USCG Consolidation DF for BSX Boating Final Redacted.pdf

DETERMINATION TO CONSOLIDATE/BUNDLE REQUIREMENTS INTO A SINGLE

CONTRACT

(NON-SUBSTANTIAL QUANTIFIABLE BENEFITS)

Determination for U.S. Coast Guard (USCG) to Consolidate Recreational Boating Safety Database Management and Recreational Boat Testing and Inspection Services into a Single Contract.

This determination is made pursuant to RFO 7.107-1.

The total value, including all options, of all actions covered by this determination is estimated to be $24,406,019.57.

FINDINGS

1. Description/Background

United States Coast Guard (USCG) Boat Safety Division (BSX-2) proposes to award a single firm-fixed-price (FFP) contract through a competitive Total Small Business set-aside. The contract will support the Manufacturer’s Identification Code (MIC) Recreational Boating Safety Database and the Recreational Boat Testing and Inspection Compliance Program. The planned period of performance includes a one-year base and four (4) one-year option years, beginning December 7, 2026, to coincide with the expiration of the current awards.

The USCG is responsible for the Recreational Boat Testing & Compliance Program, which ensures recreational boat manufacturer compliance with all statutory and regulatory requirements under 46 U.S.C. §§ 4301-4312 and 33 Code of Federal Regulations Subchapter S.

To effectively administer the program, CG-BSX-2 requires services for technical and administrative support. The current contractor services are provided by two (2) separate vendors, which encompass (1) MIC Recreational Boating Safety Database Management and (2) Recreational Boat Testing & Inspection Services. Both services are managed by the same USCG contracting, technical, and program personnel, all of whom are responsible for executing the statutorily mandated Recreational Boat Testing & Compliance Program.

The original requirement for contractor support services was awarded in 2003 and historically managed under a single accountable vendor acquisition strategy that provided comprehensive support for boat testing and inspection including the management of the resulting data, until 2019. The most recent contract that included both database management and boat testing and inspection services was awarded under Contract No. HSCG23-14-C-MBS004, with a period of performance from June 8, 2014, through June 7, 2019. From 2019 to the present, the requirement has been separated under a legacy acquisition strategy using service-category-specific awards through the 8(a) Small Business Program, specifically for: (1) database management and (2) boat testing and inspection services.

The proposed consolidated procurement action would reunify requirements that were previously combined and are operationally linked. Consolidation will improve administrative efficiency and reduce duplication created by separately awarded contracts. One requirement involves inspection services coordinated with recreational boat manufacturers, while the other involves managing the database containing the related test and inspection case information.

Table 1 below reflects current and previous awards related to this requirement:

Table 1: List of Active Awards Proposed Consolidation

Action 2 (Active Award) Award No. 70Z02325CBSX20001 (Recreational Boat Testing and Inspection

Services) Contractor(s) Professional HIR LLC Place of Performance 200 Dexter St West, Chesapeake, VA 23324 Period of Performance Base Period – 6/7/2025 – 12/6/2025

Option 1 – 12/7/2025 – 3/6/2026 Option 2 – 3/7/2026 – 6/6/2026 Option Extension Period One – 6/7/2026 – 9/6/2026 Option Extension Period Two – 9/7/2026 – 10/6/2026 Option Extension Period Three – 10/7/2026 – 11/6/2026 Option Extension Period Four – 11/7/2026 – 12/6/2026

Contract Characteristics Type: FFP Indefinite-Delivery Vehicle (IDV): N/A Award Procedures: (FAR 19.1) Others: N/A

Action 1 (Active Award) Award No. 70Z02325FBSX20003 (Recreational Boating Safety Database

Management) Contractor(s) D9Tech Resources, LLC Place of Performance 915 First Colonial Rd, Ste. 100, Virginia Beach, VA 23454 Period of Performance Base Period – 10/1/2025 – 6/6/2026

Option Extension Period One – 6/7/2026 – 9/6/2026 Option Extension Period Two – 9/7/2026 – 10/6/2026 Option Extension Period Three – 10/7/2026 – 11/6/2026 Option Extension Period Four – 11/7/2026 – 12/6/2026

Contract Characteristics Type: FFP Indefinite-Delivery Vehicle (IDV): N/A Award Procedures: (FAR 19.1) Others: N/A

Extent Competed Full and open competition after exclusion of sources.

Set-Aside Type Competitive 8(a) Total Amount Obligated $585,961.51 Total Potential Contract Value

$733,254.16

Extent Competed Full and open competition after exclusion of sources.

