21Q0064-JustificationSigned.pdf

JUSTIFICATION

Bureau Enhanced Acquisition Management System

Source Selection Sensitive in accordance with FAR 2.101 and FAR 3.104.

Procurement ID: ePRO-2021- 13887

BEAMS User Guide BEAMS Feedback

SUMMARY

Procurement Title:

Compensation Reform Support (Negotiations)

Program Office:

Operations: Human Capital

Contracting Officer:

Del Toro, Vanessa (CFPB)

Contract Specialist:

Fils, Nicole (CFPB)

Acquisition Strategy:

Sole Source - SAT or over

Anticipated Award Date: Base and All Options Value:

$602,742.80 (Total Contract Value)

BR Total Amount:

$0.00

Type Of Action:

New Contract/Agreement

Bureau:

CFPB

Contract Type:

Labor Hour

Contract Number:

GS-00F-290CA

Is it Sole Source?

Yes No

FAR Reference:

8.405-6(a(1)(i)(C) – The new work is a logical follow on to an original FSS order or BPA, and the order or BPA was placed in

PERIOD OF PERFORMANCE

Base Period (Months):

Number of Option Periods:

COSTS Note: the Base Amount(s) do not update from the Buy Request after the first time they are copied.

If the Base Amount in the BR changes, you may need to manually update it here.

Life-Cycle Estimated Total:

$602,742.80 Base (From Buy Request 1):

$125,314 Note: You may over-ride the base amount(s).

Base (From Buy Request 2):

$477,428.8 If the background color is yellow, the amount does not match the Buy Request.

FAR 8.4

JUSTIFICATION AND APPROVAL

FOR LIMITED SOURCES UNDER THE FEDERAL SUPPLY SCHEDULE PROGRAM

This Limited Source Justification has been prepared in accordance with Federal Acquisition Regulation (FAR) 8.405-6, Limited Sources, and CFPB-COO-Proc-02-2017, Contract and Legal Reviews, Policy and Procedures.

FSS Contract Number:

Nature/Description of Action: This action is being conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C. 251, et seq. and 40 U.S.C. 501). This is a limited source action proposed for award.

Type of Action:

New Contract/Agreement

Contract Type:

Labor Hour

Description of Supplies/Services:

Display Acq Plan Statement of Need In January 2021, CFPB and its union, the National Treasury Employees Union (NTEU), entered a new 3-year Compensation Agreement. The parties agreed to move ahead with reforming the Bureau's compensation program via a two-phase Bureau-wide review and reset of employee salaries. Part one involves collecting and crediting the work experience of all Bureau staff. This will be completed around October 1, 2021. The details for part two – the reset of employee salaries – will be determined via bargaining when CFPB and NTEU resume negotiations sometime in October 2021 to address pay band structure and new pay setting procedures. The Bureau procured vendor support to help prepare for and conduct the first round of negotiations. The Bureau, through the Office of Human Capital (OHC), is seeking additional support to help prepare for and conduct the next round of negotiations, expected to begin in October. We expect that support for the next round of negotiations will be very similar in nature to the support provided during the previous round of negotiations. Ernt and Young has been providing support and is sought to continue to provide support to assist the Bureau with the negotiating of compensation program changes with the Bureau's bargaining unit begining in September 2021. This is a continuation of negotiations and vendor provided support, and is required to close out this initiative. Current support is under a BPA Call which cannot be extended as the BPA has expired.

