Redacted_P00023_47QFMA23F0023_EFO_17_SEPT_2026 Final.docxv1_Redacted.pdf

CUI//SP-SSEL

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JUSTIFICATION FOR AN EXCEPTION

TO FAIR OPPORTUNITY

UNDER INDEFINITE

DELIVERY/INDEFINITE QUANTITY

(IDIQ) CONTRACTS

Solicitation 47QFMA23Q0017

Defense Civilian Personnel Data System

(DCPDS)

Software Sustainment Support Services in support of:

Defense Manpower Data Center (DMDC)

United States (U.S.) General Services Administration (GSA) Federal Acquisition Service

Assisted Acquisition Services (AAS) Army

Interagency Agreement Number 47QFMA10S0001

Controlled by AAS Contracting Officer Linda Jacobson: Linda.Jacobson@gsa.gov

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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:

Defense Manpower Data Center (DMDC) 400 Gigling Road Seaside, CA 93955

Contracting Activity:

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

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

The Government intends to issue a modification to increase the ceiling under Task Order (TO) 47QFMA23F0023, Defense Civilian Personnel Data System (DCPDS) Software Sustainment Support Services, awarded to Leidos Inc. against GSA’s Alliant 2 Government-wide Acquisition Contract (GWAC). The TO was originally awarded on September 28, 2023, in the total ceiling amount of , and consisted of one

(1) 12-month base period and three (3) 12-month option periods with an expiration date of September 27, 2027. Subsequent modifications increased the ceiling to the current amount of . The contract type is a combination Firm-Fixed-Price (FFP) and Labor Hour (LH), awarded utilizing FAR 16.505 ordering procedures. The TO is currently in Option Period two (2) which ends on September 27, 2026. This ceiling increase is at the total estimated cost of and solely supports option period three (3), commencing September 28, 2026.

c. Description of Supplies/Services and Estimated Value:

Under the current order, the contractor provides a web-based civilian Human Resource information management and transaction processing system. The system supports over 900,000 civilian employee records and 1.5 million position records. It is a global system supporting users in Asia, the Pacific, Europe and North America on a 24-hour, 7-day-a-week basis. DCPDS uses a Commercial Off-The-Shelf (COTS) product (Oracle HR), customized for the Federal and Defense environments, to provide personnel transaction processing. Software integration and maintenance services are required to ensure that all applications are fully compatible and integrated with current software and hardware within DMDC. The contractor is responsible for managing and supporting the operation, maintenance, versioning and upgrading of the DCPDS throughout its entire lifecycle. The contractor utilizes best practices, techniques and procedures essential to the application’s

Version 02/28/2025 Page 3 operation, performance and efficiency. This includes the operations, sustainment, and maintenance of DoW and non-DoW Components. DoW Components include Air Force, Army, Navy, Defense Finance and Accounting Service (DFAS), Defense Logistics Agency (DLA), and National Guard (NG); and Non-DoW Components include the Executive Office of the President (EOP) and the United States Agency for Global Media (USAGM). The applications/systems included in the scope include Reduced Sign-On (RSO) – Production and System Quality Testing, DCPDS - 8 Production, SQT – Single Combined DCPDS, MyBiz, MyPerformance, Corporate Management Information System (CMIS), Current Record Mart (CRM), Non-DoW CRM (NDCRM), SAP Business Intelligence/Business Objects (BOBJ) External Interface Transfer System

(EXITS).

The ceiling increase is estimated to be , which will increase the TO ceiling by approximately percent from to if Option Year 3 is exercised.

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

This Task Order Justification is being prepared as required by FAR 16.507-6 (GSA Class Deviation RFO-2025-16) Exceptions to Fair Opportunity. The statutory authority for this action is 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 incumbent, Leidos, Inc., is the only source capable of continuing to provide these critical services without interruption. It is impossible to re-compete the current requirement by the Option Period 2 expiration date of September 27, 2026 and avoid a lapse in the critical services required by DMDC. A competitive procurement would require an estimated procurement lead time of nine (9) to twelve (12) months which aligns with the time remaining on the current task order if Option Period 3 is exercised. Leidos has successfully performed under the DCPDS TO for the past three (3) years and therefore has employees currently in place that possess the necessary skills and institutional knowledge that are required to seamlessly continue the required support given current time constraints. No contractor other than Leidos currently has a pool of in-place support staff available with the requisite knowledge of DCPDS ready to perform these requirements immediately.

Ultimately, Leidos possesses the cleared personnel, system access, and unique, institutional knowledge required to prevent a gap in, or degradation of, services while the Oracle HR services are competitively procured.

