1.5.1 LSJ 24-278 Exceeding SAT - FAR Part 8 - GMM Agile.pdf

Limited-Sources Justification (LSJ) For orders or BPAs exceeding the Simplified Acquisition Threshold

- 1 - LSJ No: 24-278

LSJ No.: 24-278

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. Identification of the agency, contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

The Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA), Office of the Chief Component Procurement Officer (OCCPO), Acquisition Operations Division (AOD) proposes to award an order pursuant to FAR 8.405-6(a), Limiting Sources.

2. Nature and/or description of the action being approved. Describe the action being approved, and include the name and address of the proposed contractor(s).

DHS/FEMA/OCCPO intends to limit the number of sources solicited pursuant to FAR Part 8.405-6(a) for the procurement of Agile Development services in support of the Grants Management Modernization (GMM) Program to Contractor: Karsun Solutions LLC, 13655 Dulles Technology Drive, Suite 110, Herndon, VA 20171.

3. Description of Supplies/Services. Describe the supplies or services to be acquired. Provide the estimated total value (including options, if any).

The Grants Management Modernization (GMM) Program requires Agile Development services for the FEMA Grants Outcomes (FEMA GO) system. The Contractor shall provide Agile Development resources to develop software to support the national roll-out of disaster grant programs Hazard Mitigation Grant Program (HMGP), Flood Mitigation Assistance (FMA), and Disaster Case Management (DCM) and complete system enhancements for Public Assistance (PA). The national rollout of disaster programs is critical for the resilience of the country. Executive Order 13411: Improving Assistance for Disaster Victims requires that we ensure survivors are given efficient access to Federal disaster assistance.

The estimated total value of the requirement is $4.5M, and the period of performance is six months.

The single award Systems and Platform using Agile Releases and Consolidation (SPARC) blanket purchase agreement (BPA) 70FA3018A00000006 was established through GSA contract GS-35F-0580X. The purpose of the SPARC BPA was to acquire contractor services to develop and deploy the target solution of the GMM program: FEMA Grants Outcomes (FEMA GO). The scope of services of the BPA included three work streams: Agile Development, Operations and Maintenance (O&M), and System Integration (SI). The period of performance of the SPARC BPA started on 8/31/2018 and ended on 2/28/2024. New http://uscode.house.gov/

- 2 -contracts that provide O&M and System Integration services support have been awarded and started performance. Call Order #7 (70FA3124F00000008) for Agile Development services was the last call order awarded on the SPARC BPA. The period of performance of Call Order #7 started 2/12/2024 and ends 12/11/2024. The type of work performed by the contractor has not changed. The scope of currently active call order 70FA3124F00000008 cannot be modified since the BPA has already ended. The work of this requirement for software development to support the national rollout of three disaster grant programs is distinct from the work being performed on call order 70FA3124F00000008.

A new multiple award BPA for Agile Development is anticipated to be awarded in the first half of FY 25. The work of this requirement is distinct from the work of the requirements anticipated for orders under the planned multiple award BPA. This requirement does not stand in place of or change the planned multiple award BPA.

4. Authority and supporting rationale.

Select one of the circumstances justifying limiting sources pursuant to FAR 8.405-6(a)(1)(i) below and demonstrate the proposed contractor’s unique qualifications to provide the required supply or service.

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 order or BPA must not have been previously issued under sole-source or limited-sources procedures.

This acquisition is being 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, in accordance with FAR 8.405-6(a), Limiting Sources.

An award will be made in the interest of economy and efficiency as a logical follow-on to an original order 70FA3124F00000008 pursuant to FAR 8.405-6(a)(1)(i)(C). The original award was made through FEMA BPA 70FA3018A00000006, which was competitively solicited and awarded using the ordering procedures at FAR 8.405. It is necessary to limit competition for new work described herein as a logical follow-on.

Karsun currently provides essential Agile Development services on active SPARC call order 70FA3124F00000008 which was competitively awarded under SPARC BPA 70FA3018A00000006. The last date to order on the SPARC BPA has past, and the work of this requirement for software development to support the national rollout of three disaster grant programs is distinct from the work being performed on call order

70FA3124F00000008.

