JA_Older_Americans_v3_(08-05-19)_Signed.pdf

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

Authority: 41 U.S.C. 3304(a)(3)(B), as implemented by FAR 6.302-3

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the

Federal Acquisition Regulation (FAR) Subpart 6.3 and in accordance with the requirements of FAR

6.303-1, the justification for the use of the statutory authority under FAR Subpart 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

1. Identification of the agency and the contracting activity.

This requirement is being conducted by The United States Department of Agriculture (USDA), Food and Nutrition Service (FNS), Contracts Management Division (CMD) 3101 Park Center Drive, Room

228 Alexandria, VA 22302.

2. The nature and/or description of the action being approved.

USDA, FNS proposes to enter into a contract on a basis other than full and open competition, negotiated sole-source, firm-fixed price contract with the University of Kentucky, a public higher educational institution for the procurement of a second round of research studies to examine food insecurity in seniors.

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

The contractor is to develop and implement a set of research studies that will increase understanding of why many seniors in the United States experience food insecurity and the implications for nutrition assistance programs. The estimated value for this contract is $1.5M. The period of performance for this acquisition will be a 42-month period.

Historically, older Americans have participated in the Supplemental Nutrition Assistance Program

(SNAP) at half the rate of other eligible individuals. There is still much to learn about the factors that contribute to food insecurity and other food-related hardships among older adults in the United States and the role that nutrition assistance programs such as SNAP may play in ameliorating these conditions.

University of Kentucky Center for Poverty Research (UKCPR) successfully implemented research studies under the contract awarded in FY2018. Researchers representing a variety of Universities submitted applications for research studies to UKCPR; due to the available funding, only 8 research studies were funded. Given the need for studying food insecurity in older Americans and the interest shown in examining this issue by researchers representing a variety of highly-relevant academic disciplines, the Agency would like to increase the number of funded research projects.

In order to conduct a comprehensive research program that builds upon the research studies that were recently funded, and also allows for the technical guidance, monitoring, and management by well-known experts, FNS needs to continue working with UKCPR. Therefore, the purpose of this project is to maintain the program funded through the contract in FY2018 with a follow-on sole source contract to implement a second round of high-quality, policy-relevant research studies to examine food insecurity in seniors and the implications for nutrition assistance programs. The second round of research studies will complement the studies currently underway and produce a comprehensive and timely resource to inform this important customer service-related issue for older nutrition assistance program participants.

4. The statutory authority permitting other than full and open competition.

41 U.S.C. 3304(a)(3), as implemented by FAR 6.302-3, titled "Industrial mobilization; engineering, developmental, or research capability; or expert services."

5. A statement demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring the use of the authority.

UKCPR is a leading higher education institution with a long-established research record in the areas of

U.S. food assistance, food insecurity, poverty, and inequality. Through FNS’s research initiative, Understanding Food-Related Hardships among Older Americans, UKCPR expanded its research capability and developed a research program focusing on senior food insecurity. This program provides an essential research function for FNS. In FY2018, UKCPR initiated 8 research studies for this program examining a range of objectives outlined by FNS.

FNS seeks to maintain this essential research capability because there are many lingering research questions and issues in senior food insecurity that need to be investigated under a subsequent round of research studies. These include research to study the impacts of recently proposed rule changes that would affect SNAP eligibility for thousands of seniors.

FNS seeks to expand the research agenda of Understanding Food-Related Hardships among Older

Americans while maintaining uniformity of the research approach. This will require maintaining

UKCPR’s essential research capability for this research initiative. If UKCPR’s essential research capability is not maintained, the research initiative will not be cohesive. For instance, this means research efforts have the potential to be duplicated across institutions, which is an inefficient use of taxpayer funds that could result in increased costs for the Government by as much as 100%.

Additionally, if UKCPR’s capability is not maintained, the research design approach would differ across institutions, meaning the proposal design process, proposal selection criteria and evaluation process, project implementation approach, research management approach, and research synthesis methods would vary. This would result in divergent research approaches and deliverables for the

Understanding Food-Related Hardships research portfolio. The use of distinct research design approaches could result in analyses that show contradictory or opposite findings. Such an outcome could confuse stakeholders and prevent FNS from enhancing program guidance and policy. FNS may need to expend additional funds for another, unplanned round of research to reconcile the divergences in research findings in order to produce valid research findings that meet FNS’s objectives.

6. A description of efforts made to ensure offers are solicited from as many potential sources as is practicable.

A synopsis will be posted on the Federal Business Opportunities web site for 15 days in accordance with FAR 5.202. The notice will be highly visible to industry and afford a reasonable response time for potential sources to respond; and a reasonable opportunity for the Government to answer responses.

7. A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will evaluate the contractor’s proposal in accordance with FAR 15.404, Proposal Analysis. A government technical evaluation will be conducted, and a fair and reasonable price negotiated. The Contracting Officer will determine the proposed costs are fair and reasonable based on cost analysis conducted.

8. A description of the market research conducted and the results or a statement of the reason

Market Research was not conducted.

Market research was not conducted for this procurement since the Agency intends to award a sole source contract for the reasons outlined in paragraph 5.

9. Any other facts supporting the use of other than full and open competition.

UKCPR has demonstrated the ability to provide the breadth and depth of relevant subject matter expertise, researcher networks, and experience in developing and administering the first round of research studies for FNS. This acquisition is for conducting a second round of research studies over a 42 month period. This procurement is for non-severable services and the results of the research studies are deliverable at the end of the 42-month period. UKCPR has the technical expertise and experience necessary for the kind of expert, ongoing monitoring and technical oversight required to successfully execute complex, program relevant research studies on senior food insecurity for the Agency.

Maintaining UKCPR’s essential research capability in this area ensures that FNS’s project, Understanding Food-Related Hardships among Older Americans achieves FNS’s objectives within the scope and budget by producing a comprehensive body of high quality, policy-relevant, evidence-based research. Any other approach risks duplicating research efforts and producing contradictory research findings and not extending or furthering essential research - all of which would require additional

Government resources to resolve.

10. A listing of the sources, if any, that expressed a written interest in the acquisition.

Global Nutrition Professionals, LLC

11. A statement of actions, if any, the agency may take to remove or overcome any barriers to competition if subsequent acquisitions are anticipated.

FNS does not currently anticipate awarding a contract for a third round of research studies on

Understanding Food Related Hardships among Older Americans.

Certifications & Approvals

Supporting data that form the basis for and included in this justification are certified accurate and complete.

Anita Singh

Supervisor of Program/Technical Personnel

The information contained in this Justification for Other Than Full and Open Competition is certified accurate and complete to the best of my knowledge and belief.

Antoine Boissonniere

Contracting Officer

Additional Reviews & Approvals

Signatures are required at each threshold up to the total estimated dollar value of the acquisition

Advocate for competition for the procuring activity (if over $700,000, but not exceeding $13.5 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as advocate for competition for the procuring activity, I hereby approve this justification.

Chantel A. Smith

Mission Area Advocate for Competition