Set-Aside Type Competitive 8(a) Total Amount Obligated $3,276,637.04 Total Potential Contract

$3,931,964.42

Action 3 (Legacy Closed Award for Reference)

Award No. 70Z02320CM0200600 (Boat Testing & Inspections) Contractor(s) Professional HIR LLC Place of Performance 200 Dexter St West, Chesapeake, VA 23324 Period of Performance Base Period – 12/7/2019 – 12/6/2020

Option 1 – 12/7/2020 – 12/6/2021 Option 2 – 12/7/2021 – 12/6/2022 Option 3 – 12/7/2022 – 12/6/2023 Option 4 – 12/7/2023 – 12/6/2024 Option (52.217-8) – 12/7/2024 – 6/6/2025

Contract Characteristics Type: FFP Indefinite-Delivery Vehicle (IDV): N/A Award Procedures: (FAR19.1) Others: N/A

Extent Competed Full and open competition Set-Aside Type Competitive 8(a) Total Amount Obligated $15,850,095.35 Total Potential Contract

$16,044,345.35

Action 4 (Legacy Closed Award for Reference)

Award No. 70Z02325FBSX20001 (IT Support Services for Boat Testing) Contractor(s) Peregrine Technical Solutions Place of Performance 76 Egan Drive, Ste. 306, Juneau, AK 99801 Period of Performance Base Period – 4/1/2025 – 9/30/2025 Contract Characteristics Type: FFP

Indefinite-Delivery Vehicle (IDV): N/A Award Procedures: (FAR 19.1) Others: N/A

Extent Competed Full and open competition after exclusion of sources.

Set-Aside Type Competitive 8(a) Total Amount Obligated $249,999.28 Total Potential Contract

$249,999.28

Action 5 (Legacy Closed Award for Reference)

Award No. HSCG23-14-C-MBS004 (Recreational Boat Testing and Inspection Services + Database Creation/Management/Maintenance)

Contractor(s) PPG Marine Place of Performance 2612 Taylor Road, Chesapeake, VA 23321 Period of Performance Base Period – 6/8/2014 – 6/7/2015

Option 1 – 6/8/2015 – 6/7/2016

Option 2 – 6/8/2016 – 6/7/2017 Option 3 – 6/8/2018 – 6/7/2018 Option 4- 6/8/2019 - 6/7/2019

Contract Characteristics Type: FFP Indefinite-Delivery Vehicle (IDV): N/A Award Procedures: (FAR 19.1) Others: N/A

Extent Competed Full and open competition after exclusion of sources.

Set-Aside Type Competitive 8(a) Total Amount Obligated $1,911,075.00 Total Potential Contract

$10,076,269.21

2. Market Research

Members of the USCG Integrated Project Team (IPT) conducted market research from January 2025 through March 2026. USCG Subject Matter Experts acknowledged a limited known vendor base available to support recreational boat testing and inspections. As a result of this feedback, market research focused on finding capable and experienced Total Small Business vendors to support adequate competition and provide the best quality of service and value to the government. This search for vendors included a review of all available DHS Strategic Sourcing Vehicles (SSVs) and the General Services Administration (GSA) eLibrary. Furthermore, multiple rounds of Sources Sought Notices were posted through SAM.GOV, Small Business Administration D.C. Field Office, Small Business Administration Richmond Field Office, and GSA Market Research as a Service (MRAS).

To assess industry interest, capability, and capacity, a multi-phased market research effort was conducted and a series of Sources Sought Notices were issued. First, with the assistance of GSA MRAS, a combined Request for Information (RFI) for both requirements was published from March 7 to March 13, 2025, which resulted in a single response from a woman-owned small business that expressed interest and potential capability or capacity to perform the services.

Following, two separate Sources Sought Notices, one for each requirement, were posted on SAM.gov from April 17 to April 23, 2025, to which no vendors of any size status responded.

Furthermore, in an effort to identify small business interest, capability and capacity of a consolidated requirement the Contracting Officer consulted with the SBA D.C. Field Office on April 18, 2025, and the SBA Richmond Field Office on April 24, 2025; this collaboration indicated limited availability of small businesses that perform these services.

Given separate notices for each requirement failed to generate responses, the Government proceeded to the next phase of its multi-phased market research approach by issuing a consolidated Sources Sought Notice on SAM.gov from December 10 to December 22, 2025. The notice included industry-focused questions regarding the consolidated requirement. Three (3) interested small businesses responded; two (2) were determined to have potential technical capability to perform the required services.

Market research results substantiate that a Competitive Total Small Business set-aside is the appropriate acquisition strategy, in accordance with RFO 19.104-1 (FAR Class Deviation 26-03, R2). The research identified two or more Total Small Businesses, that demonstrated the interest, capability, and capacity to successfully perform a consolidated requirement.

