A09 JOFOC Financial Mgt Svs. 5.1.2020 5-12-20-signed.pdf

AOP No. 5, J&A-Other Than Full & Open Competition- Attachment 4 (Feb. 26, 2020)

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, Departmental Administration, Office of Contracting and Procurement, Procurement Operations Division, 301 S. Howes Street, Suite 321, Fort Collins, CO 80521.

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

The purpose of this action is to obtain approval to proceed with a sole source acquisition for the sustainment support for the USDA Office of Chief Financial Services (OCFO), Financial Management Services contract which is a direct link to the Department of Agriculture’s Financial Management Modernization Initiative mandated by Secretary Perdue. The procedures under FAR Subpart 8.405 Ordering procedure for Federal Supply Schedules will be used.

Once approved, the USDA office of Contracting and Procurement will request a quote and issue a new order against Deloitte Consulting, LLP’s GSA Schedule 70 contract. This will be for a 6-month period of performance for the support services required to sustain the current Financial Services Environment.

This follow-on action will afford the additional time necessary for a new requirement to be recompeted. Due the COVID-19 Pandemic, the recompete currently is not feasible. The only solution to ensure the integrity and security of the Financial Management Services USDA platform is to issue a sole-source order directly to Deloitte Consulting, LLC., based on the interest of economy and efficiency. In accordance with FAR Subpart 8.405-6(a)(1)(C) this order is considered a logical follow-on to the order already issued under the previous contract, provided that all awardees were given a fair opportunity to be considered for the original award which has been verified by the Contracting Officer.

A request for quote will be issued to the incumbent contractor, Deloitte Consulting, LLP as a logical follow-on to an order already issued on the contract. An order will then be issued to Deloitte Consulting, LLP. This will provide the additional time and resources required to recompete the acquisition and issue a new award in FY 2021.

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

The USDA, OCFO Financial Management Services requires support services to ensure the continuation of the migration of the Financial Management Modernization Initiative application transitioning to the USDA Cloud. The current Financial Management Services environment is the backbone of the evolving Financial Management Modernization Initiative. Deloitte Consulting LLC, the incumbent contractor, is familiar with OCFO’s efforts and has already stood-up the necessary technical support and expertise required to prepare and/or revise systems management documents in accordance with current government directives. This support at a minimum, shall consist of, but not limited to security, government risk compliance, functional support, technical support, business warehouse, business objectives, and HANA support.

The previous award 12314418F0779 issued as a Labor hour (LH) contract and was awarded off competitively competed under GSA Schedule 70 BPA AG-3142-B-14-0001. It expires on 5/31/2020. The follow-on effort will be issued for 6-months from date of award thru 11/30/2020.

The estimated value is $2,798,767.00.

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 follow-on to a GSA order that was originally competed.

The statutory authority permitting exception to fair opportunity is Section 41 U.S.C 4106(c)(3) as implemented by the Federal Acquisition Regulation (FAR) Subpart 8.405-6(a)(1), entitled, ”In the interest 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.”

The original contract award AG-3142-B-14-0001 was competed on GSA E-Buy in 2014. The contract was competed against eligible GSA Schedule 70 Contract holders. Deloitte Consulting LLC was the competitive awardee and has performed in accordance with the terms and conditions of the contract. They have demonstrated satisfactory or better past performance as stated in CPARS and the contracting officer has knowledge for the contractor’s performance under contract AG- 3142-B-14-0001 / 12314418F0779.

Due to the Corona virus pandemic, many USDA organizations transitioned to teleworking. As a result of the change to normal operations, the coordination process for the development of the final version of the performance work statement (PWS) for the Financial Management Service effort was negatively impacted. USDA OCFO program managers were not able to make the necessary revisions to the PWS in time to post the solicitation and give venders enough time to provide competitive quotes. Therefore, the procurement office determined that the best course of action was to award a follow-on contract to the incumbent and competitively compete the subsequent contract for Financial Management Services.

By not preserving these services immediately, the institution knowledge associated to this effort, the critical infrastructure support services required, and the disruption of services would cause a detrimental setback for the Department. Issuing an order to Deloitte Consulting, LLC., for the continued Financial Management Services, will guarantee that there will not be a gap in the procurement and will provide a significant economic and efficient value to the Government. OCFO customers will not notice a lapse in services during the transition and the issuance of a new order.

Authorizing a new order to Deloitte Consulting LLC, to continue these Financial Management Services until a new contract can be issued will save the USDA millions of dollars and will provide the infrastructure safety net necessary to ensure the mission of the USDA/OCFO can be fulfilled.

Awarding the proposed action as a logical follow-on provides significant economic and efficient value to the Government. Any source other than Deloitte Consulting LLC., would result in a loss of 30 or more days of services while the Government awards the follow-on competitively under GSA Schedule 70. This lapse would have a significant impact on OCFO’s mission and customer base delaying the modernization of its existing corporate financial and administrative payment systems and agency related program specific ledgers. This modernization effort is essential to replacing existing applications and systems with an advanced, web-based core financial management system that complies with Federal accounting and systems standards. It is logical to issue a follow-on to the incumbent contractor, Deloitte Consulting LLC., for the continuation of the Financial Management Services effort that they are currently providing under USDA contract 3142-B-14- 0001 / 12314418F0779.

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

The anticipated cost associated with this follow-on will be fair and reasonable. The order will be issued against Deloitt’s GSA Schedule 70 contract and will contain the language set by the master contract along with the contract terms and conditions including pricing factors. Inturn the contracting officer will request discounted pricing if available.

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.

Market research was conducted, and several GSA Schedule 70 contract holders were identified as having the capability to perform the required Financial Management Services effort. By approving the follow-on contract request, additional time will be afforded to further develop the effort to ensure that all GSA Schedule 70 vendors who have the capability to perform the requirement will have the opportunity to compete for this acquisition.

7. Any facts supporting the justification.

None

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

It is anticipated that the subsequent procurement will be competed on a USDA wide BPA for financial services.

Certifications & Approval

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

Kirk Young Contracting Officer Representative

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

Emil E. Abraham Contracting Officer

Additional Reviews & Approvals

Signatures are required at each threshold up to the total estimated dollar value of the acquisition

Procurement Operations Division (POD) Branch Chief (if not the Contracting Officer) (if over $700,000). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

William "Dutch" Van Stockum Branch Chief, Procurement Operations Division

POD Competition Advocate (if over $700,000). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Danielle C. Knipper Competition Advocate, Procurement Operations Division

POD Senior Procurement Analyst (if over $700,000). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Brinder Billups Senior Procurement Analyst, Procurement Operations Division

POD Deputy Chief (if over $700,000). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Kelly L. Moore Deputy Chief, Procurement Operations Division

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.

Richard Jiron Chief, Procurement Operations Division Procuring Activity Advocate for Competition