73351020F0260 P00007.signed.REDACTED.pdf

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LIMITED SOURCES JUSTIFICATION

FOR AN ORDER / BPA EXCEEDING

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 8.405-6)

Task Order: GS00F022DA / 73351020F0260 P00007

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Agency and contracting activity. Small Business Administration (SBA), Office of Performance, Planning and the Chief Financial Officer, Office of Financial Operations & Acquisition Management, Acquisition Operations Division and the Office of Performance Systems Management (OPSM).

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

This is a limited sources justification for an out-of-scope modification to task order 73351020F0260 for the SBA Loan and Lender Monitoring System (L/LMS). This order will be a sole source to:

Dun & Bradstreet 11710 Plaza Drive Suite 900 Reston, Virginia 20190

(703) 807-5068 GSA Contract Number GS00F0022DA

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

The SBA requires loan, lender and portfolio monitoring, oversight, and credit risk management services on the 7(a) and 504 loan portfolios and participating industry lenders.

These services must be consistent with best practices utilized by commercial lending industry and bank regulators for credit risk management including early warning indicators of possible changes in portfolio performance trends. This requirement will apply credit risk prediction and evaluation to the SBA’s 7(a),504 loan portfolios and thePPP, RRF, and COVID EIDL pandemic programs enabling the SBA to predict and evaluate the risk of individual SBA participants and lenders to identify high risk lenders with five (Agency guaranteed loan programs. This requirement will also provide credit risk and program management support.

The SBA requires a period of performance extension from 07/09/2020-04/07/2022 to 07/09/2020-06/06/2022 to allow time for award of a competitive follow-on task order. A 2-month optional extension period will also be included through this modification to allow for compliance with FAR 52.237-3 Continuity of Services clause. The total value of the order will be increased by $3,586,752 from $18,003,043.69 to $21,589,795.69.

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PoP Extension (04/07/2022 – 06/06/2022) $1,793,376.00 Optional PoP Extension

(06/07/2022 – 08/06/2022) $1,793,376.00

Total $3,586,752.00

4. Authority and supporting rationale. The following circumstance justifies limiting the source as supported below:

Only one source under the authority of FAR 8.405-6(a)(1)(i)(B) - Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

This modification is for a short-term extension to ensure continuity of service while the SBA awards a competitive follow-on task order. Dun & Bradstreet (D&B), in partnership with the SBA, conceptualized, created and implemented the L/LMS. D&B has been providing the required services for over6 years and is the only firm with enough knowledge of SBA risk management operations and the Loan and Lender Monitoring System to provide the services required for this contract for the limited time period and to effectuate a successful transition to another contractor for this highly critical requirement. Without L/LMS, SBA would be unable to perform off-site lender and portfolio monitoring on SBA’s 7(a), 504, microloan regular programs or on SBA’s PPP, RRF, and COVID EIDL pandemic programs. Additionally, without awarding this short-term contract during a full-competitive procurement, SBA would be unable to report to agency stakeholders including but not limited to, SBA leadership, Congress, the Office of Inspector General, GAO, and the public on the performance of those SBA programs.

The recompete for the new acquisition is anticipated to be solicited and awarded by May 6, 2022.

In accordance with FAR 52.237-3, Continuity of Services, SBA estimates 90-day transition plan. The technical issues facing a new vendor are as follows:

- System migration from D&B to new contractor (very high risk) o Currently the L/LMS system is hosted by a D&B subcontractor. It is highly encouraged that the new contractor has time to subcontract with the same vendor to continue hosting L/LMS until migration can be completed

- Quarterly credit scoring (high risk) o A new contractor will have to develop, validate, and implement a new predictive scoring system for the 6/30/22 quarterly reports. The current models use a combination of SBPS credit scores that can be purchased off-the-shelf, SBA data, and proprietary D&B data. It is highly recommended the new contractor have time to purchase SBPS scores and run the current models without the proprietary D&B data while they develop new models.

- Hiring, clearing, and training new staff to take over the work (medium-high risk)

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5. Determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

As most of the requirements can be priced using Dun & Bradstreet’s GSA pricing which has already been found fair and reasonable, and Dun & Bradstreet have successfully performed this requirement since 2003, the Contracting Officer has determined that award of a task order under Dun & Bradstreet’s schedule provides best value to the Government.

6. Market research conducted among schedule holders (or reason market research was not conducted).

Market research was not conducted for this modification for the reasons indicated in Section 4.

7. Any other facts supporting the justification.

There are no other facts.

8. Actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

Efforts to compete the follow-on of this requirement have already commenced. An RFI was issued in Nov 31, 2021 and was left open for 30 days. Multiple vendors responded and provided feedback. Based on this feedback, changes were needed to the requirements documents. It is anticipated a competitive solicitation and award will be completed within the next 30 days. This short-term award is necessary to avoid a lapse in service while SBA conducts a competitive procurement for the longer-term award.

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CERTIFICATION AND APPROVAL

9. Technical / Requirements Representative Certification. I certify that this requirement constitutes the Government’s minimum needs and the supporting data provided herein is accurate and complete to the best of my knowledge and belief.

Josh Dykema, Contracting Officer’s Representative Office of Performance Systems Management (OPSM)

10. Contracting Officer’s Certification and Approval. I certify this justification is accurate and complete to the best of my knowledge and belief, and hereby provide approval.

Laura Saddison, Contracting Officer

11. Approval

Kip Sheppard, Director, Acquisition Division

Sara Soeka, Competition Advocate