31310023D0003 FAIMIS IDIQ JOFOC Ceiling Increase_Posting.pdf

Version Control Date: October 7, 2015

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

FINANCIAL ACCOUNTING INFORMATION AND MANAGEMENT

INTEGRATED SYSTEM (FAIMIS)

INDEFINITE DELIVERY / INDEFINITE QUANTITY (IDIQ)

CONTRACT 31310023D0003

DATE: 08/28/2023

TO: Louis Gilden, Contracting Officer

FROM: Susan Hayden, Contracting Officer Representative

SUBJECT: JOFOC for Within Scope Ceiling Increase for NRC IDIQ Contract

31310023D0003 FAIMIS

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

a. Acquisition purpose and objectives.

The purpose of this justification is to issue a non-competitive modification to NRC contract 31310023D0003 to increase the existing ceiling by $5,000,000 from $40,000,000 to $45,000,000. A non-competitive modification will allow the NRC to execute task orders for the following requirements which are within the scope of the current IDIQ Statement of Work (SOW):

1) An urgent task order for Fee Billing Engine Development

2) A subsequent Fee Billing Operations and Maintenance Task Order upon the completion of the initial implementation

3) Task order(s) for Implementation of Major FAIMIS Enhancements to Support

Business Process Improvements, FAIMIS Infrastructure Security Support

b. Project background.

The purpose of the FAIMIS IDIQ contract is to obtain hosting, operations and maintenance, help desk, and enhancement support services for NRC’s Financial Accounting Information and Management Integrated System (FAIMIS). CGI Federal, Inc. (CGI) hosts and supports CGI Momentum® for Federal Enterprise Resource Planning (ERP) software that is customized to satisfy the NRC's requirements. The customized system is hosted in an external FedRAMP-compliant cloud environment.

FAIMIS also interfaces with NRC legacy applications as well as Federal e-gov solutions.

The FAIMIS IDIQ contract is a sole source award to CGI with a five-year POP from 2/1/2023 to 1/31/2028. A pre-solicitation notice of intent to sole source, notice ID 31310023R0004, was published on SAM.GOV on 11/4/2022 with responses due by 11/21/2022. The Justification was published on SAM.GOV as well.

The predecessor FAIMIS IDIQ Contract 31310018D0004, with a five-year POP from 2/1/2018-1/31/2023, which NRC also awarded to CGI, had a ceiling of $46,225,760.

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

CGI FEDERAL INC

12601 FAIR LAKES CIRCLE, GWAC SOLUTIONS CENTER

FAIRFAX VA 22033

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

a. Project title.

FAIMIS Support Services

b. Project description.

A non-competitive modification will provide additional ceiling for IDIQ contract 31310023D0003. The additional ceiling will allow NRC to execute additional task orders so that the Contractor can perform follow-on task orders for the critical requirements discussed below.

Fee Billing Engine Implementation and Operations and Maintenance – Task Order Award Imminent The purpose of the Fee Billing Engine requirement is for the Contractor to design, develop, and implement a web-based modular and fully integrated Fee Billing Engine application. The NRC will utilize this solution to simplify, centralize, streamline, and automate Part 170, 171 and General License Tracking System (GLTS) license fee billing activities, accommodate the new Small Modular Reactor fee structure, and implement future changes to license fee billing requirements. The fees that are billed and collected from this process are vital to support the agency’s mission which is the safe and secure oversight of the nation’s nuclear energy and materials. The project will include project management, requirements gathering, design, development, testing, security, training support and operations and maintenance support upon go-live.

Implementation of Major FAIMIS Enhancements to Support Federally Mandated Initiatives and Agency Business Process Improvements - Anticipated Future Task Order As a result of OCFO’s continued business process improvement initiatives, additional out-of-the-box functionality will need to be designed, configured, and tested within the FAIMIS core financial system. The task order’s scope will include but is not limited to requiring the Contractor to use built-in FAIMIS functionality to produce external reports to the Department of Treasury, configuration integrations to external Treasury systems to automate the reconciliation of NRC’s collections and implementing tie point reconciliation within FAIMIS.

FAIMIS Infrastructure Security Support - Anticipated Future Task Order OCFO may require a new task order to support federal government’s evolving Information Technology security requirements such as the logging requirements introduced in the Office of Management and Budget’s (OMB) Memo M-21-31 and the vulnerability remediation requirements in the Cybersecurity and Infrastructure Security Agency (CISA) Binding Operational Directive 22-01 and 23-01. This task order may include requirements gathering, collaboration with the NRC’s Office of the Chief Information Officer to determine the actions that need to be performed on the existing FAIMIS infrastructure, and testing to ensure that the changes have no negative impacts to existing functionality and operations.

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. Check the appropriate box:

☐ New requirement ☐ Follow-on ☒ Other (specify): Non-Competitive contract modification for a ceiling increase for requirements within the scope of the IDIQ contract scope of work

• Proposed contract/order type.

☒ Firm-fixed-price (Hybrid) ☐ 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 ☐ Subscription ☒ Level of Effort ☐ Performance Based

• Requisition number.

ZEROREQ-CFO-23-0037

• Total estimated dollar value and performance/delivery period.

The $5 million-dollar proposed ceiling increase is to accommodate the projects described above, as well as future projects, involving logical enhancements or extensions of current FAIMIS functions which are within the scope of the subject

IDIQ contract, for the duration of the five-year IDIQ period of performance through 1/31/2028.

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- 1.

☒ 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©.

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

The FAIMIS license fee billing processes are vital in ensuring that the agency can accurately bill our licensees and meet the requirements of emerging mission-critical future regulatory activities. CGI is the only responsible source that will satisfy agency requirements as they are the sole company who can perform system maintenance, operations, and modernization support to FAIMIS. Therefore, a company other than CGI would not be able to provide the comprehensive FAIMIS support NRC requires.

The NRC’s instance of FAIMIS contains highly customized code to support NRC’s complex and mission critical license fee billing process. The additional level of effort requiring the subject ceiling increase, is needed to complete the new projects listed above. Those projects are structured around the Contractor providing customized enhancements or extensions of FAIMIS modules or functions, which are tightly integrated with NRC’s core financial system FAIMIS. Essentially the new projects are customized enhancements or extensions of basic functionality that is already being provided under the IDIQ.

The NRC has made a significant investment of over $80 million in its commercial instance of FAIMIS and the custom eBilling solution over the last decade. CGI has been deeply involved in the agency’s license fee billing process since 2012.The license fee billing process is tightly integrated with eBilling and the FAIMIS core financial system, both of which are supported by CGI.

In order for another vendor to complete the additional follow-on tasks required, the NRC would have to replace its current ERP solution with some other solution which would represent a massive effort and a huge amount of risk. It would also result in substantial duplication of cost to the Government that is not expected to be recovered through competition, as well as unacceptable delays in fulfilling the agency’s requirements, and lost productivity.

5. 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.

For each task order issued under the IDIQ, the CO will request that the COR evaluate the level of effort and the mix of labor proposed to perform specific tasks being ordered, based upon the following:

• Their expert understanding of the level of effort required by different labor categories for each new requirement; and

• CGI’s IDIQ labor rates that the Contracting Officer already determined to be fair and reasonable at the time of award of the subject IDIQ contract.

The CO will only issue the task order after determining that the quotation is fair and reasonable and therefore, represents the best value to the NRC.

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

Market research was not conducted because this work is a logical follow-on to the work performed by CGI under Contract 31310023D0003.

7. Certifications

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 Representative

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

Contracting Officer

CONCUR:

Branch Chief

Competition Advocate