47QFMA21C0001_J_A USA HIRE _Redacted.pdf

CUI//SP-SSEL

Version 11/25/2024 Page 1

JUSTIFICATION AND APPROVAL

JUSTIFICATION FOR OTHER THAN FULL AND OPEN

COMPETITION

Contract 47QFMA21C0001

Office of Personnel Management Human Resources Solutions (HRS)

USA HIRE Program in support of:

Office of Personnel Management Human Resources Solutions (HRS)

United States (U.S.) General Services Administration (GSA) Federal Acquisition Service (FAS)

Assisted Acquisition Services (AAS) Army

Interagency Agreement Number 47QFMA19S0007

Controlled by AAS Contracting Officer :

Version 11/25/2024 Page 2

The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this Justification and Approval (J&A) for Other Than Full and Open Competition orders pursuant to Federal Acquisition Regulation (FAR) 6.302.

1. Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of Office of Personnel Management

Contracting Activity:

GSA AAS Contracting Office (QFAC) 1800 F Street, NW Washington, D.C. 20405

2. Nature and/or Description of Action Being Approved:

The action being approved is a modification to contract 47QFMA21C0001. The contract is a combination Firm Fixed Price and Time-and-Material. OPM HRS’s USA Hire requires PDRI to provide services that include but are not limited to the provision of core assessments for specific occupations, core assessments for multiple occupations, tailored and custom assessments to fit specific needs, psychometric and industrial-organizational psychology support, online assessment solutions, system management and testing, and assessment delivery.

3. A Description of Supplies/Services Required to Meet Agency’s Need (Including the Estimated Value):

The purpose of the contract is to deliver online assessment solutions to current and future Federal clients and other human resources related products and services relevant to online assessment and talent management.

This modification will allow for an uninterrupted continuation of services at an increased level of effort which will raise the total ceiling value by $182,792,343.02, from $212,207,958.10 to $395,000,301.12. The $182,792,343.02 will increase:

Option 4 from $31,790,160.51 by $39,844,532.71 to $71,634,693.23;

Option 5 from $33,217,524.23 by $44,188,838.09 to $77,406,362.31;

Option 6 from $23,474,225.40 by $60,329,774.27 to $83,803,999.67; and Option 7 from $0.00 by $38,429,197.95 to $38,429,197.95.

The estimated amount is comprised of delivering the volume of assessments and assessment related services to federal agencies.

4. An Identification of the Statutory Authority Permitting Other Than Full and Open Competition:

This Sole Source modification to an existing contract will be awarded pursuant to the authority of 41 United States Code (U.S.C.) 3304 as implemented by FAR 6.302-1- Only

Version 11/25/2024 Page 3

One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. A Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Requires Use of the Authority Cited:

Contract 47QFMA21C0001 was awarded January 1, 2021 to deliver online assessment solutions to current and future Federal clients and other human resources related products and services relevant to online assessment and talent management through the OPM USA Hire platform. The OPM USA Hire platform provides an online assessment program designed specifically to meet the hiring needs of government agencies.

The contract was issued for a 12-month base year and seven (7) one-year options. The contract is currently in Option 4 with a period of performance of January 29, 2025, through January 28, 2026. The Government anticipated an eight (8) year performance period due to the estimated time to complete transition from the existing USA Hire platform to a new USA Hire assessment platform. In addition, OPM required at least six

(6) years of consistent support and transition out support for the recompete of the requirement.

Executive Order (EO) 13932 Modernizing and Reforming the Assessment and Hiring of Federal Job Candidates was issued June 2020 around the same timeframe that USA Hire was being solicited. The EO directed agencies to expand the use of valid, competency-based assessments and narrow the use of educational qualifications in the Federal hiring process. The intent is to direct agencies to use a skills and competency-based approach in conducting hiring across the Federal government via assessments that carefully measure a candidate’s ability to perform the job. USA Hire is one of the few Federal programs that supports agencies with compliance with this EO. While OPM USA Hire built steady and foreseeable growth into the contract, there was no reasonable way to predict the overwhelming impact of the EO 13932. This EO was issued at a stage during the solicitation process that precluded OPM from assessing the potential impact to the contract requirements.

This explosive demand has been driven largely by Transportation Security Administration’s (TSA) adoption of USA Hire and its need to fill thousands of vacant positions after the COVID-19 pandemic. Because of the EO, the need for USA Hire assessments has far exceeded the initial estimated amount, which has grown at a pace far faster than anticipated when the contract requirements and needs were first drafted and awarded. OPM planned for the steady growth of USA Hire throughout all options of the contract; however, TSA alone has consumed 95% of the requirement in Option Year 2 and Option Year 3. The Government issued a modification to realign ceiling value to support the additional assessments; however, the delivery of the assessments has increased significantly. Option Year 7 of the contract has been fully realigned, and its ceiling depleted.

