G1.2 Exception to Fair Opportunity.pdf

EXCEPTION to FAIR OPPORTUNITY for the placement of an order >$150K nuder a Multiple Award Contract (MAC)

Upon the basis of the following justification, I, Sharon Pritchard, as Competition Advocate of SPAW ARSYSCEN, Pacific, hereby approve the Exception to Fair Opportunity Pursuant to FAR 16.505(b )(2).

JUSTIFICATION

I. Agency and Contracting Activity. Department of the Navy, SPAW ARSYSCEN, Pacific.

2. Nature/Description of Action. This is a fair opportunity exception for Booz Allen Hamilton (BAH) under multiple award contract number N66001-18-D-0169. The estimated award date of proposed order is 30 April 2018.

3. Description of Supplies/Services. This will be a level-of-effort (LOE) order providing operations and sustainment support to the Readiness and Cost Reporting Program (RCRP). The contractor will continue the implementation and integration of upgraded components and architecture, some of which have reached end of life-cycle. These upgrades are also necessary to comply with DoD mandates for associated interoperability, data exchange and cyber security.

The contractor will also develop a transition plan. If a new contractor wins the follow-on effort to this task order, the Government will exercise the six-month option period and require the contractor to responsibly transition the work. The estimated total value of one base-year and one six-month option is $ l l .69M.

Estimated Dollar Value

Funds FY18 FY19 Total O&M,N O&M,N&R

$11.69M

4. Identification of the Exception to Fair Opportunity. (FAR 16.505(b)(2)(i)(B))

Identification/Justification for Exception:

0 a. The agency need for services is of such urgency that providing fair opportunity would result in unacceptable delays.

[g] b. Only one such awardee is capable of providing such services required at the level of quality required because the services ordered are unique or highly specialized.

BAH has been the sole contractor supporting development, maintenance and sustainment of RCRP since · 2006. Maintenance and sustainment support have been executed under three predecessor task orders which were all awarded on a competitive basis (N66001-16-D-0439- N6600117F0156, N6600 l-13-D-0045-0003, N66001-13-D-0045-0001).

(b)(4), (b)(5)

In July 2013, the Department of Navy (DoN) Chief Information Officer (CIO) signed a memo mandating that data centers and applications begin migrating to virtual environments.

"To achieve operational cost reductions and improve flexibility in its existing !reformation technology (IT) infrastructure, the DON will virtualize all current servers and server-based systems/applications. Through virtualization, multiple operating systems and applications can be run on a single physical server ... To achieve required virtualization, DON Deputy CIO (Navy), DON Deputy CIO (Marine Corps), and Assistant for Administration (DON/AA) will submit ... plans for virtualization of all servers and server-based ;ystems/applications by the end ofFYl7"

As a result of this decision, the RCRP program is now conducting a multi-phase, multi-year operation to transition to a fully virtualized environment within the Defense Information Systems Agency (DISA) Enterprise Computing Center (DECC). This operation must be completed on a timeline that supports shutting down the legacy platform hosted at DISA DECC by summer of FYl 8 and also establishing a fully operational capability in the DISA virtualized environment.

To make the best use of limited program funds reallocated for this requirement and to ensure continuity of support for the RCRP system, this operation must be performed in a continuous and expeditious manner. Executing the virtual platform configuration and supporting/supported code base requires the skills and capacity of the majority of the Operations and Sustainment (O&S) team. During this process, the code base on the production systems of the legacy platform configuration and the code base within the new platform configuration must remain synchronized. Each change made to production systems in the legacy platform must be carefully coordinated with and simultaneously executed within the virtual platform. As each system component is built in the new data center, the application software and data become an extension of the analogous production component. These conditions must be maintained until each component of the RCRP system is replicated and tested in the new virtualized platform. A single experienced team is necessary to sustain operations in production while efficiently executing the modernization efforts. There is no technically feasible division of responsibilities that can be effectively implemented without complete duplication of the existing O&S team. Even then, this would also require the establishment of new layer of Government management solely responsible for coordinating the interaction of the two contractor teams.

