17O0018_JNAMEND1_082117.pdf

FAR PART 8 Amended Sole (Limited) Sources Justification

1. Department of Education (DoED), Federal Student Aid (FSA) Acquisitions.

2. The original justification, posted on FEDBIZOPS on 8 September 2017, justified the award of task order (TO) EDFSA17O0018 under Temporary Administrative and Professional Services (TAPS) GSA 736 schedule number GS-07F-0539N, to Midtown Personnel Inc. (Midtown), a woman owned small business (WOSB). This amendment to that justification is solely to increase the estimated TO total value to $700,000.00.

3. TO EDFSA17O0018 was a logical and natural follow-on award, authorized under FAR Parts 8.405-6 (a) (1) (I) (A) and (C). Under this TO, Midtown is providing barred attorneys to support FSA to expeditiously work through a large backlog of borrower defense applications received from borrowers requesting relief from student loan debts pursuant to the borrower defense regulation.

4. When TO EDFSA17O0018 was awarded, FSA projected that attorneys already onboard and other attorneys that would be optionally added by January 2018 could substantially reduce the claims backlog of pending borrower defense applications. Subsequent to the TO award, FSA has determined that because of the development and implementations of additional workflows to support policy decisions; assignment of full-time employee resources to the development of a new borrower defense platform; ongoing activities to automate and update existing claim processing tools; interim budgetary disruptions;

delays in getting added attorneys cleared; and the receipt of several thousand additional borrower defense applications, time and attorneys are required to reduce the volume of pending applications.

5. Accordingly, FSA has exercised the TO EDFSA17O0018 extension of services option to increase contractor resources needed to make a significant reduction in the number of pending applications. During July 2018, FSA will reassess schedule progress and if necessary to allow time to re-compete this requirement, will exercise the TO continuity of services option.

6. In response to the schedule change, FSA has exercised the TO extension of services option and during July 2018, FSA will reassess schedule progress and if necessary to allow time to re-compete this requirement, will exercise the TO continuity of services option.

7. The same economy and efficiency reasons cited in the original justification continue to be applicable. An extended timeframe, involving close and extensive hands-on training and guidance is required before an attorney resource is sufficiently knowledgeable and familiar with processes, workflows and tools to be able to efficiently and effectively review borrower applications. Due to staff shortages, involved government staff has limited availability to devote to this purpose. Also, to protect applicant privacy, claim reviews must be performed within a controlled environment, and security and technology clearances can take extended timeframes to complete.

FAR PART 8 Amended Sole (Limited) Sources Justification

8. Existing Midtown attorney resources are knowledgeable, experienced and improvement-oriented. Therefore, in terms of operational effectiveness, they are uniquely able, without delay and disruption, to immediately and cost-effectively continue work on a large volume of claims; they are able to continue training and monitoring other less experienced attorneys who have been optionally added; they are already fully operating within the FSA-established control environment; they have continuously performed in a high quality manner; and their cost is not only fair and reasonable (discounted GSA schedule pricing), but rather, it is considered favorable. Accordingly, this action continues to make sense; represents a wise use of government resources; and is advantageous to and in the best interests of the government.

To the best of the undersigned knowledge and belief, the above content is accurate and complete.

Contracting Officer & Date

The undersigned attests that the above BCPSS program office content is accurate and complete.

__ On File_________ ____________________ Program Manager Date