P03 - LSJ FAR Part 8 - HRA LFO.updated 05122025 NE_PAAC Signed.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), Office of Human Resources and Administration, Office of Operations, Security and Preparedness

(HRA/OSP).

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

VA intends to negotiate a sole-source task order with Creative Business Solutions Inc.

(SAM UEI: ES6RTUBDKBJ4) for Contract Oversight and Integration, and Program Management Support Services (COI/PMSS). This 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) 47QRAA17D0005 to Creative Business Solutions Inc., 13003 Winding Creek Rd., Bowie, MD 20721.

(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 a seven-month extension of the services currently in place via contract: 47QRAA17D0005 task order: 36C10X19F0108.

The current order has a Period of Performance (PoP) ending May 25, 2025, and was conducted under the authority of the GSA, FSS, MAS program. The HRA/OSP requires continued contractor support to provide contract oversight and integration services and program management support services.

Currently, there are approximately 170 separate initiatives to improve government efficiencies and effectiveness across VA’s Human Capital programs.; The Contractor shall provide support in the following areas across the HRA/OSP enterprise:

• Strategic Planning and Organizational Performance

• Strategic Communications

• Program, Project, and Operational Management

• Acquisition Management

• Budget and Financial Management

• SharePoint Administration and Development

The proposed task order will have a base Period of Performance (PoP) of seven (7) months with no option periods. The anticipated PoP for the base period is May 26, 2025

– January 5, 2026. The estimated value of this requirement is $3,187,061.35.

(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 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 36C10X19F0108 against contract 47QRAA17D0005 was posted to GSA eBuy as a competitive SDVOSB set aside.

On September 25, 2019, VA awarded a firm-fixed priced task order to Creative Business Solutions Inc for Contract Oversight and Integration, and Program Management Support Services under FSS contract 47QRAA17D0005. The task order was awarded with a 12-month base period and four (4) 12-month option periods with an estimated completion date of September 25, 2024. VA exercised all option periods and extended services to May 25, 2025.

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). HRA/OSP has a bona fide need for the services under this task order as they support the HRA/OSP with strategic planning and organizational performance, strategic communications, program, project, and operational management, acquisition management, budget and financial management and SharePoint administration and development which are critical to the operations and mission of the HRA/OSP.

For approximately the past 12 months the incumbent contractor, Creative Business Solutions, Inc. has provided acceptable support and is familiar with the current policies and practices implemented by VA and the HRA/OSP. Furthermore, Creative Business Solutions, Inc. has been related 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 HRA/OSP policies and procedures and to develop effective communications with critical stakeholders. This transition would cause a significant impact to the operations at HRA/OSP.

https://www.acquisition.gov/far/part-8#FAR_8_405_6

(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 prices of supplies and fixed-price services, and 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 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 need for continuity of services minimal market research has been conducted. The HRA/OSP is in the process of creating an acquisition package, to include a market research analysis, for a competitive award for the future contract for Contract Oversight and Integration, and Program Management Support Services. Therefore, it is most efficient to award a logical follow-on for the HRA/OSP COI/PMSS 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 anticipated to be awarded quarter two (Q2) of fiscal year 2026 (FY26) and future acquisitions will be awarded on a competitive basis.

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 https://www.acquisition.gov/far/part-8#FAR_8_405_4

(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: ____________

Michael Frierson

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 Contracting Activity Competition Advocate, 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 $15M, the certification below required by FAR 8.405-6(d)(2) serves as approval.

Efrain J. Fernandez

Director of Contracts, Acquisition Services 1-3

Procuring Activity Advocate for Competition (SAC-Frederick) Strategic Acquisition Center https://www.acquisition.gov/far/part-8#FAR_8_405_6