P03 - LSJ FAR Part 8 - FSC Waco_Bridge.draft BR NE JC.pdf

DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

LIMITED-SOURCES JUSTIFICATION

(1) Identification of the agency and the contracting activity, and specific identification of the document as a "Limited-Sources Justification."

This justification for limited sources is executed by the Strategic Acquisition Center- Frederick (SAC-F), on behalf of the Department of Veterans Affairs (VA), Financial Services Center (FSC)

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

VA intends to negotiate a sole-source, fixed-price task order with GenTech Associates, Inc. (GenTech) (SAM UEI: VHWFFFZFWSQ1). The purpose of this task order is to provide a logical follow-on to the work currently being performed by GenTech for a period of time not to exceed 90 days. This current effort is being conducted under the authority of the Multiple Award Schedule (MAS) Program. The proposed effort will be awarded under the General Services Administration (GSA) Federal Supply Schedule (FSS) GS-23F-053AA to GenTech Associates, Inc., 9100 Purdue Rd., Indianapolis, IN 46268.

The proposed task order will have a Period of Performance of three (3) months, or 90 days, with no option periods. The anticipated Period of Performance for the base period is December 1, 2025 – February 28, 2026. The estimated value of this requirement is $304,451.28.

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The purpose of the proposed task order is to provide payment and payments resolution services in support of FSC and its customers. The Contractor shall provide remote services in support of FSC’s payment and resolution environment as described within the PWS. Currently, there are 1.9 million payment and payment adjustment/exceptions processed annually. Contractor personnel will be required to input payments and perform payment adjustment actions, as needed. The Contractor shall provide all resources necessary to accomplish the requirements described in the PWS.

(4) The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

The statutory authority permitting an exception to fair opportunity is 41 U.S.C.

§ 4106(c)(3) as implemented by FAR 8.405-6(a)(1)(C). In the interest of economy and https://www.acquisition.gov/far/part-8#FAR_8_405_6 efficiency, the work is a logical follow-on to an original FSS order which was placed in accordance with the applicable FSS ordering procedures. The original order was competed under Service-Disabled Veteran-Owned Small Business (SDVOSB) limited-sources procedures.

The Request for Quote (RFQ) that resulted in the award of task order 36C10X20F0040 against contract GS-23F-053AA was posted to GSA eBuy as a competitive SDVOSB set aside.

On May 14, 2020, VA awarded an approved labor hour type task order to GenTech Associates, Inc. for payment and payment resolution services under FSS contract GS- 23F-053AA. The task order was awarded with a 12-month base period and four (4) 12-month option periods with an estimated completion date of May 31, 2025. VA exercised all option periods and extended services to May 25, 2025. Subsequent to the completion of the final option period (OY4), an additional 6-month task order was awarded to GenTech to continue performing as the recompete process was affected by attrition within the program office which caused unforeseeable delays to the development and release of a new solicitation.

VA is currently in the process of re-competing the task order and is anticipating an award during quarter two (Q2) of Fiscal Year 2026 (FY26).FSC has a bona fide need for the services under this task order as they support the greater VA mission by ensuring that payment services remain intact and that all payment resolution services continue without costly delays which would result from a lapse in services.

For approximately the past 65 months the incumbent contractor, GenTech Associates, Inc. has provided acceptable support and is familiar with the current policies and practices implemented by VA and FSC. Furthermore, GenTech Associates, Inc. has been rated satisfactory or better in all categories for their annual CPARs during the Base and option periods one (1) through four (4). It is in the best interest of the Government to continue this work as a logical follow-on task order to maintain continuity and quality of this effort. If a new contractor were to be contracted to perform this work, there would be considerable lead time required to be acclimated to the FSC policies and procedures and to develop effective communications with critical stakeholders. This transition would cause a significant impact on the operations at FSC, and thus to the greater VA mission.

(5) A determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d).

GSA has already determined the labor hour rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. Therefore, the contracting officer is not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d). By placing an order against a schedule contract using the procedures in 8.405, the contracting officer has concluded that the order represents the best value (as defined in FAR 2.101) and results in the https://www.acquisition.gov/far/part-8#FAR_8_404 https://www.acquisition.gov/far/part-8#FAR_8_405_2 https://www.acquisition.gov/far/part-8#FAR_8_405 https://www.acquisition.gov/far/part-2#FAR_2_101 lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government ’s needs.

Consistent with FAR 8.404(d), the Contracting Officer will ensure that proposed rates conform with schedule rates and although GSA has already negotiated fair and reasonable pricing, additional discounts will be sought before placing an order (see 8.405-4).

(6) A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

Considering the stringent timeframe and the need for a continuity of services, minimal market research has been conducted. The contracting activity has already developed a Solicitation for the recompete and has successfully cleared a mandated review by SAC Compliance. The Solicitation package is currently in review by VA’s Office of General Counsel (OGC). OGC has pushed back on the further use of a labor hour task order insisting that given the amount of data available in the form of historical costs that the contracting activity should develop firm-fixed pricing for prospective vendors to quote for costs that align to tasks in the Performance Work Statement (PWS). In accordance with this suggestion, the contracting activity has resubmitted an updated Solicitation with estimated levels of effort for prospective vendors to offer pricing for services that align to the PWS tasks. OGC has indicated that they will continue to review and provide feedback as soon as possible. To this end the Contracting activity has determined that given the impending end of the current period of performance, November 31, 2025, that more time will be required in order to properly compete these services on GSA’s eBuy and that permitting a 90 day logical follow on will allow additional time to facilitate a proper transition period for a new contractor, should the incumbent not be awarded a new task order following the ensuing competition. Therefore, it is most efficient to award a logical follow-on for the FSC payment and payment resolution services while the new contract is being negotiated. The services under this follow on are logically connected to the original contract. Disruption or delays in services would result in unacceptable mission impacts, delays, and loss of continuity of services.

In accordance with FAR 5.301 and 8.405-6(a)(2), this action will be synopsized at award on the Government Point of Entry (GPE) SAM.gov and the justification will be made publicly available.

(7) Any other facts supporting the justification.

None

(8) A statement of the actions, if any, 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.

No barriers to future competition are anticipated. A competitive contract award is https://www.acquisition.gov/far/part-8#FAR_8_405_4 anticipated to be awarded quarter two (Q2) of fiscal year 2026 (FY26) and future acquisitions will be awarded on a competitive basis.

(9) Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government ’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

Signature: _________________________________ Date: ____________

Bobby Rice

Program Manager Office of Human Resources and Administration

(10) The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer ’s knowledge and belief.

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

Nicole Egan

Contracting Officer Strategic Acquisition Center

(11) For justifications under 8.405-6(a)(1), a written determination by the approving official identifying the circumstance that applies.

Approval

In my role as Supervisory Contracting Officer, based on the foregoing justification, I hereby approve this acquisition on an “other than full and open competition” basis pursuant to the statutory authority cited in paragraph four above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition. As this action does not exceed $900K, the certification below required by FAR 8.405-6(d)(1) serves as approval.

Justin A. Cole

Division Chief-AS1A, Supervisory Contracting Officer https://www.acquisition.gov/far/part-8#FAR_8_405_6

Strategic Acquisition Center