IAO Consolidation DF - SCO Approved - Redacted Final.pdf

DEPARTMENT OF THE ARMY

DETERMINATION AND FINDINGS

CONSOLIDATION MEMORANDUM

Intelligence and Automation Operations; Fort Belvoir

As defined in Federal Acquisition Regulation (FAR) 2.101, consolidation means “the use of a solicitation to obtain offers for a single contract or a multiple award contract to satisfy two or more requirements of a department, agency, or activity for supplies or services that previously have been provided to, or performed for, that department, agency, or activity under two or more separate contracts, each of which was lower in cost than the total cost of the contract for which offerors are solicited.” Consolidation of requirements with a total value exceeding $2 million but less than $500 million must be justified. The Head of the Contracting Activity (HCA), with authority to delegate to a level not lower than the Senior Contracting Official (SCO), will make the determination that the consolidation is necessary and justified in accordance with (IAW) United States Code (U.S.C) Title 15 Chapter 14a Section 657q, FAR 7.107-2(b), Army Federal Acquisition Regulation Supplement (AFARS) 5107.107-2(b)(ii). Pursuant to HCA Delegation of Authority HCA DOA#25-02, the SCO is the approver of this action.

I have reviewed this requirement and associated Market Research and determined that consolidation, in accordance with FAR 7.107-2 Consolidation of contract requirements, and AFARS 5107.107 Additional requirements for acquisitions involving consolidation, bundling, or substantial bundling of contract requirements, is both necessary and justified. My review resulted in the following findings:

FINDINGS

1. Introduction: Army Contracting Command-Detroit Arsenal (ACC-DTA), plans to solicit offers for Intelligence and Automations Operations (IAO) support services and has conducted market research that demonstrates consolidation of this procurement to be both necessary and justified for this effort. The proposed IAO effort will consolidate two existing Task Orders (TOs);

Intelligence Operations Support Services (IOSS) and Intelligence Automation Support (IAS).

Both TOs support the same mission for Headquarters, Department of Army (HQDA), Office of the Deputy Chief of Staff (ODCS), G2, Directorate of Military Intelligence-Information Technology (DAMI-IT), Data Capabilities Division (DCD).

2. Description of the Procurement Action:

Requirement: ACC-DTA plans to solicit and award a non-commercial, stand-alone, Firm Fixed Price Level of Effort (FFP LOE) contract utilizing a competitive small business set aside. The anticipated contract will have a 12-month base period, four 12-month option periods, and up to a six-month option to extend services via FAR 52.217-8 for an estimated quantity of labor hours. The total estimated dollar value of this effort, if all options are exercised, is $ . The Target Award Date (TAD) is and will be competed using NAICS code 541519, All Other Professional, Scientific, and Technical Services ($34M).

The Requiring Activity (RA) seeks to consolidate two existing Cost Plus Fixed Fee (CPFF) TOs, currently providing support to the same mission, into a single stand-alone FFP LOE contract. In alignment with FAR 7.107(c), the consolidated procurement will enhance the performance outcome, reduce duplication in effort and administration, improve contract management, and realize a cost savings to the Government.

• IOSS Objective and Details: IOSS manages organizational messaging for the Army and executes operational intelligence knowledge management and access management requirements. The TO requires the contractor to conduct Army wide intelligence data lifecycle management activities and the deliver data to authorized Programs of Record to leverage data as a weapon system and manage, secure, and use data for operational effect. IOSS ensures the right data (Intelligence Products) get to the right customer at the right time in the right form in support of Army, Department of War, and the Intelligence Community’s objectives.

Hours Contract Type: CPFF for Labor, Cost for ODC’s Period of Performance: (Including 52.217-8 Option) Awarded to Competed Full and Open Holders, 3 proposals has since been acquired by

• IAS Objective and Details: Provides comprehensive automation/information technology support exclusively to the DCD’s worldwide intelligence dissemination, data, management, and knowledge management missions. A very significant part of this mission is achieved through contracted support on the IOSS TO. The IAS scope includes system administration, database administration, web/software operation and maintenance, logistics support, and operations and sustainment support.

; $ for Hours Contract Type: CPFF for Labor, Cost for ODCs PoP: (Including 52.217-8 Option) Awarded Competed Full and Open proposals

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The consolidated requirement encompasses intelligence support, data analytics, IT operations, and mission sustainment. Under the current contract structure, IAS provides ancillary support through their Information Technology objective to IOSS’s intelligence mission objectives. While each TO has been successfully executed, the separate structure has resulted in duplicative contract administration, indirect cost fluctuations, and interdependencies that complicate mission execution. By combining these services under a single FFP LOE contract, the Government will reduce administrative complexity and establish a single accountable contractor, providing integrated and coordinated mission support.

