WCF - LSJ 9.5.25 JP signed.pdf

Template for a Federal Supply Schedule (FSS) Limited-Sources Justification

Completion Instructions: HHS has established a standard template for the preparation of a Limited-Sources Justification (LSJ) pursuant to FAR Subpart 8.4. This template is for use with orders issued under the Federal Supply Schedule (FSS) program where the value exceeds simplified acquisition threshold and competition is restricted: (1) to fewer schedule contractors than required in FAR 8.405-1, 8.405-2, or 8.405-3, or (2) to an item peculiar to one manufacturer. See FAR Subpart 8.4 for additional guidance. This template is not for use with acquisitions other than those under FAR Subpart 8.4.

Tailor all aspects of this template to the individual acquisition. Consult FAR 8.405-6 for guidance. An addendum may be added in case additional space is needed.

When this document is printed, the blue italic instructions are automatically deleted on the printed version.

FEDERAL SUPPLY SCHEDULE

LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Working Capital Fund

Agency: ASPR

Acquisition Year (FY): FY25

Author: Christian Poole, WCF PMO Director

2. Description of Action:

Nature: New Requirement Follow-on Requirement

Modification to Existing Purchase Order/Contract Number:

Pricing: Firm-Fixed Price Time & Materials Cost

Other:

Funds: OMA Other Funds:

<For each proposed contractor if more than one (e.g., brand name):>

Name of Proposed Contractor(s): Deloitte

Street Address: 1919 N. LYNN STREET

City, State, Zip: Arlington, VA 22209

Remove ContractorAdd Contractor

3. Description of Supplies and Services to Include Contract Vehicle/Number Utilized:

A methodically implemented cost allocation plan will provide the budget infrastructure necessary to manage the cost recovery program and allow ASPR (Administration for Strategic Preparedness & Response)/ASHF (Assistant Secretary for a Healthy Future) to more effectively accomplish its mission by helping achieve the following goals: fiscal transparency, budget and investment management, and business efficiency and accountability. The contract will implement the cost allocation plans and working capital fund methodology previously developed in the working capital fund transformation project at ASPR during FY23 to FY25.

The solicitation will be issued against Deloitte Consulting LLP Multiple Award Schedule GSA contract 47QRAA18D001P using FAR 8.405-6(a)(1)(i)(B)).

The estimated value of the proposed action, including all options, is $ 1,500,000.00

Briefly describe the supplies or services to be provided, including make & model number where appropriate. Indicate whether the item to be procured is peculiar to one manufacturer (e.g., a particular brand name, product, or a feature of a product, peculiar to one manufacturer). If applicable, include quantities of supplies or period of performance for services.

Provide information for any options included in the order. If the action is a modification to an existing order, distinguish clearly between the work covered by the basic order and the work to be obtained by the proposed modification.

4. Authority:

ORDER AGAINST FSS: Authority of the Multiple Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501, Services for Executive Agencies; and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6. Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405-6(c)(2)(iv).

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

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

The proposed contract with Deloitte for the implementation and continued operation of the Working Capital Fund (WCF) is justified under (FAR 8.405-6(a)(1)(i)(B)) Only one source is capable of providing the supplies or services required at the level or quality required because the supplies or services are unique or highly specialized. Deloitte has unique qualifications and institutional knowledge essential for the successful and uninterrupted continuation of the WCF implementation. This includes Deloitte prior development of all necessary implementation documents and their staff's immediate readiness to commence work. This readiness eliminates the need for a transition period, which would be required with a new vendor. The government must achieve full operational capability for a major WCF implementation within days of contract award.

Over the past three years, Deloitte has developed a highly specialized knowledge base and a deeply integrated solution through its work on the transformation contract. A transition to any other vendor would fail to meet the government's timeline. No other vendor possesses the unique expertise and proprietary system knowledge required to be immediately operational. Therefore, a competitive procurement for the next phase of the WCF transformation is not feasible. The immediate operational capability required for this major implementation cannot be met by transitioning the work to a new vendor. Any other vendor would need to substantially recreate the complex, integrated work already completed.

This duplication of effort would cause a mission-critical delay that is not in the government's best interest.

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 (FAR 8.405-6(a)(1)(i)(C)); or

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)).

When competition is limited to items peculiar to one manufacturer, this justification must explain why the particular brand name, product, or feature is essential to the Government's requirements, and that market research indicates other companies' similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency's needs in accordance with FAR 11.105.

5. Market Research:

Describe the extent of the market research conducted among the schedule holders and the results, or a statement of the reason that market research was not conducted. Brand name specifications shall not be used unless the particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s need.

