01.06_Limited_Source_Justification_OLCD_Serco_Posting_Final.pdf

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OLCD Curriculum Development and Training Support Services

LIMITED SOURCES JUSTIFICATION

FOR ORDERS PLACED UNDER FEDERAL SUPPLY SCHEDULES

OFFICE OF LEADERSHIP AND CAREER DEVELOPMENT(OLCD)

In accordance with the requirements of Federal Acquisition Regulation (FAR) Subpart 8.405-

6(a), this ''Limited Source Justification" supports the exception specified in FAR 8.405-

6(a)(l )(i)(C), that the award must be issued on a sole-source basis, the work is a logical follow on to an originally competed Federal Supply Schedule award.

1. Identification of the agency and the contracting activity, and specific identification of the document as a "Limited Source Justification".

The requiring activity is Department of Homeland Security (DHS), Immigration and Customs

Enforcement (ICE), Office of Leadership and Career Development (OLCD) and Office of

Acquisition Management (OAQ) proposes to issue a task order under the authority of a logical follow-on award, as the basis for restricting competition.

2. Nature and/or Description of the Action Being Approved:

ICE has a requirement on a sole source basis to contract for a 2-month base and two (2) 1-month option periods of performance. ICE OLCD establishes and maintains standards for curricula and training programs for ICE personnel. OLCD requires the use of training experts that will systematically review and modernize existing training programs or develop new programs to facilitate accreditation ensuring that the agency’s training offerings meet or exceed minimum quality standards. Previously, the ICE Office of Training and Tactical Programs (OTTP) was the organization responsible for maintaining ICE curriculum development and training support services under service-wide contracts. Recently, training was decentralized throughout the agency and OTTP was dissolved. Since February 2018, the newly formed OLCD was tasked with issuing a new re-compete for a curriculum development and training services support contract that would transition the required agency training programs from an instructor-led, knowledge-based form of instruction to a more student centered, performance-based form of instruction.

Currently, under Task Order HSCEMR-17-F-00046, the incumbent contractor provides training and curriculum development support services to ensure that ICE law enforcement and non-law enforcement target populations receive high-quality and professionally produced training.

Services are performed by skilled instructional designers who can educate and guide course owners, instructors and component management in curriculum design and development that adhere to ICE workforce training priorities.

The name of the proposed contractor is:

Serco Incorporated

1818 Library Street, Suite 1000

Reston, VA 20190

The base ICE BPA, HSCEMR-14-A-00001, expired on May 31, 2017 and the Task Order

HSCEMS-17-F-00046 is set to expire on May 31, 2018 with no additional optional periods available. Therefore, OLCD seeks authorization to issue a task on a basis of other than full and open competition to Serco Incorporated in the interest of efficiency and economy to provide ongoing service while OLCD finalizes a re-competition of these services during its organizational restructuring effort.

Serco Inc. has the key personnel and experience to continue to provide training and support services without interruption to ongoing basic law enforcement and leadership training, testing, and tracking, and the mandatory training delivered and currently tracked on ICE’s performance and learning management system (PALMS). Further, it is not programmatically feasible to award a short-term contract to another vendor to support this program.

3. A description of the supplies or services required to meet the agency's needs (including the estimated value):

OLCD seeks to issue a firm-fixed-price (FFP) task order to Serco Incorporated. The cost of the total award is as follows:

Period POP Unit Price per month

Total Price

Base Period 05/31/18 - 08/01/18 $157,035.83 $314,071.66

Option Period 1 08/2/18 - 08/31/18 $167,786.58 $167,786.58

Option Period 2 09/01/18 – 09/30/18 $147,042.72 $147,042.72

The required services under the task order are as follows:

• Instructional Systems Design (ISD) Support – Task 1 – Project Management Plan per the

PWS dated May 2017

• ISD Support – Training Design Plan per the PWS dated May 2017

• ISD Support – Training Solutions per the PWS dated May 2017

• ISD Support – Task 4 – Online Course Development per the PWS dated May 2017

• Travel as required per the PWS dated May 2017. All travel shall be IAW FTR and shall be approved in writing by the COR prior to booking travel at a not to exceed total of

$4,500.00 for the base period and $2,250.00 for each Option period. An Optional CLIN for travel shall be added to the task order as appropriate.

