Supply Chain Funds Administrator (№28071304)

Federal Communications Commission
Enterprise Acquisition Center
EXCEPTION TO FAIR OPPORTUNITY
IN ACCORDANCE WITH FEDERAL ACQUISITION REGULATION (FAR) 16.505(b)(2)(ii)(B)
Supply Chain Reimbursement Program
Administration
1. Identification of the agency and the contracting activity, and specific identification of the
document as a "Justification for an Exception to Fair Opportunity.”
This justification was prepared in accordance with FAR 16.505 by the Federal Communications
Commission (FCC), Headquarters (HQ), Office of the Managing Director (OMD), Enterprise
Acquisition Center (EAC) located at 45 L Street NE, Washington, DC 20554. The managing
program is the Office of the Managing Director (OMD).
2. Nature and/or description of the action being approved.
The purpose of this requirement is to award a contract for a logical follow on to Task Order
273FCC21F0121 for the Supply Chain Reimbursement Program. The proposed action involves the
delivery of professional services, including program management, to assist the FCC in
administering the Secure and Trusted Communications Networks Reimbursement Program
(“Reimbursement Program” or “Program”) and processing reimbursement claims. Among other
tasks, the contract will perform the following program areas related to the Reimbursement Program:
strategic planning and outreach; processing payment requests; communications and outreach; data
management, analytics, and reporting; program compliance; and program management. This work
is necessary to continue to execute the Reimbursement Program, described in more detail below.
Because of the unique nature of the work involved to administer this program created pursuant to
the Secure Networks Act, the FCC has concluded it is appropriate to continue with the existing
contractor of these services, which has developed the particular expertise required to administer
this program efficiently and effectively. It is not likely that a new contractor would be able to ramp
up and gain the expertise to be able to perform the requirements under the timeframes required.
The Period of Performance for the new contract will be a Base Period from 5/3/2024-5/2/2025
and add two additional 1-year option periods 5/3/2025 -5/2/2026, and 5/3/2026 - 05/02/27.
3. A description of the supplies or services required to meet the agency’s needs (including the
estimated value.
The Secure and Trusted Communications Networks Act of 2019 (Secure Networks Act) directed the
FCC to establish the Secure and Trusted Communications Networks Reimbursement Program

(Reimbursement Program) to fund the removal, replacement, and disposal of covered
communications equipment or services that pose an unacceptable risk to the national security of
the United States or the security and safety of U.S. persons from the networks of providers of
advanced communications service. Specifically, recipients of Reimbursement Program funds may
use these funds to (1) permanently remove covered communications equipment and services from
their networks, (2) replace the covered communications equipment and services with non-covered
equipment or services, and (3) dispose of the covered communications equipment and services in
accordance with the Secure Networks Act. To access available funds, Reimbursement Program
participants must file applications based on cost estimates for the costs for the removal,
replacement, and disposal of covered communications equipment or services. On December 27,
2020, the President signed into law the Consolidated Appropriations Act, which, among other
things, appropriated $1.9 billion to carry out the Reimbursement Program
The Commission contracted with a third party to serve as Reimbursement Program Administrator
(Administrator), who is tasked with assisting the FCC by reviewing and providing recommendations
as to whether, among other things, applications submitted for reimbursement are complete,
whether the applicants are eligible to participate in the Reimbursement Program, and whether,
after reviewing relevant cost documentation, the expenses reported for the removal, replacement,
and disposal of covered equipment or services are eligible for reimbursement. Once the initial
applications are approved, the FCC issues funding allocations as expenses are incurred. Prior to
disbursing funds, the Administrator must review and approve submitted requests by recipients that
include documentation of costs. Once granted funding, recipients then must complete the removal,
replacement, and disposal process within a set period of time.
Submission of Cost Estimates. To participate in the Reimbursement Program, eligible providers
were required to submit initial estimates of the costs to be reasonably incurred for the removal,
replacement, and disposal of covered communications equipment or services to participate in the
reimbursement program. Participants were also statutorily required to submit, in addition to cost
estimates, “supporting materials substantiating the costs,” a “specific timeline . . . for the
permanent removal, replacement and disposal of the covered communications equipment or
services,” and the certifications required by section 4(d)(4) of the Secure Networks Act as to the
development of a transition plan and the use of funds if approved and in developing and tailoring
risk management practices.
Funding Allocation Stage. After an applicant has submitted estimated cost forms, the FCC’s
Wireline Competition Bureau (Bureau), with the assistance of the Administrator, reviewed the
submitted applications for completeness, the applicant’s eligibility for reimbursement, and the
reasonableness of the cost estimates provided. Funding was then allocated accordingly. The
funding amount allocated represents the maximum amount eligible for draw down by an eligible
provider unless a subsequent funding allocation is made.
Funding Disbursement Stage. Following the allocation of funds to eligible providers and after
eligible providers incur actual costs, recipients must file reimbursement claims along with any
required supporting invoices and other cost documentation, as directed by the Bureau, to obtain

reimbursement requests as they incur expenses throughout the reimbursement period. The
Bureau, with the assistance of the Administrator, reviews reimbursement claims to ensure that
disbursements are made only for costs reasonably incurred.
Estimated Value: Base + Options = The independent cost estimate (IGCE) projects an estimated 3-years
maximum potential value of $25,636,724.97.