D03 JA 24-030 FAR 6 EFMP_Redacted.pdf

CUI/SP-PROCURE

Control No: 24-030 Contractor: BAM Technologies LLC

Supply/Service: E-EFMP System Services Est Dollar Value:

Department of Army Justification and Approval for Other than

Full and Open Competition

1. Contracting Activity: U.S. Army Contracting Command Rock Island (ACC-RI) Rock Island Arsenal, Rock Island, IL 61299-8000.

2. Description of Action: The Headquarters, Department of the Army (DA), Deputy Chief of Staff (DCS), G-9, requests a firm-fixed-price contract with BAM Technologies LLC (referred to as BAM hereafter). ACC-RI projects award for and will obligate Fiscal Year , Operations and Maintenance, Army funds. An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement (DFARS) 207.103(d)(i)(B).

3. Description of Supplies/Services: The Exceptional Family Member Program (EFMP), as codified in Army Regulation 608-75, was established to work in concert with other military and civilian agencies, to provide a comprehensive, coordinated, multi-agency approach for community support, housing, medical, educational, and personnel services to Families with special needs, particularly during the assignment process. It is a mandatory enrollment program that works with military and civilian agencies to provide comprehensive support to Family Members with special needs, specifically designed to identify the special medical and/or educational needs of military families and take those needs into consideration during the assignment process and improve Department of Defense (DoD) support around the world for military families with special needs (whether medical or educational).

Section 582 of the 2021 National Defense Authorization Act, dated 01 January 2021, mandated, to the extent practicable, standardization of the EFMP across the military departments. Subsequently, in a report titled, EFMP (DODIG-2023-

102) dated 01 August 2023, the U.S. DoD Office of Inspector General (DODIG) cited that while improvements had been realized, there were still deficiencies in standardization and critical mission gaps. Of particular pertinence, DODIG recommended (1.a) complete standardization of assignment coordination processes across the DoD and revisions to DoD Instruction 1315.19, EFMP, providing the Services with a consistent DoD wide approach and eliminating the need for the Services to follow their own unique processes; and (2.a.) coordinating with the EFMP information technology work group to develop and implement a single DoD information technology system to maintain readily available, reliable data for oversight of the EFMP.

As a result, the DoD Office of Special Needs (OSN) identified leveraging an existing IT system utilized by a Military Service would allow for more immediate development and implementation of an integrated system to be utilized across the DoD. To determine which existing system could best meet or was positioned to meet the standard EFMP IT system requirements, Military Community and Family Policy IT subject matter experts (SMEs) conducted an analysis of the systems used by the Military Services, using the following: (i) Capability-requirements; (ii) Adaptability- the ability to modify the system to meet all Service-specific requirements; and (iii) Effort- the level of effort required to perform all required adaptations to meet the ideal state requirements. Based on capability, adaptability, and

Enterprise EFMP (E-EFMP) IT system presented the most optimal solution, as the system required the least level of effort to adapt the system to meet the identified requirements and demonstrated the best alignment to the ideal functionality. Importantly, the system can be modified to meet Service-specific data needs.

The immediate -EMFP and encompasses the other unified, joint E-EFMP system for all DoD. The E-EFMP system will provide a holistic overview of EFMP capabilities at every installation and military treatment facility, it will consolidate and provide consistent and reliable information across the service branches for military families with special needs to assist with the assignment process, and it will provide a single dashboard with data integrity for all stakeholders and users to share data.

The period of performance is , comprised of a pursuant to Federal Acquisition Regulation (FAR) 52.217-8 for unforeseen delays with the E-EFMP DoD integration, acquisition, or protest resolution. DCS, G-9 estimates a value of

, inclusive of the base and all option periods, based on the Independent Government Estimate (IGE) as follows:

4. Authority Cited: 10 U.S.C. § 3204(a)(1), as implemented by FAR 6.302-1, Only responsible source and supplies or services will satisfy agency requirements.

5. Reason for Authority Cited: As described at FAR 6.302-1(a)(2)(iii)(A) and FAR 6.302-1(a)(2)(iii)(B), for DoD, NASA, and the Coast Guard, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered though competition and would result in unacceptable delays

BAM is uniquely qualified to fulfill the requirements without substantial duplication of cost to the Government and unacceptable delays. BAM uniquely possesses the expertise garnered over the recent years, which is necessary to further develop, manage, -EFMP.

Since the initial award in , BAM has been integral to the development and implementation of the Army E-EFMP system, which is currently being hosted in the cARMY Amazon Web Service (AWS) Cloud Architecture and Database Management.

