CUISP-PROCURE_FAR PART 8 Limited Source Justification_PAS Task Order.pdf

FAR PART 8 Limited Source Justification Person Authentication Service (PAS) Task Order

1. Agency and contracting activity.

Department of Education (DoED), Federal Student Aid (FSA)

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

FSA is executing an Administrative Modification due to changes made by GSA transferring from IT Schedule 70 to MAS contract in order to conclude our competitive awarded task order period of performance. Task order number 91003119F0013 will be transferred to the GSA Multiple Award Schedule (MAS), number 47QTCA20D000E, for the Person Authentication Service (PAS) support services.

3. Description of the supplies or services required to meet the agency’s needs

(including the estimated value).

PPS InfoTech, LLC was awarded task order number 91003119F0013 in July 2019 under GSA Schedule number GS-35F-0372L. Under this task order, PPS provides the full range of technical and project management services to support operation and maintenance of Person Authentication Service (PAS) IAM Applications to include Software Maintenance and Enhancements. GSA Schedule number GS-35F-0372L expired on April 30, 2021, and while FSA’s task order may continue for up to 60 months after the date of expiration, there can be no modifications or change requests completed that require additional funding; therefore, FSA has an immediate need to transfer this task order to PPS’s MAS contract 47QTCA20D000E. The estimated period of performance for this task order will be a base and one option period. The base period will be from the date of award through June 30, 2023, and option period one will be from July 1, 2023 – June 30, 2024.

The estimated value of this task order is $8,884,322.69. This includes the remaining funding for option period 3, option 4, and all change requests previously added to task order 91003119F0013.

4. Authority and supporting rationale. The following circumstance justifies limiting the source as supported below:

Under authority FAR 8.405-6(a)(1)(C), currently, only one source, PPS InfoTech, LLC, has been identified and confirmed as the only vendor that can continue the current services and provide any appropriate enhancements without causing disruption to FSA’s student loan processing platform. A lapse on service and support, would cause an immediate halt on mandatory business operations across FSA.

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

The Contracting Officer has determined that this represents the best value to the Government, as PPS was competitively awarded this task order in 2019 and is currently the only vendor capable of continuing the PAS services and performing any urgent enhancements. GSA has already determined the rates for these services to be fair and reasonable; and PPS has confirmed that they will maintain their current PAS task order rates.

6. Market research conducted among schedule holders (or reason market research was not conducted).

Market research was not conducted, however, a new competition for these services would cause catastrophic delays to mandatory business operations across FSA.

Furthermore, FSA cannot confidently confirm that a new competition would result in any significant cost savings.

7. Any other facts supporting the justification.

PPS is the current PAS vendor and is the Subject Matter Expert (SME) for the PAS application and the PAS Tier 2 Help Desk. The task order includes operations support, maintenance, and enhancements. PPS’s knowledge and experience with PAS and PAS-integrated applications is integral to completing active and pending PAS projects. Having a different contractor would imply not having the PAS vendor do the tasks for which they were initially put under contract for.

8. 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 new task order will be a continuation of the services that were awarded and competed under task order 91003119F0013. Future requirements for the same services will be competed.

9. Technical/Requirements Representative Certification:

I certify that this requirement constitutes the Government’s minimum needs and the supporting data provided herein is accurate and complete to the best of my knowledge and belief.

Kenneth Bandy

8/11/2022 Date

Contracting Officer’s Representative

10. Contracting Officer’s Certification and Approval:

I certify this justification is accurate and complete to the best of my knowledge and belief. For justifications >$250K up to $700K, my signature also serves as approval of the justification.

Joyce Bettis Date Contracting Officer

11. Approval for Justifications:

Approve

Betty Hoapili Date FSA Competition Advocate