3. Contracting Alternatives

An alternative contracting approach that would reduce the need for a proposed consolidation effort consists of maintaining the existing acquisition strategy of conducting two separate awards: (1) MIC Recreational Boating Safety Database Management and (2) Recreational Boat Testing & Inspection Services:

o Maintain Existing Acquisition Strategy: The existing approach of separate, smaller contracts or orders for each requirement can be maintained. This approach has the ability to provide greater flexibility, tailoring separate requirements, and potentially reduce the complexity or risk associated with transitioning to a consolidated effort. However, maintaining multiple awards also perpetuates disjointed efforts of connected services and increased program management efforts, and contract administration burden.

Consolidating would reduce the duplication of effort, improve coordination, and provide greater consistency across the acquisition lifecycle. This is attributed to concentrating efforts on a single solicitation, evaluation process, award issuance, and award administration. Furthermore, streamlining services will simplify CG-BSX-2 operations and improve quality of service by eliminating segregated vendor performance of testing, inspections, and database management.

4. Small Business Participation

Market research reveals a limited pool of Total Small Businesses that are readily capable, interested, and have the capacity to perform this work. However, market research confirms that two or more capable Total Small Businesses are interested and willing to submit competitive proposals, further supporting a Total Small Business set-aside. The decision to transition this requirement out of the 8(a) program is primarily driven by failure to identify capable 8(a) firms in the marketplace for this requirement, despite extensive sources sought efforts. Additionally, consolidating the requirements and conducting a competitive Total Small Business set-aside will allow capable small businesses to compete, furthering the agency’s small business objectives.

5. Benefits

The proposed consolidation is intended to improve acquisition lifecycle efficiency, reduce administrative burden, achieve quantifiable cost savings, and streamline operations. The following summarizes the anticipated benefits of consolidation compared to the current strategy of using separate contracts:

• Benefits to Consolidating:

Combining these functions under a single vendor will streamline operations and create end-to-end efficiency, from the technical test and inspection process to the delivery of data to government and public stakeholders. The vendor conducting inspections and tests will also now manage the resulting data, eliminating the need to transfer information between vendors and varying systems. Additionally, consolidation of the two requirements will reduce USCG acquisition administrative efforts, costs, and quality assurance risks associated with managing multiple contracts and unnecessary integration activities. Specifically concerning cost benefits, definitive details of those benefits are outlined in Attachment (1), "Consolidation Cost Workbook”.

• Comparison of Alternative Approach Anticipated Benefits:

Eliminating Inefficient Costs: Transitioning to a single award will remove redundant administrative layers and fees associated with multiple awards and their potential subcontracting arrangements. Under the current acquisition strategy of two separate awards, market research indicates that prime vendors for both existing Recreational Boating Safety Database Management and Recreational Boat Testing and Inspection Service awards are experiencing increased overhead costs due to reliance on the same subcontractor to support the same end requirement. Cost savings to the government will be achieved through the elimination of duplicative layers of subcontracts as a result of a single award. Moving forward with the proposed consolidation action over the existing strategy with duplicative actions will streamline government contracting and program labor, resulting in an estimated cost benefit of 2,915 labor hours saved over a 5-year period, totaling $317,092.09.

Gaining Economic Efficiencies: A larger consolidated contract supports achieving improved competitive labor rates and securing volume discounts through economies of scale by leveraging greater purchasing power. Furthermore, travel expenses are reduced through centralized management and coordinated scheduling, minimizing redundant trips and administrative complexity.

Contract Management Efficiency: A consolidated approach eliminates redundant efforts by contracting and program personnel when issuing and managing a single contract in lieu of multiple contracts.

Table 2 below provides a summary of direct cost comparison of existing multiple award strategy versus the proposed consolidation.

Table 2: Estimated 5 Year Total Consolidated Costs

Recreational Boating Safety Database Management Cost Quantity /

HR Total Est Database Administrator 3200 $881,632.00 Graphics Specialist 3200 $409,432.00 Project Manager - Senior (Key) 800 $159,864.00

Recreational Boat Testing and Inspection Service Costs

Factory visits 2200 $10,723,273.00 Dealer visits 80 $194,830.40 Boat show visits 20 $48,707.60

Remote ed/new MIC 1000 $543,415.00 Reimbursement of boats NTE $5,737,815.85 Testing of boats 140 $1,454,945.80 Retest of boats 140 $614,765.20 Independent lab testing NTE $292,745.70 Travel NTE $1,170,982.83 Boat transportation NTE $350,743.49 Project Manager - Senior (Key) 2400 $479,592.00 Factory Optional Visits 200 $487,076.00 Factory Optional Visits 200 $487,076.00 Dealer Optional Visits 40 $97,415.20 Remote Ed Optional Visit 100 $54,341.50 Remote Ed Optional Visit 100 $54,341.50 Remote inspections Optional Visits 100 $54,341.50 Remote inspections Optional Visits 100 $54,341.50 Remote inspections Optional Visits 100 $54,341.50

