FBO_J&A.docx

Control No: JA-E-17-244 Contractor: Booz Allen Hamilton (BAH) Supply/Service: Architecture & Content/Knowledge Management Support Services

JUSTIFICATION REVIEW DOCUMENT

FAR PART 16 EXCEPTION TO FAIR OPPORTUNITY (EFO) JUSTIFICATION

For Actions Exceeding the Simplified Acquisition Threshold (SAT)

Supply/Service: Architecture & Content/Knowledge Management Support

Authority: 10 U.S.C. 2304c(b)(1) as implemented by FAR Part 16.505(b)(2)(i)(A) – The order must be issued on a sole-source basis as the need for the services is so urgent that providing a fair opportunity would result in unacceptable delays.

Amount: $11,765,605.08

Reviews: I have reviewed this justification and find it adequate to support an exception to fair opportunity.

Program Manager:

Typed Name: XXXXX Phone: (XXX) XXX-XXXX Signature:

Date: 17 Feb 2017

Legal Counsel:

Typed Name: XXXXX Phone: (XXX) XXX-XXXX Signature:

Date: 21 March 2017

FAR Part 16 Exception to Fair Opportunity Justification Under Multiple Award Indefinite Delivery Contracts For Actions Exceeding the Simplified Acquisition Threshold (SAT)

2. Description of Action: Requiring activity Software Engineering Center (SEC) requests a Cost-Plus-Fixed-Fee (CPFF) Term modification to Task Order W15P7T-12-D-E007 KX02 with contractor Booz Allen Hamilton (BAH) of 8283 Greensboro Drive, McLean VA 22102-4902. The Government projects award for April 2017 using fiscal years 2017 and 2018 Operation and Maintenance, Army (OMA) and Research, Development, Test and Evaluation (RDTE) funds. This action is to extend the Period of Performance (PoP) by an additional (14) months from 10 April 2017 through 9 June 2018. The first 12 months will be utilized to address the urgency of this need to extend the PoP and the final two months will be utilized as a transition period. An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d)(i)(B).

3. Description of Supplies/Services: The W15P7T-12-D-E007 KX02 Systems and Software Engineering Support Next Generation (SSES NexGen) Task Order provides Enterprise Solutions through Centralized Life Cycle Engineering, Management, and Support for Customers Supporting the Warfighter. The tasks to be performed remain the same between the current performance and performance required for the (14) month extension period, so there are no changes to the existing Performance Work Statement (PWS). The (14) months extension period is estimated to require 101,648 labor hours, as broken out in the Independent Government Cost Estimate (IGCE). Core activities of the requirement include:

· Enterprise Resource Planning (ERP)

· Service-Oriented Architecture (SOA)

· Business Intelligence (BI)

· Knowledge management

· Subject matter experts consulting

· Design, implementation, test and administration of Cloud Infrastructures

· Center of Excellence for Application and Data Center Support

· Enterprise Net Centric lifecycle support, from planning through blueprint, to include establishing and implementing migration strategies

· Support for the Army Chief Information Office (CIO)/G6s efforts to create a common data strategy for all of the Army through the Army Net Centric Data Strategy (ANCDS) Center of Excellence (CoE).

The majority of the customer activities for the (14) month extension period remain the same. In addition to the existing customer activities, two (2) additional customer activities will be supported by the Task Order. The customer activities to be supported during the (14) month extension are:

The periods of performance and associated values for the Task Order are as follows. The value is based upon the anticipated Level Of Effort labor hours needed for the requirement, as assessed by SEC technical experts, and utilizing the direct labor rates and indirect cost rates currently utilized by the incumbent contractor:

4. Authority Cited: 10 U.S.C. 2304c(b)(1) as implemented by Federal Acquisition Regulation (FAR) section 16.505(b)(2)(i)(A) – The order will be issued on a sole-source basis as the need for the services is so urgent that providing a fair opportunity would result in unacceptable delays.

