19P0014_SSJ_-_REDACTED_92719.pdf

Sole Source Justification (SSJ)

SECTION I: INTRODUCTION AND AGENCY AND CONTRACTING ACTIVITY

The Department of Education, Office of Federal Student Aid (FSA), FSA Acquisitions Group, proposes to solicit and issue a Purchase Order to PPS Infotech LLC (“PPS”) on the basis that only one source is reasonably available. (FAR 13.106 -1(b)(1)(i)).

This acquisition is conducted under FAR Part 13.5, Simplified Procedures for Certain Commercial Items.

Pursuant to FAR 13.501(a)(1)(iii), this SSJ will be posted at the Government point of entry (FBO.gov) within 30 days after contract award.

SECTION II: DESCRIPTION OF ACTION BEING APPROVED

The action being approved is the solicitation and award of a bridge contract to PPS to provide services necessary to maintain the Integrated Technical Achitecture (ITA) and Enterprise Service Bus (ESB) solutions currently employed at FSA. The previous contract for this effort has expired. Three new ID/IQ contracts and two task orders were recently awarded to meet these requirements but are currently under protest at GAO and subject to a mandatory CICA stay of performance. The bridge contract addresses only the elements of the task orders necessary for continuity of operations for a duration sufficient to resolve the current protest. The work will be priced on a firm-fixed price basis.

This SSJ justifies and approves FSA’s acquisition strategy to award a sole-source Purchase Order to PPS for said requirements using the Simplified Procedures for Certain Commercial Items (FAR 13.5). PPS’s address is as follows: P.O. Box 2547, Kensington, MD 20891.

SECTION III: DESCRIPTION OF SUPPLIES OR SERVICES

Background On September 13, 2019, FSA awarded the Enterprise Middleware Architecture and Services (EMAS) ID/IQ Contract to Centennial Technologies, iWorks Corporation, and PPS. As part of ID/IQ contract competition, FSA competed two initial task orders: one for Integrated Technical Architecture (ITA) services and another for Enterprise Service Bus (ESB) services. PPS was the sucessful Offeror for these two task orders, which are order numbers 91003119D0004/91003119F0602 (ITA services) and 91003119D0004/ 91003119F0603 (ESB services). These task orders started on September 15, 2019 and have a base period of ten months and a total period performance of two years and four months, including all options. PPS is the incumbent from the previous expired contract and is in place to perform the required services without any sort of transition or ramp-up effort.

An unsucessful offeror protested the ID/IQ contract award on September 23, 2019. The Contracting Officer was notified on September 24, 2019. To comply with CICA requirements, on September 25, 2019, the Contracting Officer issued a stop-work order on the ID/IQ contracts and the two initial task orders. However, aspects of services covered by the protested task orders are for requirements that are necessary for continued operations through the period of the protest. The bridge contract to be justifed in this SSJ represents the services necessary for continued operations through resolution of the protest.

Period of Performance The base period of performance of this requirement is from September 27, 2019 through October 26, 2019.

This requirement also includes three successive one-month option periods followed by a final two-week option period. This total period of performance is four months and two weeks.

Estimated Value

Description of Services The scope of the ITA and ESB requirements is to procure the full range of technical and project management services to support the continuing, comprehensive, and effective operation of an integrated set of middleware functions and supporting resources available to FSA Applications and Stakeholders to use and integrate with ESB and ITA.

ITA provides common, shared platform and architecture services for the development, deployment, and hosting of FSA Applications and enabling various commerical technologies.

ESB’s principal purpose is to enable disparate FSA applications running on multiple platforms and data centers to communicate and share data in a platform-independent manner. It serves as the enterprise backbone and driver for service orchestration in support of enterprise-wide middleware requirements. ESB provides capabilities to transform and mediate between different data formats and protocols (e.g., REST, SOAP, and XML).

An overview of the ITA and ESB work requirements is provided below:

(1) Build and Deploy Pre-Production Application Environements – In performing all other PWS requirements, the Contractor will have to lead the implementation and deployment of ITA middleware software and products to the Development, Test, and other environements. This task requires planning, architecting the specificaitons of the environments, troubleshooting problems, and coordinating with the designated FSA data center, which is the entitiy responsible for installing the environments per the specifications provided by the ITA and ESB Contractor.

(2) Capacity Planning and Capacity Management – This task requires the Contractor to monitor (principally by using the Wily tool) and analyze utilization and performance data to ensure FSA’s infrastructure is optimized to handle current and future capacity with minimal degradation to the ITA and ESB applications while ensuring infrastructure is optimized by having reasonable but not excessive infrastructure capacity. This task also requires the Contractor to follow FSA’s change management processes when leading changes to FSA’s applications, which includes documenting and process requirements.

