Data_Integration_SS_CG-913_Fair_Opportunity_Exception_Justification_SIGNED.pdf

Justification for an Exception to Fair Opportunity Data Integration Support Services for CG-913

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

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Assistant Commandant for Acquisition and Chief Acquisition Officer (CG-9), Office of Contract Operations (CG-912), Formal Contracts Division III (CG-9123) proposes to award a task order for a period of performance of one (1) twelve (12) month base period and four (4) twelve (12) month option periods under Best-in-Class solution General Services Administration (GSA) 8(a) Streamlined Technology Acquisition Resources for Services (STARS) II Contract No.

GS00Q17GWD2066 on the basis of an exception to fair opportunity.

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

The USCG proposes to issue Request for Quote No. 70Z02319RACS00900 to award a firm, fixed-price task order, without considering other sources, under GSA 8(a) STARS II Contract No. GS00Q17GWD2066 pursuant to FAR 16.505(b)(2)(ii)(B) for Data Integration Support Services for the Office of Procurement Policy and Oversight (CG-913).

The USCG proposes to award this firm, fixed-price task order to:

Ardent Technologies Inc.

6234 Far Hills Avenue Dayton, OH 45459-1927

3. Description of Supplies/Services.

The task is to integrate acquisition data from multiple sources into a consolidated Coast Guard Acquisition Directorate data mart, the Acquisition Performance Management System (APMS).

Data will be extracted from the Contract Information Management System (CIMS), Core Accounting System (CAS), Financial Procurement Desktop (FPD), Aviation Logistics Management Information System (ALMIS), Contract Lifecycle Management (CLM), and Naval Electronics Supply Support System (NESSS) and is used to develop and support acquisition performance metrics, measures, and management reports.

This requirement was not previously offered into the Small Business Administration’s (SBA) 8(a) Business Development Program. Support services are currently provided under Task Order No. HSCG23-14-J-ACS031 under Enterprise Acquisition Gateway for Leading Edge Solutions II (EAGLE II) Contract No. HSHQDC-13-D-E2019. The current task order was previously competed among EAGLE II Functional Category II Small Business Track contract holders.

The place of performance for this requirement is the USCG Headquarters (HQ). The period of performance of this task order is one (1) twelve (12) month base period and four (4) twelve (12) month option periods with an anticipated start date of 30 September 2019.

The total estimated price for the task order is as follows:

Period of Performance Estimate Base Period $224,492.80

Option Period One $231,097.60 Option Period Two $237,907.20 Option Period Three $244,921.60 Option Period Four $252,140.80

Total Estimated Price $1,190,560.00

Due to the nature of the requirements in which the acquisition performance metrics, measures, and management reports benefit both procurement, construction, and improvements (PC&I) and operating expense (OE) acquisitions, half of the requirements will be funded with Fiscal Year (FY) 2019 PC&I funding and the other half of the requirements will be funded with FY 2019 OE funding.

4. Identify the exception to fair opportunity and supporting rationale.

Justification for Exception to Fair Opportunity –

This procurement is being conducted under the authority of FAR 16.505(b)(2)(i)(E): For orders exceeding the simplified acquisition threshold, the FAR expressly authorizes or requires that the purchase be made from a specified source.

In accordance with FAR 19.8(d), for procurements above the simplified acquisition threshold, the contracting officer shall consider 8(a) set-asides or sole source awards before considering small business set-asides. The total estimated value of this requirement is under the 8(a) competitive threshold of $4M. Through market research, Ardent Technologies Inc., an 8(a) small, disadvantaged business and a GSA 8(a) STARS II contract holder, is capable of supporting these requirements. GSA 8(a) STARS II was authorized under the provisions of Section 8(a) of the Small Business Act 15 U.S.C. 637(a) and retains the 8(a) sole source, or “directed order,” authority found in FAR 19.8.

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

The Contracting Officer anticipates that the price will be fair and reasonable based on conducting a price analysis in accordance with FAR 15.404-1(b)(2)(v), comparison of proposed prices with the independent Government cost estimate that was developed utilizing the GSA 8(a) STARS II pricing tool, and FAR 15.404-1(b)(2)(ii), comparison of the proposed prices to historical prices paid under the current task order, Task Order No. HSCG23-14-J-ACS031. Prior to awarding the task order, the ordering activity will conduct a price evaluation by considering the level of effort and mix of labor hours proposed.

6. USCG intends to post this requirement on FedBizOpps pursuant to FAR 16.505(b)(2)(ii)(D).

7. A Listing of the Sources, That Expressed in Writing, an Interest in the Acquisition.

A Request for Information (RFI) was issued at the government point of entry, FedBizOpps (FBO.gov), on 21 June 2019 to determine if there are any 8(a) Small, Disadvantaged Businesses (SDB) capable of performing these requirements. Ten 8(a) SDBs responded to the RFI, as follows:

BridgeCross Ardent Chenega Professional & Technical

Services TalTeam Pioneer Corporate Services, Inc

SONA Networks, LLC Tri-Force Consulting Services, Inc.

SP8CTRUM, LLC

SRR International Inc Definitive Logic

Of the ten 8(a) respondents to the RFI, four 8(a) contractors are capable of supporting the requirements:

BridgeCross Ardent Chenega Professional & Technical Services TalTeam

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

In accordance with the GSA 8(a) STARS II ordering guide, in order to compete requirements under the $4M competitive threshold under GSA 8(a) STARS II, the ordering agency must seek and receive approval from the SBA. In accordance with 13 CFR 124.506(c)(1), the Associate Administrator for Business Development (AA/BD) may approve a request from a procuring activity to compete a requirement that is below the applicable competitive threshold among eligible participants when a large number of potential awardees exist. Ardent Technologies Inc.

is the only 8(a) business consideredcapable of supporting these requirements that is a current DHS Strategic Sourcing Vehicle (SSV) holder. There are not a large number of potential awardees that are DHS SSV contract holders at this time. In the event there are a large number of potential awardees in the future, the USCG will consider requesting approval to compete the requirements if they continue to fall under the competitive threshold.

9. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Ryan Shaughnessy Date Contracting Officer

10. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Doug Sansone Date Technical Representative/COR

09/09/2019

SHAUGHNESSY.RY

AN.W.1137531328

Digitally signed by

SHAUGHNESSY.RYAN.W.1137531328

Date: 2019.09.09 15:09:10 -04'00'

SANSONE.WILLIA

M.D.1046900452

Digitally signed by

SANSONE.WILLIAM.D.104690045

Date: 2019.09.09 17:24:43 -04'00'

11. Legal Review and Concurrence:

Data Integration Support Services for CG-913

I have reviewed this justification and consider it legally sufficient.

lfiror dA � Ta botNicholas Attorney

APPROVAL:

Bonnie Hanger

CPACA

.nAwiM� Date

Date