OCT_Justification for Bridge_GPE.pdf

NRC JUSTIFICATION AND APPROVAL

Version Control Date: November 2024

Justification and Approval (J&A) For All Commercial/Non-Commercial Contract Actions U.S. Nuclear Regulatory Commission

The COR must get approval from their respective Contracting Officer to select the appropriate FAR authority and supporting rationale prior to completing this document.

FAR 6.302 Circumstances permitting other than full and open competition.

Justification for Other Than Full and Open

Competition (JOFOC)

FAR 16.505 Ordering

Justification for an Exception to Fair Opportunity (JEFO)

538.7104-3 Sole source justifications FAR 19.808-1 Sole-Source 8(a) > $25M Contracting with the Small Business Administration (The 8(a) Program)

FAR 13.106-1(b) Sole Source Justification for Acquisitions NOT Exceeding the Simplified Acquisition Procedures (SAP)

FAR 13.5- Simplified Procedures for Certain Commercial Products and Commercial Services for Acquisitions Exceeding the SAP

FAR 19-Sole Source to Socioeconomic Small Businesses

Contracting Officer's Representative (COR) Name and Email Raissa Forakis Raissa.Forakis@nrc.gov

Title Program Office / Division Product or Service Bridge Contract for Contract Administration and Closeout Support Services

ADM/AMD Service

Requisition Number Award Date Delivery Date (Supplies)

ADM-26-0045 05/01/2026

Name and Address of Proposed Contractor

OCT Consulting LLC 8260 Greensboro DR STE 435 McLean, VA 22102-3850

Current Period of Performance Start Date

Current Period of Performance End Date

Total Estimated Contract Value (enter ONLY numbers, i.e., 12346)

05/01/2026 01/31/2027 $750,087.30

Period of Performance Extension Start Date (If applicable)

Period of Performance Extension End Date (if applicable)

Proposed Funding Increase amount (if applicable)

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

Type of Action: New Award Follow-on Award Ceiling Price Increase Extension

Type of Contract Vehicle:

Purchase Order BPA, BPA Call or Task Order against a FSS Contract/GSA Schedule Task Order/Delivery Order against an NRC Contract or GWAC Other ____________________

Description of Action:

The Nuclear Regulatory Commission (NRC) currently has an 8(a) sole source contract with OCT Consulting LLC. to provide contract administration and contract closeout support services for the Acquisition Management Division

(AMD).

Due to the unanticipated Revolutionary Federal Acquisition Regulation (FAR) Overhaul’s changes that mandate 8(a) competitions now be conducted for 8(a) valued below $5.5 million and the unexpected federal government shutdown, the agency’s procurement lead times for this procurement have been significantly . This justification will allow the agency to issue a six-month bridge contract to OCT Consulting, LLC.

The proposed bridge contract, consisting of a six-month base period and one three-month option period, is needed to prevent a break in services and unacceptable delays and allow the agency time to issue a competitive procurement, award a replacement contract and transition services. This bridge will provide continued performance of critical contract administration and closeout support services, including support for post-award modifications, closeout actions, data validation, reconciliation, and related administrative activities.

2. Contract Type:

Fixed-Price (FP) Labor-Hour (LH)

Cost-Reimbursement (CR) Hybrid

Time-and-Materials (T&M)

Sole Source Yes No

Brand Name Yes No

3. Period of Performance & Total Estimated Value of Contract.

Start Date End Date Option Period Value (Ceiling)

Base Period 05/01/2026 10/31/2026 $500,058.21

Option Period 1 11/01/2026 01/31/2027 $250,029.10

Total Contract Value $750,087.30

4. Provide a background and description of the supplies or services required to meet the agency's needs, including the rationale for the estimated value change (if applicable).

The objective of this requirement is to provide a broad range of commercial contract administration and closeout support activities. The estimated value is $750,087.30.

5. Authority:

GSAR 538.7104-3 Sole source justifications

538.7104-3(b) (ii): Only one source is capable of providing the products, services, or solutions required at the level of quality required because the products, services, or solutions are unique or highly specialized.