5. Reason for Authority Cited: The extension modification is required to maintain continuity of essential services provided under the current Architecture & Content/Knowledge Management Support Task Order W15P7T-12-D-E007 KX02. The Task Order will currently expire on 09 April 2017, but award of the follow-on contract vehicle is not planned to take place until at least after 09 April 2018. The milestone schedule is set out below:

___________________Milestone Schedule_____________________

Booz Allen Hamilton, Inc. (BAH), 8283 GREENSBORO DR, MCLEAN, VA 22102-4904, is currently performing Army Architecture and Content/Knowledge Management Support Services under competitively awarded Task Order W15P7T-12-D-E007 KX02. BAH, as the incumbent contractor, can provide the necessary manpower, skills and direct familiarity with the requirement. Based on the circumstances described, BAH is the only contractor that can reasonably and realistically provide the full scope of required services as of 10 April 2017. Transferring performance responsibility to another contractor at this time would minimally cause a two (2) month delay for the new contractor to hire all required personnel and train them to perform the SEC requirement, interrupting current SEC and customer efforts that have already begun.

If the contracted services are not provided it will necessitate each Army organization to independently interpret & implement the army data strategy, increasing the overall cost expenditures and increasing software interoperability concerns. Furthermore, it will reduce the ability to disseminate data from the highest strategic level down to the soldier in the battlefield and will affect the situational awareness on the battlefield by the loss of ensuring information relevance, accuracy, timeliness, precision, completeness and security. Lastly, it will impact Army data quality such that data supporting enterprise, business and warfighter capabilities would not be trusted or acted on and will reduce data interoperability between legacy and future systems.

The follow-on is planned to be a Single Award Indefinite Delivery Indefinite Quantity (IDIQ), to be competitively solicited among small and/or large businesses (dependent on Market Research results). Due to unforeseen pre-award delays, the acquisition strategy was altered to best fit the needs of the Government and Industry. The following delays contributed to the overall schedule delay in preparing a completed Acquisition Resource Package (ARP), which prevents the follow-on contract from being awarded by 10 April 2017, to pick up performance as the current W15P7T-12-D-E00/KX02 expires:

· October 2015: A Request For Information (RFI) Sources Sought (SS) notification was issued in October 2015, and the SEC assessment of responses was provided to ACC in April 2016.

· November 2015: SEC seeking Service Contract Approval (SCA) for a FY2016 award. FY2016 SCA approval not obtained until April 2016. Industry responses received for October 2015 RFI.

· March 2016: SEC provides a revised Service Acquisition Strategy (SAS) for the ARP, but had not realized the need for an Acquisition Plan (AP). AP is being prepared.

· April 2016: SEC technical experts perform evaluation of Industry responses to the October 2015 and provide the information to ACC.

· June 2016: SEC is revising the Source Selection Evaluation Plan (SSEP) to clarify confusing language. A revised SSEP is returned to ACC in July 2017, but requires further work to be acceptable. SEC revised the PWS in June 2016. A final Market Research Report summarizing the Industry responses to the October 2015 RFI is provided to ACC.

· July 2016: Using the Market Research Report a DD2579 Small Business Coordination Record is prepared. Due to certain details lacking in the October 2015 RFI, several small businesses, as small as only 7 employees, declared interest and capability to perform the 119-219 Full Time Employee (FTE) requirement. The Small Business Program Office (SBPO) will not approve the DD2579 for full and open competition while small businesses insist they can and want to perform the requirement. Subsequent meetings between SBPO and ACC/SEC do not resolve the issue, and as of March 2017 SBPO will not approve the DD2579 unless for a small business set-aside.

· August 2016: Requirement award pushed to back to FY2017 as the ARP is incomplete. A SCA for FY2017 is not obtained until March 2017. ACC notifies SEC that SSEP still requires further work.

· September 2016: SEC is revising ARP documents, however progress has been slowed by unavailability of a technical evaluation team to review document.

· October 2016: Follow-on award date forecast for spring 2017. SEC is revising the IGCE and determining contract type/format.

· November 2016: SEC preparing to update Market Research through release of a new RFI to FBO. New Market Research RFI will provide enough information for interested parties to realize if they are too small to be the prime contractor, thus resolving the DD2579 issue with improved, more accurate market research results.

· December 2016: SEC provides draft RFI to ACC for review. SEC revising PWS.

· January 2017: SEC provides RFI to SBPO for review. SEC revising PWS.

