P00031_47QFMA23F0019_EFO_9Feb2026_Redacted.pdf

CUI//SP-SSEL

Version 02/28/2025 Page 1

JUSTIFICATION FOR AN EXCEPTION

TO FAIR OPPORTUNITY

UNDER INDEFINITE

DELIVERY/INDEFINITE QUANTITY

(IDIQ) CONTRACTS

Solicitation 47QFMA23R0008

Cyberspace Operations and Support Services

(COSS)

in support of:

United States Cyber Command

(USCYBERCOM)

United States (U.S.) General Services Administration (GSA)

Docusign Envelope ID: A6A4B669-2E2D-42C1-844D-B49B29AB424F

Version 02/28/2025 Page 2

Federal Acquisition Service Assisted Acquisition Services (AAS) Army

Interagency Agreement Number 47QFCA-21-F-0060

Controlled by AAS Contracting Officer Linda Jacobson: Linda.

Version 02/28/2025 Page 3

The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this Justification for the issuance of an Exception to Fair Opportunity order pursuant to Federal Acquisition Regulation (FAR) 16.507-6 (GSA Class Deviation RFO-2025-16).

a. Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of United States Cyber Command (USCYBERCOM) Contracting Activity:

GSA AAS Army (QFACBC) 100 Independence Mall West Philadelphia, PA 19106

b. Nature and/or Description of Action Being Approved:

The Government intends to modify Task Order (TO) 47QFMA23F0019, currently awarded to Peraton Technology Services, Inc. (via Contract number GS00Q16AJD0002), to extend Cyberspace Operations and Support Services (COSS) for USCYBERCOM, one of the four U.S. military's functional combatant commands. This extension is anticipated to have a total potential duration of 12 months, which will be structured as one 6-month period running from February 1, 2026, to July 31, 2026, followed by two subsequent 3-month option periods, spanning August 1, 2026, through October 31, 2026, and November 1, 2026, through January 31, 2027, respectively.

The contract type of this TO is Cost-Plus-Fixed-Fee (CPFF). The TO was competitively awarded under GSA Multiple Award FEDSIM IDIQ, titled USCYBERCOM IDIQ, utilizing FAR 16.505 ordering procedures on August 1, 2021, with one 12-month base period, three 12-month options, and one 6-month extension.

This TO is set to expire on January 31, 2026, if no action is taken. The extension is required to prevent the lapse of highly sensitive services while providing the Government with the necessary time to award the follow-on competitive TO. It is anticipated that the recompete will be awarded prior to the end of the modified period of performance of this task order.

c. Description of Supplies/Services and Estimated Value:

The Cyberspace Operations Support Services (COSS) for USCYBERCOM encompasses seven core disciplines: Cyberspace Operations, Planning, Training and Exercises, Strategy/Policy/Doctrine Development, IT and Communications, Business Area Support, and Engagement Activities.

This Task Order is specifically focused on enabling USCYBERCOM to sustain its core mission of securing, operating, and defending the DoD Information Network (DODIN) and its critical dependencies. Achieving this requires continuous coordination with USCYBERCOM components and the broader military cyber community, strengthening relationships with partner nations, and crucially, coordinating, synchronizing, deconflicting, and integrating operational planning for full-spectrum cyberspace operations, especially the deconfliction of Offensive Cyberspace Operations (OCO), Version 02/28/2025 Page 4

Defensive Cyberspace Operations (DCO), and DODIN operations throughout the Joint Operational Planning Process (JOPP).

The total twelve (12)-month estimate of extension is $ which is estimated to increase the potential TO ceiling by approximately

d. Identification of the Exception to Fair Opportunity and Rationale:

This TO Justification is being prepared as required by FAR 16.507-6 (GSA Class Deviation RFO-2025-16) Exceptions to Fair Opportunity. As explained below, the justification is in accordance with FAR 16.507-6(b)(2) (GSA Class Deviation RFO-2025- 16), 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.

The critical services USCYBERCOM requirements are at risk of a lapse due to the pending expiration of COSS 2.0 on January 31, 2026. Given recent Executive Orders and directives, it is not possible to both address these orders and re-compete the requirement in time. Given the immensely technical and high-stake nature of USCYBERCOM missions, a service gap would severely compromise USCYBERCOM's ability to deter, disrupt, and defeat foreign malicious actors in cyberspace.

On November 6, 2025, the Department of War (DoW) implemented a revised cyber force generation model, focused on countering emerging cyber threats from China. This change required significant revisions to the Task Order Request (TOR) for the COSS 3.0 recompete, further postponing the anticipated award date. In compliance with Executive Order 14222 ("Department of Government Efficiency" Cost Efficiency Initiative), revisions were also made to government cost estimates for COSS 3.0 to accurately reflect the new cyber model's costs.

Version 02/28/2025 Page 5

To further understand the highly specialized tasks behind USCYBERCOM’s missions, the command plays a central role in protecting sensitive national and international networks, to maintain the safety of the United States’ citizens, allies, and property. The current contractor, Peraton, directly supports USCYBERCOM programs including (1) the Cyber National Mission Force (CNMF), (2) Joint Task Force-ARES (JTF-ARES), and

(3) the Directorate of Operations (J3). Below details the magnitude of these programs:

1. Amid the myriad of duties including the prevention of cyber espionage and ransomware, CNMF has another primary task of protecting the democratic values of the U.S. It combats the spread of false information/profiles/websites, and the hacking of political accounts and voter registration databases – all of which nation-state actors attempt to undermine American trust in its governance, strategically leak information, and control voting behavior.

