01.07_70CDCR18FC0000014-LSJ_Redacted.pdf

GS-10F-0083L / HSCEMS-14-A-00006 / 70CDCR18FC0000014

LIMITED SOURCES JUSTIFICATION

41 U.S.C. 152(3) and 40 U.S.C. 501

Office of Acquisition Management (OAQ) Support Services

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

(1) Agency and Contracting Activity

The U.S. Department of Homeland Security (DHS), Immigration and Customs Enforcement (ICE) Office of Acquisition Management (OAQ) proposes to issue a GSA Schedule Task Order, single award, 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 to sole source an interim contract while DHS completes implementation of the Electronic Contract Filing System (ECFS) for up to 11 months total, including a 5-month base period and two 3-month option periods, to continue providing Management and Support services at ICE OAQ located at 801 I St. NW Washington DC 20001. ICE OAQ is a customer-focused organization with an enterprise-wide, strategic approach to procurement, and operates as a full business partner with internal and external organizations, serving as a strategic asset dedicated to improving the agency's overall business performance. OAQ is required to maintain a contract management structure that ensures continuity of important organizational support services across its customer portfolio.

To achieve its mission, OAQ requires contract management and support services that will maintain and improve OAQ’s ability to plan, communicate and report on procurement status at ICE Headquarters, program offices and its customers throughout the agency and DHS headquarters.

The name of the proposed contractor is:

Deloitte Consulting LLP 1750 Tysons Blvd.

McLean, VA 22102

Type of Contract - A firm-fixed price BPA Call 70CDCR18FC0000014 will be written under the provisions of the Blanket Purchase Agreement (BPA) HSCEMS-14-A-00006, and GSA Schedule contract number GS-10F-0083L.

(3) Description of the Supplies/Services

One of the DHS priorities over the following year is to migrate ICE’s e-contract platform to the new ECFS. ICE OAQ needs to prepare for this implementation by utilizing the existing vendor and services unique qualifications. The current vendor designed, created and successfully supported ICE OAQ migration to the existing e-contract filing system. This e-contract filing system and proprietary processes and database are maintained by the vendor and used as the system of record and to produce ICE OAQ data and reports. Due to the system knowledge of http://uscode.house.gov/ vendor, it is imperative to continue their services in order to maintain system integrity of data and records compatibility with the new department wide ECFS.

The incumbent contractor, Deloitte Consulting, will continue management and maintenance of the OAQ electronic contract system, developed and maintained over the past two years by Deloitte. This effort will continue providing on-site support to OAQ related to organizing, tracking, administering, automating, and managing data related to requests for information and data calls in support of OAQ’s procurement programs and operations. Deloitte will also assist OAQ to uncover and resolve many issues related to collecting reliable contracting data. As these issues are constantly evolving, process improvements are still being uncovered and worked.

Additionally, the contractor shall continue performing an OAQ wide analysis of processes and systems in anticipation of integrating the new DHS records management system (currently in a testing environment) with the current OAQ records management system.

Due to the great strides in capturing and tracking electronic records through the system designed and supported by Deloitte, all OAQ divisions have adopted electronic records as the official contract record. To sustain this momentum and support increased contract compliance with the FAR, continued funding for an eleven-month period at the total estimated value for this effort is $1,239,285.93 and is required to support these activities, such as:

• Continuity in performing current Q: Drive records management effort

• Requisition intake automation support

• Designing and developing OAQ Records Management and intake automation

• Identifying and developing adaptations of eFile process/ECFS rollout

• Designing and developing eFile compliance improvements

• Rapid Sourcing analysis and tool development

• Identifying improvements to standardize Contract review and workflow

• Supporting SOP and tools updates

• Training support for updated procedures, reporting access and materials.

The proposed level of effort will be commensurate with the work currently being performed, at the rate of pay applicable to market research for each position category.

Period of Performance (POP) - The POP for this Call Order shall be up to eleven (11) months in total from May 27, 2018 through April 26, 2019.

Period

Quantity Total Price

Base 05/27/18 – 10/26/18 5 months $ 563,311.79 Option 1 10/27/18 - 01/26/19 3 months $ 337,987.07 Option 2 1/27/19 - 04/26/19 3 months $ 337,987.07

TOTAL $ 1,239,285.93

(4) Authority and Supporting Rationale.