Market research was conducted on July 28, 2025 through August 1, 2025 to determine if other sources could provide these services without unacceptable delays and substantial cost duplication. The results indicated that no other vendor possesses the necessary in-depth knowledge and experience with ASPR's existing working capital budget infrastructure to take over the work seamlessly. Any other source would require significant ramp-up time, additional training, and integration.

6. Actions to Increase Competition:

Describe the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration prior to any subsequent acquisition for the supplies or services is made. If no such actions have been taken, explain why.

A notice was publicized on August 10 through August 26, 2025. No other sources have expressed interest. This determination to sole source is made with the understanding that efforts will continue to be made to ensure that the Government's long-term requirements for the WCF will be met through full and open competition whenever practicable.

7. Any other facts supporting the justification:

The incumbent, Deloitte, has developed and integrated a deep understanding of ASPR's leadership and organizational structures, mission, office responsibilities and processes, accounting systems, budgeting process and financial transactions, policies, and history. In establishing a new cost allocation and recovery process, ASPR has made significant integration investments in aligning Deloitte techniques (complex vendor created spreadsheets) to ASPR's financial systems. While ASPR owns and will retain the spreadsheets, any future user will incur significant time and effort reverse engineering to create their own or fully understand and operate another firm's product. Transitioning this work to a new vendor would require a costly and time-consuming knowledge transfer process. A new contractor would need to spend significant funds and time to learn the existing systems and operational environment. The cost of this duplication would likely exceed any savings from competition.

8. Technical / Requirements Certification: By my signature below, I certify that the supporting data under my review which is included in this Limited-Sources Justification is accurate and complete.

Program Manager

Name: Christian Poole

Position Title: WCF PMO Director

Email address: christian.poole@hhs.gov

Phone: 227 215-4065

Program Manager Supervisor (or one level above Program Manager)

Name: Jay Petillo

Position Title: Director, Center for Administration, Office of Finance, ASPR

Email address: jay.petillo@hhs.gov

Signature:

Date: 9/4/2025

9. Best Value Determination: By my signature below, after review of the relevant documents, I have determined that the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d), and constitutes a fair and reasonable price. The basis for my determination is as follows:

Describe in detail the basis for the determination that this order provides the best value, and that the price is fair and reasonable. Attach and/or summarize applicable market research, commercial prices lists, comparable GSA schedule pricing or other markers that were used in this determination.

The anticipated cost to the Government for this follow-on contract will be fair and reasonable. Appropriate price analysis techniques will be utilized, including an assessment of the current vendor's proposed pricing against historical data and market benchmarks.

10. Contracting Officer's Approval (Required for proposed contract not to exceed $700,000 (value calculated including all options)): I hereby certify that this justification is accurate and complete to the best of my knowledge. I approve this justification subject to the availability of funds, and provided that the services and supplies herein described have otherwise been approved for acquisition.

Name: Shone D. Dickerson Phone: 2027303928

Signature: Date: 9/4/2025

11. Legal Review:

All J&As greater than $68 million must have a legal review from the General Law Division of the Office of the General Counsel prior to sending it to the Department.

12. OPDIV Competition Advocate Approval (Required for proposed contract over $700,000 but not exceeding $13.5 million (value calculated including all options)):

I have reviewed this justification and find that it adequately supports limiting sources.

Name: Makoto Braxton Phone:

Signature: Date:

13. Office of Small and Disadvantaged Business Utilization:

I have reviewed this justification and find that it adequately supports limiting sources.

Name: Phone:

Signature: Date:

14. OPDIV HCA Approval (Required for proposed contract over $13.5 million but not exceeding $68 million (value calculated including all options)):

Name: Phone:

Signature: Date:

15. Department Competition Advocate:

Concur: Non-Concur:

Name: Phone:

Signature: Date:

(The below approval paragraph is required if the cumulative contract value, including all options, exceeds $68 million.)

16. HHS Senior Procurement Executive (SPE) Approval:

Based on the foregoing justification, I hereby approve limiting sources for the above stated procurement, subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

State supplies/services being procured:

State the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304:

Name: Phone:

Signature: Date:

Template for a Federal Supply Schedule (FSS) Limited-Sources Justification

Completion Instructions: HHS has established a standard template for the preparation of a Limited-Sources Justification (LSJ) pursuant to FAR Subpart 8.4. This template is for use with orders issued under the Federal Supply Schedule (FSS) program where the value exceeds simplified acquisition threshold and competition is restricted: (1) to fewer schedule contractors than required in FAR 8.405-1, 8.405-2, or 8.405-3, or (2) to an item peculiar to one manufacturer. See FAR Subpart 8.4 for additional guidance. This template is not for use with acquisitions other than those under FAR Subpart 8.4.

