91003119F0361_MODP00007_LSJ - Redacted.pdf

LIMITED SOURCE JUSTIFICATION FOR BPA CALL 91003119F0361

DATE: August 10, 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 LLP, 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 program management support services to assist them in the areas of project management, program governance, budget management/execution, and communications. 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 Consulting LLP, FI Consulting LLC, Ernst & Young LLP (E-Y), and Summit Consulting LLC (Summit). 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. As a result of the competition between E-Y, Deloitte, and Summit, BPA Call #91003119F0360 was awarded to Deloitte Consulting LLP under its BPA #91003119A0004 and BPA Call #91003119R0361 was awarded to Summit Consulting LLC under its BPA #91003119A0008 on September 26, 2019.

Since the BPA Call’s inception Summit has been supporting the NGPO by providing resources who support large-scale, complex business and technology transformation programs and by providing a broad range of program governance and management functions including, but are not limited to: master program plan scope, schedule and cost maintenance; decision analysis and support; status elicitation and reporting;

budget estimating, forecasting, analyses, execution and tracking; capital planning support;

communications development and maintenance; general project management functions ensuring alignment between goals, objectives and performance standards; acquisitions and contract management;

and quality management.

Summit’s BPA Call #91003119F0361 is a time and material BPA Call and has one base year (September 30, 2019 – September 29, 2020) plus one option year (September 30, 2020 – September 29, 2021). The total Not-to-Exceed (NTE) amount for the BPA Call’s base year was $4,503,897.20. Faced with higher demand for these services than originally anticipated, the NGPO had to utilize a greater than expected number of resources under the BPA Call, and thus had a higher than expected burn-rate of the funds allotted.

Furthermore, the Future Act has also necessitated additional resources for its support and implementation.

With Summit’s BPA Call expected to reach and exceed its ceiling of $4,503,897.20 by August 21, 2020, an increase to its base year’s ceiling is needed as the NGPO has a continued need for the resources provided under this BPA Call.

Therefore, in order to provide the continued support of the NGPO for the remainder of the base year and beyond, the Contracting Officer (CO) has determined that an increase to the BPA Call’s base year NTE ceiling by an additional $941,071.15 and the option year’s NTE ceiling by $4,148,714.19 to be appropriate to support the new work. As a result, the base year’s NTE ceiling is increased from $4,503,897.20 to $5,444,968.35 and the option year’s NTE ceiling is increased from $4,583,346.08 to $8,732,060.27.

IV. AUTHORITY AND SUPPORTING RATIONALE

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

Rationale: In the interest of economy and efficiency, increase of $941,071.15 for the base year and $4,148,714.19 for the option year is a logical follow-on to a competitively awarded BPA Call. Summit has been closely supporting NGPO for over the past ten months and has developed a significant level of expertise. If a new BPA Call is to be awarded to provide this support, a significant amount of time would be lost to conduct a new procurement and to bring a new vendor up to speed. This would not only introduce programmatic inefficiencies, but would also result in a much higher cost due to the amount of time needed to onboard a new contractor.

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)

Summit’s BPA was established against a Federal Supply Schedule. Summit’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 eight months. Additionally, FSA competed the BPA Call amongst the TSS BPA holders and received an additional discount from Summit below their already discounted BPA pricing. Therefore, an additional determination of price reasonableness is not required. As discussed above, using Summit for the follow-on work and not recompeting this BPA Call will allow FSA to achieve significant cost avoidance and receive significant value due to the knowledge they have obtained over the previous ten months. 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 procurement and potentially bringing a new vendor up to speed would lead to a risk in FSA's schedule and result in a much higher cost than awarding logical follow on work to Summit. 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

We anticipate by the time we exhaust the available base and option periods of this BPA Call, the program will have matured and stabilized to a point that FSA can recompete this and any subsequent requirements amongst the TSS BPA Call holders.

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.

Matt Waggoner Date Director of NextGen Program Office

XI. ADVOCATE FOR COMPETITION’S CERTIFICATION

As evidenced by their signature, the Advocate for Competition has approved of this justification.

Approved:

John D. Cutlip Date Advocate for Competition