N0018919FZ548P00005_JA_22_007.pdf

J&A#22-007

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Identification of the agency and the contracting activity.

The customer activity is the Naval Education Training Command (NETC). The contracting office is the Naval Supply Systems Command (NAVSUP) Fleet Logistics Center (FLC) Norfolk, Contracting Department, Philadelphia Office.

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

This acquisition is conducted under the authority of 10 U.S.C. 2304c. This is an exception to the fair opportunity process to be awarded as a modification to an existing task order. The resultant contract action is anticipated to be a modification to firm-fixed-price (FFP) task order N0018919FZ548 with the firm Sonalysts, Inc. (CAGE: 1L297) of Waterford, CT. The task order was awarded against contract N0018916DZ019, an indefinite-delivery/indefinite-quantity (IDIQ) contract under the NETC Naval Training Products and Services (NTPS) Multiple Award Contract (MAC) vehicle for Curriculum Planning & Analysis. (The contract was awarded from solicitation N00 l814RZ037.)

3. A description of the supplies or services required to meet the agency's needs (including the estimated value).

NETC requires additional support under its existing task order for NETC HQ Fielding Staff Support for Ready, Relevant Learning (RRL) services. Task order N00 l 89l 9FZ548 provides instructional analysis, instructional systems design (ISD), media analysis, administrative, financial, logistics, and data configuration control to support NETC's fielding of the Naval Air Warfare Center Training Systems Division (NAWC TSD) developed training material. The order focuses on the NETC Fielding Plan and reviews of NAWC TSD-provided analysis and design documents on specific Navy ratings identified. The contractor supports NETC and the Learning Centers in the development and implementation of this fielding plan to support implementation of RRL Learning Content, Material and Curriculum.

The task order was competitively solicited in accordance with FAR Subpart 16.5 amongst the six (6) contract holders under the NETC Naval Training Products and Services (NTPS) multiple-award contract program.

For the instant modification, NETC NS and N7 require additional services in support of NETC RRL that will provide Instructional Analysis, Instructional Systems Design (ISD), Media Analysis, Administrative, Financial, Logistics, and Data Configuration control to support NETC 's fielding of NAWC TSD developed training material. This is the exact same work identified in the existing contract. Requesting a Mod to increase the number of hours associated with this work due to added Ratings. Services are to include additional Navy ratings handed to NETC from NAWCTSD in support of RRL Content Modernization.

4. Identification of the exception to fair opportunity.

The statutory authority which permits not providing each awardee a fair opportunity to be considered for each order exceeding the micro-purchase threshold issued under a multiple award contract is 10 U.S.C. 2304c, as implemented by FAR 16.505(b)(2). The applicable exception to the fair opportunity process for this justification for the award of an order exceeding the simplified acquisition threshold is FAR 16.505(b)(2)(B) - Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

5. Rationale supporting use of the exception to fair opportunity.

This work is currently being performed under task order N0018919FZ548. The purpose of the additional support is to accommodate the additional scoping/planning and analysis of the modified Ready, Relevant Learning (RRL) effort that is driven by new NAWCTSD requirements that are outlined below. The RRL process that has been replaced relied on "as-is" learning objectives and was leading to the same training being re-built by NAWCTSD as part of the Content Conversion contract and not meeting the objectives of RRL to provide Modernized Delivery at the point of need. Because the RRL process was not achieving the requirement, NETC and NAWCTSD had to change the scoping and analysis process to address the issue. NETC has taken over the role of creating new learning objectives and NAWCTSD is going to address media selection. The NETC part of the new RRL process is being addressed by shifting from "as-is" knowledge-based learning objectives to newly created performance-based learning objectives created from performing a Job Duty Task Analysis (JDTA). To create performance-based learning objectives from an IDTA, it is a significant increase in workload

The proposed FY22 Content Conversion efforts, projected for award in March FY22, impacts the following Ratings: fire control man (FC), fire control man aegis (FCA), interior communications electrician (IC), gunner's mate (GM), aviation ordnance man (AO), and aviation support equipment technicians (AS).

