Bridge_Contract_JEFO_CSRA_Redacted.pdf

Justification for Exception to Fair Opportunity Exceeding the SAT pursuant to FAR 16.505(b)(2)(ii)(B)

JEFO No.: FY18-0189 Rev. 3/22/2018 - 1 -

JEFO No.: FY18-0189

Date: 4/16/2018 PR Number: ICS180022

1. Agency and Contracting Activity.

The Department of Homeland Security, Office of Procurement Operations, (OPO Division), United States Citizenship and Immigration Services (USCIS), Customer Service and Public Engagement Directorate (CSPED) and Office of Contracting (OCON), prepared this justification for an exception to fair opportunity.

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

USCIS intends to noncompetitively award a bridge task order under the General Services Administration (GSA) USA Contact Indefinite Delivery/Indefinite Quantity (IDIQ) contract number GS00V08PDD0066 with CSRA LLC (formally Computer Services Corporation) pursuant to FAR 16.505(b)(2)(ii)(B). The GSA USA Contact vehicle is not a GSA Schedule, rather a multi-award IDIQ contract. This sole source action with CSRA will allow for continued Customer Engagement Center (CEC) support. In addition, provide USCIS additional time necessary to transition new technology required for the performance of the new CEC task order, 70SBUR18F00000028 with CSRA, awarded on 10/19/2018. Due to a government caused delay with the ordering and configuration of Government Furnished Property (GFP) for CEC, the new task order performance period cannot begin prior to 8/1/2018. This has necessitated the need for non-competitive bridge task orders to be issued to each of the incumbent contractors. The bridge task order for CSRA will have a performance period of four months, with an estimated value of $9,161,340.

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

CSPED has a continuing requirement for contract support to provide Tier 1 call center customer assistance under the National Call Service Center (NCSC) task order.

Applicants and U.S. citizens contact the NCSC seeking general information, to inquire about the status of their case(s), to report suspected fraud, to change their address, and discuss other areas of general inquiry by telephone and web-chat. The Tier 1 call center serves is the first line of customer support in USCIS; annually answering over 7.2 million customer inquiries, creating over 500,000 service requests, and transferring calls to Tier

2. Tier 2 is a government operated call center, which deals with inquiries outside the scope of the task order.

The intent is to bridge the current task order with CSRA for four months. See table below for breakdown of performance period and pricing.

JEFO No.: FY18-0189 Rev. 3/22/2018 - 2 -

Proposed Extension Table

Base Period of Performance 5/1/2018-8/31/2018

CLIN 0001 – Support Staff CLIN 0002 – Call Staff CLIN 0003 – Live Chat

CLIN 0004 – GSA CAF

Total

4. Identify the exception to fair opportunity and supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited.

16.505(b)(2)(i)(B): Only one awardee is capable of providing the services required at the level of quality required because the services ordered are unique or highly specialized.

Rationale:

For historical reference, on 5/17/2012 USCIS competitively awarded two task orders under the GSA USA Contact IDIQ contract; HSSCCG-12-J-00113 (expires 4/30/2018) to CSRA and HSSCCG-12-J-00114 (expires 4/30/2018) to Enterprise Services (now Enterprise Services dba DXC).

- The tasks orders are for the operation of the CSPED Tier 1 telephone call center support.

- Under these two task orders the government owns and maintains the voice and data circuits in to the contractor’s facilities; while the contractor owns all the equipment and software past the demarcation point of the circuits to operate the centers.

- The feasible alternative of a single award was rejected in order to take advantage of the competition that two task orders would provide. It was anticipated that the competition would improve (decrease) the wait time for callers. Instead, having two task orders has created an extensive administrative burden.

The purpose of this action is to ensure the continued operation of the Tier 1 call center without mission degradation during the transition from the NSCS task orders to the new CEC task order due to a government caused delay. USCIS solicited the recompete of the NSCS task order, combining the call center efforts on to one, giving fair opportunity to all USA Contact IDIQ holders. The result was the award to CSRA of the CEC task order, 70SBUR18F00000028, on 10/19/2017. Prior to award it was understood from Office of Information Technology (OIT) it would take 90 to 120 days to have the new required circuits installed and configured for CEC. The beginning of performance for CEC was initially scheduled for 2/1/2018. Due to the additional connectivity

JEFO No.: FY18-0189 Rev. 3/22/2018 - 3 -requirements, the NSCS circuits currently being used do not support the technology being used on CEC. As a result, delayed performance start date has been under the new task order until the technology is installed, configured and the contractor trained.

Once the award notice was relayed to OIT, OIT come back with it could take approximately 6 to 8 months to install and configure the new technology. In addition, OIT stated that they had budgeted for the equipment and services for 3rd Quarter of FY2018. That potentially put the beginning of performance out to July or August of 2019; which would have necessitated the cancelation and re-competing of the task order.

However, through intervention by upper USCIS management, funding came through in November 2017. The GFP and circuits were placed on order through the GSA Verizon Networx contract at the end of November 2017. The CEC network is expected to be available to go live starting in August 2018.

It is not feasible to use the new CEC task order to provide services prior to the installation of GFP and upgraded government circuits.

- From the recompete, CSRA was the successful offeror of the new Tier 1 CEC task order. The original period of performance (POP) start date of the task order was 2/1/2018. That was revised to 5/1/2018 to give the OIT time to sort out the IT requirements. Funding and equipment lead-times have contributed to the start of the POP being shifted to 9/1/2018.

- Consideration was given to using the CEC task order to provide services prior to the installation of government furnished property GFP using the existing infrastructure;

however, this would require a major rewrite of the task order requirements and repricing; which would be a scope change to the tasks and pricing.

