J&A_70Z0G319RPWZ08200.pdf

Justification for Other Than Full and Open Competition

Under 10 U.S.C. 2304(c)(7)

Only One Responsible Source and No Other Supplies or Services will Satisfy

Agency Requirements

Pursuant to FAR Subpart 13.5 and in accordance with the requirements of FAR 13.500 and FAR

13.501(a)(1)(ii), this commercial item acquisition is exempt from the requirements of FAR Part 6 but must nevertheless include a sole source justification utilizing the format prescribed in FAR

Part 6.303-2, modified to reflect that this is an acquisition conducted under the simplified procedures for certain commercial items authorized by FAR Subpart 13.5. Use of this authority is justified as follows:

(1)Agency and the Contracting Activity:

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Operations

Systems Center (OSC), Kearneysville, WV 25430.

(2)Nature and/or Description of Action Being Approved:

The USCG intends to award a sole source contract to Professional Software Consortium (PSC) for brand name Web Travel Preparation and Examination System (TPAX) and the Integrated

Automated Travel System (IATS) software licenses and support. Web TPAX/IATS provides enterprise web-based systems and solutions for processing travel authorizations and travel claims for Temporary Duty (TDY) and Permanent Change of Station (PCS) travel for civilians and

Uniformed Service members in accordance with Federal Travel Regulations (FTR) and Joint

Travel Regulations (JTR). It is the Government’s intent to issue a Firm-Fixed Price contract for a period of twelve (12) months with two option periods not to exceed three (3) years included for a total price of $XXX. The timeframe covers the competitive follow on contract, being done by

USCG Headquarters Contracting Branch (CG-9123), to solicit, evaluate, and award the follow on contract. The only company who can provide TPAX/IATS software is the owner of the software:

Professional Software Consortium

4303 Vineland Rd Suite F7

Orlando, FL 32811-7372

(3)Description of the Supplies/Services:

The USCG requires name brand TPAX/IATS software as CG-1 Human Resources Directorate uses Web TPAX/IATS for enterprise web-based systems and solutions for processing travel authorizations and travel claims for Temporary Duty (TDY) and Permanent Change of Station

(PCS) travel for civilians and Uniformed Service members. Web TPAX/IATS provides enterprise web-based systems and solutions for processing travel authorizations and travel claims for TDY and PCS travel for civilians and Uniformed Service members in accordance with FTR and JTR. The system provides all travel documentation, computations, accounting interfaces, federal tax reporting, and payment by check or electronic funds transfer, including split disbursement to government travel credit card, for all travelers, including active duty, reserve, and separated/retired military members. The USCG typically prepares and pays 150K travel claims for over 100K travelers in a single fiscal year. Without the use of Web TPAX/IATS software, USCG would be processing travel claims manually.

The total estimated amount, including options, is $.

Base Year Option 1 Option 2 Total

Contractor

Maintenance &

Enhancements

(4) Identification of Statutory Authority Permitting Other Than Full and Open Competition:

The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c)(1), implemented by Federal Acquisition Regulation (FAR) 13.500 and FAR 13.501(a)(1)(ii), Sole

Source.

(5) Demonstration That the Nature of the Acquisition Requires Use of the Authority Cited:

Web TPAX/IATS is proprietary software owned by PSC and licenses, support, and warranties can only be acquired through PSC; there are no authorized resellers. Web TPAX/IATS software is the only software that meets the requirements outlined in FTR and JTR for uniformed service members and therefore performs all the functions necessary to support all USCG travel. Web

TPAX/IATS is the only software that provides enterprise web-based systems and solutions for processing travel authorizations and travel claims for TDY and PCS travel for civilians and

Uniformed Service members in accordance with FTR and JTR.

Web TPAX/IATS is the only software that performs all functions necessary to support USCG

Travel. TPAX/IATS currently supports all travel for the Coast Guard. This system is the primary tool for USCG to provide all travel documentation, computations, accounting interfaces, federal tax reporting, and payment by check or electronic funds transfer, including split disbursement to government travel credit card. If the system were taken off the network, USCG travel community would be overwhelmed and left without a method to manage the myriad of issues associated with

USCG travel functions, thereby severely impacting all USCG missions. There are no authorized resellers for the TPAX/IATS software. The software must be purchased from the software owner, PSC.

The USCG is actively engaged in two separate and distinct procurement actions related to the

TPAX system. One action is a competitive follow on for the USCG’s travel system is being conducted by the USCG Headquarters Contracting Branch (CG-9123). The publically available

DHS APFS record F2019046024 for the competitive action states this action will enable the

“USCG implementation of the government wide mandated E-Travel System. The USCG is mandated by the Federal Travel Regulation (FTR) Amendment 2003-07, FTR 301-73.100 to implement the GSA master schedule ETS2 solution” and award is anticipated in the 4th Quarter of FY2019. Additionally, a transition time from the current contract to the follow on is around

18 months for system implementation and data transfer. The second action is this sole source action to continue licensing and maintenance with the incumbent, PSC being done by OSC

Contracting Branch. The current contract expires on 15 August 2019 so the time period will be for a base period of twelve months with potential option periods not to exceed three years. The timeframe is to ensure CG-9123 can solicit, evaluate, and award a follow on as well as encompass the designated transition for system implementation and data transfer. These option periods will allow the USCG the flexibility to transition to the competed solution at the earliest opportunity. Thus, a sole source to the incumbent, PSC, is in the best interests of the

Government to ensure continued support during the solicitation process of the follow on as well as ensuring a transition occurs with no negative mission impact.

(6) Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential

Sources as is Practicable:

The Contracting Officer issued a Request for Information (RFI) on April 15, 2019 to which five

(5) vendors responded. However, none of them were authorized resellers of TPAX/IATS software.

(7) Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable:

The Contracting Officer has determined that the anticipated price for the required software and software support will be fair and reasonable. An analysis will be done on the proposed price based on comparison with the Independent Government Cost Estimate (IGCE) and historical pricing data to ensure a reasonable price.

(8) Description of Market Research:

An RFI was done; however, there are no authorized resellers of TPAX/IATS. Therefore, PSC is the only responsible source.

(9) Any Other Facts Supporting the Use of Other Than Full and Open Competition:

None.

(10) A Listing of the Sources, if Any, That Expressed, in Writing, an Interest in the

Acquisition:

In response to the RFI issued April 15, 2019, 5 vendors responded (Apptricity Government

Services, CW Government Travel Inc., Deloitte Consulting, LLP, mLINQS, LLC, and Concur

Technologies). mLINQS, LLC provided a new capability response to the USCG Intent Notice to

Sole Source, dated June 25, 2019. The COR reviewed the capability statement but determined the statement was mixing the two requirements, the follow on and the sole source action. In speaking to mLINQS, the Contracting Officer found out mLINQS could meet the current requirements of the sole source action, but agreed they would be unable to fully meet the requirement due to the implementation and transition period that is required.

(11) 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 is Made:

The follow on is being drafted by USCG Headquarters Contracting Branch (CG-9123) and will be competed.

(12) Contracting Officer’s Certification:

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

Date

Contracting Officer, OSC

C4IT, USCG, Department of Homeland Security

(13) Technical/Requirements Personnel Certification:

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

USCG Asset Line Manager

C4IT, USCG, Department of Homeland Security

(14) Legal Counsel Review:

I reviewed this Justification and Approval and find it legally sufficient.

Procurement Law Attorney

APPROVAL:

Command Activity Competition Advocate (CPACA)