CGA Improvement Act - LSJ_FY21-058_Redacted.pdf

SOURCE SELECTION INFORMATION – See FAR 2.101 & 3.104

Limited-Sources Justification (LSJ) For orders or BPAs exceeding the Simplified Acquisition Threshold

LSJ No.: FY21-058

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Office of Procurement Operations (OPO), proposes to award on behalf of DHS, Office of the Chief Human Capital Officer (OCHCO) a General Services Administration (GSA) Federal Supply Schedule (FSS) task order pursuant to Federal Acquisition Regulation (FAR) subpart 8.405-6, Limiting sources.

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

DHS/OPO intends to limit the number of sources solicited pursuant to FAR subpart 8.405- 6(a)(1)(i)(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, for the procurement of services to support the United States Coast Guard (USCG) Academy Assessments in accordance with congressionally directed spending contained within fiscal year 2021 (FY21) National Defense Authorization Act (NDAA) Sections 8272 Coast Guard Academy Study and 8274 Assessment of Coast Guard Academy Admission Processes to the National Academy of Public Administration (NAPA), DUNS 074838103, 1600 K Street, N.W., Suite 400, Washington, DC 20006.

3. Description of Supplies/Services.

This requirement is to provide services as expressly represented within the FY21 NDAA supporting the assessment of the USCG Academy. Specifically, the NDAA, with focus on section 8272 Coast Guard Academy Study and section 8274 Assessment of Coast Guard Academy Admission Processes, requires the establishment of an arrangement with the National Academy of Public Administration (NAPA) to conduct both an assessment of the cultural competence and admission processes of the USCG Academy. Arrangements with NAPA associated with NDAA section 8272 shall be established not later than 60 days after the date of NDAA enactment, and arrangements associated with NDAA section 8274 not later than 1 year after submitting its aforementioned 8272 assessment.

An assessment (section 8272) shall be conducted of the cultural competence of the Coast Guard Academy as an organization and of individuals at the Coast Guard Academy to carry out effectively the primary duties of the USCG listed in section 102 of title 14, United States Code, when interacting with individuals of different races, ethnicities, genders, religions, sexual orientations, socioeconomic backgrounds, or from different geographic origins. Recommendations shall be developed based upon the assessment findings.

Assessment and resulting recommendations shall fully address and document the following:

(A) describe the level of cultural competence described above based on the assessment of the Coast Guard Academy’s relevant practices, policies, and structures, including an overview of discussions with faculty, staff, students, and relevant Coast Guard Academy affiliated organizations;

(B) examine potential changes which could be used to further enhance such cultural competence by—

(i) modifying institutional practices, policies, and structures; and (ii) any other changes deemed appropriate; and

(C) make recommendations to enhance the cultural competence of the Coast Guard Academy described in subparagraph (A), including any specific plans, policies, milestones, performance measures, or other information necessary to implement such recommendations. Recommendations provided shall consider and address the following potential assessment areas:

(i) improve outreach and recruitment of a more diverse Coast Guard Academy cadet candidate pool based on race, ethnicity, gender, religion, sexual orientation, socioeconomic background, and geographic origin.

(ii) modify institutional structures, practices, and policies to foster a more diverse cadet corps body, faculty, and staff workforce based on race, ethnicity, gender, religion, sexual orientation, socioeconomic background, and geographic origin.

(iii) modify existing or establish new policies and safeguards to foster the retention of cadets, faculty, and staff of different races, ethnicities, genders, religions, sexual orientations, socioeconomic backgrounds, and geographic origins at the Coast Guard Academy.

(iv) restructure the admissions office of the Coast Guard Academy to be headed by a civilian with significant relevant higher education recruitment experience.