The old RRL process includes the following steps:

• NETC performs Scoping and provides NAWCTSD "As-Is" learning objectives

• NAWCTSD performs a work analysis and media selection based on those objectives defines an instructional requirement.

• NETC then takes those instructional requirements and perform a Fielding and Feasibility (F2) study to ensure that the learning site can support the requirement.

• NAWCTSD then creates a final Functional Requirements Document (FRD) that gets approved by the

TYCOM and then contracted out for a vendor to create or perform this content conversation to RRL standards. This should be awarded in MAR FY22 to support funding levels.

• This is currently a 2 year process.

The new RRL process includes the following steps for the FY22 Ratings:

• NETC performs Scoping and provides NAWCTSD "As-Is" learning objectives

• NAWCTSD performs a work analysis and media selection based on those objectives defines an instructional requirement.

• NETC then takes those instructional requirements and perform a fielding and feasibility study to ensure that the learning site can support the requirement.

• NAWCTSD then creates a final Functional Requirements Document (FRD) that has been REJECTED by the TYCOM for not being based on performance-based learning objectives to support RRL goals.

• To fix this issue:

o NETC needs to conduct JDTA for impacted Ratings o NETC needs to create performance-based learning objectives o NAWCTSD needs to then perform a new media selection process to create inputs for the FRD o NETC needs to revisit the F2 o All to support a FY22 content conversion award by NAWCTSD in Mar 2022.

o So that NAWCTSD contracts can put out a solicitation to vendors to perform this conversation to RRL standards.

• This is now a process that must be completed in 6 months.

Many process changes are taking place to keep RRL on its congressionally mandated timeline. This impact does add the additional requirement but doesn't change the type of work being performed on this subject order.

If NETC were to resolicit this effort, it would break effort continuity and disrupt sensitive effort timelines and milestones, thus costing the Government significant additional time and money. Timeline listed below:

• Started Aug 2021

• Sep 2021 to Feb 2022 - to perform JDTA work on identified Ratings and associated paths. NETC can complete one rating a month with the currently requested additional contractor services.

• Oct 2021 to Mar 2022 - NAWCTSD and NETC are working media selection and F2 requirements to support a final FRD.

• Must be completed by Mar 2022 to meet contract timelines.

If NETC had to re-compete this effort, the resultant task order award would be made by approximately mid- Feb 2022, not allowing the above timeline to be met.

The instant work effort is part of multiple progressive processes required to execute RRL content modernizations to Navy training content. Follow-on processes required this effort to be completed prior to moving forward. This effort was assigned to NETC after the existing contract was in place. Re-competing this work would cause a significant delay to delivery of modernized content. Additionally, this effort requires consistency in work products produced and passed to the NAWCTSD for continued development of modernized content.

It is noted that task order N00189 l 9FZ548 is currently in its final option period and is set to expire on 21 Jul 2022. If a follow-on effort is required, it is the Government's intention to re-compete this work under the NETC Naval Training Products and Services (NTPS) multiple award contract program.

6. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has determined the anticipated cost to the Government of the supplies/services covered by this J&A will be fair and reasonable.

7. Any other facts supporting the justification.

No other facts are available to support this justification.

8. Actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

NAVSUP FLC Norfolk Contracting Department, Philadelphia Office will handle future requirements on a case-by- case basis. In the event a follow-on acquisition package is provided by the requiring activity, it is the contracting office's intention to competitively solicit the follow-on procurement amongst the NTPS MAC holders.

9. Contracting Point of Contact.

The point of contact at NAVSUP FLCN Philadelphia is Ellen Wright, who can be reached at 215-697-9612 or via email at ellen.s.wright.civ@us.navy.mil.

mailto:ellen.s.wright.civ@us.navy.mil