LSJ - CFO Bridge.v3 Signed PO-Procurement.pdf

JUSTIFICATION AND APPROVAL FOR OTHER-THAN FULL-AND-OPEN COMPETITION

1 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552

LIMITED SOURCES JUSTIFICATION

NEW ORDER TO CONTINUE WORK PERFORMED ON

9531CB20F0018

1.0 Agency Name & relevant office(s): Consumer Financial Protection Bureau; Office of the Chief

Financial Officer (OCFO), Office of Procurement (Procurement)

2.0 Nature and/or description of the action being approved, the supplies or services needed, and estimated dollar value.

The proposed action is to issue a task order to continue ongoing mission critical OCFO and Procurement SharePoint Support Services until a new CFPB Cloud Engineering Blanket Purchase Agreement (BPA) is awarded. The work currently performed under BPA # TFSACFPBPA14004, Call 20343018F00075 and 20343019F00020 will be continued under a single new BPA, which will result from the current competitive procurement process but has not yet been awarded. The BPA has expired and no new orders can be issued against it.

Further, CFPB cannot issue an in-scope modification and place additional funding to the current BPA Calls because the Bureau of the Fiscal Service (BFS), which is administering the BPA and all Calls thereunder, included a BPA ceiling that has been reached and is unwilling to allow such modifications to include additional funding to existing orders. A short-term bridge contract is therefore necessary to continue this mission critical OCFO and Procurement support. This task order will replace TFSACFPBPA14004, Calls 20343018F00075 and 20343019F00020, awarded to Smartronix for Sharepoint Support Services.

The services performed under this order is necessary to maintain and support the following key financial applications on the Sharepoint based system:

Buy Request System, which allows the Bureau to submit funding requests for all Bureau-wide procurement actions;

Investment Review Board (IRB) System, which allows the Bureau to submit requests for all major Bureau investments;

De-obligation and Interagency Agreement (IAA) tracker, both of which track de-obligations and IAA requests;

Traveler Stipend application, which allows qualified Bureau travelers to submit requests to receive their travel stipend, which is part of the collective bargaining agreement;

2 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552

CFO Exception application, which allows Bureau travelers to request exceptions to travel procedures; and

Travel Audit application, which allow the travel team to audit travel trips and ensure that Bureau travel is conducted within approved travel policies and procedures. These applications are only some of the many tools which CFO leverages to create efficiencies. Without qualified Sharepoint support to maintain these applications, OCFO would need to revert to manual processes, which would require re-training the entire Bureau on these new financial procedures. Given the expected short timeframe of the gap in service, creating new, manual processes to manage the Bureau’s financial processes is not an acceptable solution.

Procurement-specific projects relating to the Bureau Enhanced Acquisition Management System (BEAMS) maintenance;

Conduct maintenance of SharePoint workflows, reports, and trackers;

Continue support of these current tasks including, but not limited to:

o Signature history stamps;

o Permissions for users assigned in signature roles;

o Locking BEAMS actions for editing;

o Adding updated local clause;

o Informal Evaluation (FAR 8.405) template;

o Option D&F’s templates;

o Option to select multiple modifications in one action; and o P-Card Intake.

Fix workflows whenever necessary

OCFO and Procurement are requesting approval of this bridge task order with a base period of two-months and four (4), one-month option periods, to be exercised at the discretion of the Government. The estimated value of the task order will be up to $460,636.80 if all option periods are exercised.

The order will cover a base period of performance of December 1, 2019 to January 31, 2020.

3.0 Authority for other-than full-and-open competition (proposed contractor’s unique quals, etc.)

There are two current BPA Calls encompassing the work required in the bridge task order. The period of performances that provide these services expire on January 23, 2020 and January 31, 2020; however, the funding will be exhausted on approximately December 1, 2019. This order is being placed under FAR Part 8.405-6 (a)(1)(C), which permits the placing orders if “in the

