C38_SOA_redacted_LSJ_FCC_OIG_Mandated_Audit_Services_v1_Redacted_1.pdf

LIMITED-SOURCES JUSTIFICATION

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

Solicitation Number 140D0425Q00715

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

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

This document is a limited sources justification for the Department of the Interior (DOI), Interior Business Center, Acquisition Services Directorate, Division I, Branch I, on behalf of the Federal Communications Commission (FCC), Office of the Inspector General (OIG), as the DOI plans to contract by means other than full and open competition. This document sets forth the justification and approval to award a sole source logical follow-on Task Order for the continuation of the FCC OIG Mandated Audit Services.

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

The action being approved is the issuance of a short-term sole source logical follow-on Task Order pursuant to the procedures under Federal Acquisition Regulations (FAR) Part 8.405- 6(a)(1)(i)(C), logical follow-on, to have the incumbent contractor, Kearney and Company, P.C.

(Kearney), continue the FCC OIG Mandated Audit efforts under a 12-month base period which will run date of award through 12-months. This Order will also include one (1) 12-month option period, which could carry out services for a total of 24 months.

The objective of this GSA Task Order is to have a third-party contractor provide audit support services for the various mandated audits at the FCC. These audits include Task A – Annual Financial Statement Audit, Task B – Annual FISMA Evaluation, and Task C – Payment Integrity Information Act (PIIA) Audit.

As these separate audit tasks have various start and end dates, administration of these tasks under a single Task Order has become difficult, and the FCC has determined that it would be better to award a single award Blanket Purchase Agreement (BPA) for these services and issue each audit as a separate BPA Call. However, while FCC works to award this new competitive BPA, the FCC requires a short-term logical follow-on Task Order to continue these services until the BPA is established, where the scope of the short-term Order will include the annual audit requirements for Tasks A, B, and C as listed above.

procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

The DOI, Acquisition Services Directorate (AQD), on behalf of the FCC, awarded Task Order 140D0421F0183, Mandated Audits, to Kearney on March 9, 2021, as a result of a competitive solicitation on the General Services Administration (GSA) Multiple Award Schedules (MAS), category 541211 – Auditing Services. The existing GSA Task Order is scheduled to expire on March 9, 2026, and the Government is unable to add next year’s mandated audit cycle requirements to this existing Order as those changes would be viewed as out-of-scope in terms of dollar value and period of performance. However, the FCC OIG has an immediate need for auditing services to begin in October 2025, and it is critical that the FCC maintain these services in order to meet the Office of Management and Budget mandated audit deadlines, until the long-term competitive BPA is awarded.

This follow-on action is in the interest of economy and efficiency as the requirement has not changed since its previous iteration and there have not been any significant changes to the commercial marketplace for these services. The government is unlikely to gain significant benefit from competing this action. Utilizing a logical follow-on is in the best interest of the government.

Kearney already has personnel with appropriate clearances and internal knowledge of the audit process and FCC requirements which is essential to beginning and completing the upcoming audit cycle by the OMB mandated deadlines. Additionally, Kearney has demonstrated successful past performance under the existing contract vehicle. By using Kearney there will be no transition expense or startup time. The audit cycle begins in October and Kearney is positioned to begin work immediately. Therefore, it is in the best interest of the government to award this requirement on a sole source logical follow-on basis to Kearney.

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

The Contracting Officer (CO) will determine whether the anticipated prices are reasonable through the use of and comparison to GSA MAS schedule pricing which has already been determined fair and reasonable under FAR Part 8.404(d) - Pricing. The prices for the current Order were discounted prices received in a competitive environment and were evaluated to be reasonable at time of award. The IGE for this GSA follow-on Task Order is based on historical escalation prices utilized by Kearney’s GSA schedule. Moreover, in accordance with FAR 8.405-4 price reductions, the CO intends to request additional discounts from the offeror’s GSA schedule pricing. Travel will be on a T&M basis and the Federal Travel Regulations will be used as a standard for determining price reasonableness for estimated and actual travel costs.

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 to identify other schedule holders was not conducted but market research from the previous award was utilized to determine that a logical follow-on to Kearney is in the best