The original Independent Government Cost Estimate (IGCE) was based on historical usage and an assumption that there would be some growth in assessment use across

Version 11/25/2024 Page 4

Federal agencies. TSA’s use of USA Hire, beginning in the last quarter of Option Year 2, resulted in dramatically increased delivery of assessments that continues through OY

3. TSA’s assessment usage far exceeds that of any large-scale implementation that USA Hire had previously supported. Furthermore, the monthly rate of assessment delivery continues to climb. This continued unprecedented need drove OPM to raise the ceiling for OY3. Based on this continuing need and to ensure USA Hire can continue to deliver assessments and assessment support services to all its federal customers, a ceiling increase is again necessary. Without raising the ceiling for Option Years 4, 5, 6 and restoring the ceiling to Option Year 7, USA Hire will not be able to continue to serve federal agencies’ hiring needs. Note, the significant increase in ceiling for OY6 (approximately $60M) is attributed to not only re-establishing the original ceiling value but also increasing that original ceiling value by ~$7M to account for the increased requirements associated with the latest EO. Additional ceiling is needed to deliver the volume of assessments and assessment related services to federal agencies. If the ceilings are left as is, USA Hire will not be able to deliver assessments and related services for the remainder of the current option period and beyond, effectively nullifying any sustained hiring efforts by our customer agencies. USA Hire requires this additional ceiling to provide assessment services to 300,000 applicants for TSA, 10,000 entry level investigators for ICE, along with smaller customer agencies spanning cybersecurity positions, tax fraud investigations, entry level credit union examiners, and HR specialists across the federal government – each year. If the contract ceiling is kept at its current level, there would be a disruption to federal hiring efforts across USA Hire customers.

This will impair mission fulfillment for each of these agencies, several of which stand at the front line of national security. Without the additional ceiling, USA Hire also would fail its mission of delivering high quality online assessments to ensure better hires. The current contract ceiling would allow USA Hire to provide assessment services to TSA and no other federal clients. This will leave all current federal customer agencies unable to fulfill Executive Order 13932.

USA Hire’s rapid growth is highlighted in the increasing number of assessments delivered in each of the following years: 644,836 in the Base Year; 768,554 in Option Year 1; 1,138,743 in Option Year 2; and in Option Year 3 USA Hire outpaced Option Year 2 delivery for the same year-to-date (YTD) by almost 100,000 assessments. USA Hire delivered well over 1,238,743 assessments through the end of Option Year 3. At this point in the contract delivery, OPM USA Hire expects TSA’s needs to continue to grow exponentially through the end of the current contract performance period as well as the remaining option periods. While OPM’s other current customers use various capabilities within the USA Hire program, their requirements are also expected to grow and expand the use of USA Hire capabilities throughout the life of the contract in the areas of assessments and online interviews. In addition, OPM anticipates the addition of new customers over the remaining option periods to deploy USA Hire assessment and online interviews. This ceiling increase is necessary to increase the effort to deliver online assessments to federal clients.

The needs of Federal agencies in online assessments are expanding dramatically, and thus OPM expects this requirement to increase significantly through the remainder of the

Version 11/25/2024 Page 5 contract, including the current performance period. As a result, the workload for loading and configuring new assessments onto the USA Hire platform has grown significantly since the award of the contract.

OPM USA Hire needs to restore the Option Year 7 ceiling to $38,429,197.95 to ensure the uninterrupted continuation of services until the follow-on contract can be recompeted and subsequently awarded. Solicitation of the next contract is anticipated to begin in Option Year 5 of the current contract. The restored ceiling for Option Year 7 will allow OPM USA Hire to continue to deliver assessments to its federal customers. Due to the anticipated complexity of the next contract, OPM USA Hire is planning for a multi-year long solicitation process to include market research, stakeholder needs analysis, and evaluation of the current contract to inform requirements. As a result, OPM USA Hire will need Option Year 7 to ensure uninterrupted continuation of services during procurement of the follow-on contract as well as to allow OPM the time required for the transition out activities. Due to the complexity of requirements and the amount of market research that needs to be conducted, the USA Hire PMO expects the competition timeline to be more than a year long. OPM USA Hire requires a platform that meets federal security standards, while maintaining a broad scope to include adaptive testing, proctoring, remote proctoring, online interviewing, test content security, access to existing commercial assessment catalogues, interconnection to more than one assessment provider, extensive industrial psychology expertise, IT expertise, and project management expertise. More specifically, OPM USA Hire requires expertise in job analysis, test planning, assessment development, assessment validation (including content, construct, and criterion approaches), un-proctored internet testing, mobile assessment, computer adaptive testing, item response theory, and classical test theory. Assessment expertise must include cognitive ability tests, biodata inventories, integrity/honesty tests, situational judgement tests, personality assessment, supervisory/managerial assessment, and leadership assessment. USA Hire requires specific psychometric expertise to manage and support delivery of online assessment solutions. The requirement requires expertise in Federal Human Resources policies and practices for use of online assessment solutions in a multi-Federal agency environment.

