Notice of Intent JNA for NSLDS Non-Competitive Award Contract - 02 27 2020.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

Only One Responsible Source and No Other Supplies or Services Will Satisfy

Agency Requirements

Federal Student Aid (FSA) is proposing a to enter into a fixed-price non-competitive contract with current contractor Brief Systems Development Inc. (BSD) for the continued Operations and Maintenance for National Student Loan Data Systems (NSLDS) and for the continued support of FSA’s NextGen initiative, Enterprise-wide Data Management Platform Systems (EDMAPS).

BSD is headquartered at 731 Parish Farm Lane, Great Falls, VA 2206 with operations located at 3434 Washington Blvd, Arlington, VA 22201.

This proposed contract action will ensure support for the nation’s student loan community that depends on NSLDS while transitioning from NSLDS’ legacy systems to EDMAPS.

1. Identification of agency and contracting activity

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

2. Nature/Description of Action Being Approved

NSLDS is FSA’s data depository for all Title IV student financial aid. NSLDS stores personal data and used daily for business operations. NSLDS possesses data for 622.7 million student loans and grants that total $1.5 trillion. The data and operations involve fourteen (14) Partners.

These include, but not limited to: Students, Federal Loan Servicers, Guaranty Agencies, Colleges, Universities, Technical Institutions, and Lenders. NSLDS provides an integrated operational view of Title IV loans and grants program, which includes financial aid research;

student financial aid applications for Free Application for Federal Student Aid (FAFSA); and the approval, processing, disbursement, repayment, default, and closure. The data volume in NSLDS is:

Description Number of Records Students’ demographics 101,057,551 Student Title IV Loans 457,108,391 Federal Grants 165,615,965 Post-Secondary Schools 20,006 School Branches 56,796 Higher Education Lenders 31,796 Guaranty Agencies 85

Briefcase Systems Development (BSD), a small business contractor, under contract ED-FSA- 14-C-0014, has been providing NSLDS Operations & Maintenance (O&M) support, security enhancements, performing legislative and regulatory student loan changes, and Congressional and Executive Office reporting since FY2014.

In May 2019, FSA conducted an analysis of current NSLDS configuration. The data, ED/FSA Justification for Other Than Full and Open Competition Page 2 of 7 operations and applications reside on an IBM z/OS Mainframe; with an outdated architecture dating back to 20th century design and functionality. FSA decided to move from the outdated systems to a robust delivery system, EDMAPS, providing greater functionality with increased accessibility serving 40M borrowers, 6,000 post-secondary institutions, guaranty agencies and lenders.

Beginning June 2019, FSA began the transition process, moving data, operations and user accessibility from current legacy systems to EDMAPS, a single repository of student loan data and operations. After transitioning to EDMAPS, FSA will retire the NSLDS legacy system and estimates a cost savings over 5 years.

FSA seeks to award a sole source contract with a one-year base period and one 1-year option.

This aligns with the current NSLDS/EDMAPS transition schedule. It is estimated that the NSLDS/EDMAPS transition will be completed in March 2021. However, the one 1-year option period will be incorporated into the contract as a mitigation strategy in case there are delays associated with the EDMAPS transition. The proposed period of performance for the base period and options are:

a. Base Period: March 29, 2020 – March 28, 2021

b. Option Period 1: March 29, 2021 – March 28, 2022

Estimated Price:

a. Base Period:

b. Option Period 1:

c. Total (with Option Exercised):

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

In order to meet FSA’s needs, BSD will maintain the current platform for hosting NSLDS Operations and Maintenance requirements while supporting the EDMAPS transition, which will include information sharing and mitigation of data from NSLDS to the new EDMAPS platform.

This support includes all parties associated with FAFSA (Free Application for Federal Student Aid) as it pertains to data collection and processing; current and future students; colleges, universities, technical schools; lenders; servicers; grantors; loan processors: payment processing; deferments; and close outs.

The contractor will provide the following support under the contract:

1. Data Collection and Data Quality: Collect data and maintain a centralized, comprehensive data repository of Title IV student financial aid and its recipients. The contractor shall undertake efforts to maximize the quality, integrity, and timeliness of NSLDS data in order to ensure a high-level of customer satisfaction. The contractor shall also ensure access to the database for all authorized NSLDS users.

ED/FSA Justification for Other Than Full and Open Competition Page 3 of 7

2. Business Operations and Production Support: Maintain, support, and operate the NSLDS system and associated websites to support the primary business functions of NSLDS. Maintenance support and operations will be performed with emphasis on customer service, best practices, and measurements of performance. The contractor shall document significant recent history of maintaining and updating system code using both Common Business Oriented Language (COBOL) and the CA:Gen/Cool:Gen/Advantage:Gen case tool.

