6JOFOC for Sole Source Redacted2.pdf

1100 New York Avenue, N.W.

Washington, D.C. 20527

(202) 336-8400

Justification for Other Than Full and Open Competition

FAR 6.302

1. Identification of the agency and contracting activity.

a. Federal agency and contracting activity. U.S. International Development Finance Corporation

(DFC)

b. Sponsoring organization. Office of Financial and Portfolio Management

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

a. Acquisition purpose and objectives. DFC’s Office of Financial and Portfolio Management

(OFPM) requires contract support in reviewing and updating its internal control legacy process narrative documents to accurately reflect the current risk and control environment at the agency.

Specifically, DFC requires assessments of lower-risk business processes that have not been reviewed in recent years. While these lower-risk business processes are unlikely to contribute to a material misstatement in DFC’s reporting, the agency desires to re-assess the risk and control environment in some of these processes and update its methods narrative documents.

b. Project background. DFC’s Office of Financial & Portfolio Management (OFPM) is seeking contract support to aid in the periodic testing done to review the design and operating effectiveness of its fourteen business process controls. The Overseas Private Investment Corporation (OPIC) is DFC’s legacy institution where its longstanding internal control program began. Testing is done on a risk-based, rotational basis as guided by DFC’s robust risk assessment process.

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

a. Project title. Internal Control Technical Support

b. Project description.

The contractor shall provide the following tasks:

Task 1: Review and Update Business Process Internal Control Narratives:

Review the existing process documentation and related DFC policies, procedures, and guidance, and interview process owners and key personnel (as necessary).

Update the existing process narrative documentation in a manner that accurately reflects the current state of process flows, identifies key risks to operations, reporting, and compliance, crosswalks existing internal controls to those risks, and identifies control gaps where risks are not sufficiently mitigated by existing controls.

When updating existing documentation, particular focus must be given to changes to systems usage, reporting requirements, utilization of service organizations, and fraud risk considerations.

Task 2: Follow the steps in Task 1 for the following business processes:

Perform the above-mentioned activities for the following business processes. While each of these processes has an existing process narrative on record, the date of the last update is included.

Business Process Year of Last Update Page Count Cash and Fund Balance with Treasury

FY 2019 14

Investment Funds FY 2019 54 Purchases and Payables FY 2018; related OIG audit was conducted in FY 2022

Credit Reform FY 2018 35 Treasury Borrowings FY 2017 8 Treasury Investments FY 2017 10 Insurance FY 2016 22 Payroll FY 2016 26

Deliverable:

DFC requires three deliverables. The contractor shall provide all deliverables requested by the COR and CO on mutually agreed due dates. All deliverables, unless otherwise specified, shall use a technology platform securely accessible to DFC. Deliverables shall be submitted during the hours of operations (8:00 am – 5:00 pm).

• Requirement type.

Research & development (R&D) R & D support services X Support services (non-R&D) Supplies/equipment Information technology (IT) Construction Architect-engineer (A & E) services Design-build Other (specify):

• Type of action.

X New requirement Follow-on

• Proposed contract/order type.

_X Firm-fixed-price Other fixed-price (specify, e.g., fixed-price award-fee, fixed-price incentive-fee):

Cost-plus-fixed-fee Other cost reimbursement (specify, e.g., cost-plus-award-fee, cost-plus-incentive-fee):

Time and materials Indefinite delivery (specify whether indefinite quantity, definite quantity, or requirements):

Completion Form Term form

c. Total estimated dollar value and performance/delivery period. The total value of the order is estimated at $ for one 12-month base period and one 12-month option period from the date of award.

4. Identification of the statutory authority permitting other than full and open competition.

X This acquisition is conducted under the authority of 41 United States Code (U.S.C.) 3304(A0(4) as set forth in Federal Acquisition Regulation (FAR) 6.302-5 Authorized or required by statute, as prescribed by FAR 6.302 (b)(6) Sole source awards under the Veterans Benefit Act of 2003 and FAR 19.1406 Sole source award to service-disabled veteran-owned small business concerns.

This acquisition is conducted under the authority of section 4202 of the Clinger-Cohen Act of 1996.

This acquisition is conducted under the authority of the Services Acquisition Reform Act of 2003 (41 U.S.C. 428a).

5. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

DFC is a newly created organization established on December 20, 2019, under the Better Utilization of Investments Leading to Development (BUILD) Act from its predecessor, the Overseas Private Investment Corporation (OPIC). The agency will utilize the information gathered to assess what risk assessment program improvements will be required. As part of the U.S. Government Accountability Office’s (GAO) Standards for Internal Control in the Federal Government, the principle of risk assessment is required to assess challenges the agency will face in achieving its mission objectives. This includes clearly defining objectives to enable identification of risks and risk tolerances as well as responses to those risks. This information will also articulate what changes (if any) may be required for improvements and how these potential improvements will impact the agency’s overall internal controls program and financial objectives.

As a financial institution advancing America’s foreign policy it is imperative that the agency instills confidence that our financial programs are based on sound principles and that our data is protected from malefactors. The information we use to make financial decisions is reportable and auditable to agencies outside of the DFC. Therefore, the requirement cannot be delayed for firms to develop expertise or arrange recruitment efforts to fulfil this need. The agency requires a technical support expert immediately. Taurian Consulting, LLC was selected as the best vendor capable of fulfilling the requested need because of their experience in working with innovative methods in the area of management and data analytics.

Furthermore, Taurian Consulting, LLC is a Service-Disabled Veteran-Owned Small Business that is a newly formed joint venture between Guidehouse and ReefPoint Group. Guidehouse has significant experience and understanding of the foundations of DFC’s risk process, as they were instrumental in developing the processes currently used by DFC. The ability to sole-source this requirement to Taurian Consulting, LLC will allow DFC to promote the use of a Service-Disabled Veteran-Owned company in promotion of small business goals, while allowing the agency to retain the institutional knowledge and continuity of services and support provided by Guidehouse.

6. Description of the efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required.

Per market research information, the agency solicited this need as a Personal Services Contractor (PSC), with three different solicitations issues across multiple venues including SAM.gov. The agency solicitations did not target any one business category or socio-economic group, but instead was directed to individuals that were licensed under a limited liability corporation. No viable applications were received.

7. Determination by the Contracting Officer that the anticipated cost/price to the Government will be fair and reasonable.

The price fair and reasonable determination will be assessed through a comparative lens between the vendor’s proposed price against the U.S. General Service Administration’s (GSA) CALC+ Quick Rate price tool (located at https://buy.gsa.gov/pricing/) for similar labor categories proposed by the vendor.

8. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Market research was conducted as required per FAR Part 10, Market Research per the market research checklist. The Government conducted a review of the following: the mandatory Federal Supply Schedule, an open sources search, a review of similar procurement actions within the agency, and a review of other product/services literature published online. In addition, please see number 6 above for solicitation efforts made by the agency.

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

There are no other facts to be presented in support of this justification.

10. Listing of sources, if any, that expressed, in writing, an interest in the acquisition.

No additional sources expressed an interest in this acquisition.

11. Statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the required supplies or services.

The DFC will continue to reassess its internal control program requirements as updates are needed. The agency will make all efforts to promote competition within the various internal control program areas where permissible. When barriers to competition cannot be removed the agency will document why, as well as what reasonable steps were taken to remove or minimize such obstacles.