6. Supporting Rationale:

The following rationale supports the use of the authority cited in Section 5 of this document.

The rationale necessitating this bridge contract with the incumbent are necessary to ensure continuity of IT operations and services at the NRC while the NRC executes a modified acquisition which includes issuing a competitive 8(a) acquisition due to unanticipated circumstances outside the agency’s control that are listed below.

1)Government Shutdown and Workforce Leave Restrictions The unanticipated federal government shutdown, which lasted 43 days, resulted in significant procurement lead time. These delays directly affected acquisition planning, market research, and solicitation development.

2)FAR Overhaul Deviation 19.108-7(d) The agency adopted the FAR overhaul deviation prioritizing competitions over sole-source awards within the 8(a) program. While the requirement was initially planned as an 8(a) sole source follow-on, the deviation now mandates a contract competition when the value is below the competitive threshold of $5.5 million, significantly extending the procurement lead time needed to award a competitive contract due to the additional activities required for competitions.

Due to the limited time remaining before the expiration of the current contract, OCT Consulting—the incumbent contractor—is the only source capable of continuing the required support without causing a break in services or unacceptable delays while a new contract is awarded. The services provided under the existing contract are essential to meeting the strict contract closeout timelines established in the Revolutionary FAR Overhaul (RFO) deviation 4.308-2. OCT Consulting is also uniquely positioned to continue this work because its personnel hold active NRC clearances, have agreed to contract-specific non-disclosure requirements, and are fully familiar with agency acquisition policies and NRC’s contract writing system.

Awarding this bridge action to OCT Consulting will prevent disruption to these mission-critical support services while the NRC completes the competitive follow-on acquisition. Transitioning the work to a new contractor for such a short interim period would require additional onboarding and handoff time, create duplication of effort, and introduce a learning curve that could slow ongoing contract administration and closeout activities. These activities include file reviews, de-obligation actions, and completion of pending closeouts.

Therefore, it is in the Government’s best interest to temporarily continue these critical services under a six-month bridge contract with the incumbent. Transferring the work to another contractor at this time is not feasible and would significantly risk continuity of essential closeout and contract administration services.

Cost/Price Analysis In the price analysis, the CO will determine price reasonableness by utilizing various methods to include analysis of historical rates and comparison of the quoted prices with OCT Consulting's GSA Multiple Award Schedule (MAS) price schedule.

7. Market Research Market research was conducted in December 2025 - January 2026. The NRC identified small business vendors on GSA Schedule under SIN 541611 for a targeted competition. However, due to delays that were out of the control of the NRC, a short follow-on contract is required.

8. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under

5.202 applies.

No solicitation for this specific acquisition has been issued for these services, as only one source is uniquely qualified to provide follow-on services. No other public communication such as a notice on the Government Point of Entry web site (SAM.gov) has been issued about this procurement. However, this LSJ will be posted to the GPE after task order award as required by 538.7104-3(b)(3)(A).

9. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The GSA Contracting Officer previously determined the OCT's hourly rates under its schedule contracts to be fair and reasonable. Therefore, a separate determination is not required.

10. Any other facts to support justification.

508 Compliant

Non 508 Compliant (please provide explanation regarding the below:)

(a) The non-availability of conforming ICT, including a description of market research performed and which provisions cannot be met, and

(b) The basis for determining that the ICT to be procured best meets the requirements in the Revised 508 Standards consistent with the agency’s business needs.

N/A.

No solicitation for this specific acquisition has been issued for these services as a small business set-aside or a small disadvantaged business set-aside. No other public communication such as a notice on the Government Point of Entry (GPE) web site (SAM.gov) has been issued about this procurement.

11. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

N/A.

12. 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 supplies or services required.

AMD will continue efforts to complete competitive acquisition for the replacement contract administration and closeout support services contract and will ensure that any future restrictions to competition are adequately supported and documented

13. Publicizing Contract Actions:

This limited-sources justification will be posted on the GPE website.

In accordance with FAR 5.201 and FAR 5.301 this contract action will be publicized on System Award Management