Additionally, an assessment shall be conducted of the Coast Guard Academy admissions process as represented within FY21 NDAA Section 8274. Assessment and resulting recommendations shall fully address and document the following:

(1) complete a study, or an audit if appropriate, of the process the Coast Guard Academy uses to—

(A) identify candidates for recruitment;

(B) recruit applicants;

(C) assist applicants in the application process;

(D) evaluate applications; and

(E) make admissions decisions;

(2) discussion of the consideration during the admissions process of diversity, including—

(A) race;

(B) ethnicity;

(C) gender;

(D) religion;

(E) sexual orientation;

(F) socioeconomic background; and

(G) geographic origin;

(3) provide an overview of the admissions processes at other Federal service academies, including—

(A) discussion of consideration of diversity, including any efforts to attract a diverse pool of applicants, in those processes; and

(B) an analysis of how the congressional nominations requirement in current law related to military service academies and the Merchant Marine Academy impacts those processes and the overall demographics of the student bodies at those academies;

(4) provide a determination regarding how a congressional nominations requirement for Coast Guard Academy admissions could impact diversity among the student body and the ability of the Coast Guard to carry out effectively the Service’s primary duties described in section 102 of title 14, United States Code; and

(5) provide recommendations for improving Coast Guard Academy admissions processes, including whether a congressional nominations process should be integrated into such processes.

Included immediately below is a breakdown of the estimated total award amount associated with the above assessment efforts.

Estimated Total Award Amount

Performance Period Estimated Total

USGC Academy Cultural Assessment 12 - Month Base Period USCG Academy Admissions Assessment 12- Month Option Period

Estimated Total Award Amount

4. Authority and supporting rationale.

The authority supporting this limited source justification is FAR subpart 8.405- 6(a)(1)(i)(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. This acquisition is being conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), in accordance with FAR 8.405-6(a) and FAR 8.405- 6(c), Limiting Sources. As directed within the approved FY21 NDAA, Subtitle E – Coast Guard Academy Improvement Act, Section 8272, Coast Guard Academy Study, “The Secretary of the department in which the Coast Guard is operating shall seek to enter into an arrangement with the National Academy of Public Administration not later than 60 days after the date of the enactment of this Act….” Additionally, similar language is included within Section 8274, Assessment of Coast Guard Academy Admission Processes, which reads in part, “The Secretary of the department in which the Coast Guard is operating shall seek to enter into an arrangement with the National Academy of Public Administration under which the National Academy of Public Administration shall, not later than 1 year after submitting an assessment under section 8272….” Within each of the Subtitle E Sections 8272 and 8274 the NAPA is specifically named in several instances directly associated with the required assessment services. Based on the foregoing and the congressionally directed actions included within the FY21 NDAA, NAPA is the only source capable of providing the USCG Academy Assessment services defined within the approved FY21 NDAA, and as documented within this LSJ.

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

The Contracting Officer has determined that issuing the proposed GSA solicitation directly to NAPA, Multiple Award Schedule (MAS) contract number GS-10F-0414R, Special Item Number (SIN) 541611, for the subject USCG Academy Assessment services will result in a task order award, which represents the best value, resulting in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs. The task order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.” GSA has already negotiated fair and reasonable pricing rates. Further discounts to these GSA schedule rates will be requested within the solicitation. Additionally, prior to task order award, the ordering activity will evaluate the NAPA solicitation response to ensure an appropriate level of effort and labor mix to successfully perform all tasks included within the solicitation, in order to determine that the total price is reasonable.

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.

Limited market research was conducted in support of the subject requirement. The primary focus of market research efforts was the identification of available Government-wide vehicles that included NAPA and the appropriate scope coverage necessary in successfully performing the USCG Academy Assessments. Through its limited research, the only Government-wide vehicle held by NAPA to include appropriate scope coverage is the above referenced GSA MAS contract chosen in support of this effort.

7. Any other facts supporting the limited-sources justification.

There are no additional facts.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made.

DHS will perform market research as required in exploring available solutions, which may potentially satisfy similar requirements in the future, in the event the Department has such a need and absent further congressional direction. To the maximum extent practicable, DHS will pursue a competitive approach for soliciting similar requirements in the future.

9. DHS intends to post this Limited Source Justification on beta.SAM.gov pursuant to FAR 8.405- 6(a)(2)(i).

THE REMAINDER OF THE PAGE IS LEFT INTENTIONALLY BLANK.

10. Technical/Requirements Personnel Certification.

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

11. Contracting Officer Certification and/or Approval.

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and complete to the best of my knowledge and belief:

12. Approval.

Pursuant to FAR 8.405-6(c)(2)(xi), I hereby determine that the circumstances identified in FAR 8.405-6(a)(1)(i)(A) apply.