3. Training: Maintain and update training materials and training presentations as necessary for all authorized NSLDS users to understand the functions and data of the system and its associated websites.

4. Change Management: Participate in the FSA Enterprise and Business Operations change management process. Define and implement enhancements to keep pace with changes in legislation, policy, business and technology requirements.

5. NSLDS Database Security: Ensure that access to the database is secure and granted only to authorized users. Abide by all applicable federal and FSA rules governing (but not limited to) system access and protection of personally identifiable information.

6. Customer Assistance: The contractor will provide help desk support to all NSLDS customers and authorized users. NSLDS customers and users include schools, students, guaranty agencies, lenders, ED servicers, FSA staff, FSA contractors, state agencies, and third-party servicers. Users require technical assistance with all the required business services provided by NSLDS. Assistance topics include: website security;

navigation of the website; updating data on the database; basic Microsoft Office support (for tools/templates based in MS Office products that NSLDS provides its users); batch processing, which includes enrollment reporting, student transfer monitoring, data provider submittals, financial aid history requests, user reports/queries; and production control. NSLDS customers require a central source for resolving and negotiating data conflicts that impede the awarding of financial aid to students.

Responding to the users requesting technical assistance as described above needs support from professionals with higher education financial aid experience.

Additionally, research of these technical issues requires use of the NSLDS database and tools. The contractor will maintain a customer service staff with strong subject matter backgrounds in Title IV aid processes and data. The contractor staff members will combine their knowledge and experience with SQL querying skills to perform detailed trouble-shooting analysis and assist with user database query development.

International customers will contact NSLDS in the same manner as the continental United States customers. NSLDS, contractor is required to provide customer help services to Spanish-speaking customers. The hours of availability for customer help need to reflect customer needs across United States time zones.

7. Audit Support: The contractor will support FSA’s Security Division in managing interactions with auditors to include but not limited to Inspector General (IG), ED/FSA Justification for Other Than Full and Open Competition Page 4 of 7

Government Accountability Office (GAO), and other audits that may be conducted of NSLDS. Support includes responding to audit inquiries, providing evidence for findings, remediation plans for findings, and executing remediation plans within required deadlines of the Corrective Action Plans (CAP).

8. NSLDS/EDMAPS Transition Support: The Contractor will provide EDMAPS transition support. This support includes information sharing, code transition, code explanation; data migration, data conversion support, and support the EDMAPS contractor’s questions concerning the NSLDS system and participate in weekly meetings

The estimated value of the proposed action for the Base Period and 1 Option Period is .

4. An identification of the statutory authority permitting other than full and open competition.

This requirement is being sourced as a sole source contract under the authority of 41 USC 3304(a)(1) and FAR 6.302-1(a)(2), based on the contractor being the only responsible source and based on the fact that no other supplies or services would satisfy the agency’s requirement.

5. A demonstration that the proposed contractor’s unique qualifications or nature of

Acquisition requires use of the authority used:

In accordance with FAR 6.302-1(a)(2), only one responsible source and no other supplies or services will satisfy agency requirements. It is in FSA’s best interest to award a non-competitive contract to Briefcase Systems Development, Inc (BSD) to operate and maintain NSLDS and concurrently support transitioning NSLDS to the EDMAPS platform.

Basis for the Non-Competitive Award:

1. BSD is uniquely qualified to continue to operate and maintain NSLDS while FSA transitions NSLDS to the EDMAPS platform. Since 2009, BSD has been successfully operating, maintaining and enhancing NSLDS, supporting FSA’s student loan mission.

They possess a complete understanding of the system’s complexity, FSA stakeholders and the time sensitive nature of the many requests they receive.

In 2018, market research discussions with potential vendors revealed that to transfer BSD’s NSLDS knowledge, operational concepts and it’s functionality to a new contractor requires a minimum of 6 months to a year. At the time of Market Research, the transition time involved NSLDS Operations and Maintenance only and did not include supporting the EDMAPS’ transition. Considering FSA is contractually, financially, and resource committed to EDMAPS, a 6-month to a year transition period would financially impact FSA as the EDMAPS contractor would experience schedule delays, increased cost of retaining personnel and potentially request financial Equitable Adjustments due to a

ED/FSA Justification for Other Than Full and Open Competition Page 5 of 7 government caused delay due.

