91003119C0007_AEDS II Justification and Approval_22_23FAFSACycle_071420_Redacted5.pdf

JUSTIFICATION & APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

(AMENDMENT 1)

FAR 6.302-1 – Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

Federal Student Aid (FSA) is proposing to enter into a fixed-price non-competitive contract with the incumbent General Dynamics One Source (GDOS) located at 3150 Fairview Park Drive, Falls Church, VA 22042 for the continued Application Eligibility Determination System (AEDS). This proposed action will allow GDOS to develop the 22/23 FAFSA application development cycle support and to include a 3rd option period from September 30, 2022 to September 29, 2023 for operations and maintenance to ensure no disruption to current services.

1. Identification of Agency and Contracting Activity

United States Department of Education (ED), Federal Student Aid (FSA).

2. Nature/Description of Action Being Approved

A Firm Fixed-price non-competitive contract (AEDS II) was awarded to the incumbent, General Dynamics One Source (GDOS) on September 26, 2019 for the continued support of the AEDS. The AEDS II sole source contract is a three (3) year contract, which is comprised of one (1) Base Year (12 months) and two (2) 1-Year Options. The AEDS II Contract is set to expire on September 29, 2022.

The AEDS II Contract provides the continued support of a Central Processing System (CPS) which calculates eligibility for federal aid when students/parents apply through fafsa.gov, myStudentAid mobile app, phone, paper applications, or with help from their school’s financial aid office via Financial Aid Administrators (FAA) Access or EDExpress. In addition, the AEDS II Contract supports Participation Management, an enrollment system for schools and other partners to access FSA’s systems and exchange information with FSA through the Student Aid Internet Gateway (SAIG).

Under the AEDS II Contract GDOS was tasked with developing the 21-22 FAFSA application cycle during the base year of their contract. This 21-22 FAFSA application cycle is currently being developed and will be available on October 1, 2020. The 21-22 FAFSA application cycle will then go into Operations & Maintenance phase of this contract for two

(2) years (Option Years 1 and 2) until the 21-22 FAFSA application cycle is retired in September of 2022 (See Appendix 1 for additional explanation).

While the AEDS II sole source contract was being negotiated, an active procurement for the NextGen Optimal Processing Solution (OPS) was underway. The OPS Solicitation had a target Contract Award date of June 2020 and a scope that required the new OPS Contractor to develop the 22-23 FAFSA application cycle. This strategy would require parallel operations, with the AEDS II sole source contract continuing to maintain the other active application cycles while the new OPS Contractor developed the new 22-23 FAFSA application cycle. At the end of Year 3 of the AEDS II sole source contract, the plan was to have all AEDS II functionality transitioned to the OPS Contract.

However, the OPS procurement never proceeded beyond the solicitation phase because of the recent passing of the Fostering Undergraduate Talent by Unlocking Resources for Education (FUTURE) Act (H.R. 5363). The FUTURE Act impacts the OPS procurement since it adds additional requirements for securing Federal Tax Information (FTI) which is passed from the Internal Revenue Service (IRS) to FSA to determine aid eligibility. Concurrently, OPS funding was deferred to FY22. As a result, the OPS Solicitation was cancelled on April 3, 2020 and the requirements for OPS are being re-evaluated and revised to reflect the impacts of the FUTURE Act. For a copy of the Notice see Appendix 2; also see link for OPS cancellation on beta.SAM.gov:

https://beta.sam.gov/opp/9b6d1275b9d54ae49d25eca0b663942d/view?keywords=91003119r 0007&sort=-relevance&index=&is active=true&page=1.

Due to the cancellation of the OPS Solicitation, the OPS Contract award will be delayed significantly. Therefore, the OPS Contract will not be awarded in time for the OPS Contractor to develop the 22-23 FAFSA application cycle. FSA is requesting to extend the current AEDS II Contract by one additional year to allow GDOS to develop the 22-23 FAFSA Application cycle and the O&M of this cycle from October 1, 2021 thru June 30, 2023 and the close out period from August 1 thru September 30, 2023 under the currentAEDS II Contract. In order to continue the necessary mission critical support required until FSA's NextGen Financial Services environment replaces all AEDS functionality via the contract award for OPS, FSA will need to extend the period of performance of the AEDS II Contract by one additional year.

