redacted JOFOC.pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Goddard Space Flight Center (GSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Program Analysis and Control (PAAC V) 80GSFC20D0001

1. Federal Acquisition Regulation (FAR) 6.303-2(b)(1) – Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

This document is a justification for other than full and open competition prepared by National Aeronautics and Space Administration (NASA) Goddard Space Flight Center

(GSFC).

The procuring agency is the National Aeronautics and Space Administration (NASA), and the contracting activity is GSFC.

2. FAR 6.303-2(b)(2) – The nature and/or description of the action being approved:

This justification provides the rationale for contracting by other than full and open competition to increase the maximum ordering value for continued performance under Contract number 80GSFC20D0001, with Program Analysis and Control (PAAC) V.

PAAC is a Cost-Plus Fixed Fee Indefinite Delivery Indefinite Quantity (IDIQ) contract awarded with a five-year Ordering Period of January 1, 2019, through December 31, 2024, with a maximum ordering value of $354M. The contract also includes the ability to increase the value by 30%, if needed. Modification 71 raised the maximum value by 30% to the current maximum ordering value of $461M.

The PAAC V contract with ASRC Federal System Solutions, LLC (ASRC), provides Financial Support Services and Project Planning and Control Services (PP&C) for GSFC, Headquarters (HQ) and Langley Research Center (LaRC). PAAC V provides business functions and services in support of the GSFC Flight Projects Directorate and other NASA Headquarters programs. It is estimated that the current maximum ordering value of $461M, will be reached in July 2024 which is five months earlier than the current ordering period of December 31, 2024. As of December 21, 2023, GSFC has negotiated and awarded a total task value of $452,726,869, hence only $8,513,131 is available and we are rapidly approaching the maximum ordering value.

It is estimated that an increase to the maximum value of $65M will be needed to cover continued performance through December 2024, resulting in a maximum ordering value of $526,240,000.

In order for work to continue through December 31, 2024, the proposed $65M is essential to ensure continuity of several programs and projects, to provide critical mission support, and to avoid significant technical and schedule impacts to GSFC and reimbursable customer programs. This maximum value increase amount was determined by a review of all the existing or planned PAAC V tasks and planned modifications to existing tasks.

There were several unanticipated factors that caused the PAAC V contract to approach the maximum ordering value earlier than expected. In accordance with the NFS Appendix A – Enterprise Procurement Strategies (102.8 and 102.9) PAAC V is the required contract vehicle for GSFC, HQ’s and Langley to use for procuring Financial Support Services and Project Planning and Control Services (PP&C). NASA anticipated some level of fluctuation due to PAAC V being a regional contract, however, we did not anticipate the volume of transition of contract requirements from other contract vehicles. Langley initially informed GSFC that they intended to transition existing contract requirements to PAAC V. After further analysis was conducted prior to the transition, it was determined that even more contract requirements would transition to PAAC V.

It was also anticipated that work under PAAC would transition to other NASA agencywide contracts such as the Enterprise Multimedia and Integrated Technical Services (eMITS) and the NASA Communications Services (NCS) contracts. The delay in the award of these two agencywide contracts resulted in the need to extend the work under the PAAC contract and transition later than expected. In addition, the project support work at HQs under PAAC was supposed to transition to administrative contracts, the Agency Wide Acquisition Support Services contract, and the Operations and Programmatic Support Services contract, however, it did not occur. Additionally, there were mission delays that required increased support than previously anticipated by their scheduled launch dates. Some specific examples of the circumstances which have resulted in the rapid approach to the maximum ordering value are as follows:

3. FAR 6.303-2(b)(3) – A description of the supplies or services required, to meet the

Agency’s needs (including the estimated value):

This justification provides the rationale for using other than full and open competition to award an increase to the IDIQ maximum ordering value for contract 80GSFC20D0001, with ASRC to meet the Agency’s needs. The current scope of work for the PAAC V contract includes the following business functions and services: accounting, planning and scheduling/earned value management, documentation management, configuration management and security compliance. Without an increase to the maximum ordering value, NASA GSFC would be precluded from continuing current ongoing support requirements and issuing further new orders for services under this contract. The increase is necessary to continue performance through the effective ordering period of the contract.

