I_4 SF 1014 IRA PMO JEFO_Redacted.pdf

DEPARTMENT OF THE TREASURY

SF 1014 - JUSTIFICATION FOR AN EXCEPTION

TO FAIR OPPORTUNITY

Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505

1. Identification of the requiring activity and the contracting activity:

Requiring Activity: Internal Revenue Service, Information Technology, ACIO for Modernization Contracting Activity: Internal Revenue Service, Office of the Chief Procurement Officer (OCPO), OBSA, Contract Support, Studies and Analysis Branch 2.a Nature and/or description of the action being approved:

The Office of Online Services (OLS) was established to improve the Taxpayer Experience which is specifically emphasized as the transformative focus of the Inflation Reduction Act (IRA). As part of the IRA support, OLS has the responsibility to lead Initiative 1.4 to Improve Self-Service Options which includes leading business transformation towards digital government and developing consistent, enterprise-wide web service options.

This responsibility includes support for Individual Online Account, Business Tax Account, Tax Pro Account, and IRS.gov and support to new business objectives that have been identified in the IRA Strategic Operating Plan. As such, OLS has an urgent and compelling need to pursue the award of a sole source firm- fixed-price contract with LightFeather to meet the critical requirements as dictated in IRA for Analytics support related to Initiative 1.4. The development work is currently underway and an Analytics capability is critical to the successful deployment of capability.

The passage of IRA represents a mission-critical need for OLS Analytics contractor support while OLS works to hire Federal staff to provide these services over the long term. The support from LightFeather is required to avoid the risk of failed product and service delivery to the taxpayer which would lead to noncompliance with the IRA SOP and legislation. The need date for this support is immediate for a period of 6 months with an additional 6 month option.

The acquisition will result in the award of a 12-month task order with a 6-month base and 6-month option period using the GSA MAS vehicle to LightFeather.

2.b Name of the vendor.

2.c Requisition No.: 5 0 0 0 1 8 2 6 9 9 2.d Bridge contract: Yes No 2.e Brand name: Yes No 3.a A description of the supplies or services required to meet the agency’s needs:

The scope of work will enable OLS to obtain a skillful contract staff able to supply fast-paced knowledgeable recommendations, commercial industry proficiency and guidance to support Service-wide requirements and the following OLS goals:

Use analytics and research capabilities to:

• Deliver clear and focused communication to ensure success across products, channels, and organizations.

• Focus on digital customer service requirements to support the taxpayer, partner and

IRS business needs, preferences, and compliance behaviors to facilitate voluntary compliance.

The acquisition will result in the award of a 12-month task order with a 6-month base and 6-month option period

TO FAIR OPPORTUNITY

Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505

3.b Includes IT: Yes No PSC: DF01 NAICS Code: 541511

3.c IGCE/Estimated dollar value:

4.a Identification of the exception to fair opportunity being used:

FAR 16.505(b)(2)(i)(A) – The agency need for the supplies or services is so urgent and compelling that providing a fair opportunity would result in unacceptable delays.

4.b Supporting rationale:

This contract is necessary to provide critical analytics support to OLS for its Inflation Reduction Act (IRA) responsibilities under Initiative 1.4. It functions as a gap-filler to cover the timeframe in the hiring of Federal personnel, which is expected to last at least another six months due to the extensive timeframe related hiring Federal staff external to IRS.

LightFeather has an IRS contract not related to this work but is already working to clear personnel through the MBI process. In addition, the company has extensive experience in the following:

Leveraging AI and machine learning to extract insights from data, enabling smarter data-driven decisions which translates complex data into clear, predictive models, driving innovation and competitive advantage.

Using advanced analytic reporting and interactive dashboards to transform data into visual narratives, making complex information understandable. We empower stakeholders to swiftly grasp key insights, enabling informed decision-making.

Enhancing user value in digital products by tailoring analytic results to enhance user experience in digital products including web and mobile apps, improving engagement and satisfaction.

We service improvement for digital products by utilizing advanced analytics to significantly improve service quality of digital products, enhancing user experience and performance, contributing to growth and satisfaction.

Additionally, the subject acquisition requires:

Cleared Personnel: IRS onboarding can take more than 4 months for needed MBIs to occur and an additional 3 months is needed for knowledge transfer for a minimum transition period of 7 months.

LightFeather does not require this time to meet the deadline which is fast approaching.

Importance of Response to Inflation Reduction Act of 2022 As noted above, responding to the Inflation Reduction Act of 2022 is of the utmost importance to both the Agency and to Congress. As such, an urgent and compelling sole source bridge contract is necessary to avoid a critical work stoppage and allow the IRS to meet key milestones mandated by Congress. Failure to respond to the IRA requirements and deliver services in the expedited manner called for by IRA, will create an outsized risk to transforming taxpayer services and improving the taxpayer experience. Similarly, any delay represents an outsize risk to meeting IRS requirements such the acceleration and expansion of vital taxpayer services including scanning by filing season; allowing online responses to taxpayer notices;

expansion of customer call back for taxpayers; and other modernization capabilities in the transformation portfolio. These are the goals and mission of the IRA funding and multiple services are needed immediately and must be delivered in the first half of FY23. The Agency would be unable to meet the ambitious goals dictated by Congress as it would take over six-months, but closer to 12-months to competitively award a contract. After competitive award, it would take a minimum of six months to get a new contractor up to speed and complete the necessary background investigations. This delay is unacceptable, and the Government has an urgent and compelling need which must be met as there cannot be a break to delivering these vital services.

TO FAIR OPPORTUNITY

Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505

5. A determination that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer will determine that the anticipated price(s) will be fair and reasonable based on comparing prices/costs with prior and similar task orders issued.

6.a Any other facts supporting this justification: Yes 6.b Attachments: Yes No (See attachment 1 and 2)

7. A statement of the actions, if any, the Requiring Activity and Contracting Activity may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies and services is made: The Government will periodically recheck the marketplace and consult with the Small Business Advocate to determine if additional sources for these services have experience testing in the IRS environment.

8. Certifications and Approvals:

8.a Program Office Certification (Requiring Activity). I hereby certify that any supporting information and data provided (e.g., the Government’s minimum needs or requirements, or other rationale for the limited sources) and which form the basis for this justification for an exception to fair opportunity, are accurate and complete to the best of my knowledge and belief.

Name: Date:

Signatur

8.b Contracting Officer Certification and Approval. I certify this justification for an exception to fair opportunity is accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the authorized contracting officer for this acquisition, I hereby approve the processing of this requirement based on the authority specified in 4.a above.

Name: Date:

Signature:

TO FAIR OPPORTUNITY

Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505

9.a Bureau Chief Information Officer or Authorized Designee (for IT requirements that are over $5 million, but not exceeding $68 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification. (Note: The Bureau CIO may delegate their authority for proposed contracts over $5 million, but not exceeding $13.5 million to the Associate Bureau CIO(s).)

Name: Date:

Signature:

9.b Advocate for Competition (if over $700,000, but not exceeding $13.5 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the ordering activity’s Advocate for competition, I hereby approve this justification based on the authority specified in 4.a above.

Name: Date:

Signature:

9.c Head of the Procuring Activity or Authorized Designee (if over $13.5 million, but not exceeding $68 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity and find it to be accurate and complete to the best of my knowledge and belief.

Therefore, unless additional approvals are required as prescribed below, as the head of the procuring activity or authorized designee, I hereby approve this justification based on the authority specified in 4.a above.

Name: Date:

Signature:

Project Title: OLS IRA Support– Analytics