· February 2017: RFI has not been issued; SEC is working to finalize PWS and CDRL documents to release with RFI These delays have moved the projected award date such that it cannot pick up where the currently performing task order W15P7T-12-D-E007/KX02 expires on 09 April 2017. Including a SEC requirement for a 60-day transition period between contracts to ensure no interruption of services, W15P7T-12-D-E007/KX02 must at least be extended to June 2018.

There are no viable or realistic alternatives to issuing an extension modification to the current BAH task order. A possible alternative would be that SEC government staff performs the work, however SEC is already short-staffed and the recent hiring freeze will not allow SEC to hire additional staff. Another alternative would be to issue a new bridge contract; however, since the current task order end date is 9 April 2017, there would be an estimated 6 month delay to issue a new contract, causing a stop in work detrimental to SEC and SEC customer missions.

6. Actions to Increase Competition: The follow-on contract vehicle scheduled for award in April 2018 will be solicited on a full and open competition basis, subject to exclusion to small businesses if the market research recommends such. Depending on market research results, competition may be limited to small businesses only. Market Research is currently being conducted by the requiring activity SEC to determine the availability of interested and capable parties for the follow-on contract vehicle.

7. Market Research: A RFI-SS notification was posted to the Federal Business Opportunities (FBO) website on 29 October 2015 to identify capable and interested companies. The resulting Market Research Report produced by SEC analyst XXXXX and approved by SEC contracts manager XXXXX shows that nineteen (19) businesses responded, of which eight (8) were large businesses and eleven (11) were small businesses. Six (6) of the large businesses were evaluated as capable of performing the PWS’s tasks, as were two (2) of the small businesses. The Government technical evaluators were concerned that the information provided in this initial RFI-SS did not adequately describe the requirement, since while the two small businesses evaluated as capable of the type of work might not be able to handle the volume of work. The requirement is expected to utilize ~119 FTE, with possibly an additional ~100 employees needed when the requirement surges.

A new RFI was issued by SEC on 02 March 2017, with responses due by 06 March 2017. This RFI was issued to SSES-NG contractor holders only, and requested a response from any contacted party interested in performing the requirement. Of the eighteen (18) SSES-NG vendors, seven (7) “Yes” or “No” responses were received. The three (3) “Yes” responses came from the incumbent contractor BAH (large business), Leidos (large business), and BANC3 (small business). On the basis that switching performing contractors would take 2 months transition time, plus the acquisition processing time to compete and award a new task order, the SEC technical expert XXXXX determined that only the incumbent BAH would have a fully trained staff familiar with the Government requirement and able to fully perform as of the 10 April 2017 date that task order W15P7T-12-D-E007/KX02 is presently scheduled to expire.

The types of tasks to be performed during the (14) month extension period are the same as with the base period. There have been no significant market changes or economic indicators that would affect labor prices associated with the requirement.

8. Other Facts:

Procurement History:

Task Order: W15P7T-12-D-E007 0001 Contractor: Booz Allen Hamilton Inc. (Large business) Award Date: 27 September 2013 Period of Performance: 30 Sept 2013 to 29 Sept 2015 Competitive Status: Full and Open Competition within SSES NexGen Unrestricted Suite

Task Order: W15P7T-12-D-E007 KX02 Contractor: Booz Allen Hamilton Inc. (Large business) Award Date: 10 March 2016 Period of Performance: 10 March 2016 through 9 April 2017 Competitive Status: Full and Open Competition within SSES NexGen Unrestricted Suite

9. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

10. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable.

This determination will be made using cost analysis and price analysis.

As a part of this basis, certified cost or pricing data:

X - will be required.

12. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Approval

Based on the foregoing justification, I hereby approve the 14 month Period of Performance (PoP) extension of Architecture & Content/ Knowledge Management Support services for CECOM SEC ESD using an exception to fair opportunity pursuant to the authority of FAR 16.505(b)(2)(i)(A) “The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays”, subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition. This PoP extension is valued at $11,765,605.08 and will extend performance from 10 April 2017 to 09 June 2018. If the proposed contract action is not completed within 180 days from the date below or if there is a change to the substance of this J&A that does not meet the AFARS 5106.303-1-90 conditions for an amended J&A, the Contracting Officer shall document these changes in a memorandum for file and obtain revalidation from the approval authority below.

XXXXX Date:

Command Advocate for Competition