SF_1012 LSJ IA Support ISHPI Bridge _Redacted.pdf

DEPARTMENT OF THE TREASURY

LIMITED-SOURCES JUSTIFICATION

This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

Treasury Standard Form – 1012 (Rev 5/18)

Prescribed by Treasury: DTAP 1008.405-6 Tracking No.

1. Identification of the agency and the contracting activity:

The Requiring Activity is the Bureau of Engraving and Printing (BEP), Office of Critical Infrastructure & IT Security(OCIITS). The Contracting Activity is: Internal Revenue Service, Office of Information Technology Acquisitions (OITA), BEP Acquisition Branch.

2.a Nature and/or description of the action being approved: The purpose of this limited sources justification is to obtain approval to award a sole source, firm-fixed price GSA MAS task order for Information Assurance (IA) Support Services and Transition Services for the period of June 12, 2020 to July 31, 2020 against MAS Contract GS-35F-467DA.

2.b Name of the vendor: ISHPI Information Technologies, Inc.

2.c Requisition No.: 138313 2.d Bridge contract: X Yes No 2.e Brand name: Yes X No 3.a A description of the supplies or services required to meet the agency’s needs:

BEP requires Information Assurance (IA) support in the areas of security program management as well as analytical and technical support to protect BEP assets and ensure compliance with the Federal Information Security Management Act (FISMA), Office of Management and Budget Circular A-130, Department of the Treasury and BEP IT Security policy and procedures, and other relevant laws or regulations. Two critical areas of IA support serviced by this requirement are Certification and Accreditation (C&A) and Audit and Compliance Program Support.

3.b Includes IT: X Yes No

PSC - 5810 - COMMUNICATIONS SECURITY EQUIPMENT AND COMPONENTS,

NAICS – 541512 – Computer Systems Design Services

3.c IGCE/Estimated dollar value:

4.a Identification of the authority being used (Check the appropriate box that applies).

FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

X FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

FAR 8.405-6(a)(1)(i)(C) – In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order or BPA provided that the original order or BPA was placed in accordance with FSS procedures in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

FAR 8.405-6(b) – Items peculiar to one manufacturer.

4.b Supporting Rationale:

BEP is currently receiving Information Assurance (IA) Support Services from ISHPI under STARS II order 2031ZA18F00081. The Government has already placed STARS II order 2031ZB20F00035 to obtain follow-on bridge services as a result of a protest on a larger competitive order. The follow-on vendor is set to begin fully performing the requirement on August 1, 2020, after the transition period is completed. The Government planned to exercise FAR 52.217-8 “Option to extend services” on order F00081 to continue IA Support and

This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

Treasury Standard Form – 1012 (Rev 5/18)

Prescribed by Treasury: DTAP 1008.405-6 Tracking No.

complete transition support services to the follow-on IA Support Contractor. However, the STARS II contract has now exhausted its entire $15B ceiling much sooner than the planned ordering period end date of August 30, 2021. Therefore, exercising FAR 52.217-8 is no longer possible, as it would increase the overall order total ceiling. No increases to order ceilings are currently permitted by GSA. Support under Order F00081 is now slated to end on June 11, 2020.

BEP needs to maintain current IA and transition support for the period of June 12, 2020 to July 31, 2020 in order to prevent a stoppage of support and successfully transition to the new Contractor on order 2031ZB20F00035. Only ISHPI is currently capable of providing this support due to the unique characteristics of the requirement. In order to provide the necessary support, a Contractor would first need to have their entire workforce recruited and cleared prior to June 12, 2020. The security clearance process at BEP typically takes between 30-90 days to obtain an interim clearances. Even if a Contractor had a fully cleared workforce available, they would also need a 60-day transition-in period that would include knowledge transfer, to be capable of full performance of the requirements. At that time, this task order would already be concluded. The start date of this requirement of June 12, 2020 is less than a month away. Only ISHPI is capable of performing the required IA and transition related support services beginning on June 12, 2020. As the incumbent, ISHPI already possesses a fully cleared workforce and does not require any knowledge transfer. They are also already beginning the transition support under task order F00081.

