ECIS Consolidation DF.pdf

DEPARTMENT OF THE NAVY

NAVAL AIR WARFARE CENTER TRAINING SYSTEMS DIVISION

12211 SCIENCE DRIVE

ORLANDO FLORIDA 32826-3224

D&F# 26-135

DETERMINATION AND FINDINGS FOR AUTHORITY TO CONSOLIDATE

CONTRACT REQUIREMENTS

In accordance with Title 15 United States Code (U.S.C.), Section 657q, Federal Acquisition Regulation (FAR) 7.107-2 and the Navy Marine Corps Acquisition Regulation Supplement (NMCARS) 5207.107-2, I hereby make the following findings and determination concerning the consolidation of requirements for the Engineering Contractor Instructional Services (ECIS).

FINDINGS

1. Identification of Agency and Contracting Activity

Naval Air Warfare Center Training Systems Division (NAWCTSD)

2. Nature/Description of Action

NAWCTSD is consolidating the ECIS requirements from being competed as a stand-alone c-type contract, small business service-disabled veteran owned small business (SDVOSB) set-aside to a competitive task order within the existing Fielded Training System Support (FTSS) V Multiple Award Contract (MAC) Indefinite Delivery/Indefinite Quantity (IDIQ) Lot II (Restricted, Small Business). This consolidation is driven by the benefits of competing under the FTSS V MAC exceeding the benefits of an alternative approach.

3. Authority

15 U.S.C. Section 657(q), as implemented by FAR 7.107-2, allows the senior procurement executive to enter into the ECIS procurement on a consolidating basis.

4. Procurement Strategy

NAWCTSD, as tasked by the Surface Warfare School Command (SWSC) and Expeditionary Warfare Training Group, Pacific (EWTGPAC), requires Contractor Instructor Services (CIS) to supplement the military instructional workforce at multiple Learning Sites. These services include specialized instruction, curriculum sustainment, and subject matter expertise in areas such as engineering, firefighting, damage control, and maritime warfighting.

Historically, the ECIS program was competed as a standalone, small business SDVOSB set-aside contract (ref. N6134019C0007 and N6134022C0007), both because market research indicated there exist multiple, qualified SDVOSBs who were interested in the effort and to aid NAWCTSD in meeting its socioeconomic goals. However, this acquisition strategy produced suboptimal acquisition outcomes.

The FTSS V MAC offers a superior alternative. It provides a pre-qualified pool of high-performing contractors for similar services and, most importantly, offers significant pre-award and post-award acquisition streamlining opportunities. Of the five similar CIS/ Contractor Operation Maintenance Services (COMS) requirements that NAWCTSD administers for NAVSEA, ECIS is the only one competed outside of the FTSS MAC.

Pursuant to FAR 2.101 and 13 C.F.R. 125.1, this action constitutes "consolidation," not "bundling," because the requirement will remain suitable for small business concerns. The work will be competed exclusively under the FTSS V MAC Lot II, which is a small business set-aside.

Continuing to compete the ECIS requirement outside of the FTSS V MAC is no longer efficient or justifiable. A standalone contract would contradict recent Secretary of the Navy directives, increase acquisition costs and cycle times, and add to the administrative burden. This consolidation effort is estimated at $44M over the contract's period of performance.

5. Current Contracts

Table 1 - Contract to be Consolidated under the FTSS V MAC Current Contract

Current Contractor

Type of Work Performed

Dollar Value

POP Business Size

Award Type

N6134022C0007 Prevailance, Inc.

Fire Fighting, Damage Control, and Engineering Contractor Instructor Services (CIS)

*$28M

21 JAN 2022

to 17 JAN

Small Competitive

SDVOSB

Set-Aside

*Inclusive of unexercised options.

