JOFOC for Culture Baseline Assessment_FINAL_Signed_02-13-2020.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

Version Control Date: October 7, 2015

Date: January 11, 2020

MEMORANDUM TO: Jennifer Dudek, Contracting Officer Operations Branch B Acquisition Management Division

Office of Administration

FROM: Greg Oberson, Contracting Officer Representative

Office of the Executive Director for Operations

SUBJECT: ☒ JUSTIFICATION FOR OTHER THAN FULL AND OPEN

COMPETITION (JOFOC)

REFERENCE: Support for U.S. Nuclear Regulatory Commission Agency-wide

Culture Assessment

“Source Selection Information – see FAR 2.101 and 3.104”

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

a. Acquisition purpose and objectives.

The purpose of this acquisition is to procure a vendor with expertise to assist the U.S. Nuclear Regulatory Commission (NRC) in the development, administration, and analysis of agency-wide organizational culture survey. The survey shall systematically assess a current baseline of behaviors and norms and compare those with a desired end state, so as to identify opportunities and challenges in the context of transformation to a modern, risk-informed regulatory.

b. Project background.

In a briefing to the Commission on October 29, 2019, NRC’s Executive Director for Operations (EDO), Margie Doane, discussed aspects of NRC’s transformation into a modern, risk-informed regulator. As one initiative to support the broader transformation effort, the EDO described fostering a culture of change. She referred to culture as “…shared organizational values, assumptions, beliefs, and behaviors that provide signals about what is accepted and what is expected of our employees.”

The EDO continued to say that “…efforts in this area are focused on how we should lead during times of change to enable trust, eliminate fear of change, and encourage thinking big across all of the Agency. It includes holding ourselves accountable for meeting our mission, leading by example, meeting milestones that we set for ourselves for transformation.” NRC has determined that outside expertise is required to establish rigorous and analytically sound methodologies for assessing the agency culture, and to formulate measurable indicators of progress for a cultural transformation.

c. Name and address of the proposed contractor(s).

Human Synergistics International 148 Randhurst Village Drive Suite 200 Mount Prospect, IL 60056

2. Description of the supplies or services required to meet the agency’s needs.

a. Project title.

Support for U.S. Nuclear Regulatory Commission Agency-wide Culture Assessment

b. Project description.

There are three key elements to this contract:

(1) The contractor shall provide necessary support for staff to administer an online survey of approximately 1,200 NRC employees. The survey shall assess the NRC’s current operating culture and climate as well as the ideal culture as measured by the Organizational Culture Inventory (OCI®), the OCI®-Ideal, and/or the Organizational Effectiveness Inventory (OEI®). The support shall include, but not be limited to, project management, survey readiness, survey administration, and analysis of survey results. An optional resurvey may be conducted within one to two years of the initial survey.

(2) The contractor shall assist NRC staff with the development of improvement planning coaching that will include email support, qualitative instruction examples, results debrief templates, and an onsite executive debrief and improvement plan.

(3) The contractor shall provide training necessary for accreditation of two NRC staff to facilitate the Human Synergistics Culture Journey Experience.

c. Acquisition Information.

• Requirement type.

☐ Research & development (R&D) ☐ R&D support services ☒ Support services (non-R&D) ☐ Supplies/equipment ☐ Information Technology (IT) or Electronic and Information Technology

(EIT)

☐ Construction ☐ Architect-engineer (A-E) services ☐ Design-build ☐ Other (specify): ____________________

• Type of action.

☒ New requirement ☐ Follow-on ☐ Other (specify): ______________________

• Proposed contract/order type.

☒ Firm-fixed-price ☐ Other fixed-price (specify, e.g., fixed-price award-fee, fixed-price incentive-fee): __________ ☐ Cost-plus-fixed-fee ☐ Other cost reimbursement (specify, e.g., cost-plus-award-fee, cost-plus-incentive-fee): ___________ ☐ Time and materials ☐ Labor Hours ☐ Indefinite delivery (specify whether indefinite quantity, definite quantity, or requirements): ___________

• Statement of Work Type ☒ Completion ☐ Level of Effort ☐ Performance Based

• Requisition number.

NRR-20-0049

• Total estimated dollar value and performance/delivery period.

The total estimated dollar value of the acquisition is $119,965.00 and the period of performance is thirty-six (36) months.

3. Identification of the justification rationale.

☐ This acquisition is conducted under Federal Acquisition Regulation (FAR) 8.405-6.

☐ Urgent and compelling need exists ☐ Only one source is capable of providing the supplies or services

(i.e., peculiar item, brand name item) ☐ Logical follow-on

☒ This acquisition is conducted under FAR 13.106-1(b).

☐ This acquisition is conducted under FAR 6.302- __.

☐ 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements ☐ 6.302-2 Unusual and compelling urgency ☐ 6.302-3 Industrial mobilization; engineering, developmental, or research capability; or expert services ☐ 6.302-4 International agreement ☐ 6.302-5 Authorized or required by statute ☐ 6.302-6 National security ☐ 6.302-7 Public interest

☐ This acquisition is conducted using Simplified Procedures for Certain Commercial Items pursuant to FAR 13.500.

☐ This acquisition is conducted using Simplified Procedures for Certain Commercial Items pursuant to FAR 13.500(c).

4. Description of the proposed contractor(s) unique qualifications to provide the required supply or service.

The services provided by Human Synergistics International are necessary for NRC to conduct the type of organizational culture assessments that will support the agency transformation vision. Particularly, the assessment tool must rigorously, and with statistical validity, measure both the current organizational culture and the ideal end-state culture, such that a practitioner can analyze gaps between the two.

