1-JOFOC Limiting Source_FITT Systems-Hosting Final-COR_CS_CO_CA_HCA.pdf

FEDERAL ENERGY REGULATORY COMMISSION

OFFICE OF THE EXECUTIVE DIRECTOR

ACQUISITION SERVICES DIVISION

JUSTIFICATION FOR OTHER THAN FULL & OPEN COMPETITION

LIMITED SOURCES JUSTIFICATION

PROJECT NAME: Financial System Operational Support and Hosting Services

This acquisition is conducted under the authority of the Multiple-Award Schedule Program (see 8.401). The following Limited Sources Justification is prepared in accordance with FAR Subpart 8.405-6(c).

1. AGENCY AND CONTRACTING ACTIVITY:

Federal Energy Regulatory Commission Office of the Executive Director Acquisition Services Division 888 1st Street, NE Washington, DC 20426

Federal Energy Regulatory Commission (FERC) is an independent agency within the Department of Energy (DOE) headquartered in Washington DC that promotes dependable, affordable energy through sustained competitive markets. The Commission's legal authority comes from the Federal Power Act of 1935, the Natural Gas Act (NGA) of 1938, the Natural Gas Policy Act (NGPA) of 1978, the Public Utility Regulatory Policies Act of 1978, and the Energy Policy Act of 1992.

FERC:

Regulates the transmission and sale of natural gas for resale in interstate commerce.

Regulates the transmission of oil by pipeline in interstate commerce.

Regulates the transmission and wholesale sales of electricity in interstate commerce.

Licenses and inspects private, municipal, and state hydroelectric projects.

Oversees environmental matters related to natural gas, oil, electricity, and hydroelectric projects.

Administers accounting and financial reporting regulations and conduct of jurisdictional companies.

Approves site choices as well as abandonment of interstate pipeline facilities.

For further information regarding FERC’s mission please refer to www.ferc.gov

Within FERC, the Financial Information Technology and Travel (FITT) Division is aligned to the Office of the Executive Director and reports directly to the Chief Financial Officer (CFO). FITT serves the Commission by providing high quality services and innovative solutions that enable FERC’s financial and travel communities to successfully achieve business requirements, regulatory compliance, and strategic operational objectives.

2. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED:

The Federal Energy Regulatory Commission (FERC) intends to award a limited source action to Accenture Federal Services, LLC (AFS), 800 N Glebe Road, Ste 300, Arlington, Virginia 22203 as a logical-follow on to previously competed General Services Administration (GSA) Federal Supply Schedule (FSS) Task Order. No.

FERC-16-F-0123, which is a Firm Fixed Price (FFP) Labor Hour (LH) Task Order issued under GSA FSS 70 against Contract Number GS-35F-0371N, with Accenture Federal Services, LLC (AFS) for Chief Financial Officer (CFO) Systems Support Services in accordance with the PeopleSoft Application Support and Hosting Services.

3. DESCRIPTION OF REQUIREMENT AND VALUE:

This procurement is for the Office of the Executive Director (OED), Chief Financial Officer (CFO), Financial Information Technology and Travel (FITT) Division, is for the purchase of program management, hosting services, licenses, and operations/maintenance services for FERC’s ServiceNow system, PeopleSoft Financials application and BI Reporting Services. FERC requires AFS to continue to be a trusted advisor, to include proposing best practices, and recommendations throughout the lifecycle of the contract.

Total Anticipated Estimated Dollar Value and Performance Period:

Base Period $ 6,041,199.84 Option Period 1 $ 6,222,436.32 Option Period 2

February 20, 2024 – February 19, 2025 February 20, 2025 – February 19, 2026 February 20, 2026 – February 19, 2027 $ 6,409,110.96

Anticipated Estimated Total Contract Value: $18,372,747.12

4. STATUTORY AUTHORITY:

The statutory authority permitting limiting sources is in accordance with FAR 8.405-6:

(a) Orders or BPAs exceeding the micro-purchase threshold based on a limited sources justification.

(1) Circumstances justifying limiting the source.

(i) For a proposed order or BPA with an estimated value exceeding the micro-purchase threshold not placed or established in accordance with the procedures in, 8.405-2, or 8.405-3, the only circumstances that may justify the action are–

[ ] (A) An urgent and compelling need exists, and following the procedures would result in unacceptable delays;

[ ] (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; or

[X] (C) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

5. DEMONSTRATE PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS:

As increasing elements within FERC’s financial solution reach their ‘end of life’, FERC has entered the preliminary stages of exploring options to modernize its operations and supporting technology. FERC’s current financial solution consists of an array of applications, integrations, and reporting utilities that have been incrementally implemented to support 20+ years of evolving business requirements.

The logical follow-on contract will allow the CFO executive team in maintaining stability and reliability across all of FERC’s production financial systems while FERC conducts its analysis and identifies the optimal path forward.