Failure to execute this order would result in a loss of critical IA support services for the period of June 12, 2020 to July 31, 2020. Without this support, BEP would be unable to comply with the Federal Information Security Management Act (FISMA), Office of Management and Budget Circular A-130, Department of the Treasury and BEP IT Security policy and procedures, and other relevant laws or regulations. The BEP IT assets, including automated systems directly involved in currency production, would be at great risk of being compromised.

Therefore, the Government must place a sole source GSA MAS order to ISHPI for the period of June 12, 2020 to July 31, 2020 to maintain critical IA support and execute transition support to ensure that the follow-on Contractor is fully prepared to takeover IA support starting on August 1, 2020.

5. A determination by the ordering activity Contracting Officer that the order or BPA represents the best value consistent with FAR 8.404(d):

The Contracting Officer has determined that the GSA order represents the best value consistent with FAR 8.404(d) and lowest overall cost considering price and special features. Use of GSA MAS allows the Government access to a streamline process to placing an order against an existing Contract with established Labor Rates. The Government will evaluate labor rates and hours to determine price reasonableness at the order level. Pricing will be compared to the IGCE and historical data. Additional discounts will be negotiated as necessary.

6. A description of the market research conducted among schedule holders and the results or a statement why market research was not conducted:

The Government analyzed current Contractor’s at BEP that possess security clearances and was unable to identify any that possesses the ability to perform current IA Support needs and perform

This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

Treasury Standard Form – 1012 (Rev 5/18)

Prescribed by Treasury: DTAP 1008.405-6 Tracking No.

required transition services due to the security clearance and transition constraints.

7.a Any other facts supporting this justification:

The Acquisition Plan, IGCE and PWS support this justification.

7.b Attachments: Yes X No

8. A statement of the actions, if any, the Requiring Activity and Contracting Activity may take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for the supplies and services is made:

The follow-on task order has already been awarded. The Government does not anticipate the need for further restrictions to competition after this task order has expired.

9. Certifications and Approvals:

9.a Program Office Certification (Requiring Activity). I hereby certify that any supporting information and data provided (e.g., the Government’s minimum needs or requirements, or other rationale for the limited sources) and which form the basis for this justification for an exception to fair opportunity, are accurate and complete to the best of my knowledge and belief.

Name: Corey Costango Date: 5/21/20

Signature:

9.b Contracting Officer Certification and Approval. I hereby determine the circumstances of this acquisition support the justification to acquire these supplies or services on a limited source basis. I also certify this limited-sources justification is accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the authorized contracting officer for this acquisition, I hereby approve the processing of this requirement on a limited-source basis.

Name: Date:

Signature:

10. Additional Reviews and Approvals (As applicable):

10.a Bureau Chief Information Officer or Authorized Designee (for IT requirements that are over $5 million, but not exceeding $68 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification. (Note: The Bureau CIO may delegate their authority for proposed contracts over $5 million, but not exceeding $13.5 million to the Associate Bureau CIO(s).)

Name: Date:

Signature:

10.b Advocate for Competition (if over $700,000, but not exceeding $13.5 million) (Contracting Activity). I have reviewed this limited-sources justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the ordering activity’s Advocate for competition, I hereby approve this limited-sources justification.

Name: Date:

Corey C. Costango Digitally signed by Corey C. Costango Date: 2020.05.21 09:09:09 -04'00'

Paul V. Garner Digitally signed by Paul V. Garner Date: 2020.05.21 10:23:34 -04'00'

This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

Treasury Standard Form – 1012 (Rev 5/18)

Prescribed by Treasury: DTAP 1008.405-6 Tracking No.

Signature:

10.c Head of the Procuring Activity or Authorized Designee (if over $13.5 million, but not exceeding $68 million) (Contracting Activity). I have reviewed this limited-sources justification and find it to be accurate and complete to the best of my knowledge and belief.

Therefore, unless additional approvals are required as prescribed below, as the head of the procuring activity or authorized designee, I hereby approve this limited-sources justification.

Name: Date:

Signature:

10.d Treasury Chief Information Officer (for IT requirements that are over $68 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification.

Name: Date:

Signature:

10.e Senior Procurement Executive (if over $68 million) (Contracting Activity). I have reviewed this limited-sources justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, I hereby approve this limited-sources justification.

Name: Date:

Signature: