C38_SOA_Limited-Source_Justification_(LSJ)_GSA_FSS_Over_SAT_REDACTED_1.pdf

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C 501

SOLICITATION 140D0425Q0491

This acquisition is conducted under the authority of the Multiple Award Schedule (MAS) Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

Department of the Interior, Interior Business Center, Acquisition Services Directorate, Division 5, on behalf of the Administration for Children and Families (ACF) Office of Community Services (OCS), under the Department of Health and Human Services

(HHS).

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

This a limited source justification in support of an order for Capacity Building for Discretionary and Demonstration Programs for ACF OCS. It is a logical follow-on requirement to General Services Administration (GSA) MAS order GS00F010CA 75ACF122F80037 with ICF Incorporated, LLC.

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

The purpose of this requirement is to procure a wide range of logistical and administrative services to support the capacity building of discretionary and demonstration grant recipients for ACF OCS. OCS partners with states, communities, and agencies to eliminate causes of poverty, increase self-sufficiency of individuals and families and revitalize communities. OCS’s social service and community development programs work in a variety of ways to improve the lives of many. The contractor must provide all personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, information technology support, and other items and non-personal services necessary to perform technical assistance and training, data analytics, monitoring and evaluation, communication and outreach, conference management, logistical support, and innovation and technology as defined in the Performance Work Statement. Tasking includes the following:

Capacity Building Plan Program/Project-Management Capacity Building, Research, Training and Technical Assistance (T&TA) and Program Support Services Expand Internal and External Communications Capacity

Solicitation 140D0425Q0491

Policy Development Support

This is a one year order with a period of performance of 9/30/2025-9/29/2026. The period of performance includes a six-month base period and a six-month option. The estimated total value is .

4. The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(a)(1)(i)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 Blanket Purchase Agreement (BPA) must not have been previously issued under sole-source or limited-sources procedures.

ACF has implemented a new layer of approvals within the last few months for all new requirements, which has created a delay of several months in awarding the ACF Capacity Building Requirement. ACF internal approval was obtained on 5/30/2025;

however, this requirement must be awarded by 9/29/2025 to avoid a gap in service. If the requirement was awarded to any vendor other than the incumbent, it would require an award date of 8/15/2025, to accommodate a four to six week transition-in period before the current order expires on 9/29/2025. This transition-in period is necessary to accommodate security and training requirements for any new vendor and to fully transfer the incumbent’s critical and in-depth knowledge of the program to any other awardee, to ensure the success of the program. There is insufficient time to award a competitive order before 8/15/2025 and would result in a gap in work.

A gap in work would significantly impact ACF and its grant recipients. Interruptions in essential logistical and administrative support services would lead to delays in program implementation and service delivery. The effectiveness of training, technical assistance, and resource coordination efforts would diminish without continuous support, affecting the overall success of the programs. Grant recipients would face financial instability due to the lack of timely funding and support, hindering their ability to plan, manage, and execute their initiatives. Additionally, the ability to leverage federal, state, and local resources through partnerships would be compromised, resulting in missed opportunities for collaboration and resource maximization. Delays in disseminating information regarding the results and effectiveness of grant activities would affect transparency and the ability to make informed decisions for future initiatives. Ultimately, these disruptions would hinder ACF's mission to eliminate poverty, increase self-sufficiency, and revitalize communities.

Therefore, as the incumbent, ICF is the only vendor that does not require a transition-in period and can currently meet the requirement and prevent a gap in work. It is in the best interest of the Government to conduct a one year logical follow-on GSA order to the incumbent, ICF Incorporated, to accommodate a four to six week transition-in period for the next requirement. The period of performance will be divided into a six-month base period and six-month option period, to promote competition in case the competitive follow-on can be awarded within the six-month base period.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

Price will be evaluated in accordance with FAR 8.404(d). The Contracting Officer will determine price reasonableness based on a comparison of the proposed price with prices found reasonable on previous similar purchases, and a comparison with the Independent Government Estimate (IGE) and current GSA price lists. In accordance with FAR 8.405-2(d), the Government will consider the level of effort and the mix of labor proposed in the total price reasonableness determination. The solicitation will also request an additional discount off of the vendor’s GSA pricing.

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.

Market research included a review of federal supply schedules and various Government-Wide-Acquisition Contracts (GWACs). A Market Research as a Service (MRAS) Rapid Research Review was conducted by GSA. There were 3016 Vendors returned using the MAS Special Item Number (SIN) 541611: Management and Financial Consulting, Acquisition and Grants Management Support, and Business Program and Project Management Services. The summary also provided an additional option resulting in 46 vendors using Human Capital and Training Solutions (HCATS) U POOL2: Human Resources and Organization Support and 35 vendors using HCATS Small Business (SB) POOL2: Human Resource Consulting Services. A small business dynamic search was also conducted by searching NAICS code 541611, which resulted in 102 small business contractors in multiple socio-economic categories. GSA e-library was also searched, which resulted in available mechanisms as GSA One Acquisition Solution for Integrated Services (OASIS) -SB, HCATS- 8A, and MAS 541611. The keywords “grants management” MAS 541611 search of GSA e-library resulted in 343 vendors that provide grants management services.

Small businesses are available for NAICS code 541611 through Best-in-Class solutions and contract vehicles listed on the 2025 mandatory use list. The Small Business Dynamic Search resulted in 102 small business contractors. The GSA MAS 541611 has a combination of large and small businesses.

Market research also included a review of the history of the requirement, under the current order GS00F010CA 75ACF122F80037, which is set to expire on 9/29/2025. The requirement was openly competed, and two offers were received: one from ICF Incorporated, a large business, and another from Abaco Strategy LLC, a small business. Both vendors were deemed capable of performing the requirement, but ICF received the award. ACF has been satisfied with ICF’s performance on the order to date. Based on this review of the history of the requirement, it is unclear at this time if there is more than one small businesses capable of performing the requirement. More time is needed to conduct a sources sought to make this determination.

7. Any other facts supporting the justification.

N/A

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

The Government plans to compete the next requirement and will begin market research for it this fall. Market research will include issuing a sources sought, to determine the extent of the competitive environment among small businesses. This order will be structured as a six-month base with a six-month option period, in case the Government is able to award the competitive follow-on within the six-month base period. This will provide sufficient time to accommodate the four to six week transition-in period necessary if another vendor receives the award.