D21_Exemption to Fair Opportunity_JA_5.5.23_Redacted.pdf

Justification for an Exception to Fair Opportunity

In accordance with Federal Acquisition Regulation FAR 8.405-6(a)(1)(i)(C)

1. Agency and Contracting Activity.

This justification is prepared by the Small Business Administration, Office of Financial Operations & Acquisition Management, Acquisition Operations Division in conjunction with the Office of Entrepreneurial Development/Office of Entrepreneurship Education.

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

This is a justification for an out-of-scope modification to Call Order 73351022F0032 against GSA Schedule GS-07F-0777X. This contract supports the SBA’s Emerging Leaders executive-level training program. The program is designed to train CEO-level executives from small businesses in select underserved communities and marketplaces across the country. It provides these businesses with the support network, training resources, and motivation required to build and sustain businesses of size and scale within designated communities and marketplaces.

This J&A will allow for a modification to the order to provide additional services designed to enhance the support and overall effectiveness of the Emerging Leaders training program. The order type is firm-fixed price. This modification is restricted to the following source:

Company: Isom Events, LLC (Isom Global Strategies) Company Address: 700 Penn Ave #2005, Washington, DC 20003 Company Point of Contact and Phone Number:

3. Description of Supplies or Services.

Current State:

The SBA Emerging Leaders program is designed to support SBA's core mission to support small companies that have achieved local success and are ready for the next level of growth. The Emerging Leaders targeted outreach identifies CEO-level executives from small businesses in select underserved communities and marketplaces across the country. It provides these businesses with the support network, training resources, and motivation required to build and sustain businesses of size and scale within designated communities and marketplaces.

ISOM Events was awarded a one-year base period and four, one-year options on March 14, 2022, in the amount of . Since award, the contractor has developed a hybrid training environment with the first three months on-site and the remaining three months virtual, focusing on recovery, resiliency, growth, and/or scale for small business participants. The contractor has developed specialized curriculum and instruction, written explicitly for small business executives in communities and underserved areas across the United States. The contractor created a group-paced model with Subject Matter Experts for 8 Modules for Core Business Functions. The contractor curated its own content of Surge Sessions for Customized Business Needs and provided coaches for only three in-person sessions.

The contractor has worked with SBA to develop and deliver a synchronized national training program that assists executives in underserved areas consistent with applicable SBA guidelines using the contractor's materials. The contractor implemented larger in-person mentor groups with the current cohorts. In the Base Year, SBA worked with 44 coaches for three in-person sessions.

Enhanced State:

The OED seeks to enhance the current program based on lessons learned during the first year of performance. Lessons learned are routed in the experiences derived during the base year which occurred during a post-COVID/Virtual environment. The enhancements are expected to improve overall effectiveness of the program while balancing the various nuances of a post COVID teaching/learning environment.

The additional services in support of this modification will include the following:

• 68 full-time coaches at all eight (8) in-person sessions. This format shall hold the participants accountable for their progress completing the Modules and continuing to coach the topic;

instead of, teach the topic. The additional coaches shall work one-on-one with each business owner with creating an action plan to execute and measure the impact for these businesses.

Previously, coaches were not available for every in-person session. This provides the much needed one on one engagement needed to impart the Emerging Leaders content to the business owners.

• Additional training staff (Instructional Designers and Program Coordinators) to incorporate smaller in-person mentor groups that are paired by business size, industry, and specific needs.

The additional staff (Instructional Designers and Program Coordinators) would design, develop, and teach new content for the smaller in-person groups to meet the needs of the business owners.

• Additional content for the smaller in-person sessions shall focus on, but not be limited to Strategic Growth Plan, Stages of Business Growth, Financial Statement Analysis, Identifying Target Market, Accessing New Funding Streams, Human Resource Strategies, Doing Business in a Competitive Market, Technology, and Developing a Strategic Growth Plan. The new content shall expand the quarterly virtual educational webinar series.

• The enhanced email automation shall build on to the existing platform to personalize the experience for the SBA staff, coaches, and small business participants. The email automation shall help communicate to more than 2,000 individuals, create a better customer experience, focused or direct communication, promote the upcoming Modules or tips from the last Module, optimize costs, educe errors, and the system shall provide detailed logs and analytics.

The changes discussed above would be applied across all contract periods – Option Year 1 through Option Year 4.