BAH is the only awardee capable of providing these particular services at this time. In concert with the RCRP program office, BAH has analyzed, designed, and developed a design plan necessary to optimize the code base and architecture, while integrating and upgrading components to ensure compliance with DoD mandates. Under a separate non-SPAWAR task order, BAH has begun development/incorporation of those updates and it is not expected to complete the updates until well after award/execution of a follow-on task order for operations and maintenance. The complexity is high due to the simultaneous efforts for the upgrading and implementation of the RCRP code base and architecture modernization. This is further complicated as a result of the ongoing RCRP reaccreditation under the Risk Management Framework (RMF).

Because these efforts have direct influence on maintenance and sustainment activities, the complexity does not afford for an adequate turnover of operations and maintenance functions to a new contractor at this time. BAH is the only contractor on the MAC that has the requisite knowledge of the system and understands the design, the implementation plans, and the reaccreditation process relative to this program necessary for the continued maintenance and sustainment over the requested period.

The program office would expect that bringing on a new contractor at this time would severely impact the ongoing code and architecture optimization effort, subsequently impacting system posture, program accreditation, and operation; ultimately, this would degrade reporting of unit readiness directed by DoD policy and the Joint Chiefs. The on-going operation must be executed in a manner that preserves the continuity of the modernizing efforts without incurring substantial duplication of cost.

At this time, the Government cannot afford the cost, delays and degradation of operations that would be incurred by providing transition support to a new contractor. The cost of a disruption to the continuity of the Government-contractor team is estimated based on four discrete components. First, the transition of a complex system such as RCRP requires the incoming contractor to receive a period of turnover with the incumbent contractor. This turnover of the routine software maintenance, systems operations and sustainment activities is required regardless of any ongoing special operations. Second, in addition to the turnover period required to transfer fundamental knowledge of the program, further effort will be required to transfer the knowledge and lessons learned associated with the ongoing virtual transition and modernized operations. Third, the incoming contractor will need to be trained on the third-party data center software tools adding additional time to the transition. Finally, the net loss of productivity resulting from the three preceding factors will delay the execution of the modernized code base release to production, virtual transition of server platform, and potential credentialing/accreditation impact. Delay in the achieving any of the aforementioned will require that the legacy classified data center remain in operation beyond the fiscal year currently programmed for shutdown and will significantly impair the legacy platform due to end of life software/hardware components. The Government will have to extend payments/increase cost for maintaining two computing environments during a period for which the cost of only one environment is programmed. Additionally, a source of execution year funds will need to be identified for sustainment of the legacy platform beyond its programmed end of life.

Historically, a program of RCRP' s size and complexity would take at minimum, six ( 6) months to transition to a new contractor. In addition to the turnover of required products/processes for the basic software maintenance, systems engineering and project management responsibilities, transition of RCRP will require a turnover of knowledge and lessons learned associated with the ongoing data center transition operation.

Transitioning now compounds the complexity of a potential transition and increases time, risk and cost. This impacts not only the integration and modernization efforts, but it also negatively impacts sustainment of RCRP operations, ongoing reaccreditation efforts and unit readiness reporting. Additionally, the Government will incur unprogrammed cost of $2.436M (see last two lines in table below) to run parallel operations and extend the modernization efforts. The total estimate for transitioning now is below:

Description· _ .· Calculation > Cilst .. ·

Cost for five months of .75 xMonthly $2,805,000 turnover support Costx5

Cost for last month of .50 x Monthly $374,000 turnover support Costx I

Cost to maintain parallel $177K x6 environment with hosting months

$1,062,000 center Cost to extend Modernization/virtualization $229Kx6

$1,374,000 LOE as a result of transition months forO&M Total cost forincumbent ·.

$5,615,000 tu111oversupport .

