Roger_Schwarz_JA_final_Signed.pdf

JUSTIFICATION AND APPROVAL FOR OTHER-THAN FULL-AND-OPEN COMPETITION

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JUSTIFICATION AND APPROVAL FOR

OTHER-THAN FULL-AND-OPEN COMPETITION

A. JUSTIFICATION.

1.0 Agency and Office Name:

Consumer Financial Protection Bureau: The Office of Consumer Response

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

A Firm Fixed Price procurement for Feedback and Teamwork Training Services

3.0 Description of Requirement (including the estimated value).

The Office of Consumer Response (OCR) Operations is currently going through major organizational structure changes that will impact the Bureau’s employees.

The Bureau is working to support the model by implementing a Product Pod organizational structure encompassing various cross organization levels of senior management, non-managers and team members from the Front Office, Investigations, and Data sections. The new organization structure requires specific training so that CFPB can be successful in handling the increased number of consumer complaints. The training is needed to address the findings in the Bureau’s 2014 annual employee survey and align with the core competencies in employee performance plans.

The goal is to provide training to prepare the Product Team members and other OCR teams for the transition and to improve team performance and facilitation skills by using a mutual learning approach and methodology. This training is needed to develop and improve core skillsets in communication across teams and communication between non-managers versus managers, improve job performance by providing constructive suggestions and develop effective leaders and teams to build a shared language and consistent practice and approach for the new Product Pod organization structure.

Estimated value: $129,000.00

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4.0 Statutory authority permitting other-than full and-open competition.

FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services will Satisfy Agency Requirements (includes brand name, and exclusive licensing agreements or proprietary information)

FAR 6.302-2, Unusual and Compelling Urgency

FAR 6.302-3, Industrial Mobilization; Engineering, Developmental, or Research Capability; or expert Services

FAR 6.302-4, International Agreement

FAR 6.302-5, Authorized or Required by Statute

FAR 6.302-6, National Security

FAR 6.302-7, Public Interest

5.0 Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Roger Schwarz & Associates (RSA) Smart Leader, Smarter Teams™ Program is an internationally-recognized program in the field of team performance theory which uses its proprietary, research-based methodology to drive successful outcomes by focusing on the people side of change. RSA developed a unique “Mutual Learning” approach and methodology (versus the traditional unilateral approach) that is used to improve new organizational structures. Mutual Learning is a mindset based on a set of core values, assumptions, and behaviors that lead to a culture of transparency and accountability. The mutual learning approach contrasts with the current unilateral control approach that focuses on behaviors such as lack of communication across groups, hidden agendas, inconsistencies, less collaboration and poorer results in decision making and outcomes.

RSA is the sole provider of off-the-shelf training that focuses simultaneously on all the elements needed to create the change to a mutual learning culture: 1) team mindset (core values and assumptions); 2) behaviors; and 3) team structures and processes. RSA has developed and employs propriety models and approaches for creating this change. RSA has a proprietary methodology that includes: The Unilateral Control approach, Mutual Learning approach, Mutual Learning Cycle, and, Team Effectiveness Model.

RSA “Mutual Learning” approach and methodology has been successfully used by other federal agencies such as United States Department of Agriculture

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(USDA), Internal Revenue Service (IRS), Federal Aviation Administration (FAA), the United States Environmental Protection Agency (EPA), and the National Park Services (NPS).

6.0 A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies.

In accordance with FAR 5.2, a notice on the Governmentwide Point of Entry will be posted to give all vendors notice of the Government’s intent to sole source this requirement to RSA.

7.0 Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

RSA has offered pricing customarily provided to federal government agencies.

CFPB procurement has contacted a number of agencies and determined that the pricing is consistent across the agencies. The Contracting Officer has determined that the pricing is fair and reasonable.

8.0 A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

Market research was conducted through a review of internet web-sites of potential vendors that could provide training using the “Mutual Learning” approach. A search for vendors on the General Services Administration Mission Oriented Business Integrated Services schedule 874.4 was also reviewed. No vendors providing the “Mutual Learning” approach were found. Additional research was done by contacting other federal agencies such as USDA, FAA and NPS all of which had discovered no vendors providing the requisite training. RSA is a recognized authority in the field of effective human interactions and designs a unique approach, drawing on four core capabilities: facilitation, training, coaching, and consulting which are integral to the successful implementation of the Product Pod organizational structure.

9.0 Any other facts supporting the use of other than full and open competition, such as:

9.1 Explanation of why technical data packages, specifications, engineering descriptions, statements of work, or purchase descriptions suitable for full and open competition have not been developed or are not available.

N/A

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9.2 When 6.302-1 is cited for follow-on acquisitions as described in 6.302- 1(a)(2)(ii), an estimate of the cost to the Government that would be duplicated and how the estimate was derived.

N/A

9.3 When 6.302-2 is cited, data, estimated cost, or other rationale as to the extent and nature of the harm to the Government.

N/A

10.0 A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

None.

11.0 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 supplies or services required.

CFPB will continue to monitor the Teamwork and Feedback trainings that focus on a mutual learning approach to seek relevant programs that will fulfill CFPB’s needs.

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B. APPROVAL.

1.0 TECHNICAL/REQUIREMENTS PERSONNEL. All supporting data that is the responsibility of technical or requirements personnel, and which form a basis for the justification, have been certified as complete and accurate by the technical or requirements personnel.

Cordelia Holmes Date Operation Section Chief – Office of Consumer Response

2.0 PROCUREMENT STAFF. To the best of my knowledge and belief, I certify that this justification is accurate and complete.

Peggy Wright Date Contracting Officer

3.0 SENIOR PROCUREMENT EXECUTIVE. Based on the information contained herein, I approve procurement of this requirement on a sole source basis.

David Gragan Date Senior Procurement Executive

Cordelia Holmes Digitally signed by Cordelia Holmes DN: cn=Cordelia Holmes, o=CFPB, ou=Consumer Response, email=cordelia.holmes@cfpb.gov, c=US Date: 2015.09.03 10:15:09 -04'00' gragand@cfpb.local Digitally signed by gragand@cfpb.local DN: cn=gragand@cfpb.local Date: 2015.09.04 16:13:22 -04'00'

Digitally signed by Peggy J. Wright DN: cn=Peggy J. Wright, o=CFPB, ou=Procurement, email=Peggy.Wright@cfpb.gov, c=US Date: 2015.09.08 08:14:53 -04'00'