Consolidation Determination PASS Redacted.pdf

CONSOLIDATION OF CONTRACT REQUIREMENTS DETERMINATION

FOR

Program and Staff Services (PASS) (As prescribed by FAR 7.107-2 and AFARS 5107.107-2)

RATIONALE

1. Consolidation may provide substantial benefits to the Government. However, because of the potential impact on small business participation, before conducting an acquisition that is a consolidation of requirements with an estimated total dollar value exceeding $2 million, a written determination shall be made that the consolidation is necessary and justified in accordance with 15 U.S.C. 657q, after ensuring that--

(a) Market research has been conducted;

(b) Any alternative contracting approaches that would involve a lesser degree of consolidation have been identified;

(c) The determination is coordinated with the agency's Office of Small Disadvantaged Business Utilization or the Office of Small Business Programs;

(d) Any negative impact by the acquisition strategy on contracting with small business concerns has been identified; and

(e) Steps are taken to include small business concerns in the acquisition strategy.

2. Introduction: Army Contracting Command – Aberdeen Proving Ground (ACC-APG), Edgewood Division plans to solicit offers for Program And Staff Services (PASS) supporting the U.S. Army Combat Capabilities Development Command (DEVCOM) Chemical Biological Center (CBC) located at Aberdeen Proving Ground (APG), Maryland (MD) and has conducted market research that demonstrates consolidation of this procurement to be both necessary and justified. FAR 2.102 defines consolidation as

(1) a solicitation for a single contract, a multiple-award contract, a task order, or a delivery order to satisfy -- (i) two or more requirements of the Federal agency for supplies or services that have been provided to or performed for the Federal agency under two or more separate contracts, each of which was lower in cost than the total cost of the contract for which offers are solicited; or (ii) requirements of the Federal agency for construction projects to be performed at two or more discrete sites; or;

(2) separate contract as used in this definition, means a contract that has been performed by any business, including small and other than small business concerns.

3. Description of the Procurement Action: This single award Indefinite Delivery/Indefinite Quantity (ID/IQ) contract is to service the needs of DEVCOM CBC project management, acquisition development, financial management, and safety and risk management support in the non-medical chemical biological mission space.

In addition, on 05 September 2024, a draft Request for Proposal (RFP) was posted in SAM.gov. Over were received from industry as a result of the draft Performance Work Statement (PWS). Answers to the questions were posted in SAM.gov on 22 November 2024. As a result of the RFI and draft RFP, the Government determined that there remained significant interest and capability in the small business community to fulfill this consolidated PASS requirement.

5. Alternative Contracting Approaches and Rationale for Rejection: Alternative strategies to reduce the number of consolidated contracts for this requirement were considered, including the option of not consolidating the contract requirements at all.

This alternative was rejected based on the following rationale:

a. Quality: Issuing separate contracts would increase the likelihood of subpar performance under the contract as it specifically relates to quality and management. This consolidation will eliminate the redundancies that naturally occur when managing multiple contracts for similar services versus one (1), especially given the nature of the subject services. For example, this will reduce the accounting and invoicing burden from multiple firms as well as COR invoice and contract monitoring responsibilities for the various contracts, such as monthly surveillance and CPARS reporting. The consolidated approach streamlines the COR communication with one (1) Program Manager (PM) and other Government personnel such as the Budget Analyst, which reduces the risk of miscommunication and increases the quality of the services provided by a Contractor through standardized, consistent approach under a single contract.

b. Acquisition Cycle: Overall, solicitation and award of a single award ID/IQ contract will take significantly less time and resources than the solicitation and award of seven (7) separate contracts or placing task orders from different IDIQ contracts.

In addition, only one (1) Contracting team, Requiring Activity team, and one (1) COR will be required to support the consolidated approach. Additionally, the consolidated approach will reduce the amount of post-award administration duties required of the contracting team and the COR as it specifically relates to the monitoring and evaluating performance, submitting monthly reports, collecting funds from the directorates/divisions, preparing Purchase Requests (PR), and issuing incremental funding and exercise of option modifications over the five (5) year ordering periods.

c. Cost Benefit of Consolidated Approach: The aforementioned alternative scenario

DETERMINATION

Based on the foregoing rationale, I hereby determine, pursuant to the Federal Acquisition Regulation Supplement 7.107-2 and Army Federal Acquisition Regulation Supplement 5107.107, that the consolidation of the requirements for the following: (1) Joint Program Executive Office (JPEO) Chemical, Biological, Radiological, and Nuclear Defense (CBRND) Specialized Support Services; (2) Technical Support to Combat Capabilities Development Command (DEVCOM) Chemical Biological Center Engineering Directorate; (3) Chemical Biological Applications & Risk Reductions (CBARR) Mission Support Contract. Risk Office Support; (4) Chemical Biological Applications & Risk Reductions (CBARR) Mission Support Contract - Radiation Support;

(5) IAC - Technology Development Support Analysis; (6) Acquisition planning and strategy development and (7) Safety and Health Office Support as well as government personnel and labor relations support for DEVCOM is both necessary and justified and will serve the best interests of the Government.