3. Description of the Services Required to Meet the Agency’s Needs (including the estimated value)

The AEDS II Contract consists of the following mission critical systems, processes, and operations (also see Appendix 3 for estimated value and period of performance):

a. Operation and Maintenance of the CPS, for determining eligibility for federal student aid. This work includes: 1) processing edits to support the calculation of the Expected Family Contribution (EFC) and communicating results, 2) releasing code fixes, 3) testing patches and infrastructure upgrades, 4) conducting production troubleshooting/testing and 5) performing close-out activities at the end of each FAFSA application cycle.

b. Operation and Maintenance of FAFSA.gov, the online version of the FAFSA. In addition to electronically submitting initial applications, applicants can submit annual FAFSA renewals and corrections to their FAFSAs.

c. Operation and Maintenance of myStudentAid, the mobile app version of the FAFSA. In addition to electronically submitting initial applications, applicants can submit annual FAFSA renewals. Although the front-end of the mobile app has already been transitioned to the Digital Customer Care (DCC) Contract, GDOS will continue to maintain the mobile app’s Borrower and Aid Services Engine (BASE) which provides initial validation that the user is using a current mobile app and also provides announcements and menu options. The BASE serves as a proxy to support the transmission of the FAFSA data through FSA’s Enterprise Service Bus (ESB) to

CPS.

d. Operation and Maintenance of FAA Access, a web-based application that gives school FAAs the ability to enter FAFSA applications on behalf of their students. In addition, FAAs can submit annual FAFSA renewals and corrections to FAFSAs.

e. Operation and Maintenance of EDExpress, a desktop program that allows FAAs to submit FAFSA applications (through an interface with FAA Access) and manage their students’ aid packages. In addition to interfacing with CPS to process FAFSA applications, the software interfaces with the Common Origination and Disbursement (COD) system to exchange school, borrower/recipient, award, and disbursement data.

f. Operation and Maintenance of Participation Management, a web-based enrollment and user management system that allows schools, states, third-party servicers, and guarantee agencies to enroll for access to FSA’s services/systems and to exchange information with FSA’ systems via the Student Aid Internet Gateway (SAIG). This work includes: 1) processing paper enrollment forms and signature pages from enrollment requests submitted online, 2) imaging and storing all documents in an electronic image repository, and 3) storing hard copies in a secure warehouse.

g. Development of the 22-23 FAFSA application cycle for CPS, FAA Access, EDExpress, and Participation Management. This work will roll forward the 21-22 FAFSA application cycle's functionality in order to enable the processing of the new 22-23 application cycle. In addition to bringing forward all the 21-22 FAFSA application cycle’s functionality, this rollover also includes: 1) adjusting date references, 2) updating state deadline references 3) updating Pell tables, 4) updating tax form references, 5) updating EFC offset tables, 6) revising verification selection criteria, 7) making minor text updates, 8) deleting unwanted edits, and 9) ensuring documents posted to the web are 508 compliant.

h. Operation of the CPS/SAIG Help Desk, which provides technical help to schools, state agencies, and lenders who are processing FAFSAs or transmitting Title IV data through the SAIG system. The Help Desk provides support primarily for users of EDExpress and FAA Access. This work also includes maintaining the FSAListserv which is a forum for receiving and broadly responding to questions from schools about FAFSA, COD, and other FSA systems.

i. Operation of Image Data Capture (IDC), which processes paper FAFSAs, paper Student Aid Report (SAR) corrections, paper signature pages, and paper history corrections. The work includes scanning, data capture, uploading images to CPS, and hard copy records management. The IDC integrates with CPS to provide data and receive confirmation of processing.

j. Operation of AEDS Printing and AEDS Postage, which prints and mails Student Aid Reports (SAR), SAR Acknowledgments, and application letters to applicants.

FSA’s current development timeframe to develop the 22-23 FAFSA cycle and the need to continue with GDOS until a new solution is available and deployed to replace the AEDS II Contract.

FSA has determined a significant amount of risk and transition time would be incurred by having a new vendor assume operations and maintenance for the current configuration of the underlying system code. A study on mainframe platforms in 2008, confirmed that the available resource pool for mainframe expertise was shrinking. Organizations are having an increasingly difficult time replacing trained personnel, which are rapidly retiring from the workforce. Additional market research conducted in March of 2020, concluded that twelve

(12) years later that risk is significantly greater, and the number of trained personnel has also significantly decreased. Solutions in today’s marketplace reflect the wide use of open systems, which have grown in scale, reliability, and popularity.

