DF IOO OM Services_REDACTED.pdf

CUI/, SOURCE SELECTION INFORMATION -SEE FAR 2.101 AND 3.104

U.S. Department of Housing and Urban Development Washington, D.C. 20410

OFFICE OF THE CHIEF PROCUREMENT OFFICER

DETERMINATION AND FINDINGS (D&F)

CONSOLIDATION OF CONTRACT REQUIREMENTS

Infrastructure Operations Office (IOO) Operations and Maintenance Services (O&M)

I have reviewed the requirement for the Assistant Chief Information Officer (ACIO) O&M Services that the IOO Program Management Office (PMO) proposes to solicit as a consolidated procurement action under 15 U.S.C. 657q and Federal Acquisition Regulation (FAR) 7.107-2. My review resulted in the following findings:

FINDINGS

1. The Assistant Chief Information Officer (ACIO) for the IOO PMO, through the Office of the Chief Procurement Officer (OCPO), Infrastructure and Technology Division (NOF) Contracting Organization, plans to solicit offers for enabling Information Technology (IT) related integration, deployment, operation, maintenance, and eDiscovery efforts for all HUD’s IT Infrastructure and general support services capabilities and investments which support the enterprise and end-user operational environments and facilitate HUD’s ability to preserve, review, and produce electronically stored information (ESI) to meet the legal and business requirement of HUD.

2. Background.

HUD's Enterprise Architecture (EA) Practice initiates an information technology (IT) lifecycle that is comprised of three integrated phases - architecture, investment, and implementation. EA work is business-driven, and technology solutions begin with the intended business model as the goal. HUD "architects" before design, and designs before building and deploying technologies.

Enterprise Architects and Solutions Architects work collaboratively with business and technical subject-matter experts from throughout the Department and other agencies to guide the development of information technology Blueprints, which represent segments within the HUD Enterprise Architecture v4.0. The Practice provides strategic direction to the IT Investment Management (ITIM) process by aligning common solutions across HUD's strategic lines of business, business functions and core IT services. These activities enable accelerated IT Modernization at HUD.

HUD is mandated by the Clinger-Cohen Act and by OMB Circular A-130 to develop and enforce a single enterprise architecture. EA is also a key E-Government component in the progress of the President's Management Agenda. This enterprise approach:

a. Simplifies IT Investment Decision-Making. HUD's EA practice uses blueprints to enhance the evaluation of proposed IT initiatives. Blueprints provide a common language that links IT initiatives with the Department's strategic objectives and core business functions. The Agency’s simple approach provides executive-level staff with a strategic, enterprise view of HUD's IT portfolio.

b. Accelerates System Implementation. HUD's EA practice applies existing blueprints to accelerate system design and development. Blueprints are working documents. They define core business processes, common data elements, cross-cutting applications, and standard system platforms.

Blueprints are used to verify common system needs that span program areas and facilitate enhanced communication between program areas and technical staff to define custom requirements. Our leveraged approach means that system design does not start from scratch.

c. Reduces System Diversity. HUD's EA practice uses blueprints to streamline HUD's IT environment. Blueprints define core business processes, common data elements, and standard applications and platforms. Standardization reduces the number of IT products, reduces system maintenance and operation costs, and simplifies staff training. Our standards-based approach reduces systems diversity across the Department.

The existing IOO O&M Services contracts provide support to the HUD enterprise in support of HUD’s mission to provide affordable housing, at the direction of the Office of the Chief Information Officer (OCIO) and the IOO leadership team, for all IT related integration, deployment, operation, maintenance, and eDiscovery efforts for all HUDs IT Infrastructure and general support services capabilities and investments which support the enterprise and end-user operational environments and facilitate HUDs ability to preserve, review, and produce electronically stored information (ESI) to meet the legal and business requirement of HUD. The IOO enterprise and end-user operational environments are a hybrid environment consisting of both on-premises and cloud capabilities and investments.

Consolidation of the existing IT O&M Services contracts into a unified EA task order contract under a single provider is to be achieved by FY25. Discussed in more detail in paragraphs below, market research demonstrates that consolidation is both necessary and justified. This determination is based on the facts presented below.

