Consolidation DF_EFOM_Redacted.pdf

FEDERAL BUREAU OF INVESTIGATION

FINANCE AND FACILITIES DIVISION | PROCUREMENT SECTION

CONSOLIDATION DETERMINATION AND FINDINGS

Attachment S.3 – Determination and Findings for Consolidation and Bundling

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Background Based upon the following findings, in accordance with Title 15, United States Code (USC), Section 657q, as implemented by the Federal Acquisition Regulation (FAR), Subpart 7.107-2, it is determined that consolidation of two or more requirements for services that have been performed under two or more separate contracts is necessary and justified because the benefits of the acquisition would substantially exceed the benefits that would be derived from alternative contracting approaches.

This determination has been prepared and approved as required by FAR section 7.107-2(a) and Title 15, USC, Section 657q for the purpose of supporting an FBI consolidation of requirements that is necessary and justified for an acquisition exceeding $2 million.

FINDINGS

A. Background

Solicitation number: 15F06724R0000188 Requirement: Enterprise Facility Operation and Maintenance (EFOM) Estimated value of procurement: $

The consolidated requirement will include facility operation and maintenance services that cover the full range of services need to maintain a large facility. The anticipated award is a multiple-award Indefinite Delivery Indefinite Quality (IDIQ) utilizing FAR 15 procedures.

under NAICS code 561210. The anticipated IDIQ is a hybrid contract that will include Fixed Price Award Fee (FPAF), Labor Hour and Cost only line items where there is a fixed price monthly rate and fully loaded fixed-price labor rates for each labor category. The anticipated IDIQ will be for five (5) years composed of a base year and four (4) option years each 12 months in length.

with Task Orders being competed soon after IDIQ award. The total estimated value of the Seed Task Order for the IDIQ contract is .

B. Selection of Acquisition Strategy

1. Market Research

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This IDIQ contract is anticipated to be a multiple-award IDIQ contract which means the government can set aside at least two to three contract awards for small business. This approach will enable the government to achieve some credit toward achieving its small business goals.

The most advantageous procurement strategy for the FBI is to solicit the Enterprise Facility O&M (EFOM) procurement as an unrestricted, full, and open opportunity with a partial small business set aside on SAM.gov in order to establish a multiple award IDIQ contract vehicle for the FBI. The contracting office will be using guidance from FAR 15 to establish this hybrid contract-type (FPAF, LH and, Cost) for a period of performance consisting of one (1) 12-month base period and four (4) 12-month option periods.

The anticipated benefits of establishing a Multiple Award IDIQ contract vehicle that has the capability to provide services enterprise wide will result in streamlined procurement procedures for all resulting Task Orders. An IDIQ that is available FBI wide will result in cost avoidance of additional procurement administration that will be required if the FBI pursues individual contracts for each internal customer that requires these services. A partial small business set aside will allow the FBI to meet a large portion of its goals. It will meet small business goals while also ensuring the FBI is able to receive the Tier 3 Data Center support that it requires.

There are also many opportunities via subcontracting plan requirements to encourage small business participation.

2. Alternative contracting approaches that would involve a lesser degree of consolidation:

The only viable alternative approach to consolidating this requirement would be to maintain the status quo and award separate contracts for all the individual facilities across the FBI. Such an alternative would not enable any additional small business participation. The alternative approach fails to provide any significant and/or quantifiable benefits to the FBI or to small businesses via increased opportunities. In addition, this alternative approach negates the FBI’s ability to obtain necessary benefits which are critical to the FBI’s mission success..

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3. Coordination with respect to small business issues: This determination has been coordinated with the FBI’s Small Business Representative, the DOJ Office of Small and Disadvantaged Business Utilization, and the appliable SBA Procurement Center Representative (PCR).

4. Negative impact of the acquisition strategy on contracting with small business concerns.

The consolidation had no effect on the number of small businesses capable of performing the new solicitation. Market research results indicate the negative impact on small business concerns as nonexistent. The consolidation has not created a larger requirement. The resulting Task Orders will be equal in size to the contracts that are being replaced by the multiple award

IDIQ.

