A17_JA_LSJ_GSA_FSS_Over_SAT_FAR_8_405_BPA_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

GS-10F-0370X / 140D0423A0 (TBD)

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

Limited-Sources Justification (LSJ) for the contracting activity of the Department of the Interior (DOI), Interior Business Center, Acquisition Services Directorate (AQD), Division II, Branch V contracting on behalf of the DOI, Office of Employee Development (OED), Federal Consulting Group (FCG).

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

This LSJ is to make a short-term (15-month) sole source logical follow-on award to the current General Services Administration (GSA) Blanket Purchase Agreement (BPA) holder (LDSS, Inc.) to provide continuity of services to FCG as the current BPA approaches its maximum awarded ceiling on or around early March 2023. The BPA will include consulting, counseling, coaching, facilitation, survey, training and executive program and project management services.

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

The FCG utilizes the BPA to provide a wide array of services to nearly every Federal agency and is funded by interagency agreements from those Federal entities.

Interagency agreements are established throughout the fiscal year as Federal entities seek services from FCG. Examples of the services required include, but are not limited to:

• Providing consulting on organizational effectiveness, approaches and implementation strategies to senior leadership teams.

• Facilitation of key organizational development processes, such as re-engineering, process improvement, strategic planning, business model development, etc.

• Providing confidential executive coaching to senior managers and Federal executives.

• Working with agencies to design, deliver and implement leadership development programs, including succession planning.

• Working with agencies to design, deliver and implement training programs, including onboarding.

• Providing on-site, full-time career counseling services and organizational development services.

• Working with agencies' communications or public affairs office to conduct social media analysis and develop strategic communications plans.

• Providing project management professionals for multiple projects, such as an implementation of new applications and implementation of a training programs.

• Provide an array of consultant support that may supplement administration, human resources, training, contracting, facility management and financial (not audits) offices.

The following is an additional list of activities which may be issued under individual BPA Call Orders under this BPA:

• Management or strategy consulting, including research, evaluations, studies, analyses, scenarios/simulations, reports, business policy and regulation development assistance, and strategy formulation.

• Facilitation and related decision support services.

• Executive or Team Coaching of senior managers and/or Federal executive.

• Survey services, using a variety of methodologies, including survey planning, design, and development; survey administration; data validation and analysis;

reporting, and stakeholder briefings.

• Integrated Consulting Services.

The purpose of the sole source logical follow-on is to provide a network of consultants for professional services and deliverables through performance of executive programs and project management to meet the objective of FCG and the individual needs of Federal Agency clients.

The estimated value for the 15-month period of performance (POP) is

4. The authority and supporting rationale (see FAR 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.

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.

The current Contractor, LDSS, Inc., has provided the same type of services to FCG for many years. The current BPA with LDSS, Inc. was awarded based on competition amongst GSA Schedule holders. In addition to the current BPA, LDSS, Inc. had a previous BPA (140D15PA0004) for the same services that was issued for a base and four option periods from November 6, 2014, through November 5, 2019. This requirement was competed as an 100% small business set-aside with an estimated value of $22M. The experience LDSS, Inc. has with FCG’s Consulting, Counseling, Coaching, Facilitation, Survey, Training, Executive Program and Project Management Services BPA provides unique qualifications as they

To permit a seamless transition from one contractor to another, an adequate transition period is required to afford FCG the opportunity to market the contract vehicle and establish Interagency Agreements (IAs) with their clients for their required projects.

The current BPA was awarded on December 16, 2019, as a competitive award to a single source. Approximately 200 Call Orders have been issued against the BPA since inception and many are still active. Although the current BPA ceiling will be reached much earlier than anticipated, new Call Orders could be issued easily against the 15-month sole source logical follow-on BPA with LDSS, Inc. to prevent a break in service.

FCG is a fee for service entity, and they need time to market their products and services to their Federal clients. Clients choose FCG because of their speed and quality of services. If a 15-month follow-on is not awarded to the current contractor, FCG would not have a contract vehicle to build their client base for use, resulting in clients not being able to meet their missions. Any discontinuation of services with the current contract before the transition to a new contract is completed will put FCG at risk of disrupting their clients’ projects, and of failing to provide adequate service levels to existing Federal clients. Many of the services provided are requirements as a result of Executive Orders.

