-16635.pdf

SOLE SOURCE JUSTIFICATION

IAW FAR 13.501

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Sole Source Acquisition (>SAT)

1. Contracting Activity: Department of Veterans Affairs Veterans Benefits Administration Office of Administration and Facilities – Acquisition Division 1800 G Street N.W.

Washington DC 20006

VBA Specialized & Commodities Acquisition Team Purchase Request Number: 101-19-1-5954-0003

2. Nature and/or Description of the Action Being Processed:

This justification and approval sets forth the facts and request approval for the issuance of a Sole Source contract with The Career Index Corporation, 1078 W Peninsula Dr., Coeur D Alene, ID 83814-7793 for Semi-Autonomous Research Assistant (SARA™), a Vocational Rehabilitation-specific Virtual Software as a Service (SaaS) product. Firm-fixed Price (per user pricing, per year) contract is planned. This is a NEW requirement for the Veterans Benefits Administration.

3. Description of Supplies/Services Required to Meet the Agency’s Needs:

The proposed action under this justification and approval is to provide the Department of Veterans Affairs, Vocational Rehabilitation and Employment (VR&E) Division access to The Career Index Corporation’s Semi-Autonomous Research Assistant (SARA™) software as a service. This software is a vocational rehabilitation-specific virtual assistant that allows for bi-directional automated and on-demand communication between VR&E’s Vocational Rehabilitation Counselors and Veterans seeking to use or are actively enrolled in VR&E programs. To meet the Agency’s need, the software as a service will provide participant engagement, data entry and documentation within a FedRAMP-certified cloud environment. The Career Index Corporation has a commercial off-the-shelf (COTS) solution being utilized by Workforce Investment Boards, State Adult Education Programs, State Vocational Rehabilitation Agencies, Wagner-Peyser Workforce Programs, Non-Profits and Temporary Assistance for Needy Families (TANF). The Career Index Corporation will be responsible for providing all professional services, labor, cloud based hosting, materials and supervision for SARA™ to the VBA’s VR&E program. The estimated total contract cost for the base year and four option years is with 1,200 users each year.

4. This acquisition is being conducted following Simplified Procedures for Commercial Items in

FAR 13.5 (in accordance with 41 USC 1901 or 41 USC 1903) and documented as required by

FAR 13.501.

5. Demonstration of the Contractor’s Unique Qualifications:

The Career Index Corporation developed, tested and is marketing the Semi-Autonomous Research Assistant (SARA™) software to public and private entities. The SARA™ software is proprietary to The Career Index Corporation. The Career Index Corporation was contacted and a list of resellers was requested, however, the vendor stated they do not distribute their software through any other means but direct purchase. As such, no other vendor is available to maintain, distribute or provide updates to the software. The Career Index Corporation’s technology was developed as a client engagement and communications system that automatically gathers needed information at the right time from participants and providers without staff intervention. Using artificial intelligence (AI) and natural language processing, it can engage in intelligent, two-way communications with participants and third parties using two-way SMS (texting), email and interactive voice response (IVR). All interactions result in detailed case notes. SARA™'s AI engine can be easily taught to collect any kind of information a human could collect. It undertakes structured interviews with clients and providers to determine progress, barriers and milestones reached and can make basic decisions accordingly. This interaction produces detailed case notes and color-coded alerts to staff. SARA™ can communicate using Multimedia Messaging Service, which makes it easy for clients to send pictures of certificates, grades, etc. from their phone when requested. SARA™ allows staff across agencies to communicate directly with clients using both Text Messaging and Email from within the system. All outgoing and incoming emails and text messages are automatically made part of the client case notes thus eliminating the need for transcription and copy & paste. SARA™ can also share participant information between selected staff members. For example, a case manager can easily share a specific participant with a selected counselor and vice versa. SARA™ includes an Application Programming Interface (API) that can push generated case notes to virtually any Case Management System in near real-time.