USA Hire includes the need to develop, create and deliver individual and aggregate assessment reports, assessment scores, and other assessment-related data to OPM and OPM customers. The requirement also includes conducting ad hoc data analyses, produce on demand data access, provide options for administering different tests and tests versions, manage human resources-related user documents and interfaces, and support program evaluation activities and research initiatives.

The PMO will use the remaining option years to continue to deliver assessments to its federal customers while it conducts market research, sets an acquisition strategy and competes the next contract. This current contract took two years to research, scope, release for procurement response, review and award. The next contract is expected to be more complex and larger in scope of requirements. OPM USA Hire has begun engaging OPM leadership and USA Hire stakeholders; OPM USA Hire has conducted stakeholder interviews and focus group studies and executed surveys to inform and coordinate with senior leadership to set OPM USA Hire’s long term strategic direction. OPM USA Hire

Version 11/25/2024 Page 6 expects that the capabilities that have been developed during the current contract, remote proctoring and online interviewing, will be larger in scope in the next contract. These capabilities will be larger in terms of volume delivered and more detailed to meet specific customer needs. OPM USA Hire is also conducting extensive market research to review emerging technologies in the field of Human Resources related assessments and evaluating whether to incorporate these technologies into the OPM USA Hire portfolio of available services. All this research, strategic development, and evaluation for the next contract is being done concurrently with delivering assessments and maintaining program operations.

Federal agencies need stronger applicant assessment tools to target the best applicants and ultimately make the best hiring decisions to support a federal workforce that achieves mission success. USA Hire currently offers off-the-shelf standard assessment batteries covering more than 140 Federal job series, access to test center locations worldwide, and a broad array of assessment and IT expertise.

The OPM HRS organization provides Human Resources (HR) solution offerings to include USA Hire assessment products and services. As part of its mission, OPM provides technical assistance to Federal agencies to meet their most critical human capital challenges. OPM HRS is the division dedicated to providing exceptional HR products and services to meet the dynamic human capital and training needs of the Federal Government. OPM HRS provides the full range of human capital management and training services that agencies need to grow, improve, lead, and thrive. Providing solutions to Federal agencies for more than 50 years, HRS employs HR consultants, psychologists, IT specialists, faculty, and program managers to assist Federal agencies in achieving their missions by partnering with them to develop leaders, attract and build a high-quality public-sector workforce, and transform the agencies into high performing organizations. OPM USA Hire provides agencies with online, HR-related assessment solutions, which include delivery of assessments in un-proctored and proctored environments. The current HR solutions include providing agencies the capability to administer OPM-owned off-the-shelf assessments to applicants and employees; to upload and administer their own off-the-shelf assessments to applicants and employees; to administer Commercial-Off-The-Shelf (COTS) assessments to applicants and employees;

agencies work with OPM to develop and administer online assessments to aid Human Resources-related decisions; and to work with OPM to transition paper-based assessments and processes to an online environment for administration.

In support of its mission, OPM needs to acquire a contractor to provide support services for the USA Hire Program. The contractor shall enable OPM the capability to provide online assessment solutions to their current and future Federal clients and other human resources related products and services relevant to online assessment and talent management. The needs of Federal agencies in the area of online assessment are expanding dramatically, and thus OPM expects to increase the range of capabilities it offers through USA Hire to include new assessment tools and methods and any supporting technology required to deliver the assessment solutions.

Version 11/25/2024 Page 7

In support of its mission, OPM requires Information Technology and Psychometric and Industrial/Organizational (I/O) Psychology support services for the USA Hire Program including online assessment solution/platform, psychometric expertise, reports and documentation, data calls, system management, integration, and testing services, help desk, project management, program evaluation, data analytics, and contract transition/shut down activities.

OPM chose to procure contractor-provided information technology and Industrial/Organizational psychology expertise necessary to support government-wide employment assessments out of a need to acquire the innovation and expertise from the private sector. OPM determined that it required the expertise of the private sector to ensure it acquired an online assessment platform that had the reliability and defensibility to withstand legal challenges (employment testing typically presents significant risk of litigation). OPM also sought the innovation of the private sector to acquire a wide range of assessment types and methodologies beyond that which its own test developers could practically produce (e.g., simulations, adaptive test engines). More recently, as it has evaluated its overall technology portfolio, OPM HRS leadership has determined that it is cost prohibitive for the government to build its own platform at this time. Moreover, it would take OPM more years to develop an online assessment platform that could match the functionality, reliability, and defensibility of the current vendor solution than the years left under the current contract.

The OPM USA Hire program runs on a PDRI assessment platform, currently called Palladium, which was purpose-built to flexibly customize and configure assessments at scale for the federal market. As a result, OPM will be able to deliver assessments more quickly and cost effectively, leveraging innovative new features, such as robust metrics and analytics, real time reporting, modern interfaces, native mobile support, built-in quality checks, and an extensible workflow engine.

Any new commercial platform(s) will require 18-24 months to build out the business process and technical integration with USA Staffing that is necessary to meet federal requirements. The current commercial assessment platform, built and maintained by USA Hire’s partner vendor, successfully customizes and configures assessment solutions for the federal human resource needs. This platform was built from the ground up for scale and compliance with federal and OPM security standards. The platform, Palladium, meets all OPM security requirements.

The Information Technology (IT) system PDRI delivered to OPM is based upon customizable software from PDRI. Any work performed under this contract can only be performed by PDRI due to the customized nature of the underlying PDRI system. Due to the highly technical nature of this requirement, no other firm can provide the necessary support. The maintenance of the system cannot be transferred to a third party due to the customized nature of the system. In addition, this work requires unique expertise in psychometrics and industrial/organizational psychology as it relates to employment testing and associated legal risk and extensive experience developing and conducting analytics for large-scale, high-stakes, litigious, and highly visible assessment programs.

Version 11/25/2024 Page 8

The assessments are regularly challenged and present legal risks to the government; as such, the assessments must be developed by experts who may be later called upon in a legal context to support their use. In addition, PDRI has been supporting USA Hire for over ten (10) years. PDRI has intimate knowledge of the requirements since they built the USA Hire platform and many of its assessments. As a result, PDRI fully understands the unique features, nuances, and intricacies of the hundreds of assessment batteries that are administered using USA Hire. As such, PDRI is the only contractor with the expertise and knowledge to provide the increased support necessary for the remainder of the current period and the three remaining options. However, OPM is conducting additional market research to increase alternatives and competition. While OPM seeks more options and competition through further market research, future procurements will be designed to encourage new, non-incumbent platforms.

The EO is driving federal agencies toward modern, efficient and highly effective hiring practices that allow agencies to hire the best candidates to fulfill agency missions, thereby increasing the need for the USA Hire Contract and consequently, expending the ceiling sooner than anticipated. This is resulting in the need to increase the ceiling of the contract to allow OPM to continue to provide online assessment solutions to current and future Federal clients and other human resource related products and services without having to resolicit sooner than anticipated.

If the ceiling is not increased, OPM USA Hire will have to stop providing assessment delivery and consulting services to its customers. This will be highly disruptive to all customer agencies’ hiring agendas. Furthermore, OPM will not be able to provide services to new customers. The inability to add to the USA Hire customer base will prevent OPM from achieving greater economies of scale, which is key to the program’s viability as a reimbursable organization.

6. A Description of Efforts Made to Ensure that Offers are Solicited From as Many Potential Sources as Practicable:

This J&A will be synopsized in sam.gov providing an opportunity for potential offerors to submit a proposal. Interested persons may identify their interest and capability to respond to the requirement or submit proposals. The synopsis is not a request for competitive proposals; however, all bids, proposals, or quotations received by the closing response date will be considered by the Government. A determination by the Government not to compete the proposed ceiling increase will be based upon responses received and will be within the discretion of the Government.

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

The assigned GSA Project Manager (PM) will complete a technical evaluation on the contractor’s technical submission to ensure the labor mix and estimated hours are appropriate for the work to be performed. Price analysis will be performed in accordance with FAR 15.404-1(b)(2), the Contracting Officer anticipates using various price analysis techniques and procedures to ensure a fair and reasonable price such as a comparison of proposed prices for the additional services to historical prices paid, a comparison of

Version 11/25/2024 Page 9 proposed prices with the independent Government cost estimates as well as a comparison with similar end items.