3. Applicable Statutes/Regulations: FAR 7.107-2, Consolidation and AFARS 5107.107-2

4. Results of Market Research: Based on Market Research conducted per FAR Part 10, which included issuing a Sources Sought Notice and consulting with the Office of Small Business Programs representative, Mr. , it has been determined by the Contracting Officer, Mr.

, that a consolidated requirement is justified. The research revealed that multiple

; $ for to small businesses possess the capabilities to perform the consolidated work. Mr.

concurred with the consolidation, finding it to be in the Government’s best interest and affirming that it does not restrict small business participation. Market Research concluded that the data collected indicates that there is measurable potential for small business participation. Multiple small business respondents demonstrated relevant past performance, existing staff with required clearance and facility clearance, and the capability to perform in an intelligence environment. Market Research suggests that there is an adequate small business industrial base capable of fulfilling the requirement. Given these findings, the acquisition strategy will incorporate small business consideration IAW FAR Part 19.

The requirement has been evaluated under FAR Part 12, and the Contracting Officer determined the consolidated services do not meet the definition of a commercial item. The specialized nature of the intelligence, data support, and IT integration services, combined with the security requirements and mission specific tasks, precludes the use of commercial acquisition procedures. Accordingly, the acquisition will be conducted under FAR Part 15, Contracting by Negotiation.

5. Consolidation Benefits Analysis:

a. Quality Benefits: The consolidation of two CPFF TOs into a single FFP LOE contract will significantly enhance the quality of contract execution and mission outcomes. Under separate contracts, duplicative management structures and misaligned TOs have created challenges in synchronizing IT and intelligence support services. Consolidation improves quality by unifying performance under one contractor with end-to-end accountability for both IT infrastructure and Intelligence Support Services. This alignment reduces the risk of service gaps, enhances communication between technical and analytical personnel, and strengthens overall mission readiness. Additionally, the FFP LOE structure incentivizes contractors to maximize efficiency and innovation within a predictable cost framework, further ensuring high-quality service delivery.

b. Workforce Optimization: Workforce optimization reduces cumulative Contract Manning

Equivalents (CME) from , resulting in an estimated 30 percent drop in total contract cost. Annual savings are projected at approximately $ in the first year, which includes in CME-related reductions and a one-time $ benefit from the early termination of duplicative contract services. In subsequent fiscal years (FY27–FY30), sustained savings are projected at $ annually. The five-year lifecycle savings are estimated at $ . In addition to cost savings, the shift from CPFF to FFP LOE reduces exposure to indirect cost fluctuations, aligns contractor incentives with performance outcomes, and provides stronger cost predictability for long-term mission planning.

c. Acquisition Cycle: Consolidation also yields measurable benefits in Procurement Administrative Lead Time (PALT). Managing two separate task orders requires duplicative acquisition planning, solicitation drafting, evaluation, negotiation, and award processes. Historically, each action has required nine months to a year of effort, resulting in extended lead times for mission requirements. By consolidating into a single standalone acquisition, the agency reduces the number of acquisition cycles by half, thereby decreasing administrative burden and shortening the time to contract award.

Over the five-year life cycle, the agency avoids at least one full acquisition cycle, representing a significant reduction in procurement workload and allowing acquisition personnel to focus on higher-value mission priorities.

d. Acquisition Workforce Costs: The cost of acquisition workforce labor further supports consolidation. Using FY25 General Schedule (GS) rates for the Washington-Baltimore Arlington, DC-MD-VA locality pay area, a Gsa Contract Specialist earns approximately in annual salary before benefits, a Gsa Contracting Officer earns approximately 111111· and a Gsa Contract Officer Representative (COR) earns approximately . When applying the standard 36.25% fringe and overhead factor used for fully burdened civilian labor costs, the annualized fully burdened costs are approximately ••• for a Gsa and ••• for each Gsa. Throughout the acquisition lifecycle, the Contract Specialist, Contracting Officer, and COR are the most consistently engaged personnel, providing continuous oversight and management from planning through award and contract administration. The acquisition lifecycle for two separate task orders typically requires approximately 1,200 hours for the Gsa Contract Specialist (planning, drafting solicitations, supporting evaluations), 600 hours for the GS

Contracting Officer (reviewing solicitations, award decisions, negotiations), and 400 hours for the GS• COR (oversight of performance, monitoring, and reporting). This represents roughly 2,200 hours of labor per lifecycle, equating to approximately in fully burdened personnel costs. By consolidating into a single acquisition, administrative oversight is reduced by nearly 50 percent, decreasing expected hours by approximately 1,100 hours across all personnel. This reduction translates to approximately in avoided fully burdened labor costs annually, or roughly over a five-year acquisition lifecycle.

