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JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION AUTHORITY: FAR 6.302, 41 U.S.C. 253(c) Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by FAR 6.3 and in accordance with the requirements by FAR 6.303-1, the justification for the use of the statutory authority under FAR 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows: 1. Identification of the agency and the contracting activity, and specific identification of the document as a Justification for other than full and open competition. This document is a justification for other than full and open competition for the Department of the Interior, Interior Business Center, Acquisition Services Directorate, on behalf of the Office of Special Trustee for American Indians (OST). 2. Nature and/or description of the action being approved. This is a fixed priced contract to provide call center services. The services are critical to OSTs responsiveness to the trust beneficiaries, especially as they relate to Cobell litigation and the Land Buy Back Program. The Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD) is requesting authorization to award the option that was contemplated in the solicitation and resulting award, but was not evaluated at that time in accordance with FAR 52.217-8, Option to Extend Services, for a six (6) month extension under the contract D13PC00061, be issued to: CNI Technical Services, LLC 7601 Jefferson Street, N.E., Suite 3 Albuquerque, NM 87109-5907 3. A description of the supplies or services required to meet the agencys needs (including the estimated value). The Trust Beneficiary Call Center is a nationwide, toll free call center that enables Tribes and individual Indians to conveniently access information regarding their trust assets, check the status of a trust service or request to update to, or disbursement from their Individual Indian Money (IIM) account information. The TBCC is located within OST Field Operations, in Albuquerque, New Mexico, and is staffed with representatives trained in the Indian trust business processes and IIM account maintenance who have direct access to callers trust asset data. Implementation of the centralized Trust Beneficiary Call Center has become a significant component in meeting DOIs goal of communicating and fulfilling its responsibilities to Indian trust beneficiaries in accordance with the American Indian Trust Fund Management Reform Act of 1994 (the Trust Reform Act). Pursuant to the Trust Reform Act, OST is charged with providing effective management of and accountability for, the proper discharge of the Secretary of the Interiors Indian fiduciary trust responsibilities to account holders, both individual and tribal. 4. An Identification of the statutory authority permitting other than full and open competition. FAR 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. 41 U.S.C. 3304(a)(1) 5. A demonstration that the proposed contractors unique qualifications or the nature of the acquisition requires use of the authority cited. The Trust Beneficiary Call Center Services are critical to the overall success of OSTs implementation of the Trust Reform Act. As of February 1, 2018, OSTs mission, including the provision of the Secretary of the Interiors fiduciary trust responsibilities to account holders, will be severely degraded without seamless continued support by qualified personnel in the call center. The call center ensures ongoing communication with the Tribes and individual Indians with regard to their trust assets and enables Tribes and individual Indians to access information regarding their trust assets, check the status of a trust service or request to update to, or disbursement from their Individual Indian Money (IIM) account information. CNI Technical Services, LLC is currently providing the services onsite in OSTs offices in Albuqerque, New Mexico. The Call Center Services are vital to the daily execution of OSTs responsibilities under the Trust Reform Act. Any delay or lapse in these capabilities would endanger the Secretary of the Interiors fiduciary trust responsibilities under the Trust Reform Act. 6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies. This Justification will be publicized in accordance with FAR 5.202. The current contract is a single contract award. As such, it is impractical to compete the requirement for the extension of services. The Government intends to solicit and award a new contract requirement for the Trust Beneficiary Call Center. 7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable. At the time of contract award, the Contracting Officer made a fair and reasonable price determination on the pricing for the services offered under this contract. The Trust Beneficiary Call Center Services was competed, utilizing a trade-off analysis based upon Price and non-Price Factors. CNI Technical Services, LLC has indicated there will no change in the pricing for the extension of services. The price for the extension is determined to be fair and reasonable based upon the historical prices paid under the current contract. 8. A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted. In conjunction with the procurement of a new contract for the Trust Beneficiary Call Center, market research was conducted. There are a number of businesses that fall under small business programs, including the 8(a) Program and the Buy Indian Act, that are capable of performing the Trust Beneficiary Call Center services. 9. Any other facts supporting the use of other than full and open competition; such as: There is a significant cost and time requirement to implementing new staff in the call center. CNI Technical Services, LLC has an extensive training plan to fully train and staff the call center. The implementation of new staff, including all applicable training, would be hampered by not extending services until a new contract can be solicited and awarded.

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