91003119F0359_MODP00006_LSJ_072220_REDACTED.pdf

LIMITED SOURCE JUSTIFICATION FOR BPA CALL 91003119F0359

DATE: July 21, 2020

I. CONTRACTING ACTIVITY

The U.S. Department of Education (Department), Office of Federal Student Aid (FSA).

II. DESCRIPTION OF SERVICE AND ACTION

In early 2019, FSA sought to establish multiple Blanket Purchase Agreements (BPAs) for Transformation Support Services (TSS) to provide a range of services to aid FSA in transforming into a world class financial services organization. These contractors were to provide services that included, but were not limited to, integrated consulting services, integrated business program support services, program management services, portfolio analysis/management services, and/or pre/post award support services in order to aid FSA in transforming student financing to a customer-centric and fully integrated financial services environment. The BPA was solicited and competed under FAR Part 8.4 procedures and multiple award BPAs were established with Deloitte Services LP, FI Consulting LLC, Ernst & Young LLP, McKinsey & Company, and Summit Consulting LLC in June 2019. The TSS BPAs had a base year ordering period and four, one-year, ordering periods, with maximum BPA ceilings of $50,000,000.00.

In September 2019, FSA’s NextGen Program Office (NGPO) had a need for professional leadership coaching and strategic advice from an individual with proven, extensive private-sector experience, successfully managing large-scale transformations and running program offices responsible for integrating complex, multi-project IT development efforts in the financial service industry. The TSS BPA holders were identified as prospective sources to meet this need. The requirement was competed amongst the TSS BPA holders and FSA requested quotes from Deloitte, FI Consulting LLC, Ernst & Young LLP, and Summit Consulting LLC. FSA did not request a quote from McKinsey & Company because [REDACTED]. Furthermore, FI Consulting determined the scope of work of this requirement was outside of its core capabilities and did not submit their quote. By the end of the quote submission deadline, only Deloitte had submitted a quote. Further conversations with Deloitte determined that it would be acceptable for Deloitte to propose a team of qualified individuals as no one person was able to be identified with all of the attributes FSA was searching for. On September 20, 2019, Deloitte provided its revised quote which subsequently underwent a technical and price evaluation. As a result, Deloitte’s proposal was determined to be technically acceptable and, with a price discounted below its discounted BPA pricing, Deloitte’s price was determined to provide best value to the government. A time and materials BPA Call 91003119F0359 was awarded to Deloitte Consulting LLP (Deloitte) under its BPA 91003119A0004 on September 25, 2019.

a. Post Secondary Institution Cybersecurity Program (PSI)

FSA’s Technology Office (TO) is seeking a 90-day vendor engagement to define the optimal target state for the PSI Cybersecurity Program. This effort will lay the foundational plans and designs to implement and operationalize a comprehensive approach to managing PSI cybersecurity risks. The acquired resources are to provide advisory, research, and analysis services to assist FSA in defining FSA’s NextGen approach to PSI Cybersecurity compliance and oversight, and support FSA in establishing a PSI Cybersecurity Program Management Office (PMO). The resources are to develop and deliver an Implementation Plan that identifies the various phases of maturity of the PSI Cybersecurity Program, a PSI Program Concept of Operations and Command Center Target State, and a Program Sustainability Plan.

Deloitte’s Executive Leadership Coaching BPA Call 91003119F0359 was identified as a potential vehicle to obtain the necessary resources for the development of the PSI Cybersecurity oversight and monitoring plan.

The Contracting Officer reviewed the scope of the PSI effort and determined it to be within the scope of the subject BPA. On May 12, 2020, the Contracting Officer then provided Deloitte pertinent information regarding PSI Cybersecurity Program, including the overall scope, key activities, deliverables, and timeline, and requested a quote for the effort by labor category. The first quote in the amount of [REDACTED] was received on May 14, 2020. On May 29, 2020, FSA provided a revised Statement of Objectives to Deloitte to which the contractor provided a revised quote on June 2, 2020. The revised quote’s proposed labor categories and number of hours were reviewed by the TO and determined to be acceptable as the IGCE developed by the program office totaled [REDACTED] while Deloitte’s price totaled [REDACTED]; a difference of [REDACTED].

The Contracting Officer has determined a modification to add this additional work to BPA Call 91003119F0359 to be the best method to provide the necessary resources for the PSI Cybersecurity Program. Therefore, funding in the amount of $699,658.80 will be added to the BPA Call to fund the resources to support PSI Cybersecurity Program for 90 days from July 22, 2020 through October 22, 2020.

IV. AUTHORITY AND SUPPORTING RATIONALE

Authority: FAR 8.405-6(a)(l)(i)(a) & 8.405-6(a)(l)(i)(c)

Rationale: In the interest of economy and efficiency, the new work is a logical follow-on to the competitively awarded BPA Call. The PSI Cybersecurity Program is a relatively short-term, 90-day project that requires efficiency in every dollar spent. Deloitte is already familiar with FSA’s processes, internal structure, and personnel, and is therefore, positioned to be able to provide greater efficiency over a new vendor. If a new BPA Call is to be awarded to provide this support, a significant amount of time and money would be lost to conduct a new procurement and to bring a new vendor up to speed for a project set to only last 90 days, a cost FSA cannot afford.

The original BPA and the BPA Call were awarded in accordance with the applicable Federal Supply Schedule ordering procedures. The BPA and the BPA Call were not previously issued under sole-source or limited-sources procedures.

V. DETERMINATION OF THE BEST VALUE CONSISTENT WITH 8.404(d)

Deloitte’s BPA was established against a Federal Supply Schedule. Deloitte’s hourly rates were also provided at a discount below their GSA Schedule rates, and were determined to be fair and reasonable at the time of award. There have been no substantial changes in the marketplace that would impact costs over the past nine months. Additionally, FSA competed the BPA Call amongst the TSS BPA holders and received an additional discount from Deloitte below their already discounted BPA pricing. Therefore, an additional determination of price reasonableness is not required. As discussed above, using Deloitte for the follow-on work and not recompeting this BPA Call will allow FSA to achieve significant cost avoidance and receive significant value in the form of efficiency as previously outlined in paragraph IV. Therefore, the Contracting Officer determined that the award of this follow-on activity provides the best value to the government.

VI. MARKET RESEARCH CONDUCTED AMONG SCHEDULE HOLDERS (OR REASON MARKET RESEARCH WAS NOT

CONDUCTED)

As discussed above, conducting a new procurement and potentially bringing a new vendor up to speed would lead to a risk in FSA's budget and could result in a higher cost than awarding logical follow on work to Deloitte. As no other sources have in-depth knowledge of the NGPO’s various projects, no additional market research was conducted.

VII. OTHER FACTS

N/A.

VIII. ADDITIONAL ACTIONS THE AGENCY MAY TAKE

FSA anticipates by the time it exhausts the projected number of labor hours on this BPA Call, the PSI Cybersecurity Program will have matured to a point that FSA will not require a follow-on contract beyond the projected 90 days.

IX. CONTRACTING OFFICER'S CERTIFICATION

As evidenced by their signature, the Contracting Officer's has determined this document to be both accurate and complete to the best of her knowledge and belief.

__[REDACTED]__________________ _______________

Soo Kang Date Contracting Officer

X. TECHNICAL/REQUIREMENTS PRESONNEL’S CERTIFICATION

As evidenced by their signature, the technical and/or requirements personnel has certified that any supporting data contained herein (e.g., verifying the Government’s minimum needs or requirements or rationale for limited sources) which form the basis of this justification is both accurate and complete.

__[REDACTED]__________________ _______________

Matt Waggoner Date Director of NextGen Program Office