(3) Incident and Problem Management – This task requires the Contractor to manage production incidents to ensure they are resolved timely, which includes incidents reported by application owners and FSA’s designated data center; however, the ITA and ESB Contractor is not required to provide a mechanism to report incidents as that is provided by FSA’s designated data center Contractor; this Contractor will send the details of incidents to the ITA and ESB Contractor for problem resolution, including leading resolutions among all stakeholders and conducting the appropriate analysis (e.g., root-cause analysis, running metrics).

(4) Provide Application Monitoring and Management Support – The Contractor shall monitor FSA applications current health and ensure monitoring mechanisms are optimized to best monitor application health and continously improve monitoring by means of working with the designated data center provider on improvements and improving monitoring in areas identified in the Statement of Work (e.g., manage inbound transactions in real time, and route transactions to most optimal server).

(5) Provide Disaster Recovery and Continuity of Services – Support recovery and continuity of operations during a disaster event.

(6) Support Surveilland and Oversight – The ITA and ESB programs are subjects to various ongoing procedural reviews that are re-ocurring or the result of planned changes that will be implemented or led by the ITA and ESB Contractor, such as infrastructure and environment changes. The Contractor is required to participate in all these reviews and comply with all review requirements. The ITA and ESB programs are also subject to audits initiated by interal and external entities (e.g, the Government Accountability Office and the Inspector General); the ITA and ESB Contractor is required to participate and provide all requested information timely.

(7) Provide Management Support – The Contractor is required to maintain project management plans that comply with FSA standards and must provide various reporting regarding its ongoing operations. The

Contractor is also required to participate in FSA’s change management process regarding Change Requests, which is a process for planning and implemeting various changes to FSA appliations and systems.

(8) Operate, Maintain, and Evolve Products, Technologies, Components, and Services – The Contractor is required to maintain, including technolgy refreshment, existing ITA and ESB products and tools to various standards, including n-1 upgrades, and database management. The Contractor is also required to support security testing and resolution of security incidents and findings.

(9) FSA Application and Integration Support – The Contractor shall assist FSA application owners in integrating their applications with ITA and ESB applications, including providing customized APIs, consultive support, troubleshooting of integrations, and appropriate configurations.

(10) PEPS and eAPP Application Support (ITA SOW Only) – The Contractor shall support the upgrading, migrating, and hosting of the PEPS and eAPP applications, which are applications that will use a custom architecture (Oracle Fusion).

Impact Should this Extension Not Be Granted (Rationale for Unusual and Compelling Urgency of Need) ITA and ESB principally operate and maintain commercial products and tools, which are made available to FSA application owners. Currently over 40 applications choose to use ITA and ESB’s products and tools.

Many of these applications are critical applications, including applications that support Federal Student Aid, such as the Free Application for Federal Student Aid (FAFSA). Without having continued support from the ITA and ESB Contractor, these critical applications face significant risks of interruption to services, degradation of services, and security vulnerabilities. Examples of impacts are provided as follows:

• FAFSA and myStudentAid mobile app: ITA provides a dedicated WebSphere environment for hosting the FAFSA application and hundreds of FAFSA APIs and web services, upon which the financial aid application and aid delivery process is fully dependent. This year’s FAFSA rollover occurs on October 1, 2019, which requires hands-on ITA support for deployment, configuration, and troubleshooting. Additionally, the FAFSA peak periods occur in October and March, with as many as 60k applications processed each day. The site is used by millions of applicants. ITA services (e.g., application deployment support, configuration, capacity planning, troubleshooting, and problem resolution) are critical to ensuring the successful launch of the new application cycle, as well as availability and high performance of the FAFSA application. Nearly 19 million students submitted the FAFSA in the 2017– 2018 academic year. Therefore, should the FAFSA and its dependent systems such as the myStudentAid mobile app become unavailable for several months because the ITA Contractor is not available to provide the needed middleware operations and maintenance, causing an outage to the FAFSA and/or myStudentAid mobile app, millions of students will not be able to apply and receive financial aid.

• Enterprise Data Office (EDO), EDMAPS, and Enterprise Architecture (EA): ITA needs to complete the configuration and deployment of the ERWin tool by October 1st in the ITA environment and provide access to FSA users, or multiple FSA teams will be negatively impacted, including the EDO, the EDMAPS, and EA teams. ERWin is the new standard data modeling tool that is replacing the previous ER Studio data modeling tool hosted in the ITA. ERWin is required by EDMAPS to generate the EDMAPS Data Lake and Logical Data Architecture models and required by EA to generate the conceptual and logical enterprise data models. Without the timely completion of ERwin rollout, the EDO, EDMAPS, and EA teams will be unable to meet required deadlines. FSA is expected to provide these enterprise logical data models to the selected EPS vendor in December to provide critical guidance on how data must be structured, secured, and integrated with EDMAPS. The ultimate outcome of utilizing the ERwin tool for the generation of EDMAPS and EA enterprise conceptual and logical data models is to identify and get better insight into Personally Identifiable Information (PII) elements and data across the enterprise, eliminate data security vulnerabilities and risks associated with records stored in multiple systems with inconsistent security parameters, and prevent exposure of PII by providing guidance on the centralization of PII data. Additionally, delays may cause cost impacts to EDMAPS and EA contracts, as well as potentially cause delays and additional costs to DCC as a downstream impact.

