A17_LSJ_-_PBGC_Online_and_Telephone_Surveys_Posting_Redacted_1.pdf

LIMITED-SOURCES JUSTIFICATION

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

140D0425Q0750 - Online & Telephone Surveys_

This acquisition is conducted under the authority of the General Services Administration (GSA) 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 document is a limited-sources justification (LSJ) for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division III, Branch IV, on behalf of the Pension Benefit Guaranty Corporation (PBGC).

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

The purpose of this LSJ is to document the rationale for obtaining contract support in developing and deploying customized survey instruments from CFI Group USA, LLC under General Services Administration (GSA) Contract 47QRAA19D0060 to ensure the uninterrupted continuation of critical services for PBGC.

The prior award was made under Blanket Purchase Agreement (BPA) 140D0422A0002 - PSS ACSI, Call Order 140D0424F1354, administered under DOI, Federal Consulting Group’s (FCG) Internal Agreement (IA) . Although the BPA is not scheduled to expire until December 5, 2025, the contract is no longer eligible for additional Call Orders due to compliance with the Executive Order (EO) 14158, signed on January 20, 2025, which implements the President’s “Department of Government Efficiency” initiative aimed to modernize federal technology and software to enhance governmental efficiency and productivity. As a result, FCG’s IA has been terminated.

Awarding CFI a new Task Order (TO) will support PBGC in maintaining mission critical services with minimal disruption.

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

The PBGC is seeking a responsible contractor to provide services to measure customer satisfaction with a variety of programs, processes, contact centers and activities. Per Executive Order 13571-- Streamlining Service Delivery and Improving Customer Service dated 27 April 2011, “The public deserves competent, efficient, and responsive service from the Federal Government. Executive departments and agencies must continuously evaluate their performance in meeting this standard and work to improve it.” Meeting this Order requires deploying customer satisfaction surveys as a key performance measure.

The Contractor's work for PBGC in meeting this requirement shall involve developing customized survey instruments and using the ACSI methodology to provide statistically valid satisfaction measurements to assist with improving customer satisfaction. The survey shall include elements that drive customer satisfaction, satisfaction itself, and desirable customer behaviors; customized questions that are not related to the model but desirable for informational purposes and general analysis may be included. This project shall be completed in full compliance with the Privacy Act of 1974.

The period of performance for this acquisition is anticipated to be a twelve (12) month base period, followed by four, twelve-month option periods

Base Year September 18, 2025, through September 17, 2026 Option Year 1 September 18, 2026, through September 17, 2027 Option Year 2 September 18, 2027, through September 17, 2028 Option Year 3 September 18, 2028, through September 17, 2029 Option Year 4 September 18, 2029, through September 17, 2030

The Independent Government Cost Estimate (IGCE) is projected to be . The IGCE was developed by PBGC based on historical pricing and CFI’s rates quoted on the existing Task Order and market research analyzing GSA published price lists.

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.

FAR authority for this LSJ is as follows: 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.

An award is required by PBGC by September 20, 2025, to avert disruptions in service. Per Executive Order 13571--Streamlining Service Delivery and Improving Customer Service dated 27 April 2011, “The public deserves competent, efficient, and responsive service from the Federal Government.

Executive departments and agencies must continuously evaluate their performance in meeting this standard and work to improve it.” Meeting this Order requires deploying customer satisfaction surveys as a key performance measure.

CFI has unique qualifications as the founding partner of ACSI. ACSI is the only company within the

Failure to award a sole source award to CFI would cause PBGC to be in breach of OMB A-11, which requires PBGC to manage customer experience as well as adhere to Executive Order 15048, requiring PBGC to transform federal customer experience and service delivery to rebuild trust in government. Using the survey results is how PBGC gauges the customer’s satisfaction and improves the customer’s experience. Therefore, this requirement will be awarded as a sole source Task Order to CFI, IAW FAR 8.405-6(a)(1)(i)(b).

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 determines that a sole source contract award to CFI will likely result in the best value to the Government. The Contracting Officer believes that the anticipated prices will be fair and reasonable based upon CFI’s intimate knowledge of the work, prices paid on previous orders, and currently published GSA price listings.

Pursuant to FAR 8.404(d) Pricing, “GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d).”

In accordance with FAR 8.405-2(d) Evaluation, the Contracting Officer will consider the level of effort and the mix of labor to perform a specific task being ordered before determining the total price reasonable. Additionally, since the order exceeds the Simplified Acquisition Threshold the Contractor Officer will request price reductions in accordance with FAR 8.405-4.

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 included a search and review of several Government databases and websites. In addition to the review of the mandatory use memoranda per DOI DOI-AAAP-0088 v10, a review of the mandatory and non-mandatory sources for services required under FAR 8.002 and a review of other DOI sources revealed the following results:

a. Procurement List/Ability One: The services needed for this requirement are not services offered under the Ability’s One Procurement List for services.

b. Federal Prison Industries (FPI): FPI, now operating under the trade name UNICOR, does not provide the needed services for this requirement according to their list of services.

c. Federal Supply Schedules (FSS): GSA e-library revealed several sources that offer the required services in the open market and through GSA FSS. Using NAICS CODE 541611 revealed 3,054 potential vendors. However, due to the unique and complex nature of this requirement, 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.

d. DOI-Wide Contract Solutions: A search of DOI Contract Vehicles did not reveal any active Indefinite Delivery/Indefinite Quantity (IDIQ) contracts applicable to this action.

e. The required services are available within the commercial marketplace IAW FAR 2.101. The services are customarily used by the general public for other than government purposes and are sold competitively in the commercial market.

f. No other efforts were made to stimulate industry involvement such as pre-solicitation conferences, industry briefings, one-on-one industry meetings, draft specifications or statements of work/objectives, draft solicitation as the recommended acquisition strategy is to utilize FAR 8.405-6(a)(1)(i)(b). The anticipated TO is recommended to be awarded as a sole source award to the incumbent, CFI Group USA, LLC.

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.

PBGC will continue to conduct market research, in order to identify other vendors that are capable of meeting this highly specialized requirement for customized ASCI survey methodologies.

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.

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.

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

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.