P00005_47QFMA23F0011_EFO_For Posting_2024.05.22_Redacted.pdf

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

FOR

Defense Manpower Data Center (DMDC)

Cloud Computing Services Acquisition ID: 47QFMA23F0011

Note: This document is hereby identified as a Justification for an Exception to Fair Opportunity and was prepared in accordance with the requirements of FAR 16.505(b)(2)(ii)(B).

1. Identification of the agency and contracting activity

The requiring activity is the Defense Manpower Data Center (DMDC) located at 400 Gigling Road, Seaside, California 93955.

The contracting activity is the General Services Administration (GSA) Federal Acquisition Service (FAS), Assisted Acquisition Service (AAS) Army, Sector 3.

2. Nature/description of the action/contract type

The action being approved is a modification to extend the period of performance for DMDC’s Cloud Computing Services firm-fixed price Delivery Order (DO) 47QFMA23F0011 awarded to Emergent, LLC (Emergent) (Contract NNG15SC33B) under the NASA Solutions for Enterprise-Wide Procurement (SEWP) V vehicle.

This DO was awarded on 23 May 2023 with a period of performance start date of 29 May 2023. The order is set to expire on 28 May 2024. The extension of the current DO by twelve (12) months until 28 May 2025 will ensure that DMDC experiences no lapse in services while the requirement is solicited on a competitive basis.

3. Description of supplies/services required to meet the agency’s needs

DMDC is the DoD enterprise-wide provider of Human Resource IT services and products leveraging extensive human resource focused data assets. DMDC operates the Defense Civilian Personnel Data System (DCPDS), a multifunction, web-based civilian HR information management and transaction processing system that supports approximately 900,000 civilian employee records (appropriated fund, non-appropriated fund, National Guard, and local nationals). Deployment of DCPDS began in October 1999, reaching Full Operating Capability (FOC) in September 2002. DCPDS is a global system supporting users in Asia, the Pacific, Europe and North America on a 24-hour, 7-days-a-week, basis. While DCPDS used a Commercial Off-The-Shelf (COTS) product (Oracle Enterprise Business Suite (EBS)), the system was highly customized for the Federal and Defense environments. With over 500,000 process rules and 1.75M pay and benefit algorithm combinations, DCPDS sustains a complex set of personnel data that interfaces with the DoD payroll system and maintains over 40 other interfaces to external systems and databases. This complexity and number of interfaces resulted in increased sustainment costs and drove the need for HR reforms within the DoD.

The Reform Management Group (RMG) is a Department of Defense (DoD) decision making body comprised of Senior DoD officials with the goal of improving and streamlining the Department’s business processes in accordance with the priorities that the National Defense Strategy released on January 19, 2018. On May 23, 2018, the RMG, led by the Deputy Secretary of Defense (DEPSECDEF), made the decision to enable the delivery of a modern capability. That decision led to the selection of an Oracle Software as a Service (SaaS)

/ Human Capital Management (HCM) Cloud Platform (a software solution that allows users to connect to and use cloud-based applications over the internet). Additionally, DCPDS is being replaced by the Defense Civilian Human Resources Management System (DCHRMS). The DCHRMS is a cloud-based system that is being built on Oracle’s HCM Cloud Platform to provide a single civilian personnel service capability for the DoD. It is a commercial-based Human Resource (HR) information system (HRIS) that will support civilian HR management, establish a single employee record, and create standardized personnel data across the enterprise. It will move six separate databases that maintain DoD employee records into one integrated HRIS which will serve as one enterprise-wide database. These separate databases are currently housed in on-premises data centers. Accordingly, the data from these on-premises data centers must be transitioned to the Oracle Cloud Infrastructure (OCI) prior to the implementation of the operational version of the DCHRMS.

This requires loading 900,000 total hosted employee records for test purposes of the migration process.

Under the current delivery order, DMDC has purchased SaaS licenses that provide DMDC with the ability to use the Oracle HCM Cloud Platform for the development phase of DCHRMS. In order to prepare for the operational version of the DCHRMS program, the Government must continue its licenses to Oracle HCM to complete development services.

A twelve-month extension of the period of performance will provide continued Oracle HCM Cloud software and licenses as well as continued support for the operation of the DCHRMS HCM environment while the Government performs the recompete acquisition. The Government estimate for the twelve-month extension is $ It is anticipated that the overall potential contract ceiling will increase from $21,545,510.06 by $13,520,006.65 to $35,065,516.71.

4. Identification of the exception to fair opportunity

The statutory exception to fair opportunity for this action is FAR 16.505(b)(2)(i)(A), the agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

An extension to the current delivery order is necessary for the continued development of the DCHRMS.

Without these licenses, DMDC would be unable to load the 900,000 employee records for test purposes of the migration from the DCPDS to the DCHRMS. Additionally, DMDC would not have the ability to load personally identifiable information (PII) data into the test and development environment prior to production.

