F03_-_REDACTED_JUSTIFICATION_FOR_POSTING.docx

1. SOLE SOURCE JUSTIFICATION

SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS

AUTHORITY: FAR 13.501(a), 41 U.S.C. 1901

CONTRACT #D17PC00312

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Sole Source Justification.”

This document is a sole source justification for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division V, Branch II conducted on behalf of DOI, Office of Special Trustee for American Indians (OST), Office of Information Resources (OIR).

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

This is a modification to existing Contract D17PC00312-P00005. The contractor is:

3. A description of supplies or services required to meet the agency’s needs (including the estimated value).

The current scope of Firm-fixed-price Contract D17PC00312 is for System Development Lifecycle Services which was competitively awarded as a commercial service under Federal Acquisition Regulation (FAR) 13.5 – Simplified Procedures for Certain Commercial Items and set-aside under the Buy Indian Act for Indian Small Business Economic Enterprises (ISBEE) in accordance with the Department of the Interior Acquisition Regulation (DIAR) Part 1480 – Acquisitions under the Buy Indian Act. The objective of this contract is to ensure mission data integration; optimization; availability and integrity for hierarchical operational reporting; analysis; dashboards and visualization; in support of OST’s program/enterprise business decisions; strategies; and performance data requirements. Specifically, the following tasks are under the current contract:

1) Requirements Gathering and Documentation - Work with the OST OIR to identify and document requirements for: l) Trust Funds Accounting System (TFAS) mission application development,

2) TFAS mission support processes, 3) TFAS mission data normalization, and 4) other OIR's systems, procedural and user support.

2) Analysis and Design - Analyze, design and document re-engineered mission support workflows, roles and responsibilities for: 1) TFAS mission application development, 2) TFAS mission support processes, 3) TFAS mission data normalization, and 4) other OIR's system, procedural, user support.

3) Implementation Planning - Describe and document implementation, test and migration plan for deploying re-engineered requirements for: 1) TFAS mission application development, 2) TFAS mission support processes, 3) TFAS mission data normalization, and 4) other OIR system, procedural, user support.

4) Test and Deploy Reporting Environment - Verify and validate that implementation, test and migration solutions fulfill and satisfy mission requirements. Leverage the existing Tableau platform provided by OIR to accomplish the task.

5) Provide and Deliver Documentation - Provide accurate and complete online user and system manuals; end-user requirement and diagrams; tech notes, standard operating principles and procedures, tech notes for Milestone #4 solutions, IT services supported and reports created and generated.

The scope of the new work required under this modification is a collective continuation of the existing work performed by TGS. The new work will provide contractor support in the reformation of ten existing applications developed for the conversion from the old SEI TFAS to the new Innovest’s InnoTrust application. The specific phases and tasks identified below are for the new work as follows:

Phase I Modify existing applications to work with the already defined InnoTrust Innovest Software Oriented Architect interface to allow the transfer of TFAS data to these applications. Data work will include assisting with conversion of existing financial data into the new InnoTrust system and setting up the initial OST data warehouse.

Application Redesign Phase I

· Control Log

· Indian Trust Systems Queries (ITSQ)

· Debit Card Set Up

· Manual Lease Disbursing (formerly called BSD Web)

· Account Modifications

· 1x Disbursements

· National Change of Address (NCOA) Updates

· Return Disbursements (formerly called Return Checks)

· Expired Checks (formerly called Limited Pay)

· Explanation of Payment (EOP) for Oil & Gas Statement Generation

Phase II Develop a plan of action to execute in the redevelopment all of the applications into the OST Amazon Web Services (AWS) instance leveraging Agile processing, and Capability Maturity Model Integration (CMMI) level 3 standards. The development plan shall include single or combined application recommendations and if needed interact with the OST Tableau and data warehouse also located in the AWS instance. Data work is to evolve the OST data warehouse to include other OST and Department data sources and to help define Business Intelligence reporting services. Movement of the data warehouse to the OST AWS cloud is included.

Application Redesign Phase II

· Assist with conversion of ColdFusion applications to either ServiceNow, new .Net web applications to move to the cloud, or other products.

· Control Log

· Staffing Directory (OST and Non-OST)

· Conference Room Scheduler

· OST Dues - PDST Tasking System

· Solicitor Tracking System

· BFA work order and supply order system

· TAAMS ITSQ Reports

· TBCC Report metrics

· AIRR Box Content Verification

· OST Vehicle Check-out

· Tax 1099 (View of past 1099 Information)

· WIT Suggestion process

· Continued development of existing applications not listed herein needed for support of the new InnoTrust system (enhancement requests).

The estimated value of this modification is $1,457,820.00 with $614,250.00, which will be fully funded, for the current year of performance ending on September 19, 2019 and $843,570.00 for Option Year 2. Therefore, the total contract value will increase by $1,457,820 from $3,054,781.92 to $4,512,601.92.

4. An identification of the statutory authority permitting sole source acquisition.

This is an acquisition conducted under the authority of the Simplified Procedures for Certain Commercial Items. The statutory authority permitting sole source acquisition is 41 U.S.C 1901 as implemented by FAR 13.501(a)(1)(ii).

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The new work is associated with the tasks TGS has already performed under the contract. They have performed the evaluation of the existing software as is to fulfill the Government’s requirement to map, review, comment, and document the code, which was not done in OST over the years. In addition, they have reviewed and commented on the code, mapped the structures and databases; and now in correlation with those tasks, the Government requires their assistance in the redesign of several applications which perform functions that are not contained within the commercial off-the-shelf (COTS) product to support the new TFAS solution.

