ACF GCS Limited-Sources Justification MUSE_Redacted.pdf

JUSTIFICATION AND APPROVAL TEMPLATE

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

DEPARTMENT OF HEALTH & HUMAN SERVICES

Administration for Children Families

GOVERNMENT CONTRACTING SERVICES

ACF GCS TEMPLATE ACF GCS TEMPLATE (May 2020 version)

JUSTIFICATION AND APPROVAL

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

TRACKING#: ACF-GCS-J-21007

The Office of Government Contract Services (GCS) makes this Justification and

Approval (J&A) for Limited-Sources Justification pursuant to Federal Acquisition

Regulation (FAR) 8.405-6.

1. Identification of Agency and Contracting Activity:

Requesting Agency:

U.S. Department of Health and Human Services

Administration for Children and Families (ACF)

Acting in support of: Office of Planning, Research, and Evaluation (OPRE)

Contracting Activity:

U.S. Department of Health and Human Services

Administration for Children and Families (ACF)

Office of Government Contract Services (GCS)

2. Nature and/or Description of Action Being Approved:

This acquisition is conducted under the authority of the Multiple-Award Schedule

Program. This will be a sole source Task Order in accordance with FAR 8.405-6 with the procedures of 8.405-2.

3. A Description of Supplies/Services Required to Meet Agency’s Need:

The purpose of this contract is to understand how the evidence-based approaches of

Maternal Infant Early Childhood Home Visiting (MIECHV) operate in community contexts that serve American Indian and Alaska Native (AIAN) families, including during the COVID-19 pandemic. The MIECHV Program was created in 2010 and reauthorized in 2018 through the Bipartisan Budget Act of 2018. MIECHV has greatly increased the availability of home visiting services in the United States. According to the authorizing legislation, MIECHV is intended to improve outcomes for communities with high concentrations of adverse birth outcomes, poverty, crime, domestic violence, high school dropouts, substance abuse, unemployment, and child maltreatment. Federal grants are provided to states, territories, and tribal communities, and awardees contract with local implementing agencies to provide evidence-based home visiting services to families through supportive relationships with home visitors. Because there are there two different granting mechanisms by which MIECHV serves AIAN families, there are two study threads within the Multi-site Implementation Evaluation of MIECHV with AIAN

Families (MUSE): (1) MUSE for Tribal MIECHV grantees (MUSE-THV) and (2) MUSE for State-Tribal Collaborations through the State MIECHV program (MUSE-STC).

The current proposed contract shall supplement both study threads of MUSE, including intensive stakeholder engagement to inform analysis, interpretation of results, and dissemination of results to different audiences. The proposed action will support: 1) supplemental actions for MUSE-Tribal MIECHV (MUSE-THV) data collection, analysis, and dissemination; 2) supplemental actions for MUSE-State-Tribal Collaboration

(MUSE-STC) data collection, analysis, and dissemination; 3) application of a COVID-19 specific focus to analyze the quantitative and qualitative data collected in MUSE-THV;

ACF GCS TEMPLATE (continued)

4) supplemental actions for MUSE-STC to explore how all State MIECHV awardees serve AIAN families with home visiting; and 5) additional dissemination work to engage stakeholders and develop priority special topics, documents, reports, briefs, presentations and/or other dissemination-related materials associated with the learning generated from this contract. The period of performance for the proposed work is 8/2021-8/2026, and it is proposed as supplemental actions for an existing task order

(HHSP233201500133I/HHSP23337004T).

The MUSE-THV work obtained in the original contract covered MUSE stakeholder engagement plans with Tribal MIECHV grantees, co-creation of the conceptual model and research questions with stakeholders, design of the mixed methods approach, data collection plans, OMB package submission and approval, establishment of memorandum of agreement between 17 Tribal MIECHV grantee organizations and JBA to conduct

MUSE, data collection, modification of in-person data collection modalities for virtual data collection (due to pandemic), data collection, and analytic plans. The MUSE-STC work obtained in the original contract covered MUSE stakeholder engagement plans with

States and Local Implementing Agencies (LIAs) that serve tribes, modification of the conceptual model and development of research questions with stakeholders, design of qualitative approach, and OMB package submission and approval.

