Justification_and_Approval_-_BPI_Methodology_-_2_(003).pdf

JUSTIFICATION & APPROVALS

FOR

OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Office: Procurement Management Division Rural Development (RD)

2. Nature of the Action:

Information related to the Rural Development programs of the US Department of Agriculture is sought through this effort, to include a review and analysis of various program policy rationales and markets affected, impact and outcome evaluations, measurements of financial and economic return on investment, determination of program benchmarks and measurements for appropriate analysis and comparison to similar government programs worldwide, along with developing support research methodology and resulting data, to provide detailed data and analysis to inform senior leader decisions.

This information is required in an expedited manner as discussed below in Paragraph 6.

The Approval sought with this Justification is to make an award with other than full and open competition to obtain the expertise and experience necessary to conduct in-depth program impact and outcome evaluations, to include recommendations for potential measures of financial and economic return on investment, as well as management performance.

3. Description of the Supplies or Services:

Contractual services are required to provide analysis related to impact and outcome evaluation of Rural Development Programs and provide appropriate recommendations for improvements.

Specific tasks would include:

• In consultation with rural development, define an appropriate study on the types and methods of program impact and outcome evaluations that could be applicable to each of Rural Development’s programs, starting with the broadband programs. Among other things, this should include potential measures of financial and economic return-on-investment, as well as management performance.

• Conduct those actions needed to complete the study and make appropriate recommendations about the types and methods of program evaluations that could be used to measure the impact and outcomes of Rural Development programs. This task is anticipated to include activities such as research, outreach, and interviews with Rural Development program staff, program stakeholders, and external program evaluation experts.

• Provide a report based on the study to present recommended measures of financial and economic return-on-investment, as well as management performance.

• Perform initial in-depth program impact and outcome evaluations, incorporating the measures of financial and economic return-on-investment, and management performance determined by Rural Development policy officials and senior leadership based upon the submitted report.

• Produce reports on each in-depth program impact and outcome evaluation, including detailed information on methods and data sources.

• Assist with preparing the results of these tasks for transition to ongoing research and analysis.

4. Estimated Cost: $2,000,000

5. Period of Performance:

October 16, 2017 to October 15, 2018.

6. Statutory Authority: 41 U.S. Code § 3304(a)(2), FAR 6.302-2, Unusual and Compelling Urgency

7. Supporting Rationale:

BACKGROUND: On March 13, 2017, Executive Order 13781, Comprehensive Plan for Reorganizing the Executive Branch, was signed. On April 24, 2017, Secretary Purdue was confirmed. On May 11, 2017, Secretary Purdue submitted a report to Congress in which he announced his intent to realign Rural Development to report directly to the Secretary. Among other purposes, this allows the secretary to leverage USDA’s expertise with rural communities and new Administrative initiatives to focus on infrastructure investments in rural America. This move was identified as part of a broader on-going review of the Department based on the President’s March 13, 2017, Executive Order 13781. Pursuant to this announced reorganization, on June 12, 2017, Anne Hazelett, was appointed Assistant to the Secretary for Rural Development, the new position leading Rural Development from within the Secretary’s office.

On September 7, 2017, Secretary Purdue announced the realignment and creation of various offices, which build upon the reorganization announced earlier on May 11, 2017. The September 7, 2017, actions resulted from the Secretary’s outreach with the ‘people of America’ and meetings with the Interagency Task Force on Agriculture and Rural Prosperity.

The Announcement on September 7, 2017, included the establishment of an Innovation Center within Rural Development tasked with evaluating the impacts of the business, housing, and utilities programs provided by the department. As stated by the Secretary, ‘Through such evaluation, USDA will be better informed as to where additional investments will be most impactful when it comes to RD program delivery. RD will be continuously identifying best practices in economic development, measuring performance of programs, and promoting collaboration across agencies.’

Additionally, the Secretary announced that, “A report with concrete actions on statutes to be enacted or repealed; regulations to be promulgated, amended, or eliminated; and programs and policies to be implemented, streamlined, or discarded will be provided to President Trump in late October…”

On September 11, 2017, Anne Hazlett, Assistant to the Secretary for Rural Development, spoke publicly, specifically highlighted rural broadband access as an infrastructure component of utmost importance within Rural Development Programs, and stating that infrastructure in rural places will be focus of activity between the Administration and congress in the coming months.