The E-EFMP system requires high level integration with U.S. Army Human Resources Command (HRC), U.S. Army Office of the Surgeon General, U.S. Army Medical Command, and U.S. Army Installation Management Command as well as connection to the Integrated Personnel and Pay System Army (IPPS-A) and Defense Enrollment Eligibility Reporting System. The platform must also respond to emerging requirements and mandates from the DoD OSN. The stakeholders manage all EFMP operations at the Headquarter level down to the field level within the E-EFMP system. This complex system, with a multitude of critical touchpoints and stakeholders, further highlights the unique and specialized experience required for the next Army phases, which includes refactoring to meet Enterprise Cloud Management Agency infrastructure and complete the phase specific to Respite Care (Army) resources of E-EFMP.

With years of project-specific experience gained in the development and deployment of the Army E-EFMP, BAM is the only contractor equipped with a deep understanding of the business processes and a wholistic knowledge of the relationships and procedures. These invaluable assets are crucial for not only refining and optimizing the -EFMP, but even more importantly, enveloping the other services for a DoD-wide E-EFMP that will more efficiently aid in standardization and a comprehensive, user-friendly database with readily available, reliable data for military families with special needs.

Only BAM has intimate and invaluable knowledge of the E-architecture, underlying information security design, and operational nuances. BAM also has the experienced software developers, designers, and testers required to apply their technical skills, intellect, and industry experience to develop the robust requirements consisting of highly complex business rules and logic. As each service uses unique personnel, case management, and medical systems that must be meticulously integrated within the E-EFMP system, this integration is a significant challenge due to the diverse data structures, system capabilities, operational workflows, and security protocols involved. Additionally, ensuring interoperability with the existing infrastructure and software is crucial and involves rigorous testing and validation to prevent disruptions. -EFMP system forms the backbone for the required joint DA/DoD E-EFMP system, only BAM has the expertise to provide the experience, historical knowledge, and robust EFMPs.

Further, effective training and support are paramount for the successful adoption of the unified and joint E-EFMP system across the DoD. Developing detailed training manuals and conducting extensive training sessions tailored for different user groups, including EFMP Medical staff, EFMP Assignment staff, EFMP Family Support staff, Service regional and HQ staff, DoD OSN personnel, and Service members, are essential. BAM already has the foundational elements of these requirements, which will readily aid to ensure all users are proficient in the enterprise system. Additionally, having a singular robust help desk and support infrastructure to assist users during the transition and beyond is critical for addressing issues and ensuring smooth operation.

While the E-EFMP system is not proprietary to BAM,

1. Understanding of Existing Architecture and Integration Points: The contractor would need to familiarize with the current system architecture, including integrations with key systems, e.g., IPPS-A and Military Health System Genesis.

The contractor would need to understand the data flow, system dependencies, and any pre-filled or automated forms.

2. Workflows and Business Logic: The contractor would need to review the workflows already in place, especially related to assignment management, Family Member Travel Screening, and the EFMP. The contractor would need to understand the roles of Army Human Resources Command and Office of the Surgeon General in reassignment processes, along with specific workflows that handle assignments, as this is crucial.

3. Refactoring from OutSystems to Meet cArmy and Enterprise Cloud Management Agency Standards: Since the system was initially built using OutSystems, a new contractor would need to understand the existing OutSystems framework and how it was utilized in the current development. Then, the contractor would have to duplicate the effort of refactoring the current source code into a cloud-native environment that complies with cArmy and Enterprise Cloud Management Agency standards, which can be a time-consuming process. This would involve ensuring that all functionality transitions smoothly to the new environment while meeting all required technical standards.

4. User Experience and Component Library: If the system includes a User Interface (UI) component library, the contractor would need to familiarize themselves with

it. This ensures that any new development aligns with the established UI and experience design.

5. Compliance and Regulatory Requirements: A new contractor would need to duplicate efforts in understanding compliance requirements, such as the specific privacy and data security measures needed for handling sensitive military family data, especially given the unique nature of EFMP cases.

6. Stakeholder Expectations and Terminology: Learning about the preferences of key stakeholders, especially avoiding terms like "compassionate reassignment" or "problematic assignment," is essential. A new contractor must understand the nuanced language and expectations set by stakeholders like Army Human Resources Command and Office of the Surgeon General.

7. Testing and Quality Assurance Protocols: Any new contractor would need to includes understanding the testing phases from unit testing to system integration, particularly for key milestones like the Testing and Quality Assurance phase.