The proposed modification will support supplemental actions for the analysis of the

MUSE-THV study thread to understand implementation of home visiting with AIAN families during the COVID-19 pandemic. It will also support supplemental actions for the analysis of the quantitative and qualitative data through engagement with a dissemination committee comprised of Tribal MIECHV grantees, resulting in new findings to disseminate to priority audiences. For MUSE-STC, it will support supplemental actions to understand how all States serve AIAN families through the design of a survey, data collection, and mixed methods analysis of the qualitative and quantitative data from MUSE-STC. Through intensive stakeholder engagement to inform analysis and interpretation, both MUSE-THV and MUSE-STC will produce dissemination products that answer questions of importance to the federal government and constituents.

Key project tasks include project management and communication, stakeholder engagement in each phase of the study, memorandum of agreements with tribal organizations, human subjects review, data collection and data submission, iterative mixed methods data analysis, data security and storage, data reports, and topical briefs.

The period of performance is a total of sixty (60) months, consisting of one (1) base period and six (6) option periods. The base period is thirty-six (36) months (August 2021

– August 2024), Optional Services Component 2 is twenty-four (24) months (August

2021 – August 2023), Optional Services Component 3 is fifty-six (56) months (December

2021 – August 2026), Optional Services Component 4 is thirty-six (36) months

(December 2021 – August 2024), and Optional Services Component 5 is twelve (12) months and can be elected up to three (3) times (December 2022 – December 2023;

December 2023 – December 2024; December 2024 – December 2025). This contract is a sole source to the contractor of Contract No. HHSP233201500133I/HHSP23337004T.

4. The Authority and Supporting Rationale and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service:

The authority under which this J&A is made is pursuant to FAR 8.405-6 Limiting

Sources.

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

X 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; or

(FAR 8.405-6(a)(1)(i)(B))

In the interest of economy and efficiency, the new work involves supplemental actions 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. (FAR 8.405-6(a)(1)(i)(C))

Items peculiar to one manufacturer. An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. (FAR 8.405-6(b)).

1. Only one such contractor is capable of providing the supplies or services required at the level of quality required because the services ordered are unique or highly specialized.

JBA is the only responsible source who can provide supplemental actions to the

MUSE study. The purpose of the MUSE study is to use a mixed methods approach to understand implementation of the evidence-based MIECHV program in tribal communities that are very different from the communities where the evidence for

MIECHV was initially established. Importantly, there is a history of mistrust of federal evaluations by tribal communities. To address the mistrust and successfully evaluate programs, time-intensive approaches are required to establish and maintain trust between contractors who conduct federal evaluations and the specific communities involved in those studies. For example, a key requirement of MUSE is that it is a stakeholder-engaged study with active participation in the study design and plans, analysis, interpretation, and dissemination by the tribal communities served by

MIECHV-funded programs. JBA has carried out all of the requirements of this stakeholder-engaged study with due diligence and has developed a trusted relationship with each of the tribal communities in MUSE. A change to another contractor would break the trust that currently supports the MUSE study and similar trust could not be re-established in timely fashion.

A major time-intensive requirement of MUSE is a memorandum of agreement with each entity participating in the study. For MUSE-THV, the contractor has negotiated an Agreement of Collaboration and Participation in MUSE (ACaP) and Tribal or

Organizational Statement of Study Approval of MUSE (TOSSA) with 17 separate

Tribal MIECHV grantees. These agreements are between JBA and each grantee.

Additionally, JBA has acquired human subjects approval for the study from the

Colorado Multi-Site Institutional Review Board (COMIRB) and from the local tribal

IRBs of 7 Tribal MIECHV grantees that require an additional level of review. The

17 Tribal MIECHV grantees in MUSE-THV have cooperative agreements that are currently slated to end in September 2022. A new contractor would need to establish their own memorandum of agreement with each grantee, a process that may take up to a year with some communities and would likely be more time-intensive due to the consequences of changes to the previous memorandum of agreement with JBA.

Additionally, in addition to a Multi-Site IRB approval, the contractor would need to go through the IRB approval processes with at least 7 Tribal MIECHV grantees. It is not feasible for a new contractor to develop trust with grantees, re-negotiate and establish new agreements, and receive secure data transfer of grantee data from JBA in a timely fashion.