At the time of contract award to TGS, OST did not know which applications would meet the criteria for revamping to the new TFAS given the complexity of the overall interfaces and the COTS conversion. Thus, in Fiscal Year 2018, OST began the evaluation of several dozen custom built internal applications developed over a 20-year period. All of these applications support the legacy TFAS performing a variety of non-COTS functions. The purpose of the evaluations were to one, understand the outline, makeup and structure of the programs and two, document and record the workflow structure and business mappings; and three, help the OST understand which programs would be needed in the new TFAS application.

TGS started performance under Contract D17PC00312 on September 20, 2017 and the Contract is currently in Option Period 1 ending on September 19, 2019; of which during this time they have provided software analysis of the ten (10) software applications that require redesign as identified in Item 3 of this justification under the supplemental scope. Additionally, the original tasks under the contract included reviewing code; mapping instructions; process workflows and information on use which includes primary, secondary; and externally hosted data sources. This review included over five hundred thousand (500,000) lines of code. Their previous and current efforts under the contract have placed TGS in a unique position to start on the redesign of the applications with minimal to no learning curve since the code involved in the redesign has already been reviewed, analyzed and understood by TGS. Their understanding of these ten (10) applications is critical to the success of the redevelopment efforts in support of the TFAS migration.

TGS’s unique position in regard to this supplemental requirement makes them the only contractor who could complete the work within schedule and at a fair and reasonable price. With the time expended and work completed by TGS to analyze and review the 500,000 lines of code, it is estimated that it would cost a new contractor $1,500,000.00 to be able to gain the knowledge and understanding that TGS already has to be able to then perform successfully and within schedule. Additionally, it is estimated that it would take a new contractor 12 months to be able to gain the understanding of the code to be able to successfully perform on this task.

OST has invested a significant amount of funding already into this development lifecycle project and TGS has invested the better part of 15 months into this project. Should a new contractor come in at this point and take over performance for this supplemental work, it places the project schedule at a significant risk of failure and would require OST to invest additional funding into a contract to allow for a new contractor to be brought up to speed on analyzing the 500,000 lines of code. This situation essentially would require OST to pay double for certain areas of work required under this project.

Currently OST is running both the legacy and the new TFAS in parallel to ensure continuity of operations during the migration and subsequent stand-up. The legacy contract will cost the OST an estimated $1.9 million to operate each month beyond the March 29, 2019 deadline. If a month-to-month pricing structure was utilized, it would extend through FY2019 totaling an estimated $9.9 million. Therefore, the supplemental requirements under this modification will avoid the parallel costs of the estimated $1.9 million per month.

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

Due to the extreme risk of the TFAS program and the need to complete, minimally phase one of the tasking prior to conversion of the SEI TFAS system to Innovest’s InnoTrust System by March 2019, the knowledge of the existing contractor, TGS, and the known expertise in-house, other contractors have not been sought.

In accordance with FAR 5.203-Publicizing and response time, a Notice of Intent was published in FedConnect and Federal Business Opportunities; providing an opportunity for only responsible ISBEEs to submit their capability statement. Two businesses responded to the Notice. The first response is from a global business; no capability statement submitted, referenced in their email one requirement from the Notice, referred to a link for their website and requested contact information of the program office to discuss the requirement. Hence, their response is not sufficient and as a global business, they are not in compliance that only ISBEEs can respond.

The second response is from a small, woman-owned and minority-owned business; no reference to the Notice of Intent with simply the wording of “CAPABILITY STATEMENT” in the email with generic general sales pitch information about the company with a link to their website. Therefore, their response is not sufficient and they are not an ISBEE in accordance with the Buy Indian Act. Thus, the two responses could not be considered to determine if this requirement should be competed as an ISBEE set-aside. An email was sent notifying both with the rationale as to why their response would not be considered. No additional response was received from either business to dispute the Government’s findings.

After the contract is modified and in accordance with FAR 13.501, a copy of the redacted justification will be publicized within 14 days of the execution of the modification.

7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

Prior to the execution of this modification, the contracting officer will make a fair and reasonable price determination. The contracting officer may use historical data, contractor pricing information, contract pricing information or other sources as necessary to make the determination that price is fair and reasonable.

8. 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 with the Notice of Intent for ISBEEs to submit capability statements which the Government would consider to determine if to compete this requirement. However, no responses from ISBEEs were received by the closing date of the Notice of Intent.

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

As this requirement is directly related to the tasks already performed by TGS, and as previously stated in Item 5 of this justification, the Government estimates that it would cost a new contractor $1,500,000 in a learning curve to be at the same level of knowledge and experience of TGS. This is based on the amount already spent under the current contract.

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

Two vendors expressed an interest in this modification; however, they were not from ISBEEs and their responses were referring to their websites with no in-depth narrative supporting this current requirement.

11. 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.

Contract D17PC00312 was conducted under FAR 13.5 and was an ISBEE set-aside, with six (6) contractors submitting quotes. At this time, given the level of knowledge and understanding TGS has, the amount of time TGS and OST have invested in this project and the amount of funds OST has invested as well as the deadlines in March 2019 which will equate to an estimated savings of $9.9 million; there are no actions that can be taken to overcome the barriers to competition for this immediate requirement. Should a supplemental task be identified in the future, the Government will then assess the sources available and make a determination as to the course of action, on a case-by-case basis.

12. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

I certify that this justification is accurate and complete to the best of my knowledge and belief.

13. Requirements personnel certification.

I certify that the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

14. Reviews and Approvals

Concur

Concur

Approve

CONTRACT #D17PC00312

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