Tailor all aspects of this template to the individual acquisition. Consult FAR 8.405-6 for guidance. An addendum may be added in case additional space is needed.

When this document is printed, the blue italic instructions are automatically deleted on the printed version.

FEDERAL SUPPLY SCHEDULE

LIMITED-SOURCES JUSTIFICATION

2. Description of Action:

Nature:

Pricing:

Funds:

<For each proposed contractor if more than one (e.g., brand name):>

3. Description of Supplies and Services to Include Contract Vehicle/Number Utilized:

Briefly describe the supplies or services to be provided, including make & model number where appropriate. Indicate whether the item to be procured is peculiar to one manufacturer (e.g., a particular brand name, product, or a feature of a product, peculiar to one manufacturer). If applicable, include quantities of supplies or period of performance for services. Provide information for any options included in the order. If the action is a modification to an existing order, distinguish clearly between the work covered by the basic order and the work to be obtained by the proposed modification.

4. Authority:

When competition is limited to items peculiar to one manufacturer, this justification must explain why the particular brand name, product, or feature is essential to the Government's requirements, and that market research indicates other companies' similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency's needs in accordance with FAR 11.105.

5. Market Research:

Describe the extent of the market research conducted among the schedule holders and the results, or a statement of the reason that market research was not conducted. Brand name specifications shall not be used unless the particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s need.

6. Actions to Increase Competition:

Describe the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration prior to any subsequent acquisition for the supplies or services is made. If no such actions have been taken, explain why.

7. Any other facts supporting the justification:

8. Technical / Requirements Certification: By my signature below, I certify that the supporting data under my review which is included in this Limited-Sources Justification is accurate and complete.

Program Manager Name:

Position Title:

Email address:

Phone:

Program Manager Supervisor (or one level above Program Manager) Name:

Position Title:

Email address:

Signature:

Date:

9. Best Value Determination: By my signature below, after review of the relevant documents, I have determined that the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d), and constitutes a fair and reasonable price. The basis for my determination is as follows:

Describe in detail the basis for the determination that this order provides the best value, and that the price is fair and reasonable. Attach and/or summarize applicable market research, commercial prices lists, comparable GSA schedule pricing or other markers that were used in this determination.

10. Contracting Officer's Approval (Required for proposed contract not to exceed $700,000 (value calculated including all options)): I hereby certify that this justification is accurate and complete to the best of my knowledge. I approve this justification subject to the availability of funds, and provided that the services and supplies herein described have otherwise been approved for acquisition.

Name:

Phone:

Signature:

Date:

11. Legal Review:

All J&As greater than $68 million must have a legal review from the General Law Division of the Office of the General Counsel prior to sending it to the Department.

12. OPDIV Competition Advocate Approval (Required for proposed contract over $700,000 but not exceeding $13.5 million (value calculated including all options)):

I have reviewed this justification and find that it adequately supports limiting sources.

Name:

Phone:

Signature:

Date:

13. Office of Small and Disadvantaged Business Utilization:

I have reviewed this justification and find that it adequately supports limiting sources.

Name:

Phone:

Signature:

Date:

14. OPDIV HCA Approval (Required for proposed contract over $13.5 million but not exceeding $68 million (value calculated including all options)):

Name:

Phone:

Signature:

Date:

15. Department Competition Advocate:

Concur:

Non-Concur:

Name:

Phone:

Signature:

Date:

(The below approval paragraph is required if the cumulative contract value, including all options, exceeds $68 million.)

16. HHS Senior Procurement Executive (SPE) Approval:

Based on the foregoing justification, I hereby approve limiting sources for the above stated procurement, subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

State supplies/services being procured:

State the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304:

State the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304 Name:

Phone:

Signature:

Date:

11.0.0.20130303.1.892433.887364 Justification & Approval - Federal Supply Schedule Health and Human Services Justification & Approval - Federal Supply Schedule

The solicitation will be issued against Deloitte Consulting LLP Multiple Award Schedule GSA contract 47QRAA18D001P using FAR 8.405-6(a)(1)(i)(B)).

Over the past three years, Deloitte has developed a highly specialized knowledge base and a deeply integrated solution through its work on the transformation contract. A transition to any other vendor would fail to meet the government's timeline. No other vendor possesses the unique expertise and proprietary system knowledge required to be immediately operational. Therefore, a competitive procurement for the next phase of the WCF transformation is not feasible. The immediate operational capability required for this major implementation cannot be met by transitioning the work to a new vendor. Any other vendor would need to substantially recreate the complex, integrated work already completed. This duplication of effort would cause a mission-critical delay that is not in the government's best interest.