NASA GSFC is proposing to increase the contract maximum ordering value by an amount of $65M to allow for new work and continued performance of mission critical services under the PAAC V contract.

4. FAR 6.303-2(b)(4) – An identification of the statutory authority permitting other than full and open competition:

The statutory authority permitting other than full and open competition is 10 U.S.C.

3204(a)(1), as implemented by FAR 6.302-1, "Only one responsible source and no other supplies or services will satisfy agency requirements.”

5. FAR 6.303-2(b)(5) – A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

The rationale supporting the use of 10 U.S.C.3204(a)(1), as implemented by FAR 6.302-1, is “Only one responsible source and no other supplies or services will satisfy agency requirements” as described below.

As the incumbent contractor, ASRC is uniquely qualified with the combined training and experience to provide uninterrupted continuation of a broad range of current mission critical support. Additionally, as we begin the last year of the effective ordering period, ASRC is considered the only contractor that can meet GSFC’s needs without disruption to current programs and services required in the interim period until the follow-on contract is awarded.

Should these services be interrupted, NASA will be unable to perform and fulfill critical mission support to remain on schedule. In determining a solution that represents the least amount of risk to the government, stability and continuity are critical factors. ASRC is considered the only contractor that can meet GSFC’s needs, given the short amount of time remaining under the current contract. These services clearly function as integral parts of all the supported NASA missions.

If NASA attempts to procure these services from any other source, the combination of delay due to the competitive process and the time required to transition a new management team to coordinate staffing levels, schedules, and to become familiar with work requirements and systems would cause unacceptable delays in fulfilling NASA’s mission. Based on the time and costs that would be involved in procuring and phasing in another contract, ASRC is the only entity possessing the detailed knowledge necessary to provide seamless continuation of the services provided under the PAAC V contract without risk of an unacceptable interruption or delay of critical services. Failure to increase this ceiling would result in significant costs to the government. Also, it is very likely that there would be significant ramp up costs for a new contractor to try to quickly replicate the knowledge/systems/processes that the incumbent has, and it would take significant effort and cost to do so.

6. FAR 6.303-2(b)(6) – A description of the efforts made to ensure that offers are solicited from as many potential sources as 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:

A notice to the Government Point of Entry (GPE) website (Sam.gov) was published on February 16, 2024, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award this sole-source contract to ASRC. The results of this synopsis are contained in Section 10 below.

7. FAR 6.303-2(b)(7) – A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer’s signature on this document indicates that the Contracting Officer has determined that the anticipated cost to the government will be fair and reasonable. Since this justification is solely to increase the maximum ordering value to align with the current ordering period, the rates are already included in Attachment B in the current contract, and a proposal is not required for this action.

8. FAR 6.303-2(b)(8) – Description of the market research conducted, and the results, or a statement of the reasons market research was not conducted:

Market research for this effort was not conducted, however, market research is being conducted for the follow-on contract and competition is expected.

Based on the short duration of the remaining ordering period, there are currently no other offerors that could take on full contract responsibility in such a short timeframe without significant performance, cost and schedule risks that could cause delays to critical mission milestones. The Government would unnecessarily incur significant additional cost if another contractor were to perform this effort.

9. FAR 6.303-2(b)(9) – Any other facts supporting the use of other than full and open competition:

ASRC is the only entity that currently possesses the detailed knowledge necessary to provide a seamless continuation of the services and operations provided under the PAAC V contract. PAAC V has 121 active tasks and 209 subtasks. Reprioritizing existing tasks and shifting current or new requirements to other IDIQ support service contracts in order to remain within the current $461M ceiling for the duration of the current PAAC V contract ordering period will result in a costly and inefficient duplication of effort. The