3. Description of the Consolidation Action. This procurement will consolidate Common Use IT O&M Services into a unified EA requirement under a single service provider for reasons described in section 2 above. This can be accomplished by consolidating the efforts of four “C” contracts (i.e., 86615321C00010, 86615321C00011, 86615323C00002, 86615423C00001) and one task order (i.e., ID11190013) contract, along with new, emerging requirements. The table below provides the salient characteristics of the four current “C” contracts and one task order contract requirements (only) contemplated for consolidation. The requirements of all five contracts will be consolidated under this effort; however, the overall scope and magnitude of this new requirement is markedly different from the existing contracts. The new consolidated requirement will be offered as enterprise-wide service offering in support of the EA, to include integration, deployment, operation, maintenance, and eDiscovery efforts for all HUDs IT Infrastructure and general support services capabilities and investments which support the enterprise and end-user operational environments, which were not contemplated under the current contracts. The increased scope and magnitude of this consolidated effort is evident in comparing the lifecycle values of the five existing contracts. The five existing contracts have a lifecycle value of approximately $363,617,091.31 (see Table 1).

Table 1: Total Lifecyle Value of Contracts

Contract / Task Order #

Title Contractor Small Business Category

Total Value Overall Period of Performanc e (POP)

POP

(# months)

86615321C00010 HITS End User Contract

Leidos

Other than small

$102,241,497.06 2/28/21 – 2/27/24

86615321C00011 E-Discovery

$5,694,542.55 2/28/22 – 3/29/23

86615323C00002 E-Discovery

$3,042,782.00 8/28/23 – 2/27/25

GS35F146DA-

47QFDA20F0017

/ID11190013

GSA DCS

Contract

Peraton (formerly Perspecta)

Other than small

$133,962,747.70 1/20/20 – 1/16/25

86615423C00001 HITS CS

Bridge

Peraton

$118,675,522.00 2/1/23 – 1/31/25

TOTAL $363,617,091.31

The table below shows the new enterprise-wide effort has a lifecycle value of $XXXXXXXXXXX. This is an increase in magnitude of $XXXXXXX when compared to the consolidated effort of $XXXXXXXXXXX. The potential savings are approximately 10.76% and will likely increase with adequate competition. For example, contract 86615321C00010 has a three-year (36 months) period of performance (POP) from February 28, 2021, through February 27, 2024 with a lifecycle value of $102,241,497.06. Extrapolating this value over a five-year (60 months) period would result in a total lifecycle value of $170,402,495.10, which combined with the lifecycle values of the other four contracts yields $XXXXXXXXXXX.

Table 2: Lifecycle Value of Contracts Extrapolated to 60 months

a. 86615321C00010 is a hybrid Cost Reimbursement / cost plus fixed fee (CR/FFP) contract. The objective of the requirement is to require a stable and reliable End User environment to meet HUD’s strategic business objectives and responsibilities under Federal legislation and executive orders, while transitioning the Contractors End User services to a new service provider. The contractor performs all work required to meet the following stated requirements:

Operate and maintain existing infrastructure, as of January 31, 2019, to meet the End User requirements for HUD staff and business applications and/or systems that currently reside in the HUD Information Technology Systems (HITS) infrastructure prior and during Transition Out.

Contract / Task Order #

Total Value POP (# months)

Total Value Burn Rate (1 month)

Existing Contracts - Total Value Extrapolated to 60 months

New Consolidated Requirement (60 months)

86615321C00010 $102,241,497.06 36 86615321C00011 $5,694,542.55 6 86615323C00002 $3,042,782.00 24

ID11190013 $133,962,747.70 60

86615423C00001 $118,675,522.00 24

TOTALS

$363,617,091.31

Savings

(~XXX%)

Adhere to all applicable Federal laws and regulations and policies and procedures as they apply to HUD, including but not limited to the infrastructure services being performed.

Conform to HUD Enterprise Architecture Standards and all HUD governing documents associated with the HUD IT infrastructure.

Participate in HUD’s established Configuration Change Management Board (CCMB), established to govern changes to HUD’s established infrastructure, as directed by HUD.

Ensure End User Support services are in accordance with the Performance Requirement Summary prior to completing Transition Out activities.