DCPDS was originally slated for decommissioning following the development of its follow-on system, the Defense Civilian Human Resources Management System (DCHRMS), and thus was in a “sunset” posture. DCHRMS was an effort to align with the DoW Reform Management Group (RMG) decision directing the Chief Management Office (CMO) Information Technology (IT) reform team to deliver a new modern DoW civilian personnel system based on a commercial Software as a Service (SaaS) cloud product offering. However, the DCHRMS development program, as well as all associated contracts at the Defense Human Resources Agency, was terminated at the

Version 02/28/2025 Page 4 direction of the Secretary of War's Memorandum for Senior Pentagon Leadership titled, “Continuing Elimination of Wasteful Spending at the Department of Defense.” As a result, DCPDS immediately transitioned out of its "sunset" posture and is now the enduring Department of War (DoW) enterprise solution for civilian personnel data management, necessitating an unplanned, extended sustainment lifecycle.

Due to the revival of DCPDS, the DoW now faces an immediate compliance gap with mandates that were not applicable while DMDC was transitioning out of DCPDS.

Specifically, the aging DCPDS infrastructure must comply with Executive Order 14028 titled, “Improving the Nation’s Cybersecurity” which charges multiple agencies including the DoW with enhancing cybersecurity through a variety of initiatives related to the security and integrity of the software supply chain. Further, DCPDS must adhere to the DoW Zero Trust Strategy which assumes adversaries are already inside the network and requires continuous authentication, least-privilege access and micro segmentation.

DCPDS must also now comply with civilian workforce mandates including the modernization of DoW civilian HR capabilities to improve talent acquisition, development, and retention outlined in recent Fiscal Year National Defense Authorization Act’s 2020 – 2022, all of which were previously deferred to the now canceled DCHRMS. Consequently, legacy DCPDS modifications were frozen to avoid duplicative development costs. DCPDS must rapidly engineer and deploy these legally required, congressionally mandated updates into its aging architecture to avoid violating Federal statutes.

If this TO ceiling is not increased and Option Period 3 is not exercised, a lapse in service will cause a complete cessation of mission-essential Civilian HR capabilities such as managing employee payment and leave records, performance management, processing and tracking human resources and personnel actions, employment verification, and professional development. Furthermore, a lapse would jeopardize the integrity of the DoW HR records system as well as delay payment to over 900,000 DoW Civilian employees.

Based on the above analysis, Leidos is the only contractor capable of providing the supplies or services required at the level of quality required within the necessary timeframe. As explained, no other contractor can offer the immediate support required to maintain mission continuity.

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. Additionally, the contractor is expected to utilize the existing TO labor rates, or similar rates, which were previously analyzed and found fair and reasonable as part of the original award determination in its revised proposal. This determination was based on comparisons of the proposed prices (both the proposed labor rates and the total proposed price) against the Independent Government Cost Estimate (IGCE) and relevant market research data for similar items, consistent with FAR 15.404-1(b)(5) (GSA Class Deviation RFO-2025-15) and 15.404-1(b)(4) (GSA Class Deviation RFO-2025-15). The

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Contracting Officer will make a new fair and reasonable price determination in accordance with the techniques identified in FAR 15.404 (GSA Class Deviation RFO- 2025-15) for the revised total price before awarding the modification. This subsequent determination for the revised proposal is anticipated to rely primarily on a comparison with the client developed IGCE specifically for the PWS requirements.

f. Other Facts Supporting the Justification:

There are no other facts supporting the justification.

g. Statement of Actions:

The Government will solicit only Leidos, Inc. under their GSA Alliant 2 Government-wide Acquisition Contract (GWAC) contract (47QTCK18D0008) / TO 47QFMA23F0023. This action will increase the ceiling under the current order for Option Period 3 from September 28, 2026 to September 27, 2027. No other firm 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. This ceiling increase provides the necessary coverage while the Government conducts acquisition planning for the recompete Order under the DEHRADS BPA, ensuring a fully competitive award is established before the current DCPDS TO expires. There are no barriers to competition as the DCPDS recompete will be solicited through the DMDC DEHRADS BPA. This vehicle was originally established with Multiple Award Schedule contractors representing the best value per legacy FAR 8.405-3(b)(2)(viii) and currently includes ten (10) active BPA holders.

h. Certification by Technical or Requirements Personnel:

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

Date

Project Manager, AAS Army

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.

Contracting Officer, AAS Army

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Assisted Acquisition Services

AAS Advocate for Competition:

Competition Advocate, AAS Army

AAS Client Executive:

Client Executive, AAS Army