UNUSUAL AND COMPELLING URGENCY: Over the last 6 months, the newly confirmed Secretary of Agriculture has been receiving input from a variety of sources through multiple fora.

Over the last three months, the newly appointed Assistant to the Secretary for Rural Development has also been involved in various fact finding events. USDA has been tasked to provide information to other executive agency offices, as well as Congress, with respect to RD Programs, within the next few months in order to meet Administration requirements. On September 7, 2017, the Secretary announced the formation of a new office within the Rural Development mission area, tasked with, among other things, the evaluation of RD Programs. Rural Development does not currently have evaluation methods or data to adequately measure its programs in order to appropriately support senior leader deliberation and decision making processes within the newly reorganized structure, nor the current administration’s paradigm.

The recent decision of the Secretary to realign functions and create new offices, the corresponding requirement to provide information to other government entities, and the lack of adequate program evaluation methods (and data) to respond to multiple information requirements, has combined to create an unusual and compelling urgency requiring contractor support and expertise.

The specific need is a result of recent decisions made at organizational levels above the contracting activity, and therefore is not caused by a lack of preparation.

Delay in the award of this contract for the development of appropriate measurements and corresponding data and evaluations, would result in serious injury caused by far reaching policy, program, and budgetary decisions which are not supported with adequate, appropriate, and meaningful data. This injury would result in the agency’s inability to meet statutory mandates of Rural Development, and would damage the agency’s ability to meet the needs of farmers, ranchers, foresters, and producers, while providing increased accountability to American taxpayers.

LIMITATION OF SOURCES: The statutory authority supporting this justification allows for other than full and open competition, but requires consideration of as many potential sources as is practicable under the circumstance. See 41 U.S. Code § 3304(d). In order to meet required timeframes and be considered qualified, any contractor would need to currently have:

1. In-depth knowledge of, and experience with, Rural Development Programs and Functions;

2. In-depth knowledge and experience with rural credit subsidy modeling;

3. In-depth knowledge and experience measuring and analyzing government policy and programs across a wide array of governments and programs;

4. In-depth knowledge with the Federal budget process;

5. In-depth financial analysis capabilities and familiarity with accounting;

6. In-depth economic analysis capabilities;

7. In-depth data analysis capabilities;

8. In-depth research and outreach capabilities;

Items 1 and 2 were used as limiting factors for jumpstarting the market research process. The major portion of RD programs (by value and volume) is involved in credit subsidy and modeling.

This is a specialized field, and because of RD’s unique programs and position in the market, it is unreasonable to assume that such experience and in-depth knowledge could be acquired without RD’s knowledge and involvement. Only two contractors satisfying this limitation were positively identified based on agency knowledge.

Capabilities briefings were conducted with these two contractors on September 12, 2017. These capabilities briefings demonstrated that Deloitte Consulting, LLP was the only contractor who could provide current knowledge, experience and expertise necessary to fulfill this requirement in the timeframe required. Overall, the market research identified that Deloitte Consulting, LLP currently has the necessary experience and familiarity in the analysis and measurement of government programs worldwide. Combined with their current understanding of RD Programs, they are unique in their ability to provide the required analysis and recommendations on development of appropriate measures to evaluate RD Programs; including the analysis and comparison to similar government programs throughout the world. This ability is necessary at the initiation of this effort in order to provide senior leaders with the information necessary for policy and organization decisions within the first quarter of the FY18.

In addition, Deloitte Consulting, LLP has gained more in-depth knowledge and experience with Rural Development programs through their support of the RD Risk Management Office and their related evaluation of risk across all of RD Programs. Deloitte Consulting, LLP would be able to immediately utilize and incorporate this information into their analysis.

Based upon the market research conducted, further competition is not practicable for this initial requirement.

8. Competition Effort:

See Paragraph 7. This is considered an initial effort. Follow-on research and studies will be competed.

9. Fair & Reasonable Cost:

Pricing for the resulting contract will be negotiated. The Contracting Officer will determine the price fair and reasonable pursuant to FAR 15.4 prior to award.

10. Market Research:

Market research was conducted and has been discussed above.

11. Other Information:

N/A

12. Interested Sources:

None further received.

13. Competition Barrier:

The barrier to competition that RD can impact is the in-depth knowledge and experience with complex RD Programs. In an effort to promote future competition, Rural Development will continue to work with contractors to develop the in-depth knowledge and experience with RD Programs necessary for supporting requirements.