A. Identification of Statutory Authority Permitting Other Than Full and Open Competition

IAW FAR 8.405-6(a)(1)(i)(C): In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures.

The original BPA was competitively awarded to Deloitte Consulting LLP from 8 proposals.

This order is being issued under the authorities of 8.405-6(a)(1)(i)(C) “In the interest of economy and efficiency,” with the new work issued as a logical follow-on, the statutory authority permitting other than full and competition, 41 USC 152(3), and 40 U.S.C. 501, Services for Executive Agencies implemented by FAR Subpart 8.405-6 entitled “Limited Sources.”

B. Demonstration that the Contractor’s Unique Qualification or the Nature of the Acquisition Requires the Use of the Authority Cited.

The justification of FAR 8.405-6(a)(1)(i)(C) is due to ICE OAQ’s business processes maturing and pending adoption of the Electronic Contract Filing System (ECFS) as the contract system of record across DHS components. There is a critical and urgent need to 1) prepare for the OAQ transition and integration of ECFS, due for rollout late 2018 or early 2019, in order to minimize the risk of data and compliance loss during the transition, and 2) implement additional capabilities for establishing a framework for automated and manual data collection and reporting to better substantiate internal/external reporting.

One of the DHS priorities over the following year is to migrate ICE’s e-contract platform to the new ECFS. ICE OAQ needs to prepare for this implementation by continuing the existing services and coordinating with DHS on transitioning to the new solution. The current vendor successfully supported ICE OAQ in the migration to its current e-contract filing system and has commenced on a transitional effort to maintain ICE OAQ data and records compatibility with the new department wide system. This transition stage is a critical function that involves collaboration with OAQ, DHS HQ, and the ICE Office of the Chief Information Officer (OCIO).

A successful transition will allow the agency to rely on a centralized records management system resulting in cost savings and efficiency. All DHS components are now testing ECFS, and therefore, a full understanding of what will be required is not yet known.

Competing this effort at this point would result in a break in service that would be detrimental to the agency’s ability to provide reliable, current data. It would also negatively impact the ongoing transition effort until the department wide system becomes available for full implementation.

Given the steep learning curve on the standard operating procedure for collecting and maintaining the electronic records, introducing a new contractor at this critical juncture would not only substantially duplicate costs to the Government, but would also unacceptably delay the fulfillment of acquisition record requirements and the ultimate ability of OAQ to respond to the backlog of data calls and management reports.

An eleven-month contract minimum for electronic records management, reporting and transition support is essential.

(5) A determination by the ordering-activity contracting officer that the order represents the best value consistent with 8.404(d).

The services being acquired are available on GSA Federal Supply Schedule for Business and Program Solutions for Law Enforcement (BAPSLE). Deloitte quoted rates from the BAPSLE BPA (GSA) rate card. The CO performed price analysis against other Deloitte contracts and GSA schedule pricing and reviewed other GSA schedules for similar services against Deloitte and found the Deloitte pricing to be fair and reasonable. In addition to the pre-existing GSA discounting, ICE negotiated additional cost savings.

(6) Description of Market Research

Market Research is required in accordance with FAR Part 10. OAQ conducted market research at the time of award for Business and Program Solutions for Law Enforcement (BAPSLE) and by considering internal department-wide contract vehicles and Federal Supply Schedules on GSA in mid-2015 on the initial award. Market research was conducted for this extension in January 2018 through GSA and DHS Strategic Sourcing Contract Vehicles for administrative and data/records management support services to be current with the Federal Supply Schedules market.

(7) Any Other Facts Supporting the Use of Other than Full and Open Competition

Recommendations for changes in the ICE OAQ overall business structure were made as result of the ICE OAQ Project, including changes to cross-department responsibilities in the contract lifecycle around requisition and award obligation. Additional time is required to properly determine ICE’s long-term needs for the contractor provided support services once the transition to the DHS records management system is complete and automation processes are in place.

(8) A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

This Task Order 70CDCR18FC0000014 is issued against BPA HSCEMS-14-A-00006 as an interim order to provide mission essential support services until the DHS ECFS program is completed. With the implementation of ECFS, these support services are no longer necessary.

(9) Certifications

I certify that the facts and representations under my cognizance, which are included in this justification, meet the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.