- The new task order is different from the current task order, as it incorporates GFP inside the contractor’s facilities in order to allow greater continuity between Tier 1 and 2 contact centers. The move from the contractor furnished property to GFP represents a major shift between NCSC and CEC.

- The government is required to procure all new data and voice circuits in order for the contractor to perform under the new award to support the added technology. This is a major upgrade from the existing NCSC circuits.

- Before the CEC task order performance can start, OIT needs to purchase GFP as part of a complete government owned computer network; with voice over internet protocol (VOIP) capacities and software, as well as connectivity to Tier 2. The government is then responsible to install and configure the network inside the contractor owned facilities.

- OIT ordered the Verizon circuits and software in December 2017. That should allow for equipment and software installation to start April 2018 and be completed in early to Mid-August of 2018.

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While USCIS OIT works on installing GFP for the new task order, only the two existing contractors are capable of providing the services required at the level of quality needed for a contractor to successfully perform the NCSC services, as it requires the government to supply the voice and data circuits. Neither CSRA nor Enterprise Services have the USCIS circuit capacity to handle much more than 50 percent of the call volume, due to the size of the current NCSC circuits. Therefore, a sole-source task order must be issued to each.

- The current cost of the circuits is approximately $8.7 Million. For a non-incumbent contractor to perform the services, the government would have to procure the circuits.

Typically there is a 90 to 120 day lead-time to install new government circuits as used on NSCS. However, a non-incumbent contractor would also need to obtain an Authority to Operate (ATO), which could and has taken longer than 120 days.

Enterprise Services was initially delayed from its 6/1/2012 start day on the NCSC to 11/13/2012 due to the ATO process.

- Each of the two current task order contractors has circuits installed through the GSA Verizon Networx contract. It is not feasible that any contractors other than the current two incumbents could perform services for USCIS without substantial cost and delay to the government.

- Neither of the two incumbent contractors has the government circuit capacity to handle the entire USCIS Tier 1 call volume; therefore, the bridge requirement cannot be competed between the two incumbent contractors.

Failure to award an exception to fair opportunity bridge to CSRA will result in major degradation to the USCIS primary mission. Since CSRA handles nearly 50% of the call volume for Tier 1, that call center capacity would be lost until USCIS’ new CEC task order with CSRA performance begins on 9/1/2018.

5. Determination by the contracting officer that the anticipated cost to the government will be fair and reasonable.

Award is being made against the GSA USA Contact IDIQ contract; which has an ordering period currently set to expire on 9/10/2018. The current IDIQ includes negotiated pricing tables already determined by the GSA contracting officer to be fair and reasonable, which covers task orders issued against the IDIQ prior to the end of the ordering period for performance periods through 9/10/2023. The contracting officer will perform a price analysis comparing negotiated GSA pricing tables against the CSRA’s price proposal. The contracting officer determines that the anticipated price to the Government will be fair and reasonable based upon price analysis performed in accordance with FAR 15.4, comparing the proposed pricing to historical prices paid for the same or similar items, other than cost or pricing data provided by CSRA, and technical analysis. Therefore, it is determined by the contracting officer will have an adequate basis upon which to determine the anticipated cost to the government to be fair and reasonable.

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6. Any other facts supporting the justification.

Market research performed for 70SBUR18F00000028 indicated that GSA’s USA Contact vehicles were prequalified contact center companies with the relevant capability to provide live assistance and all services available as self-serve and in addition process service request and address changes under Tier 1. While the seven pre-qualified companies have similar capabilities, none could offer a seamless transition. Only CSRA and Enterprise Services can immediately provide CEC support beginning 1 May 2018, without an adverse impact to the immigration system – therefore, no market research (outside of that done for the above contract) was conducted for this requirement. In addition, only CSRA and Enterprise Services has personnel in place with the required clearances, extensive knowledge and experience with the on-going efforts. Therefore, it was determined that only CSRA and Enterprise Services could meet the Government’s requirements at this time.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

The subject requirement is a temporary, short-term task order to fill the gap until the CEC task order, which was competitively awarded, is in full production (expected to take place around September of 2018). Closer coordination will take place with the financial office and OIT for the newly awarded task order for CEC. Once successful transition to the newly competed task order is accomplished, there will no longer be a barrier that would lead to the exception to fair opportunity.

8. USCIS Office of Contracting intends to post this requirement on FedBizOpps, pursuant to FAR 16.505(b)(2)(ii)(D).

JEFO No.: FY18-0189 Rev. 3/22/2018 - 6 -

9. Technical/Requirements Personnel Certification.

Pursuant to FAR 16.505(b)(2)(ii)(B)(9), I certify that this requirement meets the government’s minimum need and that the supporting data, which form a basis for the justification, are accurate and complete.

Date

Supervisory Management and Program Analyst

USCIS CSPED

10. Contracting Officer Certification and Approval.

Pursuant to FAR 16.505(b)(2)(ii)(B)(8), I certify that this justification is accurate and complete to the best of my knowledge and belief and hereby determine that the circumstances for an exception to fair opportunity exist.

James A. Boehm Date Contracting Officer USCIS Office of Contracting

11. Approval.

Pursuant to FAR 16.505(b)(2)(ii)(B)(10), I hereby determine that the circumstances in FAR 16.505(b)(2)(i)(B) for an exception to fair opportunity exist and applies to this task order extension.

OPO Procuring Activity Advocate for Competition Date

04/17/2018 james.a.boehm @uscis.dhs.gov

Digitally signed by james.a.boehm@uscis.dhs.gov

DN:

cn=james.a.boehm@uscis.dhs.gov Date: 2018.04.17 09:01:50 -04'00' 17 April 2018

CATHERIN

E M BASKIN

Digitally signed by CATHERINE M BASKIN Date: 2018.04.17 13:36:46 -04'00'