FBO_Posting_-_Limited_Source_Justification_-_Sunflower_Systems.docx

LIMITED-SOURCES JUSTIFICATION FOR FEDERAL SUPPLY SCHEDULE PROGRAM

Upon the basis of the following justification, prepared in accordance with Federal Acquisition Regulation (FAR) 8.405-6(c), I, as the Contracting Officer, hereby approve the use of sources limited to fewer than those required in FAR 8.405-2 pursuant to the authority of FAR 8.405-6(a)(1)(i)(B).

Identification Numbers: PR-OARM-19-00171

1. Identification of the agency and contracting activity.

The U.S. Environmental Protection Agency (EPA), Cincinnati Acquisition Division (CAD), Cincinnati, Ohio, proposes to enter into a task/delivery order on the basis of other than full and open competition for the Office of Mission Support, Administration & Resources Management, Office of Administration.

2. The nature and/or description of the action being approved.

This is a limited source justification, Federal Supply Schedule (FSS) acquisition for the procurement of technical and administrative support of the existing Sunflower Enterprise Assets software, SunflowerMobile and MobileTrak software, and Sunflower Intermec barcode scanners (configured with Sunflower asset management software) that was developed utilizing Annams Systems Corporation’s Sunflower asset management software. The contract type is Firm-Fixed-Price. The vendor is a small business.

3. A description of the supplies or services required to meet the agency’s needs.

The Agency Asset Management System (AAMS) includes a software/hardware solution for enterprise wide asset management intended for tracking physical and financial accountability for all EPA assets from acquisition through disposal. The AAMS consists of a software product called Sunflower Enterprise Assets, and related Sunflower Systems software products. The AAMS enables property managers to monitor, control and account for all property transactions and supports the annual physical wall-to-wall inventory that is conducted EPA-wide. The data collected in the AAMS is used for; a) reporting annual wall-to-wall physical inventories of all accountable assets; b) assignment of assets to employees via a property decal; c) financial reporting of capitalized Agency assets; d) management of non-accountable personal property; and e) recording of asset lifecycle transactions from acquisition through disposal. To conduct the annual physical inventories EPA-wide, operators of the AMMS utilize hand-held bar-code scanners to assist in their identification of assets throughout EPA spaces. Hand-held scanners are used by system end users to help avoid the manual entry of assets’ physical location data by scanning a bar code decal attached to the asset. The SOW format is designed to support the inventory activities of Program offices (whose requests to purchase handheld bard-code scanners are ad-hoc in terms of timing and quantities each year), therefore includes unfunded Optional Services to allow ad-hoc ordering. The estimated value for this acquisition is ______________.

The AAMS is the authoritative system for all enterprise asset management for the Agency and is used by over 950 employees with property management roles and responsibilities. There are over 60 handheld bar-code scanners deployed throughout EPA.

This requirement is for the purchase of technical and administrative support of the Sunflower Systems’ line of products including: Sunflower Enterprise Assets software, Sunflower MobilTrack software, Sunflower Intermec hand-held barcode scanners, and related accessories for use with the EPA’s existing asset management system. The existing asset management system was developed utilizing Annams Systems Corporation’s Sunflower asset management software and has been in use at EPA since February 2016.

4. An identification of the LSJ rationale, and if applicable, a demonstration of the contractor’s unique qualifications to provide the required supply or service.

The statutory authority permitting other than full and open competition is 41 U.S.C. 3304 (a)(1), as implemented by the Federal Acquisition Regulation FAR 8.405-6 (a)(1)(i) (B) – Only one source is capable of responding due to the unique or specialized nature of the work.

Annams Systems Corporation (Annams) of San Ramon, CA is uniquely qualified to provide these items to the EPA based upon the following:

Annams Systems Corporation (Annams) is a Small Business Program 8a certified participant, and self-certified small disadvantaged business. The order awarded in 2014, EPG14H00877, was competed amongst schedule holders on GSA Schedule 70.

Annams is the sole proprietor of the Sunflower suite of software products. The EPA currently utilizes the Sunflower Assets, Sunflower Mobile, and Sunflower MobileTrak software for physical property and inventory management, and handheld bar-code scanners, respectively. Sunflower Assets, Sunflower MobileTrak, and Sunflower Mobile software are considered a Commercial-off-the-Shelf (COTS) software product supported and updated by only Annams. Annams has established GSA catalog pricing for its Sunflower suite of software products. It is proprietary software developed exclusively at private expense. It is not available through third party resellers. Sunflower software labor for installation services, maintenance services, and repair services are procured for support of Sunflower software products, which are provided by the same source and are limited to personnel directly hired and trained by Annams to maintain, repair and install the software. Handheld bar-code scanners must be purchased from Annams in order to have the required Sunflower MobileTrak software installed by Annams personnel. Handheld bar-code scanners are unique to one system end user, and are therefore custom configured for each AAMS system-end user.

