A18 JA Redacted.pdf

OCFO-A 003 V1 1 05/03/2019

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

FOR AN ORDER OVER THE

SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 16.505(b)(2)(i))

SBHAQ-15-D-0003 / 73351019F0052

1. Agency and contracting activity. Small Business Administration, Office of the Chief Financial Officer (OCFO), Acquisitions Division, Denver and Office of Financial Analysis and Modeling (OFAM).

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

This is a Justification for an Exemption to Fair Opportunity to extend the period of performance under the authority provided under Federal Acquisition Regulation (FAR) 52.217-8, Option to Extend Services. The option was not evaluated as part of the basic award, therefore a separate justification is required. The period of performance will be extended for a maximum of six months, beginning on 12 March 2020 and ending on 11 September 2020. The estimated value of the extension is not anticipated to exceed $29,795.58.

3. Description of supplies or services required to meet agency needs (including the estimated value):

The services to be procured are financial modeling and budget preparation services for the SBA, OCFO, OFAM. The Task Order has a labor hour pricing. The current estimated value is $50,000.00. The estimated value will potentially be increased to $79,795.58. Requisition has been provided to fund the extension period with annual appropriations.

Identification of the awardee to be solicited: FI Consulting, Inc, 1500 Wilson Blvd. 4th Fl, Arlington, VA 22209-2404

4. Authority and supporting rationale. The Contracting Officer has determined the circumstances of the contract action to meet the following statutory exception under FAR 16.505(b)(2)(i) as supported below:

Only one awardee is capable - FAR 16.505(b)(2)(i)(B) – Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

The Task Order was issued under a single award Indefinite Delivery Indefinite Quantity (IDIQ) contract that was competed in the open market. The Awardee, FI Consulting, Inc. is already performing the required services and possesses the clearance and historical knowledge and data to allow for continuity of operations. Procuring the services through an alternative means will result in a greater administrative burden and cost to the Government, especially because the SBA has already begun the re-procurement process for the IDIQ that expires on 04/10/2020.

Unacceptable delays in services can result in the disruption of mission essential duties which include, but are not limited to, maintaining, enhancing, and automating existing modeling processes for SBA loan programs that many small businesses, nationwide, are reliant upon to stay operational.

OCFO-A 003 V1 2 05/03/2019

5. Determination that the anticipated cost will be fair and reasonable:

The Contracting Officer has adequate information to ensure that the cost to the Government for this action will be fair and reasonable. An independent government estimate was provided that is based on the Option 4 rates that were evaluated and determined fair and reasonable at the time of award. Additionally, the Contracting Officer will perform an informal review of the general market conditions to ensure there have been no substantial changes that will negatively impact the fair and reasonableness of the current Task Order rates.

6. Any other facts supporting the Justification:

None

7. A statement of actions to overcome barriers:

The SBA has and will continue to perform market research to ensure the in-progress replacement acquisition offers the highest level of competition available. Additionally, the option provided by FAR 52.217-8, Option to Extend Services will be evaluated as part of basic replacement acquisition.

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Certifications, Determinations and Approvals

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

Contracting Officer

Technical Representative

9. Determination and Approval: I determine that authority shown in paragraph 3, above, applies to this order and approve this justification.

Contracting Officer

Supervisor, Acquisitions Directorate