Ultimately, these licenses provide the ability to perform the necessary tests to ensure that the DCHRMS can support the civilian employee records currently maintained by the DCPDS, which is in the process of being decommissioned, without issue. If the current DO is not extended and there is a break in service in the provision of SaaS software licenses for the Oracle HCM Cloud Platform, the DCHRMS will fail to reach Initial Operational Capability (IOC) (IOC is achieved when a capability is available in its minimum usefully deployable form).

The need for this extension is driven by a delay in the estimated timeline for IOC of the DCHRMS, which is now set for Q3 of FY 2025. This delay is due to a corporate decision made by Oracle to release DoD required enhancements, which include workflow improvements and the ability to validate data on a more granular level, within Oracle’s new Redwood User Interface/User Experience (UI/UX). Given that Redwood is a completely new UI/UX, modifications to cybersecurity accreditations are required and DMDC will have to reanalyze and reconfigure the DCHRMS functionality for all 900,000 civilian records seamlessly within the Redwood UI/UX. Based on the estimated time required to configure these final DCHRMS IOC requirements, IOC deployment shifted from Q3 FY 2024 to Q3 FY 2025.

As a result of this unexpected delay, an extension of the current Cloud Computing Services DO (47QFMA23F0011) is necessary. If the Cloud Computing Services DO is not extended, the DoD would be unable to test and release the DCHRMS in an IOC state for Q3 FY 2025. Furthermore, the DoD would be unable to streamline their six separate databases that maintain DoD employee records into one integrated enterprise database and ultimately transition out of their on-premises data centers into a Cloud environment per DoD guidance. This would result in critical impacts to civilian employee pay and benefits without the ability to rely on business rules to ensure data quality. In addition, there would be significant workload impacts that the DoD HR community is not resourced to handle.

Based on the above information, conducting fair opportunity procedures at this time would not be feasible.

The current delivery order is set to expire on 28 May 2024. A competitive procurement could not be completed by this date as it would require approximately six (6) months to be competed and awarded. This would result in a break in service for an extended amount of time which would severely impact the development of the DCHRMS and disrupt the DoD HR community. The need for an additional twelve (12) months of services and supplies provided by the current delivery order could not be anticipated given Oracle’s business decision discussed above. The only solution to prevent a DMDC mission failure and catastrophic results is to extend services of the current Cloud Computing Services DO to continue these essential services while a new delivery order is competed.

5. Determination by the ordering activity Contracting Officer that the anticipated cost to the

Government will be fair and reasonable

Emergent, LLC offers the required services for this extension under its NASA SEWP V contract number NNG15SC33B. By extending the existing DO that is already in place, the ordering activity has concluded that the order represents the best value (as defined in FAR 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government’s needs. The Contracting Officer (CO) has determined that this action will result in the greatest overall benefit to the Government as Emergent, LLC is the only contractor that can satisfy the Government’s requirements within the allowable timeframe. Additionally, the CO will consider the proposed cost for the procurement of SaaS licenses and make a determination that the proposed price is fair and reasonable in accordance with FAR 15 techniques such as a comparison of proposed prices for the extension to historical prices paid and comparison of proposed prices for the extension with independent Government cost estimates.

6. Any other facts supporting the justification

No other facts are currently available.

7. A statement of actions to remove or overcome barriers to exception to fair opportunity

If future expenditures and allowances are granted for continued support during the period of performance of this order, all efforts will be made by the Government to seek alternate sources of service for the support.

The Government is in the process of gathering the requirements to recompete DMDC’s Cloud Computing Services.

Signatures Begin on Next Page

CERTIFICATIONS AND APPROVALS

8. Contracting Personnel Certification:

I certify that this Exception to Fair Opportunity is accurate and complete to the best of my knowledge and belief.

______________ Date: _________________ Contract Specialist

GSA/FAS, AAS Army, Sector 3

I certify that this Exception to Fair Opportunity is accurate and complete to the best of my knowledge and belief.

___________________________ Date: _________________ Jon Woloszyn, Contracting Officer

GSA/FAS, AAS Army, Sector 3

9. Requirements Personnel Certification:

I certify that the supporting data under my cognizance, which are included in the Exception to Fair Opportunity, are accurate and complete to the best of my knowledge and belief.

_______________ Date: _________________ Project Manager

Reviewed by:

______________ Date: _________________ Branch Chief AAS

________________ Date: _________________ Director of Contracts

_ _______________ Date: _________________ Assistant Regional Counsel

Approval:

10. Approval Official Determination:

I determine that the circumstance in FAR subsection 16.505(b)(2)(i)(A), the agency need for the supplies or services is so urgent that providing fair opportunity would result in unacceptable delays, applies to this order.

____________ Date: _________________ Competition Advocate