Lee-2016-4_JA_Redacted_Final.pdf

Control No: Lee-2016-4 Contractor: Penn Foster, Inc.

Program/Equipment: Gunsmith Credentialing

FOR OFFICIAL USE ONLY

JUSTIFICATION REVIEW DOCUMENT

FAR SUBPART 13.5 SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL

ITEMS – SOLE SOURCE JUSTIFICATION AND APPROVAL

Program/Equipment: Gunsmith Credentialing

Authority: Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5.

Amount: The estimated value is

Prepared by: Xanthe Otterstedt DSN: 539-4985 Contract Specialist Date: 10 August 2016 Email: xanthe.a.otterstedt.civ@mail.mil

Contracting Officer: Peyton Rowley DSN: 539-3115 Contracting Officer Date: 10 August 2016 Email: peyton.l.rowley.civ@mail.mil

Technical/Requirements: DSN:

91F Course Manager Date: 10 August 2016 Email:

Reviews: I have reviewed this justification and find it adequate to support sole source.

Technical/Requirements:

Name:

DSN:

Signature: _ Date: ____________________

Legal Counsel:

Name:

DSN:

Signature: ___ __ Date: ____________________

Digitally signed by

2016/08/16

Digitally signed by t

2016/08/16

Program/Equipment: Gunsmith Credentialing

Version – MAY 2016 FOR OFFICIAL USE ONLY

FAR Subpart 13.5 Simplified Procedures for Certain Commercial Items – Sole Source Justification and Approval

1. Contracting Activity: Mission and Installation Contracting Command – Fort Lee

2. Description of Action: The U.S. Army Ordnance School, Conventional Weapons Division, Fort Lee, VA 23801-2102 requests a firm-fixed-price, new contract with Penn Foster, Inc., 925 Oak Street, Scranton PA, 18515. The Government projects award for August 2016 and fiscal year 2016, Operations and Maintenance funds will be used.

x 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).

This action is a follow-on to contract W91QF5-15-P-0039 That contract was not competed under authority 10 U.S.C. 2304(c)(1) as implemented by FAR Part 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. Paragraph, “Actions to Increase Competition” of the previous justification, stated: “The process started over a year ago requesting vendors to supply information for this service, only Penn Foster responded”. Those actions were accomplished through correspondence via phone, email and the web.

3. Description of Supplies/Services: The purpose of this contract is to not only provide a credentialing program for the Small Arms/ Artillery Repairmen but to continue to achieve the Army Learning Concept 2015 goals. This contract will allow Conventional Weapons Division (CWD) to continue to take steps towards a more competitive learning model:

(1) Establishing a computer lab for Soldiers who are enrolled in this program.

(2) Establishing a competence level based on the results of assessments. The Soldiers will have comprehensive exams after each modules and a certification exam upon completion of program.

(3) Establishing a blended learning approach that incorporates a technology-delivered instruction. CWD knows that using technology will establish a learning system that will continue to attract young people.

(4) To give students credit for skills learned during military occupational specialty training.

A total number of 693 trainees will be enrolled in a self-directed program encompassing a total of 20 study lessons, each taking approximately five hours to complete. The training program will be tailored to the needs of the Conventional Weapons Division.

Total Value:

Program/Equipment: Gunsmith Credentialing

Version – MAY 2016 FOR OFFICIAL USE ONLY

The anticipated Period of Performance is from 12 August 2016 to 11 August 2017 The Estimated Total Value is

4. Authority Cited: Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5:

x Other: Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Reason for Authority Cited: As described at FAR 13.501(a)(1)(i), conduct sole source acquisitions under this subpart only if the need to do so is justified in writing and approved at the levels specified in paragraph (a)(2) of this section.

Penn Foster is the only contractor that can provide the required credentialing services to assist the Conventional Weapons Division (CWD) in managing the complete Gunsmith/Military Conventional Weapons certification process: developing courseware solutions to meet needs, the actual instructional process, and measuring success towards desired goals and results. Penn Foster will provide targeted performance–based training that can be completed at the Soldier’s own pace. The program will contain 20 study modules (each module will take 5 hours or less to complete) and pre- assessments after modules. The program will also contain a customized cumulative pdf. formatted proctored exam for certification that will be graded by the contractor.

Additionally, Penn Foster is the only college that can provide a flexible program design to custom tailor the unique needs of Conventional Weapons Division. As required, the contractor shall issue a nationally and regionally accredited career diploma; Penn Foster is the only college that is accredited both internationally and regionally.

If this J&A is not approved, the Ordinance School will not be able to enroll students through the program due to the lack of vouchers for Gunsmith Credentialing. A different class starts every two weeks and several classes have been missed already.

6. Efforts to Obtain Competition: The Contracting Officer shall publish the notices required by FAR 5.201.

7. Actions to Increase Competition: The Government will continue to perform Market Research in order to identify any possible sources that can fulfill the required services as stated in the Performance Work Statement (PWS).

8. Market Research: Market research was conducted between May-August 2016 to identify all qualified sources. The research was conducted via Internet by accessing

Program/Equipment: Gunsmith Credentialing

Version – MAY 2016 FOR OFFICIAL USE ONLY various colleges and gathering information relating to Gunsmith Credentialing. The research conducted did not result in any other possible sources besides Penn Foster, Inc.

In accordance with Defense Federal Acquisition Regulation Supplement (DFARS) 205.205-71, DFARS 206.302-1(d), and DFARS Procedures, Guidance and Information (PGI) 206.302-1(d), a sources sought was posted to Federal Business Opportunities (FBO) on 11 May 2016 for 30 days; zero (0) capability statements were received in response to the notice.

9. Interested Sources: To date, no other sources have written to express interest in the acquisition.

10. Other Facts:

a. Procurement History:

(1) Contract numbers W91QF5-14-P-0068 and W91QF5-15-P-0039 have previously been awarded for the same requirement.

(2) Both aforementioned contracts were issued on a sole source basis.

(3) The authority previously for both contracts was 10 U.S.C. 2304(c)(1) as implemented by FAR Part 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

(4) The justification prepared to support the procurement made before this one, stated Penn Foster was the only one who responded to the Request for Information.

(5) There have been no prior contracts for this requirement that was accomplished using full and open competition.

(6) There have been no unusual patterns revealed by the history, e.g., several consecutive, urgent buys.

(7) A justification was prepared to support the procurement made before this one, there have been no significant changes to this requirement.

11. Technical/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.

Name: Date:

Title: 91F Course Manager Signature: Digitally signed by

2016/08/16

Program/Equipment: Gunsmith Credentialing

Version – MAY 2016 FOR OFFICIAL USE ONLY

12. 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 the following: x price analysis x other:

Comparison of the proposed price with prices found reasonable on previous purchases

As a part of this basis, certified cost or pricing data is not required because the item and/or services being acquired are considered commercial.

Name: Peyton Rowley Date:

Title: Contracting Officer Signature:

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

Name: Peyton Rowley Date:

Title: Contracting Officer Signature:

16 August 2016

ROWLEY.PEYTON.

LOESLEIN.1045804

Digitally signed by

ROWLEY.PEYTON.LOESLEIN.1045804042

DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, cn=ROWLEY.PEYTON.LOESLEIN.1045804042 Date: 2016.08.16 14:30:50 -04'00'

16 August 2016

ROWLEY.PEYTON.

LOESLEIN.1045804

Digitally signed by

ROWLEY.PEYTON.LOESLEIN.1045804042

DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, cn=ROWLEY.PEYTON.LOESLEIN.1045804042 Date: 2016.08.16 14:31:05 -04'00'