Justification FAR Part 16 (JEFO) (JUNE 2025)_W9124J-25-F-A123_OMPA_ 10 Apr 2026_Redacted.pdf
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This is a Justification Review Document for an exception to fair opportunity under FAR Part 16, seeking approval to award a sole-source task order for instructor and multimedia support services.
The Medical Center of Excellence (MEDCoE) at Joint Base San Antonio–Fort Sam Houston, Texas, requests approval to award task order W9124J-25-F-A123 as a sole-source logical follow-on to the incumbent contractor, Nisga'a Tek, LLC, under an Instructional Multimedia Multiple Award Task Order Contract (MATOC). The contract value is $709,199.04 for the fiscal year 2025 period. The services support curriculum delivery review and evaluation, coordination, and execution of course support services for the Department of Operational Medicine (DoOM) at MEDCoE. The original task order was initially awarded on 29 August 2024, expiring 28 August 2025. The justification cites Title 10 U.S.C. §3406(c)(2) as implemented in FAR 16.505(b)(2)(i)(C), authorizing sole-source awards as logical follow-ons when necessary for economy and efficiency. The government determined that conducting another annual recompete poses unacceptable mission risk due to likely loss of incumbent personnel with critical institutional knowledge and specialized MEDCoE training, which would delay the delivery of trained medical personnel to support worldwide contingency operations. Market research confirmed that only the incumbent contractor possesses fully trained, security-cleared, and site-acclimated personnel needed to guarantee uninterrupted instruction. The justification commits to developing a new Performance Work Statement and adequate transition period for the next competitive action to maximize future competition.
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CUI//SP-PROCURE//FEDCON
Control Number:2025-31
CUI//SP-PROCURE//FEDCON
under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.
6. Reason for Authority Cited:
a. Background: The MEDCoE has a requirement to provide Instructor services.
The U.S. Army Medical Center of Excellence (MEDCoE), Department of Operational Medicine (DoOM) is responsible for training and educating medical personnel. To accomplish this mission, MEDCOE/DoOM must provide trained and ready medical personnel to support worldwide contingency operations; produce concepts, doctrine and organizational structure that meets current and future force requirements; create integrated and relevant training strategies, products and programs and make them available for use; and support the Readiness and Managed Care missions of the Military Health System.
Task orders are currently structured as 12-month awards and are subject to annual recompete. While procedurally compliant, this recurring cycle introduces significant risks to both operational continuity and cost efficiency. Each recompete increases the likelihood of performance disruptions, added onboarding delays, and higher long-term costs to the government in terms of risk, time, and resources. If the incumbent company wins the recompete, continuity is maintained, incumbent personnel remain in place, and mission support proceeds without disruption. However, there is no guarantee the incumbent will win each cycle. When a new company is awarded the contract—often through a technically acceptable proposal at a lower price—the award value is frequently below the current performance baseline. This creates immediate challenges in retaining incumbent personnel who hold critical institutional knowledge and technical expertise. Lower salaries or reduced benefits under the new award often led to staff attrition, leaving the contractor unable to field a fully qualified team at the outset of performance.
b. Alternatives: The Government considered all viable alternatives to this action and determined no one could meet its minimum needs without causing unacceptable mission risk and delay. Conducting another annual recompete was deemed to pose an unacceptable risk; a new awardee would likely be unable to retain the incumbent's experienced instructors, and the subsequent recruitment and MEDCoE-specific training for new personnel would create an unacceptable delay in training delivery, directly jeopardizing the DoOM's mission to produce "trained and ready medical personnel."
Furthermore, performing these instructional services in-house with Government personnel is not a feasible alternative due to the current Government-wide hiring freeze, which prohibits the onboarding of the necessary staff to fill this requirement. Finally, the option to take no action and accept a gap in service is untenable, as it would result in a
Control Number:2025-31 complete failure to meet the MEDCoE's congressionally mandated mission and would halt the production of trained medical personnel for the force.
c. Impact if not approved: Failure to approve this logical follow-on extension will have immediate and severe consequences for the MEDCoE mission. Disapproval would force the Government to accept one of the untenable alternatives outlined above: either initiate a high-risk recompete or allow a complete gap in service. A recompete would trigger a disruptive transition period, leading to an immediate degradation of instructor quality and the loss of critical institutional knowledge. The resulting delay in delivering qualified instructors would directly compromise the pipeline of "trained and ready medical personnel" being supplied to worldwide contingency operations. In short, disapproval will directly result in either a severely degraded training capability or a complete cessation of mission-critical instruction, both of which are unacceptable outcomes for Army readiness and the health of the force.
7. Actions to Increase Competition: For this specific logical follow-on requirement, no immediate action can be taken to increase competition without incurring unacceptable mission delays and duplication of costs detailed in this justification.
However, the Government is fully committed to maximizing competition for the follow-on effort. In preparation for the next competitive action at the conclusion of this extension, the Government will develop a new Performance Work Statement (PWS) that clearly defines the requirements and will allow for an adequate phase-in/transition period. This will ensure all potential offerors are positioned to compete on a level playing field for the subsequent contract award.
8. Market Research: Market research was conducted to determine if a source other than the incumbent could satisfy the Government's minimum requirements without causing unacceptable delays and a duplication of cost. This research consisted of a review of the capabilities of the other contractors within the Instructional Multimedia MATOC pool, combined with the Requiring Activity's intimate knowledge of the specific, highly specialized instructor qualifications needed to support the MEDCoE mission. The research confirmed that only the incumbent contractor possesses the fully trained, security-cleared, and site-acclimated personnel currently in place to guarantee uninterrupted instruction. Any other source would require a significant spin-up period to recruit, screen, and train new personnel, which would result in the mission failure outlined in this justification. Therefore, the market research concludes that only the incumbent can continue performance without a break in service.
9. Other Facts:
a. Procurement history. As mentioned above, this requirement is a task order under a MATOC ID/IQ which was competed among 8(a) participants in FY23. This requirement was initially awarded on 29 August 2024 to Nisga’a Tek, LLC, expiring on 28 August 2025. However, during the re-compete period contractor concerns regarding staffing qualified personnel surfaced. This concern, as well as the issues mentioned
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