As such, in coordination with the Small Business Representative, the consolidated acquisition will be procured under a partial set-aside for small businesses. The effort is recommended to be a multiple-award IDIQ utilizing the open market. The effort will be solicited under SAM.gov.

• How was the determination that the requirement is appropriate for SB made?

To determine the requirement as appropriate for small business, the FBI reviewed the RFI responses that were received from small businesses and found that a few did in fact have experience operating a Tier 3 Data Center under similar circumstances as required by the FBI.

The vendor pool for this specialized support is small even when both small and large businesses are considered.

• How was the determination made that the consolidation does not negatively impact

SB?

This requirement will contain a partial small business set aside which will help small businesses compete to be included on the multiple award indefinite delivery – indefinite quantity (IDIQ) contract. Small businesses have consistently responded to Requests for quotes and when awarded, demonstrated they possess the capabilities to perform/deliver as evidenced through consistent CPARS ratings. Market Research also demonstrated that when a large business was awarded these services in the past, they frequently subcontracted a large portion of the work out to other companies, predominately to small business partners. Based on these facts, the FBI has determined that this consolidated requirement is appropriate for a partial small business set-aside and will result in no negative impact to small business.

CONSOLIDATION DETERMINATION AND FINDINGS

Attachment S.3 – Determination and Findings for Consolidation and Bundling

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5. Steps taken to include small business concerns in the acquisition strategy:

The government intends to include a subcontracting plan requirement in the RFP in accordance with FAR 19.704. There are many opportunities for small businesses to support this contract through subcontractor opportunities executed via subcontracting plan requirements.

C. Benefits Note: To successfully establish that a proposed consolidation is “necessary and justified” the determination document must demonstrate that the benefits of the acquisition would substantially exceed the benefits that would be derived from each of the alternative contract approaches. This will require the identification of benefits that are quantifiable in amounts along with other specifically identified benefits. FAR section 7.107-2(d) presents a 10% and 5% formula for gauging if benefits are measurably substantial. This will involve the calculation of cost savings and price reductions as well as other factors listed at FAR section 7.107-2(c). These include quality improvements that will save time or enhance performance or efficiency, reductions in acquisition cycle times, terms and conditions and any other demonstrable benefits.

The FBI analyzed the benefits of consolidating Facility Operations and Maintenance (O&M) services enterprise wide. Normal consolidation is not the goal of this multiple award IDIQ. Though it is the FBI’s intent to solicit many contracts from one single solicitation - individual contracts will still be the result.

Once the multiple award IDIQ is established the FBI will compete among the vendors each Task Order for each individual location. The FBI found that consolidation is necessary and justified because it will greatly streamline the procurement process saving substantially on contract admin and solicitation costs.

Measurable Benefits:

Consolidation will reduce administrative burden and provide consistent terms and conditions within a single contract for the FBI. Consolidation should offer increased discounts as well as a single point of contact for problem resolution or warranty inquiries, and mitigate supply chain issues. Reduction of administrative or personnel costs alone is not sufficient justification for this consolidation unless the cost savings are expected to be substantial. Though perhaps difficult to quantify numerically, the above benefits all contribute to the justification for consolidation.

• Benefits that are NOT quantifiable in dollar amounts shall be specifically identified and otherwise quantified to the extent feasible.

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2. The benefits of the acquisition substantially exceed the benefits that would be derived from each of the alternative contracting approaches identified under paragraph B.2 above, including benefits that are quantifiable in dollar amounts as well as any other specifically identified benefits, and the benefits of the acquisition are critical to the FBI’s mission success.

3. As a result, consolidation; for the above referenced requirement is necessary and justified.

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I certify that this justification is accurate and complete to the best of my knowledge and belief.

Reviewed by:

Contracting Officer:

Signature Date