Additionally, CNMF safeguards the U.S.’ critical infrastructure, which includes sectors as Energy (e.g, power grids), Financial Services, Water Systems, and Agriculture. In this practice, CNMF also deploys and executes defend-forward/hunt missions abroad to inhibit malicious attempts originating in foreign networks before they reach U.S. networks.

2. JTF-ARES is a task force initially created in 2016 to undermine the Islamic State of Iraq and the Levant (ISIL) in cyberspace, notably through its operation, GLOWING SYMPHONY, where the unit accessed and disrupted ISIL propaganda, recruitment, and funding perpetrated via online platforms. In this mission, JTF-ARES also played a role in intercepting command and control communications and misleading terrorists in kinetic battlefield operations.

JTF-ARES has since carried over its model to the Indo-Pacific region, where it has partnered with one of the eleven U.S. military’s geographic combatant commands, the U.S. Indo-Pacific Command, to counter China’s aggression in the region. For instance, since FY24, JTF-ARES has notably increased sensing capabilities against China’s cyberattacks in/around the vital outpost of Guam by employment of over 3,000 operational technology assets that resulted in a 52% reduction in malicious and anomalous behavior in the environment, and a 32% decrease in known vulnerabilities to key assets such as firewalls, switches and routers, achieving a 76% adherence to U.S. Navy’s More Situational Awareness for Industrial Control Systems (MOSAICS) frameworks. This is significant as Guam, home to Air Force; Navy; and Marine bases, has been a top target of China as it wants to undermine potential rapid response efforts in the case of an attack or invasion on Taiwan or other surrounding allied nations.

Version 02/28/2025 Page 6

3. The Directorate of Operations (J3) is one of the most integral components of USCYBERCOM as it directs day-to-day operations among USCYBERCOM programs to meet the core mission of securing the DODIN. It runs the Integrated Cyber Center/Joint Operations Center (ICC/JOC), which is USCYBERCOM’s first dedicated facility for command-and-control of cyber operations. It is housed with the National Security Agency (NSA) and maintains a 24/7/365 operations floor, allowing for rapid responses to cyber threats and oversight of all cyber forces world-wide. It coordinates and integrates global cyber operations by planning missions and organizing their respective forces, routinely collaborating with geographic combatant commands and intelligence agencies.

As explained above, the work performed by USCYBERCOM requires continuation from qualified personnel with tight-niche skillsets in a classified setting. As such, hiring a new contractor would require a Top-Secret clearance followed by granting special approval for access to a specific mission and its respective systems/tools. Completing these procedures could take over a year, and a new contractor would still need to be trained by already tasked personnel to obtain familiarity with USCYBERCOM programs.

Not extending the COSS 2.0 TO would clearly undermine USCYBERCOM’s mission of defending DoD networks, reinforcing national cyber capabilities, and conducting national and international cyber operations for the protection of the U.S. and its allies. Nearly if not all aspects of our governance, security, and daily life are digitally reliant and world powers know this. Not maintaining a strong cyber force will undoubtedly make the U.S.

and its allies overpowered by nations that do not hold democratic values. As such, COSS

2.0 must be extended to avoid risking this tragedy.

e. Determination That the Anticipated Cost is Fair and Reasonable:

The assigned GSA Project Manager (PM) will complete an evaluation of the contractor’s price submission to ensure the labor mix and hours are appropriate for the work to be performed. In accordance with FAR 15.404-1 (GSA Class Deviation (RFO-2025-15) and 15.404-2 (GSA Class Deviation (RFO-2025-15), a price and cost analysis will be performed including the verification of rates, as well as a comparison to prices currently paid to determine the prices fair and reasonable. As in the last extension for this order, it is anticipated that the proposed rates will reflect close similarity to those currently being paid to Peraton.

f. Other Facts Supporting the Justification:

Please note, this requirement was awarded prior to June 13, 2025, and therefore SPE review and/or approval for this non-commercial action is not required.

g. Statement of Actions:

The Government will only solicit Peraton for the current TO extension under this GSA MA FedSim IDIQ to extend the existing TO for twelve (12) months. No other firm can provide the essential services at the requisite level of expertise within the timeframe required. The Government is actively working on the COSS 3.0 recompete, which is

Version 02/28/2025 Page 7 currently in the pre-solicitation phase. GSA anticipates a fully competitive award to be in place upon or prior to the expiration of the current TO’s twelve (12) month extension. For the re-compete, multiple Requests for Information (RFI) have been posted to the acquisition community to ensure competitive acquisition. The RFIs involved soliciting feedback from industry to eliminate any barriers that will hinder competition. GSA will ensure that offers are solicited from as many potential sources as practicable.

h. Certification by Technical or Requirements Personnel:

I hereby certify that the supporting data is accurate and complete.

i. Signature of Authorized Officials:

I hereby certify that the Justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that the exception to fair opportunity is in accordance with the requirements and is in the best interest of the Government.

Date

Contracting Officer, AAS Army Assisted Acquisition Services

GSA Office of General Counsel:

Office of General Counsel

AAS Advocate for Competition:

AAS Contracting Executive:

Version 02/28/2025 Page 8