Summary of Cost and Efficiency Gains: In addition to the direct � in projected contract savings from workforce optimization and termination of duplicative services, the Government achieves measurable quality improvements, reduced acquisition lead times, and workforce labor cost avoidance. These benefits strengthen mission performance, lower administrative overhead, and provide greater predictability in both cost and contract outcomes, fully justifying the consolidation.

6. Alternative Contracting Approaches and Rationale for Rejection: Several alternative approaches were considered. Maintaining two separate CPFF TOs would provide flexibility but would result in duplicative overhead, additional administrative burden, and increased cost risk to the Government, estimated at approximately � over five years. Awarding two separate FFP LOE contracts by functional area would reduce cost risk but introduce inefficiencies and performance overlap, complicating coordination. Additionally, it should be noted that ACC-DTA initially chose to conduct Request for Information (RFl)s on both CHESS and GSA, it does not intend to award under either of those contract vehicles. The acquisition team considered utilizing these sources to better leverage purchasing power, but the decision to repurpose Intelligence Professionals with existing data service knowledge is more cost effective than using separate Data Service Professionals who have a higher market labor rate and would require additional training in intelligence products. As this unique personnel requirement is fundamental to the procurement's success, neither CHESS nor any GSA contract vehicle are suitable for the procurement of Intelligence Professionals. Due to the uniqueness of this concept competition should not be limited to GSA and no longer fits the CHESS vehicle. A full and open competition without set aside would increase the vendor pool but would limit small business participation, contrary to statutory objectives. After careful consideration, only the proposed consolidated FFP LOE contract ensures cost predictability, reduces administrative and indirect costs, integrates performance, and maximizes small business participation.

7. Bundling: This procurement does not constitute bundling. While the requirement is consolidated, it remains suitable for award to small business concern through a small business set-aside competition. The benefits of consolidation substantially exceed those of maintaining separate contracts without restricting small business participation.

8. Considerations, Facts, Reasoning Supporting the Determination: The Office of Small Business concurred with consolidation. DD Form 2579 will reflect full coordination with the Small Business Office. The RA has verified this stand-alone contract provides for a specific LOE over a stated period of time on work that can only be defined in general terms, making FFP LOE the most appropriate contract type. Historical data from the incumbent contracts demonstrate that the consolidated level of effort can be accurately forecasted and effectively managed to complete the requirements found in the Performance Work Statement (PWS).

9. Summary: In conclusion, consolidating two CPFF TOs into a single FFP LOE standalone contract is in the Government’s best interest. This action reduces cost risk, eliminates duplicative administration, and enhances efficiency and performance integration. The acquisition strategy maximizes small business participation while supporting mission objectives and improving contractor accountability. The financial, operational, and strategic benefits of this consolidation clearly exceed the benefits of maintaining separate contracts, and the procurement approach is fully justified under FAR 7.107.

DEPARTMENT OF THE ARMY

DETERMINATION AND FINDINGS

CONSOLIDATION MEMORANDUM

Intelligence and Automation Operations; Fort Belvoir

ELECTRONIC SIGNATURE PDF COORDINATION AND APPROVAL PAGE CAN BE FOUND

IN PAPERLESS CONTRACT FILES (PCF)

Prepared By:

Christina Cano-Dickey Date Contract Specialist

Concurred By:

Paul Horrell Date Contracting Officer

Benjamin Netzky Date Legal Official

Shane Strehler Date Chief, INSCOM IT Support & Sustainment Branch

Donald W. Leath Date Chief Acquisition Support Division

Adam Weir Date Office of Small Business Participation

Jeffrey Willey Date Command Advocate for Competition

Steven J. Balthazor Date Chief of the Contracting Office Army Contracting Command-Detroit Arsenal

DETERMINATION

Upon the basis of the findings above, I hereby determine, pursuant to the authority of Federal Acquisition Regulation 7.107, and Army Federal Acquisition Regulation Supplement 5107.107 Consolidation of contract requirements, that the proposed consolidation of the requirements for Intelligence and Automation Operations is both necessary and justified.

John D. Jolokai Date Senior Contracting Official Army Contracting Command-Detroit Arsenal

DETERMINATION