NAWCTSD awarded this contract to Prevailance, Inc. on 21 January 2022 to provide SWSC, PMS 339, Submarine Learning Center (SLC) Groton, CT Specialized Engineering, Fire Fighting, Damage Control, Sonar and Fire Fighting Control Instructors to include instruction, operation, testing, remediation, curriculum sustainment activities (includes updates and maintenance of curriculum), administration, safety and management support services for formalized naval training under the management of SWSC, PMS 339 and SLC. After award, the contract was modified to include EWTGPAC.

6. Market Research

The scope of this requirement aligns with the approved ISTRAP-M for the FTSS V MAC.

Utilizing the FTSS V MAC is the most logical and efficient procurement strategy. Awarding this requirement via a standalone contract would introduce unnecessary administrative burdens, increase program risk, and run counter to established best practices for delivering critical training support.

Market research confirmed that robust competition is achievable under two potential scenarios: a standalone SDVOSB set-aside and a task order competition under the FTSS V Lot II (Restricted, Small Business) MAC. Analysis of contractor interest and historical performance data indicates that a healthy competitive environment for small businesses is maintained under the MAC structure. It is noted that if the effort was a standalone SDVOSB set-aside, that the pre-qualified and experienced small businesses under the FTSS V MAC would not be able to propose.

Therefore, consolidating this requirement into the FTSS V Lot II MAC will have a neutral impact on small business prime contracting opportunities while providing significant acquisition and administrative efficiencies. This finding has been coordinated with the agency�s Office of Small Business Programs (OSBP) and the Small Business Administration (SBA) Procurement Center Representative (PCR).

7. Benefits of Planned Consolidation

The consolidation of this requirement is necessary and justified, delivering substantial benefits critical to mission success. These benefits, realized through improved efficiency and reduced administrative burden, are detailed below.

Reduction in Acquisition Cycle Time:

Consolidating this effort under the FTSS V MAC is projected to reduce the acquisition cycle time by approximately three to four months compared to a standalone C-type contract competition. This significant time savings is achieved through:

Efficient Administration The MAC framework fosters standardized post-award surveillance, administration, and support across all task orders. This consistency, combined with the sharing of lessons learned among MAC holders, leads to more efficient and effective performance of operation, maintenance, and instructional services.

Cost Savings and Avoidance The consolidation yields quantifiable cost benefits. By streamlining the acquisition process and reducing the level of effort for government monitoring and administration, o Streamlined Ordering Procedures: The MAC utilizes established, fair opportunity ordering procedures that eliminate the lengthy steps of a full and open competition, directly reducing solicitation development, evaluation, and award lead times.

o Elimination of Redundant Documentation: The MAC structure removes the need to develop and approve some of the acquisition documents for each requirement, as these are governed at the MAC level and streamlines the drafting of those that remain.

o Pre-Qualified Vendor Pool: The FTSS V MAC provides a pool of vendors already determined to be technically qualified. This familiarity with government requirements results in higher-quality proposals, more efficient evaluations, and shorter award timelines.

NAWCTSD avoids significant pre-award and post-award costs. NAWCTSD�s analysis projects cost savings of $666,396 for this effort.

The combined operational and financial benefits of this consolidation exceed those of any alternative contracting approach. This action directly executes the core tenets of Executive Order 14265, 'Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base.' By reducing acquisition cycle times, lowering administrative costs, and leveraging an existing MAC with a pre-qualified pool of small business contractors. This consolidation delivers the speed and efficiency necessary to provide critical training services to the warfighter without delay.

DETERMINATION

Based upon the above findings, the consolidation of the ECIS is necessary and justified under the authority of 15 U.S.C. 657q. Further, this Determination and Findings fulfills the requirements of FAR Part 7.107-2 and NMCARS Subpart 5207.107-2.

REVIEWED AND CONCURRED BY:

WILLIAM ZELLER

Director of Surface and Undersea Warfare Programs, NAWCTSD

KORI WILSON

Associate Counsel, GT9000

ISSA MALKI

Procuring Contracting Officer, GT26000

TERRESSA BEBOUT

Acting Director, NAVAIR Office of Small Business Programs

APPROVED BY:

LINDA MOBLEY

Director, Procurement Group Naval Air System Command