Karsun is currently an integral part of the FEMA GO delivery approach, actively delivering the final capabilities needed to complete the grants management lifecycle, including http://uscode.house.gov/

- 3 -clouseout and reporting modules, and having previously delivered all the existing business workflow. With their active knowledge and engagement of these workflows, Karsun is in a position to be able to perform the urgent workflow updates required, within the timeline available. Karsun would not require significant time to become familiar with the FEMA GO system or requirement before beginning work. Transition of this urgent requirement to another contractor would require an estimated 2-3 additional months of transition-in and result in mission risk to FEMA. The workflow enhancements must be completed and validated by FEMA disaster grant programs prior to the start of the 2025 hurricane season.

Any delays would result in unacceptable mission risk to FEMA.

If this effort were competed and awarded among a larger pool of contractors, FEMA would incur significant delays in the process and unacceptable schedule risk to allow a new contractor to become familiar with the system and transition in before reasonably being expected to begin the critical work. A new contractor would require an estimated 2-3 months of additional transition-in time, resulting in significant schedule risk. FEMA would incur delays, risk, and additional costs associated with a new contractor to become familiar with the system and the work as well as the learning curve of a new contractor, which is an inefficient use of time and resources for a 6-month requirement to support disaster grants. It would be unreasonable to expect a new contractor to execute a comprehensive transition-in and execute the work without incurring significant delays and unacceptable impacts, with a high likelihood of mission failure.

Transition to a new contractor during this period would place significant risk on FEMA. A lapse in Agile services would not just impact the GMM program, it would impact other programs within FEMA.

The work of this requirement is distinct from the work of the requirements anticipated for orders under the planned multiple award BPA. This requirement does not stand in place of or change the planned multiple award BPA.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

Karsun currently holds GSA contract GS-35F-0580X. The period of performance is from 9/6/2011 to 9/5/2026. The General Services Administration (GSA) has already negotiated and determined fair and reasonable pricing rates. Additional discounts to these current GSA schedule rates will be requested. The ordering activity will consider the level of effort and the mix of labor proposed to perform the specific task being ordered and compare to historical data. The contractor’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate (IGCE). The contracting officer has determined that awarding the proposed order to Karsun for SPARC services represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs.

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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.

Ongoing industry market research has been conducted and contracts that actively support the FEMA GO system have been reviewed, including 70FA3124F00000008 and 70FA4024F00000028. Only Karsun has performed this type of work as the prime contractor for FEMA GO, all of which has been done on call orders from competitively awarded BPA 70FA3018A00000006. Karsun is the only prime contractor that has had access to FEMA GO code in the Development role and has familiarity with it as a prime contractor acting in the Development role. To take on this requirement, other contrators would be stepping into the role for code development work on the FEMA GO system as the prime contractor for the first time. The transition-in and ramp-up time for other contractors would negatively impact the schedule for the workflow enhancements to be completed so that they may be validated by the FEMA disaster grant programs before the 2025 hurricane season.

7. Any other facts supporting the limited-sources justification. Additional facts may be stated in this section. If there are no additional facts, you must state that here.

N/A

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made. Include a statement of actions taken or that will be taken to increase competition for future acquisitions of the same item/service (e.g., the government intends to revise overly restrictive technical specifications, acquire data rights, or pursue some other means to increase future competition).

In accordance with FAR Part 8.405, a new competitive small business multiple award BPA for Agile Development is anticipated to be solicited in the first half of FY 25. The work of this requirement is distinct from the work of the requirements anticipated for orders under the planned multiple award BPA. This requirement does not stand in place of or change the planned multiple award BPA.

9. FEMA intends to post this requirement on SAM.gov pursuant to FAR 8.405-6(a)(2)(i).

10. Technical/Requirements Personnel Certification.

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

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Technical Representative/COR Date

11. Contracting Officer Certification and/or Approval *

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and complete to the best of my knowledge and belief:

Contracting Officer Date *Note: In accordance with FAR 8.405-6(d)(1) for BPAs with an estimated value exceeding the simplified acquisition threshold, but not exceeding $750,000, the ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the ordering activity contracting officer’s knowledge and belief will serve as approval.

12. Approval.

Over $750,000 but not exceeding $15 million Date Component Competition Advocate