Based on usage, it is anticipated that the current Consulting, Counseling, Coaching, Facilitation, Survey, Training, Executive Program and Project Management Services BPA will reach its limit prior to Spring 2023. If the 15-month sole source logical follow-on BPA is not approved, FCG will be without the required services for a substantial time while the re-compete is accomplished. This delay will prevent FCG from receiving any new IAs during the busiest part of their contracting year. The impact to FCG if the 15-month sole source logical follow on is not approved is substantial as they receive fees for use of their services.

FCG’s clients would not have time, infrastructure and resources to contract on their own for the needed services, risking mission failure and/or significant delays for their projects.

FAR 8.405-6(a)(1)(i)(C) is appropriate because LDSS, Inc. has been performing the requirements for coaching, consulting, counseling, training, and facilitation for several years for many of FCG’s current clients. Their services are known to FCG clients, and they are familiar with the ordering process from AQD. No other contractor could start performing this requirement without creating delays and inefficiencies.

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

The current BPA with LDSS, Inc. was competed and awarded amongst GSA Schedule holders. In accordance with FAR 8.404(d), GSA has already determined the rates under Schedule contracts to be fair and reasonable. In addition, the rates on the BPA have been previously determined fair and reasonable based on competition at time of BPA award.

The Contracting Officer (CO) will continue to request additional discounts from the awarded rates with each Call Order level RFQ.

Prior to award, the CO will determine if the quoted rates represent the best value, and is in the best interest of the Government to make award to LDSS, Inc. It is expected that the rates will continue to be fair and reasonable in comparison to the current BPA rates, GSA published rates,

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 completed prior to exercising option period two (March 3, 2022) and Modification P00004 (July 11, 2022). Market research included review of the acquisition history and Government databases, internet searches and discussions with the Small Business Specialist and the program office. The market has not changed substantially in the last six months. Therefore, the CO determined additional market research was not warranted for the 15-month sole source logical follow-on requirement.

7. Any other facts supporting the justification.

The acquisition of a new competitive contract vehicle is in the early stages. The Independent Government Estimate (IGE) and the associated acquisition timeline has prompted the need for a 15-month sole source logical follow-on BPA to allow FCG to continue servicing their clients until a new award can be made, they can market the award, and get IAs in place for individual projects.

The procurement timeline for a five-year contract includes numerous high-level reviews and approvals at multiple stages in the process. The process can take up to twelve months. Additionally, FCG will require significant time to market a new contract and get IAs in place with their clients. The IA process between Federal entities can take up to three months to complete. Given the time requirement for the marketing and FCG’s IA process, a new contract would need to be in place at least four months prior to Call Orders being placed against the new contract vehicle.

In accordance with FAR 8.405-6(a)(2), within 14 days after establishing a BPA exceeding the simplified acquisition threshold that is supported by a limited sources justification, the ordering activity shall publish a notice in accordance with FAR 5.301 to https://www.sam.gov for a minimum of 30 days.

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.

The barrier to competition for the 15-month logical follow-on is time. A competitive re-compete for FCG’s Consulting, Counseling, Coaching, Facilitation, Survey, Training, Executive Program and Project Management Services is beginning, but the new contract cannot be in place prior to the current BPA reaching its ceiling. The acquisition timeline for the new procurement is longer due to the new requirement’s expected value.

https://www.sam.gov/

GS-10F-0370X / 140D0423A00XX (TBD)

*****Do not sign this document. Please sign the PDF Signature Sheet.*****

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.

Contracting Officer Date

10. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify the technical data which forms a basis for this justification is complete and accurate and meet the Government’s minimum needs.

Program Office (FCG) Date

11. For justifications under FAR 8.405-6(a)(1), a written determination by the approving official identifying the circumstance that applies.

In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order and the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures in accordance with FAR 8.405-6(a)(1)(C). The original BPA was not previously issued under a sole-source or limited-source procedures.

GS-10F-0370X / 140D0423A00XX (TBD)

12. Reviews and Approvals

Concur ranch Chief Date

Division Chief Date ureau Competition Advocate Date

Approve

Head of the Contracting Activity Date

U.S. Department of the Interior Interior Business Center Acquisition Services Directorate