A08 Redacted Additions to 2020 WIC PC - LSJ (FINAL - signed).pdf

Limited Sources Justification United States Department of Agriculture

FAR 8.405 Federal Supply Schedules Multiple Award Schedule Program

1. Identification of the agency and the contracting activity.

United States Department of Agriculture (USDA) Food and Nutrition Service (FNS) Contracts Management Division (CMD) 1320 Braddock Place, Alexandria, VA 22314

2. The nature and/or description of the action being approved.

The Government anticipates awarding a firmed-fixed price task order against a Federal Supply Schedule contract utilizing FY2020 WIC research funding to Insight Policy Research in accordance with GSA Schedule No. GS-10F-0136X for professional research services to make critical additions to and corrections to the 2020 Women, Infants, Children (WIC) Participant and Program Characteristics report in support of the Office of Policy Support, USDA Food and Nutrition Service. The proposed order period of performance is one (1) base year. The contractor shall propose deliverable dates consistent with the current 2020 WIC PC report, a contract already awarded to Insight Policy Research (task order AG-3198-K-15-0048).

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

The proposed order makes critical additions to and corrections to the 2020 WIC PC report, a contract already awarded to Insight Policy Research (task order AG-3198-K-15-0048). The critical additions and corrections are as follows:

Combining the 2020 Food Package Cost Report with the PC 2020 Food Package Report: The contractor shall combine the WIC PC 2020 Food Package report with the 2020 WIC Food Package Cost Report using the same or similar methodology, subject to FNS approval, as the published 2018 WIC Food Package Cost Report. The 2018 WIC PC report included this combination already, and it is in the best interest of the Government to combine these two reports, as it saves the Government money to combine the Food Package Cost Report with the already-awarded Food Package Report rather than purchasing a standalone Food Package Cost Report. This task should have been included with the original contract, but was not included due to time pressure to get the original contract awarded before the end of the fiscal year. It has been added via a contract modification to previous years of the WIC PC report, but further modifications to the base contract are no longer possible.

Interactive graphics for FNS website: The interactive graphics for the WIC PC report (the 2018 graphics are available here: https://www.fns.usda.gov/wic/participant-and-program-characteristics- 2018-charts) must be updated with the data from the 2020 WIC PC report.

Disclosure analysis for adding State agency identifiers to the public use file: The contractor shall conduct an assessment to provide FNS with information on how much added disclosure risk results from including geographic identifiers on the public use file (PUF) and list methods that would be https://www.fns.usda.gov/wic/participant-and-program-characteristics-2018-charts https://www.fns.usda.gov/wic/participant-and-program-characteristics-2018-charts capable of reducing the risk to acceptable levels. This is a logical follow-on and addition to the WIC PC 2020 report.

Collection and analysis of anemia data: The contractor shall conduct a multivariate analysis utilizing PC2018 (or PC2020 data, if possible) data, data collected from State agencies, and data/findings from other existing WIC studies to assess the relative contribution of different factors to the national and state-level anemia rates. This is a logical follow-on and addition to the WIC PC 2020 report.

White paper on the feasibility of creating a longitudinal dataset: The contractor shall test a method to collect and create a longitudinal dataset using WIC PC data. The data set would provide all records on infant participants from one state, from enrollment in the program until eligibility ends. This is a logical follow-on and addition to the WIC PC 2020 report.

Analysis of the Effects of COVID-19 on WIC Enrollment: The COVID-19 crisis is causing large, mostly unknown changes to participation and enrollment in WIC. Under this task, the contractor shall provide a method to analyze the effects of COVID-19 on WIC participation and enrollment using WIC PC data. This is a logical follow-on and addition to the WIC PC 2020 report.

CLIN Description Estimated Amount

1.0 Required Task: Combining the 2020 Food Package Cost Report with the PC 2020 Food Package Report

$ 138,706

2.0 Required Task: Interactive graphics for FNS website $ 84,325

3.0 Optional Task: Disclosure analysis for adding State agency identifiers to the public use file $ 82,402

4.0 Optional Task: Collection and analysis of anemia data $ 128,687

5.0 Optional Task: Feasibility white paper to create a longitudinal dataset $ 94,420

6.0 Optional Task: Analysis of the Effects of COVID-19 on WIC Enrollment

$ 249,011

Subtotal $ 777,551

“Optional” in this sense does not mean that the tasks are unimportant; rather, “optional” means that FNS shall decide, at its sole discretion, whether to award the tasks at the time of contract execution.

The total estimated value of the services (if all tasks are awarded) is $777,551.

4. The authority and supporting rationale.

FAR 8.405-6(a)(1)(i)(C), “In the 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. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.”

This acquisition is being conducted under the authority of the Multiple-Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.) and Title 40 U.S.C. 501 in accordance with FAR 8.405-6, “Limited-Sources Justification.” This procurement is being conducted in the interest of economy and efficiency as a logical follow-on to an original Federal

Supply Schedule order # AG-3198-K-15-0048, already awarded to Insight Policy Research, GSA schedule GS-10F-0136X. The original award was competitively solicited and awarded using the ordering procedures at FAR 8.405.