Based upon additional information contained within this sole source justification, specifically the Request for Information (RFI), the Government’s technical experts from OI&T Enterprise Portfolio Management Office, Vocational Rehabilitation and Employment Division, Office of Business Process Integration and Strategic Acquisition Center – Frederick have determined that no other such Vocational rehabilitation-specific product exists currently in the marketplace. The Government’s technical experts have determined that The Career Index Corporation is the only source able to meet the Government’s requirements now. Therefore; only one responsible source.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:

The following details the market research conducted for this requirement. The Strategic Acquisition Center in Frederick, MD (SAC-F), issued RFI/Sources Sought Notice 36C10X18Q9105 via https://www.fbo.gov on May 25, 2018. The RFI/Sources Sought Notice closed on June 8, 2018. The notice was based upon a commercial off-the-shelf (COTS) solution that will preserve Government oversight and accountability of the VR&E process while empowering VR&E counselors to focus on Veterans receiving the service they are entitled to in the most efficient manner possible. The strategic goal for this requirement will eliminate the administrative burden of ingestion, establishment, and processing of Veteran eligibility through establishment of automated capabilities so VR&E personnel can focus on managing Veteran outcomes. The RFI/Source Sought Notice was for Market Research Information Only to determine commercial practices of companies engaged in providing alternative business paradigms with direct or related industries regarding Case Management for delivery of VRE benefits, determine GSA Federal Supply Schedule availability, determine availability of SDVOSB and VOSB, and the requirement for the company to present their capabilities briefing to the VA. The Statement of Objective lists out the VA’s Vision on managing solutions, the current state/environment, business objectives and additional considerations. The RFI requested detail responses to allow the VA to decide on the direction to be taken.

Ten responses were received, presentations were made by the respondents and reviewed/evaluated by VBA’s Office of Business Process Integration (OBPI) and VR&E Central Office staff, one company has been determined feasible to deliver a Virtual Assistant that is VR&E specific and deployed in the market place now. The Virtual Assistant was one part of the RFI/Sources Sought Notice. Statement of Objectives, Section 4.2 – Automation regarding locating a contractor that can provide an automated assistant with artificial intelligence, natural language processing that will facilitate two-way communications, tracking and case follow-up, automated appointment scheduling, data entry and data integration with case management platform. The Virtual Assistant piece of the RFI/Sources Sought Notice is the only part applicable to this sole source acquisition.

7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable:

No award will be made until the Contracting Officer determines the costs to the Government to be fair and reasonable. Price analysis utilizing competition in pricing is the preferred method to determine price reasonableness, however, with only one quote; other methods can be utilized such as:

FAR: 13.106-3(a)(2)

(i) Market research;

(ii) Comparison of the proposed price with prices found reasonable on previous purchases;

(iii) Current price lists, catalogs, or advertisements. However, inclusion of a price in a price list, catalog, or advertisement does not, in and of itself, establish fairness and reasonableness of the price;

(iv) A comparison with similar items in a related industry;

(v) The contracting officer’s personal knowledge of the item being purchased;

(vi) Comparison to an independent Government estimate; or

(vii) Any other reasonable basis.

The Contracting Officer will use one or more of the techniques within FAR 13.106-3 to determine the price quotation is fair and reasonable prior to awarding the contract. It is certain that the proposed vendor will offer their commercial pricing which represents the price they charge the commercial market place, which is an indicator of market conditions. The Contracting Officer will seek discounts from that price. It is anticipated that the final price will be fair and reasonable.

8. Description of the Market Research Conducted and the Results:

Market Research was conducted in accordance with VA Procurement Policy Memorandum (PPM) (2016-05) (Revised AUG 2018), Implementation of the Veterans First Contracting Program because of the U.S. Supreme Court Decision.

Searches of the following sources was completed: AbilityOne

VA’s Vendor Information Pages (VIP) GSA eLibrary SBA’s Dynamic Small Business Search eCMS RFI/Sources Sought

AbilityOne – 0 Results were returned.

VA Vendor Information Pages (https://www.vip.vetbiz.gov/) – was searched by NAICS 518210 – Data Processing, Hosting and Related Services. 941 total results, 760 are verified as SDVOSB and 181 verified as VOSB. When you also include the Product Service Code (PSC) D318 - IT and Telecom – Integrated Hardware/Software/Service Solutions, being used for this requirement, 0 Results were returned.

GSA eLibrary – Schedule 70 – Category 132 40 - Cloud Computing Services - SUBJECT TO COOPERATIVE PURCHASING Includes commercially available cloud computing services such as Infrastructure as a Service (IaaS), Platform as a Service (PaaS), and Software as a Service (SaaS) and emerging cloud services. 111 Contractors listed including 9 SDVOSB and 4 VOSB. Each of these 13 Veteran-Owned Companies where crossed referenced with VetBiz data based to determined verification (8 Verified - 7 SDVOSB – 1 VOSB, 5 NOT Verified). The following Keywords were searched for matches within each companies GSA Terms and Condition Price Lists, “Vocational Rehabilitation” and “Virtual Assistant”. 0 Results were returned.

