LSJ_FSS_2016-06_Hewlett_Packard_fully_signed.pdf

LIMITED-SOURCES JUSTIFICATION

Tracking No. Page 1 of 3 Treasury Form – 1012 (Rev 10/15)

Prescribed by Treasury: DTAP 1008.405-6

1. Identification of the agency and the contracting activity.

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

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

3.b Estimated value.

4.a Identification of the authority being used (Check the appropriate box that applies).

FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

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 or BPA provided that the original order or BPA was placed in accordance with FSS procedures 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.

FAR 8.405-6(b) – Items peculiar to one manufacturer.

4.b Supporting Rationale.

Treasury Office of Financial Stability (OFS); IRS Office of Treasury Procurement Services

The IRS intends to award a labor hour FSS order against GSA Schedule GS-35F-446AA to Hewlett-Packard (large business); 13600 EDS Drive, Herndon, VA 20171.

The Office of Financial Stability (OFS) requires contractor support to operate, maintain, and enhance custom applications for operational systems supporting the Troubled Asset Relief Program (TARP). The applications include the custom developed Consolidated Investment Transaction Flow (CITF) to track TARP program funds for the operation of the Transaction Processing System and Accounting Sub-Ledger for OFS and the creation of required reports based on CITF data. This work also entails: providing the Information Systems Security Officer (ISSO) with change management and audit logging processes in relation to the CITF application; providing continuous development, operations and maintenance services for OFS’ IT environment that include Modular Systems Management and Support, “Stick Build” Solutions (waterfall development or agile approach), and Production Support for:

• O&M application development of “stick build” solutions, including .NET, InfoPath and SQL Server-based applications.

• Development, operations and maintenance of solutions using OFS IT’s modular systems capabilities.

BY 3/21/16-3/20/17 $1,255,905.78. OY1 3/21/17-3/20/18 $1,293,582.95. OY2 3/21/2018-3/20/2019 $1,332,390.44. Total: $3,881,879.18

The Emergency Economic Stabilization Act of 2008 established the Office of Financial Service (OFS) to manage the Troubled Asset Relief Program (TARP), a temporary program to respond to the financial crisis. Through TARP, Congress granted OFS the ability to purchase and insure troubled assets in the auto, banking, credit, and mortgage industries. The Act also requires the program to undergo extensive oversight and reporting requirements. The special and urgent mission of OFS as a result of the crisis demanded unique custom-developed IT solutions to be created, implanted and supported.

Under the IRS' Data and Document Management Blanket Purchase Agreement (BPA), Hewlett Packard Co. (formerly MicroLink) custom developed and implemented the Consolidated Investment Transaction Flow (CITF) application which tracks the $400 Billion in TARP program funds. CITF is critical for the operation of the Transaction Processing System and the Accounting Sub-Ledger for OFS as well as for the creation of required reports based on CITF data. The CITF application is subject to GAO audit every year. Hewlett Packard Co. has a deep institutional knowledge regarding CITF which is essential to its continued operation. The BPA has expired and no new orders may be placed.

When the BPA was awarded, OFS was staffed with nearly 300 federal employees. That number is now well below 80 and still going down (often on a monthly basis). Despite the declining staff numbers, OFS still has $27 billion in active programs that must be maintained and the solutions referenced here play a critical part in those programs. As the OFS staff reduces, the institutional knowledge the contractor maintains become more critical and relied on. OFS lacks the technical expertise to run, maintain or transition these solutions to a new vendor and to work with our internal technical partner, the Office of the Chief Information Officer (OCIO), to maintain the servers, when directed to do so by OCIO.

Procuring the services through another contractor would impose excessive risk to the TARP program in the current political and strategic environment. Given the phasing out of staff, OFS relies heavily on Hewlett Packard's institutional knowledge to resolve issues that arise. OFS cannot be exposed to the risk of a new vendor being unable to support, maintain and further implement these solutions, as needed.

Hewlett Packard (formerly MicroLink) :

• Has institutional knowledge that now only resides with them due to OFS employee departures around the “sunset” of the OFS organization.

• Knows all CITF code, functions, deployment packages and instructions, troubleshooting, development model, and report creation.

• Possesses full understanding of CITF IT Internal Controls processes, including access management, change management and audit logging processes.

• Has repeated experience with developing CITF disaster recovery plan and successfully conducting repeated CITF disaster recovery exercises.

As a result of the circumstances described above, Hewlett Packard Co. must be retained to ensure the operation of OFS applications and the programs they serve continue without interruption, loss of quality or function, and to ensure the continued ability to develop new code.

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Tracking No. Page 2 of 3 Treasury Form – 1012 (Rev 10/15)

Prescribed by Treasury: DTAP 1008.405-6

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

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

7. Any other facts supporting this justification.

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

As stated at FAR 8.404(d), GSA schedule contracts contain hourly labor rates deemed fair and reasonable. The IRS Office of Treasury Procurement Services will follow FAR 8.405-2(d) and consider the offered level of effort and mix of labor to determine if the total price is reasonable for this requirement.

OFS and IRS considered other GSA Schedule holders. They concluded that due to the decreasing number of federal employees in OFS and current environment under which the TARP program is operating, only Hewlett Packard can provide the services without placing great risk to the OFS mission. Market Research Summary TSF 1010 is attached to the Acquisition Plan.

Documents that support this LSJ include: SOW, Acquisition Plan, IGCE, Market Research.

This acquisition is intended to complete OFS' requirement for these services. Any subsequent acquisition for these services would likely be limited sourced due to the fact that the TARP program is winding down and it is not expected for the organization of OFS to exist in a few years.

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Control No. FSS 2016-06

Tracking No. Page 3 of 3 Treasury Form – 1012 (Rev 10/15)

Prescribed by Treasury: DTAP 1008.405-6

9. Certifications and Approvals:

9.a Program Office Certification (Requiring Activity). I hereby certify that any supporting information and data provided (e.g., the Government’s minimum needs or requirements, or other rationale for the limited sources) and which form the basis for this justification for an exception to fair opportunity, are accurate and complete to the best of my knowledge and belief.

Name:____________________________________ Date: _____________________

Signature: ___________________________________ 9.b Small Business Specialist Determination (Contracting Activity). I have reviewed this justification, including any attached documentation, if applicable, and concur / do not concur with the findings.

Name:____________________________________ Date: _____________________

Signature: ___________________________________ 9.c Contracting Officer Certification and Approval. I hereby determine the circumstances of this acquisition support the justification to acquire these supplies or services on a limited source basis. I also certify this limited-sources justification is accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the authorized contracting officer for this acquisition, I hereby approve the processing of this requirement on a limited-source basis.

Name:____________________________________ Date: _____________________

Signature: ___________________________________

10. Additional Approvals (if applicable):

10.a Advocate for Competition (if >$700,000 and <$13.5 million) (Contracting Activity). I have reviewed this limited-sources 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 the ordering activity’s Advocate for competition, I hereby approve this limited-sources justification Name:____________________________________ Date: _____________________

Signature: ___________________________________ 10.b Head of the Procuring Activity or Authorized Designee (if >$13.5 million and <$67.5 million) (Contracting Activity). I have reviewed this limited-sources 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 the head of the procuring activity or authorized designee, I hereby approve this limited-sources justification.

Name:____________________________________ Date: _____________________

Signature: ___________________________________ 10.c Senior Procurement Official (if >$67.5 million) (Contracting Activity). I have reviewed this limited-sources justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, I hereby approve this limited-sources justification.

Name:____________________________________ Date: _____________________

Signature: ___________________________________

Matthew Levy

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Control No. FSS 2016-06