It is necessary to limit competition for new work described herein as a logical follow-on because the work described herein are all changes to, extensions of, or additions to the work that Insight Policy Research is doing on the 2020 WIC PC report, awarded as Federal Supply Schedule order # AG-3198- K-15-0048.

Insight Policy Research has already completed much of the preparatory work required for the 2020 WIC PC report, including completing the OMB approval package for the data collection and providing guidance to the WIC State agencies that will be providing the data.

In terms of combining the 2020 Food Package Cost Report with the PC 2020 Food Package Report and updating the interactive graphics: Insight has already completed both of these tasks for the 2018 WIC PC report, and they are a logical extension of the work they are currently doing on the 2020 WIC PC report. If these tasks were competed on the open market, it is highly unlikely that another offerer would have the technical expertise with the 2020 WIC PC report process to be able to proffer a competitive quotation, and the award process would lead to a significant delay in the publication of the 2020 WIC PC report due to government delay, which would incur additional (and potentially substantial) costs to the Government.

Over the past few months, the COVID-19 crisis has caused large, mostly unknown changes to participation and enrollment in WIC. Insight Policy Research is already going to collect enrollment data as of April 2020 for the existing 2020 WIC PC contract, it is a logical follow-on that they collect another round of data from the same State agencies in November or December to be able to analyze the effect of COVID-19 on WIC participation and enrollment. Offering this award on the open market would cause unnecessary (and perhaps catastrophic, in the sense that we would not be able to complete the analysis at all) delay in analyzing the effects of COVID-19 on WIC participation.

The three other analyses (disclosure analysis for adding State agency identifiers to the public use file, collection and analysis of anemia data, white paper on the feasibility of creating a longitudinal dataset) are all dependent on the ability to collect and analyze data from the 2020 WIC PC data collection effort. As Insight already has the contract for that data collection effort, it is a logical follow-on to have them conduct these accompanying analyses and include them in the 2020 WIC PC report. Awarding these analyses to a completely different contractor would result in duplicative charges to the Government and would cause extreme delay in conducting and publishing these analyses, which are needed by the Government before the 2022 WIC PC contract can be awarded.

5. A determination by the ordering activity Contracting Officer (CO) that the order represents the best value consistent with FAR 8.404(d).

Although GSA-FSS has already determined prices under its Multiple Award Schedule (MAS) contracts to be fair and reasonable, the Contracting Officer will ensure the proposed cost to the Government for the supplies or services covered by this justification are evaluated for price reasonableness and the contemplated order represents the best value to the Government. A best value determination will be based on a Government technical evaluation and price analysis of the contractor’s quote, which will include a comparison of the contractor’s quote to the Independent

Government Cost Estimate, previous prices on similar contracts, or by comparison to established GSA or other published price lists.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

The market research was conducted using historical information. The estimated prices for this work are similar to comparable work conducted before by Insight (see previous modifications to this contract [AG-3198-K-15-0048]), and for similar modifications made to other contracts awarded to other contractors (see modifications to contract AG-3198-K-16-0033 awarded to Westat, Inc.).

The hourly rates charged by Insight Policy Research for this work have already been determined to be fair and reasonable according to the GSA Schedule GS-10F-0136X.

7. Any facts supporting the justification.

If this follow-on order is not awarded, the following costs may be duplicated:

Data cleaning plan: $22,000 OMB Package Development: $27,000 Guidance to State Agencies: $182,000 Preparing Data Files: $130,000

Total possible cost duplication: $361,000 – this is probably a conservative estimate and is in addition to the $780,000 estimated cost for the work to be performed. Actual additional costs are likely to be higher due to almost certain delay in being able to publish the 2020 WIC PC report (or, if the 2020 WIC PC report is not delayed to include these analyses, then there would be at least an additional $150,000 in duplication costs, due to the need to write and clear an additional report to publish the results of these analyses).

8. A statement of actions the agency may take to remove or overcome any barriers to competition if subsequent acquisitions are anticipated.

Subsequent actions are not anticipated. The contract/BPA for the 2022 WIC PC report (and subsequent WIC PC reports) is due to be publicly re-competed in FY2021.

Certifications & Approval

Supporting data which form the basis for and included in this justification are certified accurate and complete.

TYLER G. LOVELLETTE

Social Science Policy Analyst

The information contained in this Limited Sources Justification is certified accurate and complete to the best of my knowledge and belief.

KARA STITH

Contracting Officer

Additional Reviews & Approvals

Advocate for competition for the procuring activity (if over $700,000, but not exceeding $13.5 million).

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as advocate for competition for the procuring activity, I hereby approve this justification.

CHANTEL A. SMITH, CFCM

Mission Area Advocate for Competition