273FCC20F0166-P00007 Limited Source Justification_posted.pdf

Federal Communications Commission Enterprise Acquisition Center

LIMITED-SOURCES JUSTIFICATION FOR FEDERAL SUPPLY SCHEDULE PROGRAM

IN ACCORDANCE WITH FEDERAL ACQUISITION REGULATION (FAR) 8.405-6

IP CTS URD Upgrades

273FCC20F0166/ 47QRAA18D00FA

FAR 8.405-6(a)(1)(i)(C) (“In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures.”)

This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C.

152(3), et seq. and 40 U.S.C. 501).

1. Identification of the agency and the contracting activity.

This Limited-Sources Justification (LSJ) was prepared by the Federal Communications Commission (“FCC” or “Commission”), Office of Managing Director, Enterprise Acquisition Center, located at 45 L Street NE, Washington DC 20554, with the assistance of FCC’s Office of Managing Director, Financial Operations (the “requiring activity” or “Bureau”).

2. Nature and/or description of the action being approved.

Contract 273FCC20F0166/47QRAA18D00FA modification P0008 authorizes the development, training, testing, and implementation of an Application Programming Interface (API) as a companion to the web based User Registration Database (URD) application for use by both the Video Relay Service (VRS) and Internet Protocol Captioned Telephone Service (IP CTS) providers for and eligible users of the IP-CTS User Registration URD. This modification also authorizes the improvement of process for manual verification of failed user registrations.

3. A complete description of the supplies and/or services required to meet the agency’s needs.

This request is for enhanced IP CTS URD functionality and the improvement of process for manual verification of failed user registrations. This is a follow-on, firm fixed price action.

This involves re-engineering the URD process by developing and deploying a secure web-based application for use by the service providers for registration purposes. The front-end web application offers registration and maintenance features as well as providing an administrative view for Rolka Loube staff.

Additionally, the contractor will develop an API, which the providers may tap into to pass data directly from their own systems and repositories into the URD and receive responses programmatically. Rolka Loube needs to migrate from Lexis Nexis to TransUnion as Lexis Nexis no longer wanted to provide the service. With the switch to TransUnion as the third-party identity provider, the verification process (Provider to Rolka Loube to TransUnion and back to the Provider) will be shortened to be near real-time processing for those individuals that can be verified without risk codes. The components for these changes are:

• Development and deployment of an external API to enable automation and seamless integration of provider systems with the URD.

the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures.”). The services requested are a logical follow-on as they continue work begun under the current contract and performed under CLIN 2005 and adds services that need to be integrated with the current VRS and IP CTS systems. This change is in scope as it could be reasonably anticipated at the time of award that the database may need to be updated due to changes in technology and the needs of the users. Additionally, changes required due to new FCC rulings are reasonably anticipated at the time of award. Finally, the total amount of the change is less than 12% of the total value of the order and there is no material difference between the services being added by this modification and the services at the time of award.

IP-CTS annual payments to providers are approximately $1 billion from a fund that makes total annual payments of approximately $1.3 billion. The incumbent has created a similar database for video relay services. Audits of that database revealed that thirty percent of registrants were problematic. IP-CTS is a significantly larger program that poses similar risks to video relay service; accordingly, there are exigencies requiring accelerated action to create an IP-CTS user registration database. As with the video relay service database, it will provide quicker approval of applicants and will enable providers to ping the database prior to putting calls through to ensure that the call is eligible for compensation. The contractor is uniquely knowledgeable of both the service and the detailed work of creating, testing, training and implementing user registration databases for the telecommunications relay program.

Another Contractor would not be able to integrate into the current systems without a complete overhaul of the system. The FCC must complete this action limiting sources because, otherwise, delays, interruptions, and risks to fund administration would grievously impair the TRS program. The growth in the use of the current systems has led to the need for new more robust systems to handle the growth in the user volume.

The modification is to create a user registration database so that providers and the administrator can ensure that users are properly registered. The size of the affected TRS function has increased by 25% over the past 2 years. A recent audit disclosed significant errors in registrations, for example 800 deceased people using the system. The modification will also enable the FCC Enforcement Bureau and Inspector General to have direct access and the ability to operate the data in a relational database. The data is now too large to continue the existing process of transmitting data. The current methods do not allow simple manipulation of the data which will be possible with the modification. The FCC Enforcement Bureau, which has recovered millions of dollars in investigations, has requested the need for this type of access to the data, particularly as the volume of information has grown since contract award. The audit highlighted the need for a new database with modern controls and one that can handle the growth in use of the system. Therefore, the additional services are a logical follow on to enhance the current contract services in response to increased use of the VRS and IP CTS systems.

5. A determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d) and FAR 8.405-2(d).

After reviewing the proposal, and comparing the effort to that approved for the video relay services database, it has been determined that the proposal represents a reasonable total price and is the best value for the Commission.

As the pricing represents a discount off GSA labor rates, which were determined to be fair and reasonable at the time of award, the price for this order is determined to be fair and reasonable. The CO and COR have reviewed the labor categories and number of hours proposed for this modification and have determined those to be reasonable. Therefore, as the number of hours, types of labor proposed, and hourly labor rates are reasonable the overall proposed price is determined to be fair and reasonable.