2. FSA would be required to pay 2 separate contractors for the transition period plus the new O&M contractor for the remaining 6 months of the base period. FSA’s total estimated price for paying 2 contractors is an increase over the projected cost of the base period of performance for the proposed non-competitive award.

3. A 6-month transition would delay FSA’s projected savings.

4. NSLDS uses COBOL for the mainframe applications. COBOL, initially designed in 1959 has gone through various revisions, but remains ‘monolithic’, primarily used for maintaining existing applications. Through market research, FSA learned there is a very limited COBOL experienced labor pool. To project that a new vendor would overcome this challenge by hiring the existing contractor’s labor force is counterproductive. If the current contractor loses its labor force, then they would not be able to perform critical NSLDS Operations and Maintenance. NSLDS is no longer functional and FSA’s mission, “Funding America’s Future, One Student at a Time” is compromised.

6. Description of Efforts Made to Ensure That Offerors are Solicited from as

Many Potential Sources as is Practicable

As required by FAR Subparts 5.201 and 5.203(a)(1), FSA intends to issue a notice of intent on or before February 27, 2020 via beta.SAM.gov for 7 days. The reduction from 15 days to a shorter time is permitted by FAR for the acquisition of commercial services and is necessary for the timely contract award. Vendors may submit comments or capability statements to the Contracting Officer during this period. Additionally, in accordance with FAR 6.305(a), FSA will post the approved Justification for Other than Full and Open Competition on beta.SAM.gov within 14 days after contract award.

7. Determination of Anticipated Price Reasonableness

The Contracting Officer, working with the Technical Evaluation Team, will determine that the final price negotiated for this contracting action is fair and reasonable prior to award. This determination will be supported by NSLDS historical pricing information, FSA’s Independent Government Cost Estimate (IGCE) as well as the vendor’s proposal.

8. Description of Market Research Conducted

In 2018, FSA conducted market research for the Operation and Maintenance (O/M) of the National Student Loan Data System (NSLDS). FSA used the government’s Past Performance Information Retrieval System (PPIRS, now incorporated into CPARS), internet research and contractors that previously participated in FSA’s 2014 solicitation. The objective was to identify a representative sample of potentially qualified contractors. Six (6) companies were identified and given the opportunity to submit their qualification statement followed by individual meetings. The representative sample included small and other than small companies. They were:

Accenture Briefcase Systems Development Inc Digital Spec

ED/FSA Justification for Other Than Full and Open Competition Page 6 of 7

General Dynamics Information Technology, Inc. (GDIT) PPS Info Technology Salient CRGT

Market research revealed:

NSLDS has limited system documentation Transition period is 6 months minimum, a year transition is more probable High probability of contractors encountering hiring delays to acquire qualified technically trained personnel in COBOL and Cool:Gen

9. Other Facts Supporting Other Than Full and Open Competition

There are no additional facts supporting the use of other than full and open competition.

10. List of Interested Sources for NSLDS

Accenture Briefcase Systems Development Inc Digital Spec General Dynamics Information Technology, Inc. (GDIT) PPS Info Technology Salient CRGT

11. Future Competition

The proposed NSLDS non-competitive contract period of performance is limited to the time required for transitioning to EDMAPS. When transition is completed, NSLDS will begin decommissioning and the contract closed.

12. 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.

Valerie Sherrer, Director Date Systems Integration Division Business Operations Federal Student Aid

02/27/2020

ED/FSA Justification for Other Than Full and Open Competition Page 7 of 7

Ron Bennett, Acting Director Date Systems Operation and Aid Delivery Management Services Business Operations Federal Student AID

Robin Minor Date Deputy COO for Partner Participation and Oversight FSA Executive Sponsor

13. Acquisitions’ Office Certification of Accuracy and Completeness

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Wayne A. Brim, Contracting Officer Date US Department of Education/Federal Student Aid

APPROVING OFFICIAL’S DETERMINATION

I concur that there is a justified need to enter into a sole source procurement with BSD to continue support and avoid interruption of National Student Loan Data System. This sole source procurement period of performance will be effective from March 29, 2020 through March 28, 2022.

It is hereby determined that it is in the best interest of the Department, and that the above constitutes sufficient justification for this sole source procurement. It is determined that the proposed acquisition falls within exception of 41 U.S.C. § 253(c) (1).

APPROVED:

James E. Davis, Executive Director, Acquisitions Date U.S. Department of Education/Federal Student Aid

02/26/2020

02/26/2020

02/26/2020