the level CL&S requires continued, support from the incumbent to fulfill its requirement for professional, technical & administrative support. This action is necessitated by a formal bid protest received in response to the intended award for technical, professional, management, policy, and operational support under a newly awarded Blanket Purchase Agreement (BPA) for OUSD(I&S). The BPA was awarded on February 14, 2025, and the protested EXDIR and SASP Call Orders were awarded on February 20, 2025, with a transition-in start date of March 13, 2025. This current contract is in a FAR 52.217-8 extension and expires on July 13, 2025.

Failure to extend these services and losing the support and expertise of the Galapagos Federal Systems, contract team would result in incalculable delays that would derail or halt missions across CL&S. These delays would impact the CL&S’s on-going efforts to develop directives, perform oversight functions, and execute processes that impact over $18 Billion of DoD investment in strategic capability development.

CL&S resides within OUSD(I&S) and provides necessary support to develop broad thematic guidance focused on strategic capabilities and key adversaries; promulgate competitive strategies focused on specific defense issues. CL&S works across the DoD, with the Intelligence Community (IC), and with Non-Defense Federal Departments and Agencies (NDFDA) to develop integrated directives to align Operations, Activities, and Investments (OAI) for an influential effort in support of the National Defense Strategy (NDS). CL&S is responsible for oversight of all defense intelligence support and initiatives within the Department of Defense. In addition, to accomplish the work within the allotted schedule, an extension must seamlessly follow the initial effort to maintain continuity of services. Therefore, an extension to HQ0034- 24-C-0046 is needed to maintain continuity of services and is the most logical and cost-effective solution to the Government, as a break in support is unacceptable and would cause detrimental mission failure to OUSD(I&S) and across the DoD, IC and with OAI initiatives with NDFDA.

In addition, failure to extend Galapagos Federal Systems LLC’s support would result in substantial duplication of costs to the Government. The substantial duplication of costs is estimated at $13,008.09 and includes 3 full-time equivalents (FTE’s) needed from another vendor to provide a support service to OUSD (I&S) which is not expected to be recovered through competition. The Government would incur significant and unnecessary use of government funding for onboarding, training, and knowledge transfer costs and administrative activities in order to reach the current incumbent's level of expertise. We estimate the following cost breakdown for duplication of effort:

Onboarding and Training: $1,919.04 Based on a week of onboarding costs which consists of in-doc with security, updating credentials on Common Access Card (CAC), Pentagon Access, and network accounts being processed.

Knowledge Transfer: $3,836.34 Based on estimated 80 hours required for current staff to document work and transfer knowledge.

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Opportunity Cost of Delays: $7,252.71 Assuming a 30-day lapse in service to complete the award, based on financial risk due to delayed ability to address national regulatory issues arising from key U.S. regulatory bodies, executive branch agencies. The ability to provide research and advice to develop and advance strategy that addresses the evolving international regulatory environment.

Awarding services to a contractor other than Galapagos Federal Systems LLCs would involve multiple transitions between potential vendors (incumbent vendor, temporary vendor, and new long-term vendor) which involves the Government paying multiple vendors for the transition of different contracts for an estimated $13,008.09 for continuous support. These multiple transitions involve additional resources and unnecessary costs for the Government, and can cause unacceptable risks, delays, and interruptions in services. To accomplish the work within the allotted schedule, the follow-on effort must seamlessly follow the initial effort to maintain continuity of services. Additionally, if a new contractor were to transition into the environment, it would cause a 21-30-day gap in support due to the amount of time that it would take to bring on new personnel, conduct the appropriate security indoctrination procedures, issue new accounts, and grant accesses to respective applications. These 30-days would not account for any ramp up or training time that would be needed, that would add another 15-30 days. This This sort of gap or work stoppage in support is unacceptable to continuity of CL&S’ mission. To maintain continuity of services, an extension of services is the most logical and cost-effective solution to the Government as a break in support would be detrimental.

5. EFFORTS TO OBTAIN COMPETITION: Due to the urgent need to extend services to avoid a lapse in contractor support, the Government published a “Notice of Intent” (NOI) on SAM.GOV to notify industry of its intent to extend services on July 7, 2025, with a closing date of July 10, 2025. The NOI posted did not receive any responses.

6. FAIR AND REASONABLE COST DETERMINATION: The Contracting Officer (CO) determines that the anticipated prices will be fair and reasonable by using the techniques identified at FAR 15.404-1 “Proposal Analysis Techniques”, specifically FAR 15.404-1(b)(2)(ii) and FAR 15.404-1(b)(2)(v) to ensure award will be at fair and reasonable prices. In addition, the Government will compare proposed prices set forth by Galapagos Federal Systems to historical prices paid by the Government under the current contract, HQ0034-20-C-0112. The Government will also compare proposed prices with the Independent Government Cost Estimate (IGCE) prepared for the period of performance extension and request price reductions or discounts.

7. MARKET RESEARCH: Market Research has been limited to the NOI to sole source this action and was posted on SAM.gov as described in paragraph 6, above. WHS/AD will execute a bilateral modification to the existing contract to extend it to maintain continuity of support being provided to CL&S. The contract extension is the most efficient and logical strategy and solution to the Government to avoid unacceptable delays in fulfilling the agency’s requirement and a potential gap in performance of critical services to

CL&S.

8. OTHER FACTS: Due to the irreparable damage that may result to CL&S's mission should services be interrupted; a sole source contract extension will be negotiated with Galapagos Federal Systems.

Galapagos Federal Systems has been critically instrumental to the success and continuation of the DoD mission.

9. INTERESTED SOURCES: To date, no other sources have expressed an interest, feedback, or challenges in writing and no bids or proposals have been received to the Notice of Intent” required by FAR 5.201, that was published on SAM.GOV to notify industry of its intent to extend services.

11. ACTIONS TO INCREASE COMPETITION: This requirement was initially competed with fair opportunity to the vendors deemed capable and eligible under the establishment of the WHS-AD OUSDI Enterprise multiple award BPA via the General Services Administration (GSA) Multiple Award Schedule (MAS) 8(a) Pool. However, due to a protest filed against the BPA’s SASP Call Order award made from the

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fair opportunity solicitation, and severe time constraints due to the protest being filed weeks before the end of the current bridge contract POP, the Government must restrict award consideration and implement an extension to Galapagos Federal Systems. Soliciting an open competition for a contract for these services will take at least 120 days based on the $4 million contract value, which would cause a gap in services.

CL&S’s mission cannot afford any interruption of services or resultant gap in services to compete an additional contract during the protest. There could be irreparable damage to CL&S 's mission should services be interrupted and/or delayed.

Is this acquisition for a non-competitive follow-on acquisition previously awarded on a non-competitive basis?

☒Yes. A copy of the previous justification is attached. The actions to remove any barriers to competition cited on the previous justification ☒ were ☐ were not completed.

☐ No. The original acquisition was conducted on a competitive basis.

☐ Not Applicable. This is a new requirement.

CERTIFICATION

I, hereby, certify that the supporting data under my cognizance included in this justification are accurate and complete to the best of my knowledge and belief.

Corey Dawson, Contracting Officer’s Representative/Program Office Date

Syreeta A. Donald, Contracting Officer Date