4. The authority and supporting rationale and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

This order is being issued under the authority of FAR 8.405-6(a)(l)(i)(C) ''In the interest of economy and efficiency"; with the new work issued as a logical follow-on.

Failure to execute this task order will temporarily halt support to the following mission critical training tasks: (1) Any required functionality modifications to online courseware mandated by OPM and DHS, (2) ongoing testing and recordation of training completion,

(3) Director-level awards to basic trainees, (4) proof that new graduates qualify to carry a firearm, baton, or oleoresin capsicum upon entry at the field office,

(5) registration for mandatory leadership training, and (6) high priority training completion requests.

5. A determination by the Ordering Activity Contracting Officer that the order represents the best value:

As the proposed action is a logical follow-on u n d e r a GSA Schedule contract, the Contractor's prices were determined to be fair and reasonable, based on superior discounts provided through competition, at the time of the initial GSA award. In addition, the proposed pricing reflects a

1.053% discount applied to the vendor’s schedule pricing.

The Contracting Officer hereby determines that this action represents the best value to the

Government in accordance with FAR 8.404(d) in that the current incumbent, Serco, Inc. provides three (3) significant cost savings advantages to consider as follows: (1) avoidance of the transition costs or delay in services, (2) a staff with complete knowledge of the system and processes and

(3) cleared employees already on site.

Other facts to support why this work is a “logical follow-on” and the incumbent is the best suited to perform are as follows:

• There is no material difference between the requirements of the new task order and the original task order (i.e., the fundamental nature/type of work will remain the same).

• The rates for the tasks required to provide ongoing instructional design and curriculum development services as described above correspond to the labor rates established in the vendor’s professional services schedule (PSS) #47QREA18D0007. These rates have been determined to be fair and reasonable by the General Services Administration prior to awarding the schedule contract.

• The rates offered are discounted at 1.053% of the vendor’s schedule contract.

• The order will be placed in accordance with FAR 8.404, “Use of Federal Supply

Schedules.” The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates.

• The Contracting Officer has assessed the vendors proposed discounted price for the task order and has determined that the price is fair and reasonable, and is the best value to the

Government and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted:

Market research was conducted for the initial competitive BPA award. Due to the level of urgency to maintain the current training processes, market research for this task order was not conducted.

7. Any other factors supporting the justification:

Based on the rationale stated above, it is determined to be in the best interest of the Government to utilize Serco, Inc. to continue the current services for a 2-month base period of performance, and to include two 1-month optional periods of performance. Due to the training being mission critical, the Government cannot afford a break in service. Furthermore, any new contractor would require a transition period for personnel to become sufficiently knowledgeable, which would result in unnecessary risk to ongoing support services and mandatory training offerings as described above.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition/or t h e supplies or services are made:

OLCD is in the process to award a competitive contract for a period of five years for curriculum development and training support by August 1, 2018, and several steps have been taken to facilitate reorganization efforts and OLCD’s ability to operate effectively and at full capacity:

The Director of ICE issued a memo to formalize the OLCD and its funding in February 2018.

Additionally, approved omnibus funding eliminates the need for continuing resolution funding requests as of May 1, 2018. The Office of Human Capital recently approved the job announcements to backfill financial personnel who can fulfill the responsibilities to ensure appropriate funding and oversight for the new contract. Further, OLCD has put in place an organizational chart to delineate responsibilities for curriculum development and financial support services. In addition, OLCD will receive full FY18 funding for the base year of the new award which ensures funding requirements for the base period of the new award are met without disruption.

Finally, in accordance with FAR Part 17, a Justification for the Use of Options will be completed prior to issuing the RFQ for the new award. Prior to exercising each option, a Determination &

Findings will be completed to determine if the contractor is performing satisfactorily within the terms of the contract and decide if exercising the next option is in the Government’s best interest.

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