Banclab_mod_JOTFOC_FE.pdf

DEPARTMENT OF TRANSPORTATION

FEDERAL HIGHWAY ADMINISTRATION

Justification for Other Than Full and Open Competition

1. Identification of the agency and the contracting activity.

Federal Highway Administration (FHWA), Office of Acquisition and Grants Management, 1200 New Jersey Avenue, S.E., Washington, DC 20590.

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

This is a justification for other than full and open competition to award a modification on a sole source basis to Banclab under Contract No. DTFR5315C00018. This modification is to add work within the scope of the contract. Specifically, the objective of this modification is to integrate the new OMB-approved model methodology into Railroad Credit Assessment and Portfolio Management System (RCAPM) system. This justification is prepared in accordance with the content requiremetns in FAR 6.303

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

The Contractor, Banclab, maintains the RCAPM tool, and has previously modified RCAPM in response to ongoing OMB requirements. RCAPM supports the Railroad Rehabilitation and Improvement Financing (RRIF) loan program. In mid-August 2019 OMB approved a new model methodology, which needs to be integrated into RCAPM software.

Under this modification, the Contractor shall integrate the new requirements for the RRIF model into RCAPM system, based on the following model methodology approved by OMB in August 2019:

• Allow for Geometric Periodic Conversion of Default Rates.

• Allow for a restart of Default Curves for Financing Account Interest, Technical

Reestimates, and Modification Cost calculations.

• Allow for Recovery Cashflows to be calculated based on the defaulted payments

(current model assumes that the recoveries are calculated based on the defaulted balance).

• Allow for all calculations to use the S&P U.S. Default Study as the basis for Default Rates.

The Contractor shall ensure that the aforementioned requirements are embedded and tested in the calculations within the RCAPM system. This additional work must be completed before the end of the 2019 Fiscal Year for financial statement purposes.

The estimated value of this work is $16,550.

4. Identification of the exception to fair opportunity and the supporting rationale.

The exception to fair opportunity utilized for this proposed action is FAR 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Banclab is the only source able to provide the proposed services to enhance the RCAPM software. Banclab created RCAPM and maintains the software under the subject contract.

Under this contract, Banclab has previously modified RCAPM in response to ongoing OMB requirements. It is noted that no other software is suitable to perform the work.

RCAPM was created by Banclab for the RRIF program because of the unique credit risk premium requirements and how RRIF loan re-estimates are calculated.

The additional work to be performed is closely related with the services currently performed, as Banclab uses this software for the related RRIF support services it performs for the Build America Bureau.

Accordingly, coordination and use of the software by another contractor would, at a minimum require significant additional time and resources to perform the work. There is a reasonable expectation that Banclab would need significantly less time than any other contractor to perform the work, which will translate into lower fees for such services. A new Contractor would not have the requisite background knowledge to efficiently complete the work under the order at a level of quality necessary to ensure the Government’s best interests. This makes Banclab’s work more efficient than a new contractor.

Thus, Banclab is the only capable source to meet the Government’s requirements.

7. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The modification will be issued on a firm fixed price basis. The Government will ask for a detailed price proposal and will evaluate the labor rates and labor categories. The Government will evaluate the level of effort to ensure it is realistic in relation to the requirements. The Government will also evaluate the cost against historical costs for similar services to ensure the amount is fair and reasonable.

9. Other facts supporting the use justification.

In addition, it is noted that OMB did not approve a new model methodology until mid- August 2019, and this work is required to be completed before the end of the 2019 Fiscal Year for financial statement purposes. Therefore, performance of these related services by a single contractor ensures that all of the work and work product is done in a single standard and consistent way that does not require spending additional time and resources for the Build America Bureau to coordinate the work and work products of more than one contractor.

11. Statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

Because the change is due to new methodology required by OMB, there is no known action that the Government can take to remove or overcome the barrier that led to this exception.

12. Certification and Approval

The evidence and any supporting data which form a basis for the justification is complete and accurate.

Linda Woodfolk Date Contracting Officer’s Representative Portfolio Manager Build America Burueau U.S. Department of Transportation

I certify that the information provided in this justification is accurate and complete to the best of my knowledge and belief. Based upon the preceding information, I hereby approve this justification for an other than full and open competition to award a modification to Banclab under Contract No. DTFR5315C00018.

Hector R. Santamaria Date Contracting Officer Office of Acquisition and Grants Management Federal Highway Administration

Linda B. Woodfolk 09/17/2019

9/17/2019