• Postsecondary Education Participants System (PEPS): PEPS is in the process of a major re-platforming initiative that requires ITA Contractor support for the successful buildout of the new platform and resolution of any middleware issues. This re-platforming is urgent because the current platform has some significant security vulnerabilities.Without the ITA Contractor’s support, the project will be delayed and the existing security vulnerabilities will exist longer than expected, which increases the overall risk of system outages, degradations of performance, and security vulnerabilities to the PEPS system.

• Digital Customer Care (DCC): The DCC system is in the process of working with the Integrated Student Experience (ISE) team, NSLDS team, and the ITA team to migrate and consolidate content and functionality from ISE and NSLDS, both of which are currently hosted in the ITA, to DCC. ITA’s role is critical to the success of this transition, and without ITA services and support, the transition will be delayed. Additionally, the ESB team is also working closely with the NSLDS team to develop and deliver system interfaces and web services to support the integration of DCC and NSLDS.

Furthermore, the ITA and ESB teams are needed to support several ongoing DCC requirements. As a critical part of the Next Gen FSA effort, DCC requires additional test environments to be built out by ITA and ESB, and if these requirements are not met, DCC testing may not be completed, which may cause additional cost and schedule impacts to the DCC initiative.

• ESB-Specific Impacts: Without ESB services and support, FSA systems will lose critical real-time and batch ESB messaging infrastructure and web services required to retrieve and exchange data across the enterprise. ESB supports system-to-system communications and interactions between AIMS, PAS, FAFSA, FSAIC, and other FSA systems, including Borrower Defense, Central Processing System, FAA Access, SAIG, COD, EDConnect, Enterprise Feedback System, FMS, MSIT, NSLDS, and others. ESB also supports multiple data exchanges between FSA systems and external providers including DHS, SendGrid, and SumoText. ESB manages interfaces for 17+ FSA systems within the NGDC, in the Cloud, and externally, and is responsible for processing millions of file transfers, system-to-system messages, and millions of web service calls. The ESB also supports a number of real-time web service operations and provides more than 300 discrete system-to-system interfaces. Without the ESB Contractor’s support, should any of these interfaces require an update or have problems, FSA will not be able to validate data, the data in a system may no longer be updated, the systems will be out of sync, and users may not be able to be authenticated. ESB also needs to continue ongoing efforts to implement security protections around existing internal and external APIs so that web service calls are only publicly visible and accessible only by authorized users. The impacts of a loss of ESB support will depend on each system that is impacted and the length of the delays. Data provided via these interfaces and web services are used to validate student loan or application data and perform other critical application functions. FSA systems and applications dependent on ESB may experience outages or degradations due to their inability to process various student loan actions or applications for federal student aid. For instance, should ESB interfaces required by the FAFSA application or the myStudentAid mobile app cease to work, the FAFSA application and/or myStudentAid mobile app would not be operational, as the application requires ESB interfaces to operate. Without ESB support for COD system interfaces, if the interfaces cease to work, COD will not be able to process the records for the new award year. Additionally, with COD moving to the cloud, if their ESB system interfaces are not performing optimally, it will impact COD’s ability to process school files and the delivery of aid to millions of students (impacting their ability to receive aid to attend higher education), as well as cause impacts to EDWA reporting.

• Security Vulnerabilities: The ITA and ESB vendor are required to continuously update and configure products to address and resolve security vulnerabilities that are identified through scheduled scans, through vendor announcements, or through NIST/FISMA/EDCIRC, or other mechanisms. Without the ITA and ESB Contractor’s support, the number of security vulnerabilities will increase as they are not resolved, which increases the risk, impact, and severity of security incidents occurring, including loss of PII data, loss of non-PII data, denial of services attacks (which cease an application temporarily), and other security breaches. FSA will be operating at risk when using unsupported software and software that is not being maintained with the latest security patches.

• Outages: During an outage event for an application, the ITA and ESB Contractor are responsible for isolating the problem, identifying the root cause, and leading its resolution. Without the ITA and ESB Contractor support, problem resolution will likely result in longer FSA application and system outages.

In many cases, the outage may not be able to be resolved without the expert technical architecture and engineering support provided by the ITA and ESB Contractor.