Organizational health survey instruments may be distinguished as those that measure organizational climate and those that measure organizational culture. An organizational climate survey has some similarities to the Federal Employees Viewpoint Survey, in that it generally characterizes what people think about how the organization functions at a given point in time. An organizational culture survey is meaningfully different than an organizational climate survey and encompasses the implicit or explicitly communicated norms that influence the behaviors of members of the organization. As it relates to the agency transformation, assessing the organizational culture, as opposed to the climate, is critical, so as to identify and address the underlying issues that could cause resistance to change.

A review of organizational heath survey instruments on the market by NRC subject matter experts identified that Human Synergistics International is the only vendor that provides the requisite type of organizational culture survey instruments.

The Human Synergistics survey instruments have the following unique attributes:

• Proprietary question sets that elicits meaningful data on organizational culture and behavioral norms, rather than just organizational climate.

• Validated methodologies to correlate survey responses to specific aspects of organizational culture.

• A repository of many thousands of prior survey results from other organizations, so as to allow comparisons and benchmarking of the NRC survey results.

• Integration with a holistic culture change framework that translates survey findings into actionable recommendations at both an individual employee and organization-wide level.

• Statistically meaningful repeatability, to allow periodic resurveys that will measures cultural shifts over time.

• Allows accreditation for NRC staff to conduct resurveys.

These attributes are, collectively, necessary to meet NRC’s requirements for an agency culture assessment and cannot be replicated by another vendor or combination of vendors.

5. Description of the efforts made to ensure that offers are solicited from as many potential sources as practicable. Indicate whether a FedBizOpps notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies.

The COR conducted market research to identify other potential organizational culture assessments and found none that would fully meet NRC’s needs. A Senior Organizational Development Specialist in the NRC’s Office of the Chief Human Capital Officer assisted the COR and also concluded that Human Synergistics International is the only source for the required services.

No other known sources exist that meet NRC’s requirements for a true culture baseline assessment. A notice of intent was posted on the betaSAM.gov website on December 11, 2019 for 7 calendar days in accordance with FAR 5.203 (i.e., Notice of Intent No.

31310020Q0008). Eight (8) interested parties submitted statement of capabilities. An NRC panel of technical experts reviewed the eight (8) submitted statement of capabilities and concluded that none demonstrated the capability to meet NRC's requirement entitled, "Support for the NRC Agency-wide Culture Assessment.” All eight

(8) interested parties were notified of NRC’s evaluation and determination on January 03, 2020.

https://beta.sam.gov/

6. Description of the efforts made by the Contracting Officer (CO) to determine that the cost/price of the contract/order is fair and reasonable consistent with FAR 8.404(d) or 15.406-2.

In order to determine the proposed price is fair and reasonable, the CO had the offeror provide invoices issued to other entities for similar services. The prices quoted to NRC were determined to be comparable to the prices offered to other entities (i.e., commercial companies). The CO also performed a comparison to the Independent Government Cost Estimate.

7. Description of the market research conducted (see FAR Part 10) and the results, or a statement of the reasons market research was not conducted.

The market research for this requisition was conducted by NRC staff with subject matter expertise in organizational performance and psychology. They reviewed technical literature and identified potential vendors that have provided cultural assessment support to organizations similar to NRC. The capabilities of these vendors were compared to the specific needs of NRC for a baseline assessment to support the transformation vision.

Staff determined that the preponderance of assessments on the market are focused on measuring organizational climate, which is the shared perceptions and attitudes about the organization. Organizational climate can be measured through indices such as employee engagement, satisfaction, motivation, teamwork, clarity of mission, management actions, employee involvement, and benefits.

Human Synergistics, on the other hand, offers the OCI® and OEI®, which provide an integrated diagnostic system for otherwise unmeasured elements of culture that underlie observed behaviors. This is necessary to truly assess the way people approach their work and interact with others. The OCI® and OEI® measure these dimensions and provide a complete picture of culture, beyond the climate perceptions (symptoms) that are often a reflection of the cultural norms (root cause).

Furthermore, the OCI® and OEI® are specifically designed to distinguish between the traditional climate assessments (e.g., employee viewpoint surveys or organizational health/effectiveness surveys that measure individual perceptions and attitudes) and that of organizational culture – the shared beliefs and assumptions about the organization’s expectations and values.

The assessments and all materials associated with the OCI® and OEI® are copyrighted by Human Synergistics and are not available by any resellers or third-party vendors.

8. Other factors supporting the justification, if any.

N/A

9. List sources, if any, that have expressed an interest in the acquisition.

As noted in item 5, eight (8) interested parties submitted statement of capabilities in response to Notice of Intent. An NRC panel of technical experts reviewed the statement of capabilities and concluded that none demonstrated the capability to meet NRC's requirement entitled, "Support for the NRC Agency-wide Culture Assessment.”

10. If applicable, describe the actions the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

N/A

11. Certifications

By signing below, the COR certifies that the justification is accurate and complete to the best of his or her knowledge and belief.

Contracting Officer Representative

Greg Oberson, Contracting Officer Representative Office of the Executive Director for Operations

This is to certify that the justification for the proposed acquisition has been reviewed and that, to the best of my knowledge and belief, the information and/or data provided to support the rationale and recommendation for approval is accurate and complete.

Contracting Officer

Jennifer Dudek, Contracting Officer Operations Branch B Acquisition Management Division