SBA’s Dynamic Small Business Search – was searched for NAICS 518210 and resulted in 9,146 profile matches but stated Error – Insufficient search criteria were entered. The search was modified to include these Veteran Owned Companies and Keywords, “Vocational Rehabilitation” and “Virtual Assistant”. 1 profile matched for Veteran Owned and Vocational Rehabilitation. 0 profile for Veteran Owned and Virtual Assistant. Another Keywords search “Virtual Assistant Software” was completed without the NAICS Code or Veteran Owned. 0 Results were matched.

eCMS Information – the VBA SharePoint for SDVOSB and VOSB awards does not include any awards being made under this NAICS code or any similar Software as a Service requirements.

RFI/Sources Sought – Strategic Acquisition Center - Frederick (SAC-F) issued a RFI/Sources Sought Notice on May 25, 2018 via the https://www.fbo.gov to ascertain if there were sources able to meet the Government’s requirements. Responses were received from ten sources, however nine of these sources did not demonstrate capabilities to meet the Government requirements for a readily available, Vocational Rehabilitation-specific Virtual Assistant. The one remaining source can readily meet the Government’s requirement, which is The Career Index Corporation. As stated previously, there software is a vocational rehabilitation-specific virtual assistant that allows for bi-directional automated and on-demand communication between VBA’s Vocational Rehabilitation Counselors and Veterans seeking to use or are actively enrolled in VR&E programs. The Government’s technical experts performed market research on Virtual Assistant commercial off-the-shelf (COTS) products, including the review of responses to the RFI. However, after further research, the Government’s technical experts have determined that no other such Vocational rehabilitation-specific product exists currently in the marketplace. Based on this market research, the Government’s technical experts have determined that The Career Index is the only source able to meet the Government’s requirements now.

Company Ranking Small Business?

Feasible to Deliver Virtual Assistant?

VR&E Specific Virtual Assistant Deployed to Market?

Requirements Assessment

9. Any Other Facts Supporting the lack of competition:

Failure to procure this capability will result in the continued misuse of resources, specifically Vocational Rehabilitation Counselors, who currently conduct an overbearing number of administrative tasks which prohibit them for performing the value-added tasks providing direct benefits to the Veterans and beneficiaries whom they serve.

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:

The RFI/Sources Sought Notice published on the Federal Business Opportunities (FBO) website mentioned prior, seeking potential qualified firms for the requirement produced ten responses.

However, nine of these sources did not demonstrate any capabilities to meet the Government requirements for a readily available, Vocational rehabilitation-specific Virtual Assistant.

The following of business groups submitted a response to the RFI/Sources Sought:

Four – Large Businesses One – SDVOSB Two – VOSBs Two – Small Businesses One – EDWO Small Business

11. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required:

Based on above data and market research, the VA Customers, as well as the Contracting Officer, have conducted extensive market research looking for other capable sources or other comparable products and found none that can satisfy the requirement for a VR&E based Virtual Assistant now. There is only one source that can provide The Career Index Corporation’s Semi-Autonomous Research Assistant (SARA™) software. The Contracting Officer will continue to conduct market research and synopsize future requirements for these same software services to see if any additional vendors can provide these software services to the Government. Additional, a Case Management solution outside the Virtual Assistant is anticipated to be solicited under a separate requirement.

12. Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Joshua D. Sitton, Program Analyst VBA Office of Business Process Integration

13. Approvals:

a. Contracting Officer’s Certification: I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Stuart W. Stovall, Contacting Officer

b. Supervisory Contract Specialist: I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Mary K. Hoelscher, Supervisor

Joshua D. Sitton

STUART W. STOVALL

Mary K Hoelscher

02/26/2019

HIGHER LEVEL APPROVAL (Required For actions over $700,000):

c. Veterans Benefits Administration (VBA), Acquisition Director concurrence and VBA Head of Contracting Activity Approval: I have reviewed the foregoing justification and find it to be complete and accurate to the best of my knowledge and belief and approve or recommend approval.

Concur:

Daniel J. Pagone, Deputy Chief Acquisition Division

Approve:

Jeffrey M. Smith, Head of Contracting Activity

VBA

Daniel J. Pagone

Jeffrey M Smith