B. Limited Sources Justification-Signed.pdf

LIMITED SOURCES JUSTIFICATION

CUI//PROCURE

PROJECT NAME: Automated Acquisition Management System (AAMS) Logical follow on Contract.

This acquisition is conducted under the authority of the Multiple-Award Schedule Program (see 8.401).

The following Limited Sources Justification is prepared in accordance with FAR Subpart 8.405-6(c).

1. ORGANIZATION:

Federal Energy Regulatory Commission Office of the Executive Director Acquisition Services Division 999 North Capitol Street, NE Washington, DC 20426

2. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED:

The Federal Energy Regulatory Commission (FERC) intends to award a limited source action to Distributed Solutions, Inc. (DSI), 12350 Pinecrest Road, Reston, Virginia 20191 as a logical-follow on to previously competed General Services Administration (GSA) Federal Supply Schedule (FSS) Task Order.

No. FERC-10-F-0551, which is a firm-fixed price Delivery Order issued under GSA FSS 70 against Contract Number GS-35F-5370H, with Distributed Solutions, Inc. for software licenses and maintenance support associated with their proprietary Automated Acquisition Management System

3. DESCRIPTION OF REQUIREMENT:

The FERC’s Acquisition Services Division currently utilizes AAMS as a contract document generation, milestone tracking, and contract file management system. The IGCE for a yearly license is $353,895.67 and $1,061,687.02 for the three years of the logical follow on contract. The estimated integration costs of adopting a new system are $1,662,962.16 and will be incurred after the follow-on contract is completed and the re-competition is completed.

4. STATUTORY AUTHORITY & RATIONALE:

FAR8.405-6

(a) Orders or BPAs exceeding the micro-purchase threshold based on a limited sources justification.

(1) Circumstances justifying limiting the source. (i) For a proposed order or BPA with an estimated value exceeding the micro-purchase threshold not placed or established in accordance with the procedures in, 8.405-2, or 8.405-3, the only circumstances that may justify the action are–

[ ] (A) An urgent and compelling need exists, and following the procedures would result in unacceptable delays;

[ ] (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; or

[ X ] (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.

Rationale for follow on contract The follow-on contract will allow the Acquisition Services Division (ASD) and the Financial Information Technology & Travel Division (FITT) to complete an on-going interdependent project that is ultimately going to impact the final requirements of FERC’s contract writing system solicitation. Specifically, ASD

And FITT are actively engaged in implementing a ServiceNow application that is designed to enforce interdependencies that exist between CFO business processes, maximize automation and elevate the quality of information available to support internal decision making. Fundamentally, the CFO ServiceNow project aims to:

• design and implement a central gateway for CFO customers to request and receive financial-related services (including procuring goods and services)

• create a unique identifier that ties an initial funding request through contractual award to disbursement of treasury payments

• leverage the initial office funding request unique identifier to forecast future the Department of Budget and Acquisition Services Division’s workload

• absorb and integrate all the residual customer-facing ASD business processes that fall outside the existing CFO applications

• provide clear visual processing pathways that enforce the natural progression of action items defined by interdependencies that exist between ASD business processes that cross organizational boundaries

• automate the compilation and distribution of acquisition information

• enable CFO customers to gain transparency and insight into the status of ASD service requests and/or business processes

• create a unified portfolio of tailored reports/dashboards strategically designed for target CFO audiences (i.e., CORs, Office Directors, OED executives, etc.)

As the CFO organization works toward achieving the objectives outlined above, ASD is vigorously reassessing and reengineering their business processes, which is having cascading effects on how Contracting Officers/Specialists interact with FERC’s acquisition application and how the acquisition application interfaces with FERC’s complimentary peripheral financial systems. Given the current state of evolving application requirements, FERC management is not able to solicitate a reliable/finalized Statement of Work, or able to commit to the high level of effort that would be required to support a new contractor with the following transitional activities:

• Procuring and configuring the necessary technological infrastructure for the new contract writing system

• Certifying the new acquisition system (i.e., crafting/attesting the entire FedRAMP package, Memorandum of Understanding, Interagency agreement, etc.)

• Participating in application configuration work sessions for the new system

• Outlining the Acquisition Service Division’s core mission

• Defining FERC’s ‘As-Is’ business processes (which are actively changing as a result of the CFO ServiceNow project)

• Assessing and providing feedback on proposed ‘To-Be’ business processes

• Defining functional roles and translating business process responsibilities into applicable system security roles and application permission lists

• Entering all baseline application settings and security administration configuration

• Crafting all change management documentation related to the new system (i.e., end-user guides, process flow diagrams, online tutorials, etc.)

• Developing and delivering classroom training on the new system

• Overcoming the inherent knowledge curve associated with learning a new system

• Migrating historical acquisition data to a new application

• Designing, developing, testing and implementing new integrations between FERC’s financial applications (i.e., PeopleSoft Financials, ServiceNow, Business Intelligence, etc.) and a new acquisition system

• Configuring the new application to successful interface with peripheral acquisition systems (e.g., SAM, FPDSNG, eBuy, FBO, ORCA, etc.)

Based upon the aforementioned factors, FERC management has determined that recompeting the acquisition system prior to the completion of the ServiceNow project would result in increased risk, potential delays in schedule, and increased costs, all of which not be in the best interests of FERC, the Federal Government and the American taxpayer. Moreover, FERC believes the existing DSI team possesses a broad range of institutional knowledge (i.e., FERC’s business processes, policies, procedures, systems, technological infrastructure, etc.) that is essential to ensure operational stability while ASD personnel focus on integrating and streamlining their business processes within the ServiceNow platform.

Upon completion of the ServiceNow project (projected to be another 14 months) the entire ‘acquisition system’ contract will be subject to full and open competition.

5. MARKET RESEARCH CONDUCTED AMONG SCHEDULE HOLDERS :

On February 21st, 2020 FERC sent a Request for Information (RFI) to three schedule holders (CGI, CACI, Unison). Each firm responded and were found to be all capable.

6. CONTRACTING OFFICER (CO) DETERMINATION THAT THE ORDER REPRESENTS THE BEST

VALUE CONSISTANT WITH 8.404(d)

The AAMS system is provided at a Firm Fixed Price even though a Statement of Work is used. GSA determined the pricing fair and reasonable at award of DSI;s master GSA contract award. This in combination with the rationale explained in section 4 of this document leads the CO to determine that the follow-on contract with DSI for continued use of the AAMS system represents the best value to the government.

7. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR

OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION FOR

THE SERVICES REQUIRED:

The FERC will commence a re-compete competition issuing a solicitation to at least the three firms who responded to the RFI and Distributed Solutions in 14 months or after completion of the Service Now project whichever comes first.

8. CERTIFICATIONS & APPROVALS: (Signatures are required)

Technical & Requirements Certification:

I certify that the supporting data under my cognizance that are included in this document are accurate and complete to the best of my knowledge and belief.

Geoff Gilliar Date

COR

Office of the Chief Financial Officer (CFO) Federal Energy Regulatory Commission

Contracting Officer Certification:

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

Ryan I Kirkwood Date Contracting Officer Acquisition Services Division Office of the Executive Director

Competition Advocate Approval: (required over $250,000.00 under $750,000.00) I have reviewed the Justification and find the document adequately addresses the requirements of FAR Subpart FAR8.405-6(a)(1)(C).

Marc G. MacKeigan Date Competition Advocate Acquisition Services Division Office of the Executive Director