3 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552 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.” Any service interruption would result in unacceptable risk to ongoing program operations. Failure to obtain these services will result in key financial and procurement applications becoming inoperable. The services performed under this Bridge contract currently assist the CFPB with maintaining and supporting key financial and Procurement applications that are used by the Bureau, including:

the Buy Request System, which is a Sharepoint based system which allows for the Bureau to submit funding requests for all Bureau-wide procurement actions; the Investment Review Board (IRB) System, which is a Sharepoint based system which allows for the Bureau to submit requests for all major Bureau investments; the De-obligation and IAA tracker, both of which track de-obligations and IAA requests; the Traveler Stipend application, which allows for qualified Bureau travelers to submit requests to receive their travel stipend, which is part of the Collective Bargaining Agreement (CBA); the CFO exception application, which allows for Bureau travelers to request exceptions to travel procedures; the Travel Audit application, which allow for the travel team to audit travel trips and ensure that Bureau travel is conducted within approved travel policies and procedures; and the Bureau Enhanced Acquisition Management System, which is single portal where program office personnel and procurement experts can shepherd each action through the acquisition process. These applications are only some of the many tools which CFO and Procurement leverages to create efficiencies. Without staff to maintain these applications, CFO would need to rely on manual processes, which would require re-training the entire Bureau on new financial processes and procedures. Procurement would need to rely on email and excel spreadsheets to track and manage procurements. Given the expected short timeframe to the gap in service, creating new, manual processes to manage these processes is not an acceptable solution. The original BPA Call was competitively placed under the authority of the Multiple-Award Schedule Program, FAR Part 8.405.

4.0 Best Value Determination.

In the interest of economy and efficiency, the Contracting Officer will negotiate the same rates currently being used by Smartronix on TFSACFPBPA14004, Call 20343018F00075 for use on this order. Those rates have been determined to be fair and reasonable and the contemplated order would represent the best value consistent with FAR 8.404(d). First, GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by FAR 8.405-2(d). Second, the original BPA Call was competitively placed under CFPB’s Cloud Infrastructure System Administration Services (TFSACFPBPA 14004) awarded by BFS and that award was based on adequate price competition, where two or

4 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552 more BPA holders, competing independently, submitted priced offers that satisfied the Government’s expressed requirement. As such, I determine that using the same rates under this bridge contract is fair and reasonable and represents the best value to the Bureau for these services, as the work will continue at the rate the Bureau is currently paying without a need for a costly transition or gap in service.

5.0 A description of the market research conducted and the results, or a statement of the reason market research was not conducted.

Market research was not conducted for this order, as the delay in the Cloud Engineering BPA award has necessitated the bridge task order contract for continuing these services.

6.0 A description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was, or will be, publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies. Include a listing of sources, if any, that expressed a written interest in the acquisition as a result of the FBO posting.

A notice of intent to issue or a notice of award will be publicized either before or after award at the Governmentwide Point of Entry (GPE) website https://beta.sam.gov/ in accordance with FAR 8.405-6 (a)(1)(C) and FAR 8.405-6(a)(2)(i).

7.0 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 supplies or services is made.

Future cloud engineering needs performed under this order will be migrated to the newly competed BPA. Further, this order has been structured with a two-month base period of performance and four (4), one-month option periods, to be exercised at the discretion of the government, to allow the CFPB to discontinue services as soon as practicable.

8.0 A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The labor categories and pricing proposed by the Contractor will be verified to ensure they are consistent with the current Smartronix Call 20343019F0002 rates. At the time of the BPA award, the Contractor’s pricing was deemed to be fair and reasonable based on competition, data related to prices (such as market research, comparison of the proposed price with prices found reasonable, and comparison to the Independent Government Cost Estimate (IGCE)). An IGCE has also been created for comparison before award of this order is made. The CO has

5 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552 determined that these prices, and the resulting estimated cost, represents the best value to the Government.

9.0 Approvals.

9.1 TECHNICAL/REQUIREMENTS PERSONNEL. All supporting data that is the responsibility of technical or requirements personnel, and which form a basis for the justification, are hereby certified as complete and accurate by the technical or requirements personnel.

Name: Sinead Noga Date Title: Finance & Policy Analyst

9.2 PROCUREMENT STAFF. To the best of my knowledge and belief, I certify that this justification is accurate and complete.

Name: Laurent E. Pichet Date Title: Contracting Officer

Name: Joshua Galicki Date Title: Competition Advocate

Sinead Noga Digitally signed by Sinead Noga Date: 2019.12.02 15:49:39 -05'00'