Total Estimated Costs

$24,406,019.57

Estimated 5 Year Cost Breakdown Continuing Current Procurement Strategy of Separate

Awards - 10% Profit Overhead Implemented Across Line Items (Boat Reimbursement and Travel Are Fixed at Actual Reimbursed Cost)

Recreational Boating Safety Database Management Cost

Quantity /

HR

Total Est Database Administrator 3200 $969,795.20 Graphics Specialist 3200 $450,375.20 Project Manager - Senior (Key) 800 $175,850.40

Recreational Boat Testing and Inspection Service Costs

Factory visits 2200 $11,795,600.30 Dealer visits 80 $214,313.44 Boat show visits 20 $53,578.36 Remote ed/new MIC 1000 $597,756.50 Reimbursement of boats (reimbursed actual costs only) NTE $5,737,815.85 Testing of boats 140 $1,600,440.38 Retest of boats 140 $676,241.72 Independent lab testing NTE $322,020.27 Travel (reimbursed actual costs only) NTE $1,170,982.83 Boat transportation NTE $385,817.84 Project Manager - Senior (Key) 2400 $527,551.20 Factory Optional Visits 200 $535,783.60

Factory Optional Visits 200 $535,783.60 Dealer Optional Visits 40 $107,156.72 Remote Ed Optional Visit 100 $59,775.65 Remote Ed Optional Visit 100 $59,775.65 Remote inspections Optional Visits 100 $59,775.65 Remote inspections Optional Visits 100 $59,775.65 Remote inspections Optional Visits 100 $59,775.65 Total Estimated Costs $26,155,741.66

• Quantifiable Benefit Threshold Test:

As identified in Table 3 below (See Consolidation Cost Workbook), the proposed consolidated action is estimated to provide the government with cost benefit savings of $2,066,814.18. Although the anticipated quantifiable benefits are not substantial, as they do not meet the 10% threshold of a substantial quantifiable benefit, the proposed consolidated action still provides quantifiable savings of 8.47% and is fundamental to achieving efficiency and improved operations.

Table 3: Summary of Quantifiable Benefits

Total Projected Cost Utilizing Current Acquisition Strategy (Including Additional Govt. Admin Cost of $317,092.09 for Separate 5 Year Awards)

$26,472,833.75

Total Planned Consolidated Contract $24,406,019.57 Total Cost Savings from Current Acquisition Strategy Including Govt. Admin

$2,066,814.18

Percentage of Benefits Savings 8.47%

6. Critical to Agency’s Mission Success:

This consolidation is critical to the USCG's CG-BSX-2 mission success. It directly enhances the USCG's ability to fulfill its legally mandated responsibilities under 46 U.S.C. §§ 4301-4312 and 33 Code of Federal Regulations Subchapter S. While the quantifiable expected benefits under this consolidation do not meet the 10% threshold for a substantial benefit, the administrative efficiencies and cost benefits gained from a single, transparent contract are essential for supporting current requirements and planned expansions of these mission-critical activities, including:

o Mandated technical compliance inspections o Expanded database management work o Accurate boat reimbursement cost tracking

Therefore, this streamlined contract structure is not merely a cost-saving measure; it is a necessary step to provide a more robust framework for successfully executing current and future mission requirements in compliance with federal law.

Date: 2026.09.16 12:53:39 -04'00'

DETERMINATION

I hereby determine that the benefits of this consolidated acquisition substantially exceed the benefits of alternative contracting approaches, and that this strategy is necessary to meet the agency’s mission requirements.

JACKSON.BRITTANY.LYNN.151482 Digitally signed by

JACKSON.BRITTANY.LYNN.1514829361

Date: 2026.09.15 10:28:53 -04'00'

Brittany Jackson Date Procuring Contracting Officer U.S. Coast Guard

CONCURRENCE: COCO Small Business Specialist submit for Director, Strategic Programs & Career Management Division (CG-HCA-PPO3) review/concurrence to smallbusiness@uscg.mil.

KERSEY-ROBINSON.MARIA.L.1092844176 Digitally signed by KERSEY-ROBINSON.MARIA.L.1092844176

Maria L. Kersey-Robinson Date Director, Strategic Programs & Career Management U.S. Coast Guard

Digitally signed by

MORRIS.SHREENA.LYONS.1144950301

Date: 2026.09.17 12:31:50 -04'00'

Shreena L. Morris Date Head of the Contracting Activity U.S. Coast Guard

APPROVAL:

Chief Procurement Officer, or designee Date Department of Homeland Security mailto:smallbusiness@uscg.mil