As the CFO works towards achieving this goal, FERC management is not able to solicitate a reliable/finalized Statement of Work, or able to commit to the high level of effort that would be required to support a new contractor with transitioning to a new system integrator would expose FERC to a significant amount of avoidable risk, because the new organization would have to overcome an immense knowledge curve to proficiently administer the Commission’s financial applications. AFS possess the unique qualifications to deliver the highest possible value and has:

accumulated tenure with designing and administering FERC’s applications and programs, which directly translates into proficiency investigating and resolving issues that materialize within FERC’s Production environments, configured and implemented all of FERC’s financial applications (i.e., PeopleSoft Financials, ServiceNow FLOW, and Business Intelligence reporting), designed and implemented FERC’s six customized interfaces that automatically exchange, interpret, and process information from the following sources: SAP Concur’s eTravel application (ConcurGov);

Distributed Solution Inc.’s Automated Acquisition Management Solution (AAMS); Department of the Interior's Federal Personnel Payroll System; US Bank’s Lockbox; US Department of Treasury Intra- Government Payment and Collection system; and ServiceNow (FLOW). Retaining the same resources that were directly responsible for developing the interfaces is advantageous, because it preserves continuity and ensures accountability, established valued partnerships and productive working relationships with FERC office personnel, complementary Commission contractors, and other partnering federal agencies, operated within FERC’s culture (understand priorities, personalities, etc.) to achieve results, designed, developed, tested, and implemented every customized module, program, and report, partnered with FERC’s existing Financial Hosting Provider – Rackspace Government Solutions, passed every FedRAMP Third Party Assessment Organization (3PAO) audit, passed every OIG FISMA/FISCAM audit, and established a highly respected record of achieving FERC’s strategic objectives.

Based upon factors explained in this document FERC Management determined a logical follow-on contract for which this Limited Sources Justification applies in accordance with FAR 8.405-6(c) is appropriate.

6. SOURCES SOUGHT EFFORTS:

This Limited Sources Justification and Request for Quote (RFQ) will be posted to a Government point of entry within 14 days after award for 30 days in efforts to seek additional sources.

7. DETERMINATION OF BEST VALUE FAR 8.404(d):

GSA has already determined the prices of supplies and fixed priced services under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d). By placing an order against a schedule contract using the procedures in 8.405, the ordering activity has concluded that the order represents the best value (as defined in FAR 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government’s needs. Although GSA has already negotiated fair and reasonable pricing, ordering activities may seek additional discounts before placing an order (see 8.405-4). The total price will be compared to the IGE and the previous contract.

8. DESCRIPTION OF MARKET RESEARCH CONDUCTED & RESULTS:

Market research was performed via GSA eLibrary, Department of Energy (DOE) CIO Business Operation Support Services (CBOSS) Call Order, and historical data.

On September 19, 2023, a draft SOW was presented/circulated with DOE representatives to confirm FERC’s CFO-FITT’s requirements fall within the scope of services covered by DOE CBOSS. FERC’s goal was to implement an independent Call Order on February 19, 2024. On December 7, 2023, ASD Director, Kim Lewis spoke to DOE CBOSS Contracting Officer and was told that DOE did not have the “bandwidth” to process call order under DOE CBOSS for FERC’s CFO-FITT requirement.

On December 20, 2023, ASD Director, Branch Chiefs and CO met, and decision was made to change FERC’s CFO-FITT acquisition strategy to a logical follow-on contract for which this Limited Sources Justification applies in accordance with FAR 8.405-6(c).

9. ANY OTHER FACTORS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN COMPETITION:

AFS developed solutions tailored to specific business processes for FERC, through PeopleSoft Financials which is a key Oracle Commercial off-the-shelf (COTS) application that is used by FERC for Federal financial, accounting and security requirements. FERC is reaching the end of PeopleSoft Financials lifecycle and is currently in the process of performing an assessment that will determine a timeline to replace PeopleSoft Financials. The assessment will highlight the potential move to a next generation Software as a Service (SaaS), and will help FERC understand the following:

The readiness of these SaaS offerings for Federal financial, accounting and security requirements, The benefits and potential cost for migrating to and operating a SaaS solution/service, The ideal timing for such a migration, and The leaders in the market and which may be feasible options for FERC to consider.

10. A LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST IN THE

ACQUISITION:

None.

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 THE

SERVICES REQUIRED:

The logical follow-on contract for which this Limited Sources Justification applies to will be done in accordance with FAR 8.405-6(c). This requires that the preceding award to have been made in accordance with the applicable FSS ordering procedures. After the logical follow-on contract has expired the preceding contract will have not been awarded in accordance with the applicable FSS ordering procedures and thus must be re-competed unless it falls under another exception. This acquisition will enable competition in the future.

12. CERTIFICATIONS & APPROVALS: (Signatures are required)

I certify that the supporting data under my cognizance that are included in this document are accurate and complete to the best of my knowledge and belief.

Marc Atchade Contracting Officer Representative Financial Information Technology and Travel Division Office of the Executive Director

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Lisa Tillman Contract Specialist Acquisition Services Division

Victoria Max Contracting Officer Acquisition Services Division

I have reviewed the Justification and find the document adequately addresses the requirements of FAR Subpart FAR 8.405-6(a)(1)(C).

Ryan I. Kirkwood Competition Advocate Acquisition Services Division

Anton C. Porter Executive Director