5. A determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d).

The EPAs Office of Administration purchased the Sunflower Asset Management System software in February 2012 and 2014 as a small business award to Annams Systems Corporation under contracts EP-G12H-00331 and EP-G14H-00862, and EP-G14H-00877, respectively. Additionally, EPA Contract EP-C-16-019 was issued to Annams in 2016 for supply of Sunflower Configured Intermec handheld bar-code scanners. Using historical Annams contract pricing, plus the current Annams’ Authorized GSA schedule GS-35F-0504L, best value pricing was determined. In addition, Annams was contacted directly in order to determine if it utilizes resellers in an effort to ascertain cost realism analysis for comparison. As a result of this research, it was confirmed that Sunflower software is not available from other vendors, and that Annams is the sole source provider of the Sunflower software, therefore eliminating the ability to conduct a comparative price analysis.

The probable costs for continued support with Annams is reflected in the IGCE (dated May 13, 2019). To the extent practicable, the differences between the historical costs and probable costs reflects price reasonableness and poses no significant risks of future performance. FAR 8.404(d) requires ordering activities to perform a price evaluation in accordance with FAR 8.405-2(d). The latter provision requires ordering activities to consider the level of effort and mix of labor in determining best value. The labor mix and LOE reflected in the IGCE is based on historical usage for these support services incurred in the current contract. In addition, EPA may require additional labor and/or equipment, identified as options in the solicitation, in order to expand the usage of the Sunflower system to additional EPA organizations and to expand usage in tracking additional assets. The optional labor and equipment is estimated based on the anticipated expansion in usage of the system. The labor rates for the required labor categories are established in Annams’ GSA Schedule, which have already been determined to be fair and reasonable by GSA. Given that that Annams is the only vendor for the required supplies and services and that it would not be economically feasible to purchase, install and implement an entirely new asset management system (see Section 7 below), and based on the demonstrated need for technical support as reflected in the IGCE labor categories and level of effort estimates, and on the reasonableness of the labor rates as determined by GSA, EPA has determined that the order will represent the best value to the Agency. Moreover, in accordance with FAR 8.405-4, EPA will seek additional discounts for all the items and labor associated with this requirement.

6. A description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted. A statement must be made that the supplies and services are available from the FSS.

Market research was conducted among GSA schedule holders in August 2019, and are reflected in the Market Research Report for this acquisition. The Sunflower suite of software products and labor categories used at EPA are available on GSA schedule are confirmed GS-35F-0504L. Internet searches were conducted using GSA schedules for comparative value analysis. Of the three vendors on GSA schedule who provide asset management solutions, none offered any support for the existing Sunflower software products or services installed at the Agency

7. Any other facts supporting the use of other than full and open competition.

Based on the market research conducted, only IBM Maximo offers a comparable asset management solution, but it would require approximately ____________ of upfront startup costs (excluding purchasing of mobile scanner devices) to implement a new platform versus a _________ annual license fee for Sunflower. Since the agency has already implemented the Sunflower system and already purchased the mobile scanner devices, it is not economically feasible to change over to a new asset management system, purchase new mobile scanner devices, develop interfaces to the Agency’s financial system, and training for over 900 system end-users.

Furthermore, while the use of Sunflower software products has restricted rights of U.S. Government end users (the software is a “commercial item” as that term is defined in 48 C.F.R. 2.101, July 2019, there are no such restrictions on data rights for EPA. To ensure risks have been considered in order to remove barriers to further competition, data rights for proprietary software was considered for this requirement (as well as types of software categories). Unrestricted data rights allow for EPA to export any data created in the performance of work under contract into other EPA systems such as the financial system. Once obtained, the data can be migrated to a complementary asset and inventory management software product such as financial systems software. Should the EPA require a subsequent acquisition for the supplies or services, the requirement can be competed without need for exceptions to competition requirements for Federal Supply Schedule orders. Market research will continue to be conducted for any future requirements in order to avoid the continued noncompetitive acquisition of the requirement. Given the Sunflower Assets products have been in use since 2016, and given the typical useful life of an enterprise system is 10 years, the determination to remain with Sunflower products was made for this requirement, with the risk too high for the Agency to migrate and transform the IT infrastructure to a competitive product.

8. A statement of any actions the agency may take to remove or overcome any barriers to competition, if subsequent acquisitions are anticipated.

The Agency will continue to monitor the marketplace to determine if Annams Systems Corporation allows third-party access to its source codes for the Sunflower software products.

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 and evidence that the supporting data that form a basis for the justification have been certified as complete and accurate by technical/program personnel.

Certification

Project Officer: Pamela Gillikin

I certify that the facts and representations under my cognizance, which are included in this justification and which form a basis for this justification, are complete and accurate.

________/s/____________ __________ Signature Date

Contracting Officer: Scott Tharp

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

________/s/____________ __________

Reviews and Approvals

Agency Advocate for Competition: Tommie Madison

I have reviewed this Limited Source Justification and find it to be accurate and complete to the best of my knowledge and belief for procurement of technical and administrative support of the existing Sunflower Enterprise Assets software, SunflowerMobile and MobileTrak software, and Sunflower Intermec barcode scanners (configured with Sunflower asset management software) that was developed utilizing Annams Systems Corporation’s Sunflower asset management software from Annams Systems Corporation (Annams) of San Ramon, CA. Since this LSJ does not exceed $13.5M, this review serves as approval.

_______/s/_____________ __________