As a result of this modification, the estimated total value of the order is increased from by to . The originally awarded contract value was $6,996,808 however a modification was executed on 9/9/2022 to add the transcription of 168 videos from voice to text, edit for content accuracy, SME content review, and apply a closed caption to all videos within each of the eight core learning modules. This change was valued at and increased the Base Year cost from to The estimate for this modification is based upon the Independent Government Estimate (IGE). As a result of this modification, the period of performance/delivery date remains unchanged.

program’s post COVID era where it seeks to offer the Emerging Leaders content to business owners in the safest and effective way possible. These changes could not have been foreseen prior to the award of original contract as the state of the pandemic was unknown at that time.

o Continuity of Services: Based on OED’s assessment and technical expertise concerning this program, if a new vendor were to provide the enhanced services described herein there would be a significant disruption of the program which is currently underway. The Option Year 1 was exercised on 3/14/2023 and ends 3/13/2024. ISOM is currently providing the services and managing the curriculum. If a new contractor were to provide the increased work (namely 68 coaches and content development), it is anticipated that a new vendor would need to integrate its style of teaching/curriculum approach with ISOM’s. This additional layer of coordination and development will most likely cause a disruption in the delivery of the enhanced services and the overall program. ISOM also has a pool of coaches and Subject Matter Experts to which it relies on for expedited hiring. These coaches are already trained and certified with ISOM to deliver their material. A new vendor would need to onboard staff that are capable of integrating with the current curriculum and program construct which has been developed by ISOM.

This change would most likely lead to a disruption to the continuity of services and therefore is not in the best interest of the Government and/or the Emerging Leaders program.

o Duplication of costs: ISOM is already obligated to hire coaches for the program under the current, base contract. If a new vendor were brought on to hire coaches to fill the role requested in the contract SBA would not only be paying the new vendor for the coaches’ attendance but would also be paying the new vendor for the time to recruit, interview, and onboard the coaches selected by a new vendor. SBA would then also have to dedicate time and resources to integrate the two vendors’ coaches into as cohesive an arrangement as possible. It is estimated that the duplication of costs would include a total cost of based on applying an escalation factor to proposals received in response to Solicitation for similar services.

o Schedule: If a new requirement were solicited, is it estimated to require 3-4 months for the Solicitation and Contract Award phase. Additionally, the new vendor would need at least 3 weeks to complete the onboarding process within SBA. The next Emerging Leaders program begins in July 2023. It would be almost impossible to award a new

RFP labor category GSA Schedule labor category

OY 1

Rate Rate Hours Total

Task 3: Provide Instructors and Training Implementation - 68 Instructors @ 20 hours per instructor

Sr. Management Consultant

Task 4: Deliver Emerging Leaders Initial Curriculum N/A $ - $ - 0

Total contract by July 2023 much less for a new vendor to recruit, interview, hire, and onboard a coaching team by July 2023. Also, additional time would be required for the new vendor, SBA, and ISOM to coordinate and integrate the coaches into ISOM’s coaching regimen. Therefore, the SBA estimates a total 4-5 month delay in the program schedule if the new work is competed instead of executing a modification as discussed herein. At the time of this J&A being written, there are only 2-3 months until the Emerging Leaders program begins. Notwithstanding the above, ISOM is already contracted to recruit, interview and hire staff to fulfill the coach role. Therefore, a schedule delay could be avoided, and the program would begin on time which would be in the best interest of the Government and the Emerging Leaders program.

o Quality/Efficiency: If a new vendor were to provide the enhanced services there is risk that the quality and efficiency of the program would suffer. Two vendors providing the same or similar services on the same program could cause unnecessary duplication of effort, lack of role clarity and lack of cohesion. These problematic areas could lead towards longer lead times and deliverables, less effective coaching techniques, and less of a cohesive experience for participants. These anticipated problems affect Program Management and ultimately the success of the program. Therefore, it is in the best interest of the Government and the Emerging Leaders program to execute the modification.

5. Determination that the anticipated cost to the government will be fair and reasonable.

The contracting officer determines the anticipated cost will be fair and reasonable based on price analysis, using historical prices paid for similar services, proposals received in response to Solicitations for similar services and the IGE. These tables are listed below. When compared to prices paid for similar services, it is clear that ISOM pricing is fair and reasonable.

The current contract covers 68 locations. A price per location was derived by dividing the contract price per year by location. The previous contract price per location is and the current contract price per location is When comparing the prices per location there is an increase of This increase can be justified when you consider inflation/escalation over 5 years, the increase in the number of locations served and the pivot to support a virtual environment during the pandemic.

Likewise, when reviewing the proposal prices received in response to Solicitation 73351022Q0001, the range for a 5-year effort is

Therefore, it is clear that the total price estimated for this order with the proposed added changes, still falls well within the range of fair and reasonable based on adequate price competition.

Current Contract Compared to Historical Prices Paid for Similar Services.

Contract No. Period of Performance Contractor Name Price per location Total Price Scope

*Value includes this modification increase

8. Certification

I certify that the facts and representations under my cognizance, to include but not limited to paragraphs 3 and 4 of this justification, are accurate and complete.

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

9. Approval

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.