NSC_-_FAR_13.106(b)_Sole_Source_Justification_for_Acquisitions_under_the_SAT_(TSF_1009)_redact.pdf

FAR 13.106(b) SOLE SOURCE JUSTIFICATION FOR

ACQUISITIONS UNDER THE SIMPLIFIED ACQUISITION THRESHOLD

Treasury Standard Form – 1009 (Rev 10/16)

Prescribed by Treasury: DTAP 1013.106(b)

A. FINDINGS.

1. Identification of the requesting and contracting activity.

Economics Department

2.a A description of the supplies or services required to meet the agency’s needs.

Requirements of the data include:

Individual-Level Data on Post-Secondary Enrollment and Degrees

The OCC has a requirement for individual-level data on post-secondary enrollment and post-secondary credentials that it shall be linkable to the OCC’s existing consumer-level dataset provided by a national credit bureau. Other requirements on the individual-level data on post-secondary enrollment and post-secondary credentials include:

- National coverage (for sufficient sample size post-merge with OCC’s Equifax Consumer

Credit Panel (CCP) dataset and for analysis of a sample that is nationally representative)

- Coverage in excess of 80% of post-secondary enrollees during the 2005-2017 period covered by the OCC’s Equifax Consumer Credit Panel (CCP) dataset (for adequate separation between those without post-secondary enrollment and those with post-secondary enrollment in our nationally representative analyses)

- Coverage in excess of 80% of degrees awarded during the 2005-2017 period covered by the

OCC’s Equifax Consumer Credit Panel (CCP) dataset (for adequate separation between degree earners and college drop-outs)

- Data on degree major (to be able to closely mimic the information leveraged by Fintech firms in their credit decisions)

2.b Name of the Vendor. National Student Clearinghouse (NSC) 2.c Requisition No. 2921

3. Estimated dollar value of the acquisition.

4.a Identification of the circumstances that preclude competition (Check the appropriate box that applies).

Urgency.

Exclusive licensing agreements.

Brand-name.

Industrial mobilization.

X Other: Only one responsible source 4.b Supporting information and facts (i.e. the details surrounding the requirement that supports the selection made in 4.a).

National Student Clearinghouse (NSC) is the only organization/vendor that has data that a) is national in coverage, b) covers the enrollment and degrees of those with student loans and those without, and c) has demonstrated an ability to reach agreements with two out of three national credit bureaus to deliver educational data that is linkable to the bureau datasets held

Prescribed by Treasury: DTAP 1013.106(b) by governmental agencies. The only other database somewhat close in coverage to the NSC database is held by the Department of Education, Office of Federal Student Aid (FSA).

Although FSA possesses fairly extensive individual-level enrollment data, their information is limited to enrollees with federal student loans, and their data would be blind to the post-secondary enrollment and the post-secondary degrees/credentials earned by those who did not take federal student loans. Thus, the lack of coverage of post-secondary enrollees without federal student loans by the FSA’s data would result in coverage of at most 70% of post-secondary enrollees, which would prevent the OCC from analyzing research topics that are critical to its mission. Further, NSC has reached agreements with two out of three national credit bureaus to deliver educational data that is linkable to the bureau datasets held by governmental agencies. One of the two national credit bureaus provides the educational data in the OCC’s existing credit bureau dataset.

5. Any other information.

B. Certifications and Approvals.

6.a Program Office Certification (Requiring Activity). I hereby certify that the supporting information and data provided and which form the basis for this justification are accurate and complete to the best of my knowledge and belief.

Name: Date:

Signature:

6.b Small Business Specialist Determination (Contracting Activity) [applicable only if the vendor is not a small business]. I have reviewed this justification for an exception to competition, including any attached documentation, if applicable, and concur / do not concur with the findings.

6.c Contracting Officer Approval. In accordance with FAR 13.106-1(b)(1), as a warranted contracting officer, I hereby determine that the circumstances of the acquisition make only one source reasonably available for the reasons indicated above; therefore precluding competition and supporting the Government’s determination to solicit and award to the vendor stated herein.

https://www.acquisition.gov/?q=/browse/far/13

FAR 13.106(b) SOLE SOURCE JUSTIFICATION FOR

ACQUISITIONS UNDER THE SIMPLIFIED ACQUISITION THRESHOLD

Prescribed by Treasury: DTAP 1013.106(b)

Instructions for FAR 13.106(b) Sole Source Justification for Acquisitions under the Simplified Acquisition Threshold

A sole source justification is a stand-alone document. Simply copying and pasting information from a vendor’s website or marketing literature fails to support the use of such justification. The sole source justification shall be completed by the requiring activity to extent practical with assistance provided by the contracting office.

A. FINDINGS.

Section 1 Identification of the agency and the contracting activity. Provide the name of requiring agency and the name of the actual requiring activity (e.g. Treasury’s Washington, DC Office – Central IT Division). Provide the name of the contracting agency and the name of the actual contracting activity (e.g. Treasury’s West Virginia Office – Contracting Division for IT).

Section 2.a A description of the supplies or services required to meet the agency’s needs.

Provide a clear, concise description of the supplies or services to be procured. Include a statement regarding the delivery schedule and/or the period of performance, inclusive of all option periods and award terms. State the schedule and associated schedule category(ies) the supplies or services are being procured against. For supplies, include details such quantity and a brief description of the items (e.g. twelve (12) laptops).

For brand name, provide the name of the brand, model number and other specific details associated with the brand name item(s) being procured; name(s) of known sources that can provide the brand name.

Section 2.b Name of Vendor. Insert the name of vendor to whom the award will be made out to.

Information can be obtained from the SAM database.

Section 2.c Requisition Number. If known, include the requisition number.

Section 3 Estimated dollar value of the acquisition. Provide the estimated dollar value of the acquisition, inclusive of all options, award terms and any other monetary incentives. However, if brand name then this dollar value reflects the total estimated dollar value of the portion of the proposed acquisition, inclusive of all options, award terms and other monetary incentives, that is brand name, only.

Section 4.a Identification of the circumstances that preclude competition. Check the applicable circumstance of the contract action that deems only one source reasonably available (see FAR 13.106-1(b)).

Section 4.b Supporting information and facts (i.e. the details surrounding the requirement that supports the selection made in 4.a). The rationale for the sole source must be thoroughly explained within this section. Explain why the vendor is the only one that can provide the product or service if using only one source (e.g. urgency, industrial mobilization, a patent, copyright, proprietary data, or exclusive licensing agreement). If brand name, provide sufficient

Prescribed by Treasury: DTAP 1013.106(b) detail to describe the rationale for the brand name. For example, Why is this particular brand name needed? Why won’t another brand of product work? If urgency, explain what harm, monetary or schedule wise, (and include dollars that would be lost, time lost, etc.) that will result if an aware is not made to this vendor by a certain date.

Section 5 Additional information. Include, as applicable, any other information that might support this sole source justification.

B. Certifications and Approvals Section 6. Obtain the Requiring Activity’s, Small Business Specialist’s and Contracting Officer’s signatures as indicated. See DTAP 1004.7004(a) & (b).