Identification of the Justification Rationale:

8.405-6(a(1)(i)(C) – The new work is a logical follow on to an original FSS order or BPA, and the order or BPA was placed in accordance with FSS procedures and must not have been issued under sole source or limited sources procedures

GS-00F-290CA

The Bureau currently requires a bridge contractlogical follow-on task order with an estimated five (5) month base period of performance to assist the Bureau in preparing for and conducting labor-management negotiations, and to support negotiated changes to the compensation program. These negotiations were previously postponed and reschedules several times. They will not happen before the current task order expires on August 27, 2021. The parties (CFPB and NTEU) agreed to move ahead with compensation reform via a two-phase Bureau-wide review and reset of employee salaries. Part one involves collecting and crediting the work experience of all Bureau staff; that will take place between now and September. The details for part two – the reset of employee salaries – will be determined via bargaining when the parties resume negotiations regarding pay band structure and related pay setting matters. These negotiations were initially scheduled for April, but the union was not ready and asked to delay bargaining until September. Management agreed. EY’s support is critical to help the agency effectively prepare for and conduct these negotiations when they resume in September, thus the sole source contract.

Demonstration of Contractor’s Unique Qualifications:

Description of Market Research and Results:

Display Acq Plan Market Research

Determination of Best Value: GSA has already determined the prices of the schedule contracts are fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing.

Does the order contain a brand name specification?

Yes No

Is an exception permitted by FAR 8.405-6(b)(3)(ii)?

Yes No

Please attach RFQ eBuy Posting No file attached

Actions Taken to Remove or Overcome Barriers to Competition:

CERTIFICATION

Technical/Requirements Official: I certify that the facts and representations under my cognizance, which are included in this justification and which form a basis for this justification, are complete and accurate.

Contracting Officer: Using the procedures in FAR 8.404(d) and 8.405-2(d), I certify that the above referenced BPA or order represents the best value and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government’s needs.

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

REVIEWS AND APPROVALS

Senior Program Official(or designee): I concur that the facts and representations under my cognizance, which are included in this justification and which form a basis for it, are complete and accurate.

Competition Advocate: I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

SIGNATURES Contract and Legal Reviews Policy

Person Decision Approved Date and Time

Senior Program Official (Only applicable under FAR 8.4)

ApproveSumberg, Jeffrey (CFPB)

Technical/Requirements Official Approve

Contracting Officer

ApproveDel Toro, Vanessa (CFPB)

Competition Advocate

ApproveColeman, CC (CFPB)

Head of Contracting Activity Approve

EY has the subject matter expertise required as EY has been supporting the Bureau sine 2019 on the agency’s effort to overhaul its compensation program. This is CFPB’s most important workplace change initiative and is aimed at fostering internal pay equity; supporting fair and effective pay setting practices; and improving transparency regarding how the Bureau sets pay. Therefore, there is a need to award a logical follow-on task order contract consisting of a four (4) month base period to EY.

The follow-on task order will be to receive support for the ongoing compensation negotiations. it will be for five months and after negotiations conclude, any subsequent support for OHC will be competed.

8/6/2021 3:58:06 PM

8/6/2021 3:11:03 PM

8/6/2021 5:11:25 PM

Senior Procurement Executive Approve

Justification Signature History Stamp

Source Selection Sensitive in accordance with FAR 2.101 and FAR 3.104.

STATUS

Pre-Solicitation Review

NOTES Flag for Review

Notes captured in this common space facilitate communication between all Stakeholders in this Procurement.

Please specify which tab your note is about Created By Date and Time

Acq PlanAcq Plan

Acq PlanAcq Plan Jennifer Horan

HISTORY

Created By:

Jacob, Roland (CFPB)

Creation Date:

6/28/2021

Creation Time:

7:59:56 PM

Last Modified By:

Coleman, CC (CFPB)

Last Modified Date:

8/6/2021

Last Modified Time:

5:16:31 PM

Office of the Chief Procurement Officer Operations Division

Consumer Financial Protection Bureau

||Competition Advocate Coleman, CC (CFPB)has Approved 2021-08-06T17:11:25 ||Senior Program Official Sumberg, Jeffrey (CFPB)has Approved 2021-08-06T15:58:06 ||CO Del Toro, Vanessa (CFPB)has Approved 2021-08-06T15:11:03 ||||||

Please ensure that the vendor understands how to create 508 compliant documents for delivery to

CFPB

6/29/2021

4:33:54 PM