JOFOC Limiting Source_Sole Source_AAMS COR_CO_CA Signed.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:

Automated Acquisition Management System (AAMS) Software as a Service (SaaS)

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 sole source action to Distributed Solutions, Inc. (DSI), 12350 Pinecrest Road, Reston, Virginia 20191 to continue the use DSI’s proprietary Automated Acquisition Management System (AAMS).

This acquisition is a follow-on to an existing General Services Administration (GSA) Federal Supply Schedule (FSS) Contract Number 47QTCA18D0095 Task Order 89603021F0011, with performance ending on March 26, 2024, which was a logical follow-on to Task Order FERC-10-F-0551 which is a firm-fixed price Delivery Order issued under GSA FSS 70 against Contract Number GS-35F-5370H, with DSI for software licenses and maintenance support associated with their proprietary AAMS.

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, information technology security support, and operations/maintenance services for FERC’s AAMS application. FERC requires DSI to continue to be a trusted advisor, to include proposing best practices, and recommendations that optimize FERC’s acquisition processes and service delivery throughout the lifecycle of the contract.

FERC’s Acquisition Services Division (ASD) currently utilizes AAMS as a contract document generation, milestone tracking, and contract file management system.

Total Anticipated Estimated Dollar Value and Performance Period:

Base Period March 27, 2024 – March 26, 2025 $ 304,002.94 Option Period 1 March 27, 2025 – March 26, 2026 $ 313,123.03 Option Period 2 March 27, 2026 – March 26, 2027 $ 322,516.72 Anticipated Estimated Total Contract Value: $ 939,642.69

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–

[X] (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

[ ] (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:

There is an urgent need for FERC’s ASD to continue to use DSI’s proprietary Automated Acquisition Management System (AAMS) because replacing AAMS at this time would require that FERC integrates and configures AAMS’ replacement twice. AAMS is utilized for contract document generation, milestone tracking, contract file management, and is closely integrated with PeopleSoft Financials, a key Oracle Commercial off-the-shelf (COTS) application which is used by FERC for Federal financial, accounting and security requirements.

FERC is in the process to determine a timeline to replace PeopleSoft Financials with a next generation Software as a Service (SaaS) offering. Changing AAMS would require accommodating, integrating, and configuring AAMS’ replacement; firstly, with PeopleSoft Financials, and secondly with the SaaS replacement of PeopleSoft Financials.

The period of performance for the new contract shall consist of a 3-year period and will allow DSI to continue providing software licenses and support to FERC, while the ASD and the FITT complete the migration from PeopleSoft Financials to the next generation SaaS solution for financial management. Specifically, ASD and FITT are actively engaged in implementing applications that are designed to enforce interdependencies that exist between CFO business processes, maximize automation, and elevate the quality of information available to support internal decision making. Fundamentally, the CFO SaaS Financials project aims to:

design and implement a central gateway for CFO customers to request and receive financial-related services (including procuring goods and services).

create a unique identifier that ties an initial funding request through contractual award to disbursement of treasury payments.

leverage the initial office funding request unique identifier to forecast the Department of Budget and Acquisition Services Division’s workload.

absorb and integrate all the residual customer-facing ASD business processes that fall outside the existing CFO applications.

provide clear visual processing pathways that enforce the natural progression of action items defined by interdependencies that exist between ASD business processes that cross organizational boundaries.

automate the compilation and distribution of acquisition information.

enable CFO customers to gain transparency and insight into the status of ASD service requests and/or business processes.

create a unified portfolio of tailored reports/dashboards strategically designed for target CFO audiences (i.e., CORs, Office Directors, OED executives, etc.)

As the CFO organization works toward achieving the objectives outlined above, ASD is vigorously reassessing and reengineering their business processes, which is having cascading effects on how Contracting Officers/Specialists interact with FERC’s acquisition application and how the acquisition application interfaces with FERC’s complimentary peripheral financial systems. Given the current state of evolving application requirements, 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 the following transitional activities:

Procuring and configuring the necessary technological infrastructure for the new contract writing system Certifying the new acquisition system (i.e., crafting/attesting the entire FedRAMP package, Memorandum of Understanding, Interagency agreement, etc.)

Participating in application configuration work sessions for the new system.

Outlining the Acquisition Service Division’s core mission.

Defining FERC’s ‘As-Is’ business processes (

Assessing and providing feedback on proposed ‘To-Be’ business processes.

Defining functional roles and translating business process responsibilities into applicable system security roles and application permission lists.

Entering all baseline application settings and security administration configuration.

Crafting all change management documentation related to the new system (i.e., end-user guides, process flow diagrams, online tutorials, etc.)

Developing and delivering classroom training on the new system.

Overcoming the inherent knowledge curve associated with learning a new system.

Migrating historical acquisition data to a new application.

Designing, developing, testing, and implementing new integrations between FERC’s financial applications (i.e., PeopleSoft Financials, ServiceNow, Business Intelligence, etc.) and a new acquisition system.

Configuring the new application to successful interface with peripheral acquisition systems (e.g., SAM, FPDSNG, eBuy, FBO, ORCA, etc.)

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):

The AAMS system is provided at a Firm Fixed Price (FFP) though a Statement of Work (SOW). GSA has already determined the prices of supplies and fixed priced services under schedule contracts to be fair and reasonable at award of DSI’s master GSA contract award. 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. This in combination with the rationale explained in this document the CO determines that the contract with DSI for continued use of the AAMS system represents the best value to the government.

8. DESCRIPTION OF MARKET RESEARCH CONDUCTED & RESULTS:

Market research was performed via GSA eLibrary, and historical data. On February 21, 2020 FERC sent a Request for Information (RFI) to three schedule holders (CGI, CACI, Unison). Each firm responded and were found to be all capable.

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

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

The FERC’s ASD currently utilizes AAMS as a contract document generation, milestone tracking, and contract file management system. The IGE for the three years of this new contract is $939,642.69. The estimated integration costs of adopting a new system are $1,662,962.16 and will be incurred after this contract is completed and the re-competition is completed.

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 urgent and compelling need exists sole source contract for which this Limited Sources Justification applies to will be done in accordance with FAR 8.405-6(c). FERC will commence a re-compete competition issuing a solicitation upon completion of the CFO SaaS Financials project the entire ‘acquisition system’ contract which will be subject to full and open competition.

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 Federal Energy Regulatory Commission

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

Lisa Tillman Contracting Officer Acquisition Services Division Office of the Executive Director Federal Energy Regulatory Commission

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 Office of the Executive Director Federal Energy Regulatory Commission