8. A Description of the Market Research Conducted and the Results or a Statement of the Reason Market Research was not Conducted: (Reference FAR 6.303-2(b)(8))

Market research for this action will not be conducted since the PDRI Information Technology (IT) system is based upon software developed by PDRI to deliver an IT employee assessment for Human Resources decision making. The assessments are delivered on customized IT systems (i.e., assessment platforms). PDRI is the only firm capable of providing the support due to the technical nature of the requirement.

Prior to award of the current contract, GSA issued a Sources Sought Notice in sam.gov seeking small business with the qualifications to provide the required support. Five (5) responses were received; however, none had the qualifications to provide support to the OPM USA Hire Program. GSA then issued a Request for Information (RFI) in sam.gov using an Advisory Multi-Step (AMS) process in accordance with FAR 15.202. Three (3) large businesses responded, and all were determined to be viable offerors. The viable Offerors were provided opportunities to ask questions regarding the Government’s draft requirements by participating in virtual Due Diligence Sessions. These pre-solicitation activities were meant to give industry a better understanding of the requirements as well as assist the Government in improving the solicitation package. One of the main discussion points with Offerors was the estimated time to complete transition from the current USA Hire platform to a new assessment platform. The exchanges with industry supported the Government’s need for an extended period of performance to allow for sufficient transition to the awardee’s new assessment platform. The reasons for this are not only to allow the development and implementation of the new platform, but the candidate data that needs to be transferred from the old platform to the new. OPM also needs both platforms to run in tandem to ensure the new platform is fully functioning before the old platform is retired. The functioning USA Hire platform is so important that OPM must have the safety net of rolling back to the old platform if the new platform fails in production. The Government estimates that transition could take up to two years depending on the awardee’s solution. As such, it is in the best interest of the Government to restore the performance period back to the full 8 years.

For the recompete, the OPM is currently conducting market research to develop the acquisition strategy. Integral to this strategy is open competition.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition:

This acquisition is not suitable for competition at this time due to the circumstances described above. At the expiration of the contract this requirement will be recompeted.

As this requirement is highly technical in nature, no other contractor would be authorized access to the system; therefore, no other contractor can do the work. The Government estimate is based on the prices negotiated in the contract multiplied by the revised quantities.

Version 11/25/2024 Page 10

10. A Listing of the Sources, if any, That Expressed, In Writing, An Interest in the Acquisition:

This J&A will be synopsized in sam.gov providing an opportunity for potential offers to submit a proposal. Interested persons may identify their interest and capability to respond to the requirement or submit proposals. The synopsis is not a request for competitive proposals; however, all proposals received by the closing response date will be considered by the Government.

11. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for the Supplies or Services Required:

The requirement was solicited on a full and open competitive basis in accordance with FAR Part 15 resulting in the receipt two proposals with an award being made to PDRI.

The contract is currently in Option Year 4 with 3 options remaining. The government began conducting market research in accordance with FAR Part 17 prior to exercising Option 4. Currently, the Government is in the process of recompeting this requirement.

Given the specialized technical nature of the service requirements, only PDRI is currently capable of providing them. However, OPM is actively conducting market research to identify and increase alternative providers, thereby enhancing competition. The current service provider becomes exclusively engaged only after the contract is awarded and their platform is developed. Each new competitive solicitation presents an opportunity for other contractors to be selected, allowing them to create and implement their own platforms.

Version 11/25/2024 Page 11

12. Contracting Officer 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, and I determine on the basis of the findings above that an other than full and open competition approach is in accordance with the requirements and is in the best interest of the Government.

Date

Contracting Officer, AAS Army Assisted Acquisition Services

Assistant Regional Counsel Office of General Counsel

AAS Advocate for Competition

Advocate for Competition, AAS Army

AAS Contracting Executive:

Date

Contracting Executive, AAS Army

GSA Assisted Acquisition Services Head of the Contracting Activity:

Date

Head of the Contracting Activity

Version 11/25/2024 Page 12

FAS Office of Policy and Compliance:

I have reviewed this contract action, and I have determined to the best of my knowledge and belief, based on the information contained herein, that it complies with all applicable policies and regulations.

Assistant Commissioner Office of Policy and Compliance

Final Approval:

I certify that this justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that an other than full and open competition approach is in accordance with the requirements and is in the best interest of the Government.

GSA Office of Government-wide Policy

Senior Procurement Executive Office of Government-wide Policy