A16_JOFOC_LSJ_GSA_Redacted_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C 501

RFQ# 140D0422Q0145

This acquisition is conducted under the authority of the Multiple Award Schedule (MAS) Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This is a Limited Source Justification, under FAR 8.405-6(a)(1)(i) C, executed by the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division II Branch I, on behalf of the US Department of Agriculture (USDA), Food and Nutrition Service (FNS).

2. Nature and/or description of the action being approved.

The Government intends to award a task order against existing General Services Administration (GSA) MAS Contract # 47QRAA21D006L, which will be a follow-on to Order # 140D0421F0512. This follow-on will allow the vendor, Walter R. McDonald & Associates (WRMA), to conduct the tasks as specified in the study plan that was delivered under the existing order.

3. A description of the supplies or services required to meet the agency’s needs

(including the estimated value).

The USDA FNS office has a new requirement for a vendor to collect information from State Monitoring Review (SMR) reports created from among nine (9) states about their sponsoring organizations (SOs) of Child and Adult Care Food Programs (CACFP) and Family Day Care Home (FDCH) providers. The SMR reports will include information on the number of meals and snacks claimed during a specific month, the dollar amounts claimed, errors in meal claim numbers, amounts of meals collected during onsite meal observations at the homes, and a five-day reconciliation period with the FDCH providers. This collected information will be used to estimate the amount and percentage of meal claim errors during a one-month period among sponsors within the sampled states.

SOLICITATION #140D0422Q0145

The period of performance is for a 30-month base contract (no year funds). The Independent Government Cost Estimate (IGCE) is

4. The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

The basis for this justification is set forth in 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 must not have been previously issued under sole-source or limited-sources procedures.

This logical follow-on requirement is based on a continued need because of services provided in contract 140D0421F0512 . The incumbent contractor, WRMA is uniquely qualified to implement the methodology as indicated in their current contract resulting study plan. Their team is comprised of subject matter experts and statisticians that are well versed in CACFP’s. They had proposed a unique and innovative solution of employing existing data from reliable reports in lieu of implementing additional, duplicative, and labor-intensive processes on already burdened participant families, FDCH providers, SOs, and State Agencies. In their approved study plan (submitted as a deliverable under Contract # 47QRAA21D006L, Order # 140D0421F0512). WRMA proposes to collect and examine SA monitoring review (SMR) reports as a primary data source for estimating meal claim errors. The SMR reports include information on the number of meals and snacks claimed during a month, the dollar amounts claimed, errors in meal claim numbers and amounts of meal provided. This information can be used to calculate the meal claiming error rates.(What is the significance of their effor claim rates. Collecting the meal claim error rates is necessary due to the Payment Integrity Information Act of 2019 (PIIA), in which federal agencies must periodically review and identify programs that may be susceptible to significant improper payments.

FNS conducts periodic studies of improper payments due to the misclassification of FDCH facilities into incorrect reimbursement tiers.

As the incumbent contractor, WRMA is currently in place performing in an acceptable manner. Going to another contractor, either through competition or other method would require additional time and expenses to the government just for the re-procurement effort for this requirement. If the award is not made to WRMA, a new vendor will potentially charge the Government for time needed to familiarize themselves with the study plan, the proposed data sources and analyses, as well as the operations and program integrity concepts. In addition to the definitions of CACFP – tasks and activities which have all already been performed by WRMA. These are services that the Government has already paid for. In addition, this additional effort would result in a duplication of unnecessary costs to the Government and unnecessary project delays.

SOLICITATION #140D0422Q0145

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

The Contracting Officer anticipates the price(s) will be fair and reasonable because the vendor has an established GSA contract with GSA approved rates already determined fair and reasonable by a GSA Contracting Officer. In addition, the CO will compare pricing from the quote to market pricing in accordance with DOI-AAAP-0024.. The initial Contract # 47QRAA21D006L, Order # 140D0421F0512 was issued against the GSA MAS with pre-approved rates. This follow-on effort will be requested to be priced against the GSA approved rates. The Contracting Officer will also request further price reductions for the required product/services in accordance with FAR 8.405-4, as the estimated value of this acquisition exceeds the simplified acquisition threshold.

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 initial task order was competed via GSA eBuy among all GSA MAS 541611(Management and Financial Consulting, Acquisition and Grants Management Support, and Business Program and Project Management Services) vendors. The market research report was completed for that effort on 04/28/2021. In accordance with FAR 10.002(b)(1), the previous market research is still applicable, as it was conducted within 18 months prior to the issuance of a new task order and the information is still considered current, accurate, and relevant. , It is further noted that GSA MAS 541611 still aligns with this type of work.

7. Any other facts supporting the justification.

None.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

Any future requirement descriptions will include both the development of a feasibility study and the carryout of the study in the same effort, as compared to awarding two separate task orders.

9. The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

I certify this justification is accurate and complete to the best of my knowledge and belief.