A key component of the memorandum of agreement, and a requirement of the contract, is the protocol for data ownership and data security. JBA has established the data security plans for MUSE that includes 12 data flows that are approved by

OPRE for storing, sharing, and returning data to grantees. Entirely new plans would need to be created and approved to transfer the data from JBA to a new contractor;

these plans would need to be approved by OPRE and by each individual grantee in accordance with their own requirements for data security, storing, sharing, and returning data to grantees. Another key component of the memorandum of agreement is the intensive involvement of grantees in the dissemination committee to guide the identification of secondary analysis for specific audiences.

Because of concerns about how federal evaluations have been conducted with tribal communities in the past, a requirement of MUSE is that it utilizes both quantitative and qualitative data in a mixed methods approach. JBA brings this specialized expertise in mixed methods to the MUSE study. A mixed-methods approach increases the study’s scientific rigor, reduces the limitations of strictly qualitative

(e.g., reduced generalizability) or quantitative studies (e.g., limitations associated with statistical power), and ensures the study is culturally rigorous and responsive to stakeholders’ input. JBA has developed analytic plans for the mixed methods that use an iterative approach whereby each type of data informs and builds on the other.

JBA has unique access to and knowledge of these specialized plans for the data.

The Office of Management and Budget approved the MUSE-THV research design, data collection, and analysis plans in December 2018 (i.e., OMB #0970-0521). In

May 2019, after the ACaP, TOSSA, and IRB processes for all the Tribal MIECHV grantees were completed, the MUSE team began their two-year period of data collection. In March 2020, when the pandemic caused a shut down in the United

States, the MUSE team paused data collection and developed procedures for virtual data collection to replace in-person modalities. After a four month pause, virtual data collection began. As stewards for the data collected thus far, JBA has unique proprietary access to data collected prior to the COVID-19 pandemic and data collected during the pandemic.

Another complexity of federal evaluations conducted in tribal communities are concerns tribal communities have about outsiders collecting data. Given concerns

Tribal MIECHV grantees expressed about having outside researchers collect data in their communities, JBA created a data collection protocol for MUSE so that home visiting staff administer MUSE data collection instruments to caregivers during home visits. The JBA team provides evaluation technical assistance to Tribal MIECHV grantees to collect this data. As such, JBA has proprietary knowledge of how to provide technical assistance for the MUSE study.

JBA also has unique capacities for MUSE-STC given their long-term convening of the State-Tribal Collaborations Community of Practice for MIECHV (CoP). JBA has leveraged the stakeholder relationships built through the CoP to design the MUSE-

STC qualitative study; this stakeholder engagement will be invaluable to expanding the MUSE-STC to include quantitative data.

Other contractors could not adequately support OPRE's goal because they do not have existing agreements with tribal communities to conduct the study, do not have human subjects approval from a multi-site IRB or local tribal IRBS for the study, do not have possession of the data collected to date, do not have the specialized knowledge related to the analytic plans for MUSE, and do not have trusted relationships in place to facilitate the stakeholder engaged activities of the dissemination committee.

It is also to the benefit of the Government for this particular contractor to continue this work because the contractor is a small business. This status will help ACF and

HHS to meet their small business targets.

5. A Determination by the Ordering Activity Contracting Officer that the Order

Represents the Best Value Consisten with 8.404(d).

An analysis of the Contractor’s proposal will be performed by the ACF, Officer of

Government Contract Services (GCS), Contracting Officer to determine the price fair and reasonable pursuant to 8.405-2. The Contracting Officer will ensure the Contractor’s fixed rates do not exceed the schedule and will seek additional discounts prior to placing an order.

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.

This requirement provides supplemental actions for the ongoing contract/order

HHSP233201500109I HHSP23337003T awarded in September 2016 to study the implementation of the Maternal Infant Early Childhood Home Visiting (MIECHV)

Program in tribal communities. The initial award was competed through PSC ID/IQ

(Task Order) list. Market research was conducted in 2016 based on a review of research literature, contact of knowledgeable researchers in home visiting and American Indian /

Alaska Native communities, contact of project officers who have projects focused on drug use prevention in tribal communities, and queries of the PSC ID/IQ list looking for

Date

Competition Advocate

HHS, ACF, GCS