Note: Monthly Cost is $748,000 based on FYI 8 IGCE

It has been determined that turnover of the basic software maintenance, system operations, and sustainment activities will require 75% of the BAH team for a minimum of five months.

Turnover of the additional activities related to the ongoing data center transition is assessed to require 50% of the BAH team for at least one month.

The Government has developed a more responsible approach to solving the potential RCRP transition issues. The task order performance work statement (PWS) and Independent Government Cost Estimate (IGCE) include a one-year base for the ongoing RCRP operations and sustainment work as well as the integration, modernization and reaccreditation efforts.

Additionally, a six-month option period is included to support transition to a new contractor if required. This transition would take place one year from award of this task order. Prior to completion of the base, the Government plans to compete a follow-on task order for RCRP operations and sustainment efforts in time to execute the six-month option period if a new contractor wins that award. Waiting until all ·the integration and modernization efforts are completed in the base period allows the Government and the contractors to focus solely on the technical aspects of transitioning RCRP Operations and Sustainment. The requirement for $2.436M ofunprogrammed cost would be eliminated.

The cost to fund 6 months of limited turnover suppoti one year from now based upon the Government plan is calculated below.

I .. -- Description. • ' Calcufatioiis - ·. -. -Cost -- _:

Cost for five months of .75 x Monthly Cost x 5 turnover support

Cost for last month of turnover .50 x Monthly Cost x I support

'.fot~l Cost for incumbent

I -

.. -transition support -- _- -- .··

Note: Monthly Cost 1s based on FYl 8 IGCE

This would allow the program office to complete the modernization effmts, develop a sustainable transition plan, competitively award the follow-on effort, and responsibly transition the work to a new vendor if necessary.

D c. The order mnst be issued on a sole-source basis in the interest of economy and efficiency as a logical follow-on to an order already issued under the MAC, provided that all the awardees were given fair opportunity to be considered for the original order.

D d. It is necessary to place an order to satisfy a minimum guarantee.

D e. For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

5. Determination of Fair and Reasonable Cost..

The contractor will submit a formal cost proposal with cost or pricing data and sufficient information to support the accuracy and reliability of the estimate. BAH's proposal will be reviewed by the technical customer, the contract specialist, and the contracting officer. Field pricing assistance will be requested from the Defense Contract Audit Agency (DCAA) and the Defense Contract Management Agency (DCMA). The cost or pricing data will be certified by BAH at the conclusion of negotiations in accordance with FAR 15.403-4.

6. Any Other Facts Supporting the Justification.

None.

7. Actions Taken to Remove or Overcome Barriers that Led to the Exception to Fair Opportunity.

As described above, the Government's plan to award this task to the incumbent with a six-month option for transition allows the program office to complete the modernization/reaccreditation efforts, eliminate unprogrammed costs, and remove the barriers to full and open competition.

(b)(5), (b)(4)

(b)(4), (b)(5)

TECHNICAL AND REQUIREMENTS CERTIFICATION (FAR 16.505(b)(2)) I certify that the facts and representations under my cognizance, which are included in this Justification and which form a basis for this justification are complete and accurate.

Technical Cognizance/or COR:

Signature:

APPROVAL:

CONTRACTING OFFICER CERTIFICATION (FAR 16.505(b)(2)): C::$3K to <-$700K) I certify that this justification is accurate and complete to the best of my knowledge and belief.

22560 (619)553-4466

REVIEW:

2.0 BRANCH HEAD (FAR 16.505(b)(2)): (>$700K)

Signature:

Bryan Mansfield/Branch Head

APPROVAL:

22560 (619)553-1356

COMPETITION ADVOCATE (FAR 16.505(b)(2)) (>$700K to $13.SM):

Signature:

Sharon Pritchard/Competition A vocate 20000 (619)553-3200

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Date

Date

(b)(6)

(b)(6)

(b)(6)

(b)(6)