SECTION IV: IDENTIFICATION OF THE SINGLE SOURCE SOLICITATION AUTHORITY

This action is being taken under the authority of 41 U.S.C. 1901(e)(2), as implemented by FAR 13.106- 1(b)(1)(i) and FAR 13.501(a).

SECTION V: DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE AUTHORITY

CITED.

In accordance with FAR 13.106-1(b)(1)(i), the circumstances that show that only one source, under unusual and compelling urgency, is reasonably available to meet FSA’s needs are as follows:

FSA is in immediate need of interim services to meet its ITA and ESB requirements for the duration of the current protest before GAO. That protest may be resolved in less than 30 days or may require corrective action after GAO issues its decision as late as January 2, 2020. The precise duration of the need met by this bridge contract cannot be determined.

FSA does not have the internal capabilities or staffing resources to perform the required ITA and ESB middleware and operational support without contractor support.

As the incumbent from the previous contract and current awardee of the two task orders under protest, PPS is the only contractor that can immediately provide FSA with the needed ITA and ESB services for a period of between one and four and half months. PPS is currently in-place and ready to provide immediate services.

PPS is the only Contractor that can immediately provide cleared and qualified staff for the required period of performance. Past experience indicates that it would take approximately three months for a new contractor to recruit staff and complete mandatory Department of Education background investigations for staff assigned to support the ITA and ESB Programs. Further, to properly transition from PPS to a new Contractor, FSA anticipates a two-month transition period would be needed once the staff was recruited and cleared. PPS and the new contractor would need to conduct knowledge-sharing activities, allow existing projects to phase-out or be transferred to the new Contractor, and allow new projects to start timely. In total, the transition period could be up to three months.

Even if there was a contractor willing to compete for a bridge contract with a one-month base period of performance, such a contractor could not possibly begin providing effective services until the second or third option period. FSA’s need is immediate and cannot reasonably wait for two or three months. Further, once the current protest is resolved, FSA will no longer require the interim ITA and ESB services provided by this bridge contract and will procure those services from the ID/IQ contract holder(s). No contractor besides PPS could account for the degree of risk inherent in performing a bridge contract that guarantees only one month of performance yet would require a ramp-up far exceeding one month and still offer FSA a reasonable price. Any contractor besides PPS that attempted to offer a reasonable price would represent an unacceptable performance risk due to its unrealistic pricing.

PPS is the only Contractor available to immediately provide full support for all ITA and ESB tasks for FSA’s minimum requirement of one month of services.

SECTION VI: DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED

FROM AS MANY POTENTIAL SOURCES AS IS PRACTICABLE

As described above only one source can perform the requirements due FSA’s immediate need for a short duration bridge contract. FSA has not solicited from other potential Offerors because they would not be reasonable sources under the circumstances of this procurement.

This requirement is proceeding under simplified acquisition procedures and because the circumstances are of unusual and compelling urgency, the pre-award synopsis required by FAR 5.2 will not be publicized as the exception at FAR 5.202(a)(2) applies.

SECTION VII: DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST

TO THE GOVERNMENT WILL BE FAIR AND REASONABLE.

Award to PPS is contingent upon the Contracting Officer’s determination of price reasonableness. The Contracting Officer anticipates evaluating the price for fair and reasonableness by comparing the resultant proposed pricing with current pricing found in the existing task orders for these services that are subject to stop-work orders.

SECTION VIII: MARKET RESEARCH DESCRIPTION

FSA conducted market research as part of the award for award of the EMAS ID/IQ Contract and the ITA and ESB requirements by issuing a Sources Sought Notice and evaluating submissions. FSA’s evaluation determined that multiple small-business vendors can meet FSA’s ITA and ESB requirements. However, that research was conducted in the context of soliciting 5-year EMAS ID/IQ contracts with 5-year option periods, not the current bridge contract. The limiting factor on reasonable offerors is not the nature of the services but the immediate need and uncertain, limited duration of the bridge contract.

SECTION IX. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION

None.

SECTION X: A LISTING OF THE SOURCES, IF ANY THAT EXPRESSED, IN WRITING, AN INTEREST

IN THE ACQUISITION.

None.

SECTION XI: A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR

OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION FOR

SUPPLIES OR SERVICES REQUIRED.

FSA anticipates that the resolution of the protest of the EMAS ID/IQ contract will permit FSA to proceed with the competitively awarded EMAS ID/IQ contracts and related task orders. Future ITA and ESB task orders will be competitively solicited under the EMAS ID/IQ contract.

SECTION XII: TECHNICAL OR REQUIREMENTS PERSONNEL CERTIFICATION

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Name Signature Date

SECTION XIII: ACQUISITION OFFICIAL APPROVAL

I certify that this justification is accurate and complete to the best of my knowledge and belief. Based on the facts and findings described herein, I hereby approve the strategy to negotiate a contract award on a sole-source basis with PPS InfoTech LLC.

Name Signature Date