The estimated time of years would be in addition to the length of time it would take to conduct a source selection and make an award, which ACC-RI estimates at approximately based on the Assistant Secretary of the Army Acquisition, Technology, and Logistics memorandum for procurement acquisition lead time estimates. Additionally, ACC-RI estimates it would take approximately to receive a procurement ready package based on acquisition requirement lead times for similar procurements.

As stated above, DoD OSN and Military Community and Family Policy IT SMEs

-EFMP system as the most suitable system to envelope the other Service L implementing an integrated DoD-wide enterprise solution. For context regarding the magnitude of effort, the Army E-EFMP system currently supports Service Members (Army Active Duty, Guard, and Reserve) and Family Members. The DoD OSN has committed to leveraging the existing Army E-EFMP system to transform and implement a standard DoD-wide system to support approximately DoD Service Members and Family Members, so more than doubling the existing capability.

To achieve this substantial challenge to unify and create an enterprise EFMP, DA and DoD developed a timeline that would be required to onboard the additional military Branches (Air Force, Marine Corp, Navy, and Space Force) iteratively, to account for each Services unique EFMP processes and procedures, to reach the DoD-wide E- EFMP. Given the scale and complexity of this project, encountering challenges is inevitable. These may include technical difficulties, integration issues, and user adaptation hurdles. The timeline allows for:

1. Staggering the incorporation of each Branch specific requirements to pace the phases of system modifications, user testing, training and support, and deployment to an aggressive, yet reasonable timeline.

2. Proactive Issue Resolution: Identifying and resolving issues before they escalate, thereby minimizing disruptions.

3. Comprehensive Testing and Validation: Ensuring all components of the system are thoroughly tested and validated across all Services.

4. Flexible Adjustments: Allowing sufficient time for necessary adjustments without compromising the overall project timeline or objectives.

The timeline below accounts for the extensive phases of adaptation, testing, and refinement required to ensure the system meets all functional and operational requirements, as well as customizing the existing Army E-EFMP system to meet the requirements of the Air Force, Marine Corps, Navy, and Space Force. Each service must conduct comprehensive user testing to identify and rectify issues specific to their business processes and operational needs. Any identified issues must be promptly addressed, and given the complexity, multiple rounds of testing, adjusting, and refinement are anticipated.

Supply/Service: E-EFMP System Services Est Dollar Value:

As stated above, it took BAM approximately years to become operational with the unique and complex processes and workflow landscapes, requirements gathering, and overall integrated project planning. It is anticipated that another contractor would require similar duration and cost ) to complete Steps 1-7 above to become operational -EFMP before being able to start integrating in -EFMP, as shown in the table above.

Furthermore, the duplication of costs annotated above would not be recovered through savings associated with competition. Assuming adequate competition existed (although the other two companies expressing interest were deemed not capable of successfully fulfilling the requirements of this contract as indicated in paragraph 8 below), it was found that competition would not achieve materially lower rates. The IGE assumed competition and in doing so, utilized average rates from General Services Administration (GSA) Salary Rates based on GSA Specialty pay scale, which are expected as reasonable for the level of expertise required for the effort. Vendors could choose to apply discounts to these rates in the face of competition; however, due to the learning curve required to support this nuanced EFMP effort, discounts would most likely be minimal.

on the standard processes and procedures of the EFMP. BAM also included cloud architecture, contract support experience, and generative Artificial Intelligence experience. BAM conveyed knowledge of the c-Army environment and experience in all security requirements for AWS IL5 and all Army Protected Health Information handling and processes. BAM has developed and proven relationships with EFMP key stakeholders and experience in EFMP IT solution help desk support.

Subsequent to posting the RFI on GSA, the strategy has shifted to do a direct award to BAM outside of GSA to avoid unnecessary and non-value-added fees to the Army.

Albeit the contract vehicle changed, the Government determined to not post an than the market research that was already conducted in GSA, which revealed no other contractor besides BAM can support this requirement without substantial duplication of cost and unacceptable delays as described in paragraph 5.

9. Interested Sources: To date, no other sources have expressed a written interest in this requirement.

10. Other Facts:

a. Procurement History:

Contract: GS-35F-0489V Order W9124J-23-F-0077

Award Date:

Competitive Status: Sole Source Authority: FAR 8.405-6(a)(1)(i)(B)

Contract: 47QFDA-19-A-0011 Order 47QFDA-21-F-0045 Contractor: BAM Technologies LLC Award Date:

Competitive Status: Unknown

b. Other Facts: As referred to above, GS-35F-0489V Order W9124J-23-F-0077 was issued sole source under the authority of FAR part 8; however, for the immediate action, ACC-RI is not utilizing GSA, so to avoid unnecessary fees to the Army with no benefit given the sole source nature of the procurement.