In addition, CPS is not thoroughly documented; and as result, it is impractical to have another vendor support AEDS during the requested period. Changing vendors would disrupt ongoing FAFSA application release cycles and impact the availability of the FAFSA application for students to apply for student aid. Without the FAFSA, many potential students will not only lose out on Federal loans, but potentially State and institutional aid, as many States and institutions require the completed FAFSA application in order to determine overall student aid packages.

6. Description of Efforts Made to Ensure That Offerors are Solicited from as Many Potential Sources as is Practicable

As required by FAR Subpart 5.203, FSA plans to issue a Notice of Intent on or before July 15, 2020 via Beta.Sam.gov for fifteen (15) days, prior to issuing the Request for a Proposal for an additional FAFSA application cycle, to allow for vendor responses. Comments or capability statements may be submitted to the Contracting Officer during this period. In accordance with FAR Subpart, 6.305, the Approved Justification for Other than Full and Open Competition will be posted on Beta.Sam.gov within fourteen (14) days after contract award.

7. Determination of Anticipated Price Reasonableness

The Contracting Officer will determine that the final cost or price negotiated for this contracting action is fair and reasonable prior to award. This determination will be supported by AEDS historical pricing information, as well as the vendor’s proposal.

The development of the 22-23 FAFSA application cycle is based on actual pre-negotiated contract prices included in the Contractor’s proposal as extension pricing at the time of the base award; while, the additional year of O&M is an estimate based on historical pricing, with a 3% adjustment for inflation. Additionally, the Contracting Officer will review and compare other contracts and schedule prices for anticipated labor categories for similar services.

8. Description of Market Research Conducted

Market research was conducted in 2014 for a new Application and Eligibility Determination System. Three of the firms that participated in the market research proposed the following timeline for development, implementation, and transition to a new system:

Accenture indicated they could implement and transition to a new “aid delivery for a Digital Today and Tomorrow” solution in fifteen (15) months.

General Dynamics One Source proposed two (2) years to get to a target state.

IBM proposed three (3) releases, with full implementation in two and a half (2 ½) years.

Based on the 2014 market research, FSA estimated that it would take an average of two (2) years to develop a replacement AEDS solution. In 2017, FSA conducted additional market research and allowed vendors to give oral presentations. Those companies included:

Accenture, Deloitte, General Dynamics One Source (GDOS), and Price Waterhouse Coopers.

The above vendors also indicated an interest in developing an AEDS replacement solution and gave similar time frames to develop an AEDS replacement.

Recent consultation in 2020 with FSA’s Enterprise Technical Integration Management Support (ETIMS) contractor around FUTURE Act implementation also confirmed that a re-engineered CPS platform would take approximately two years to stand up. As a result, the current NextGen strategy is targeting an OPS Contract award in early 2021 so the new OPS Contractor has sufficient time to develop and launch the 23-24 FAFSA application cycle on October 1, 2022, to coincide at the same time as the implementation of the FUTURE Act for the FAFSA.

9. List of Interested Sources for AEDS

Accenture Federal Services LLC, General Dynamics Information Technology Inc (GDIT) also known as GDOS IBM Corporation Infosys Public Services Inc.

Pennsylvania Higher Education Assistance Agency (PHEAA) Deloitte Price Waterhouse Coopers

10. Actions to Promote Future Competition

FSA has no plans to promote future competition of the AEDS II Contract. The AEDS II functionality will be fully transitioned to the OPS Contract by FY 2024, at which time the AEDS II Contract will be closed out and the system will be decommissioned.

11. Program Office Certification of Accuracy and Completeness

This is to certify that the portions of this justification developed by the undersigned program office personnel, including supporting information and data verifying the Government’s minimum needs, schedule requirements and other rationale for other than full and open competition, are accurate and complete.

APPENDIX 1

FAFSA Application Cycles

The following diagram depicts the sequencing of the FAFSA application cycles, with the red 22-23 cycle indicating the new work proposed under the AEDS II contract, as a result of the OPS award delay. If GDOS develops the 22-23 FAFSA cycle in Option Year 1, FSA would need to add an additional year (Option Year 3) to the sole source in order to complete the O&M of this cycle.