As directed by HUD, provide infrastructure services required to implement Federal wide security requirements that include Department of Homeland Security Continuous Diagnostic and Mitigation (CDM) program requirements and HUD’s Department Identity and Access Management System (DIAMS).

The Contractor is responsible for working with HUD on a phased transition of the following End User services to a new provider, while also providing the resources necessary to efficiently and effectively manage, monitor, support, and operate and maintain services before and during all transition out activities. The Contract identifies optimization options and recommendations and take HUD’s direction on actions that would improve End User performance levels or lower lifecycle costs prior or during implementing Transition Out service plans. The Contractor develops and submit to HUD the necessary Transition plans that describes the process, details, and schedule for providing an orderly transition of End User services and minimize the impacts on and risks to continuity of operations;

maintain communication with staff and affected communities; identify key issues; and overcome barriers to transition. The contract was awarded to Leidos Inc., a large business; it has a three-year POP, and expires on February 27, 2024.

b. 86615321C0001 was a Firm Fixed Price (FFP) contract. The objective of the requirement was for the Contractor to support the current transferrable automated solution for storage, retrieval and search of all Electronically Stored Information (ESI) for current employees and HUDGONE individuals, to include, but not limited to, primary and archived e-mail, C drive, G drive, J drive, instant messages, and SharePoint data. In addition, the Contractor proposed and implement enhancements that provide specified functionality not currently available. The transferrable automated solution included a comprehensive solution to:

Collect and preserve ESI subject to litigation hold, Perform case-specific (keyword) searches on ESI necessary for litigation purposes and proved electronic review for responsiveness and privilege, Export ESI responsive to litigation in native file format, Administer and maintain the system and infrastructure for HUD's eDiscovery Program, Administer and maintain HUD's eDiscovery SharePoint site and automated workflows for

HUD's eDiscovery Program, Provide end user support for HUD's eDiscovery system users, Ensure federal IT security standards are implemented and maintained for HUD's eDiscovery system and SharePoint site, Optionally procure and implement a new eDiscovery Review Tool, and Optionally expand HUD's eDiscovery storage and processing capability

The contract was awarded to Leidos Inc., a large business; it had a six-month POP and expired on March 29, 2023.

c. 86615323C00002 is a follow-on bridge contract to 86615321C0001 for the services cited in paragraph 3b above. The contract was awarded to Leidos Inc., a large business; it has a two-year (24 months) POP and expires on February 27, 2025.

d. GS35F146DA-47QFDA20F0017 / ID11190013. This federal contract award is a delivery order against the HUD’s Office of the Chief Information Officer (OCIO) data center services contract with Peraton Enterprise Solutions LLC (large business) as the prime contractor. The potential value of the award is $133,962,747.70 to provide IT services to HUD for five-years (60 months) from January 20, 2020, through January 16, 2025. Peraton utilized major subcontractors including Ntelicor LLC, Advance Professional Resources Inc., Teksystems Inc., Insight Global LLC, and Apex Systems LLC to perform systems administration, software development, database administration, and project management services. HUD aims to modernize its IT infrastructure through contracts like this one. As the largest public housing agency in the nation, HUD relies on effective technology to support its mission of providing housing and community development.

This data center services contract will help HUD maintain and enhance critical systems over the

POP.

e. 86615423C00001 is a Firm Fixed Price (FFP) contract awarded to Peraton Enterprise Solutions

LLC (large business); it has a two-year (24 months) POP and expires on January 31, 2025. The objective of the requirement is for the Contractor to support a stable, reliable enterprise-wide infrastructure to meet HUD’s strategic objectives and responsibilities under Federal legislation and executive orders. The Contractor shall is responsible for the provisioning, management, storage, maintenance, backup, and operation of all infrastructure hardware, software, and support services to maintain HUD’s current Enterprise Infrastructure core functions consistent with the assigned Contractor functions. Due to the anticipated changes in the information technology and telecommunications marketplace that will occur over the next several years, and as directed by HUD, the Contractor incorporates innovative and emerging technologies that improve infrastructure and mission performance in the most economic and efficient manner.

f. The new consolidated requirement provides support for all IT related integration, deployment, operation, maintenance, and eDiscovery efforts for all HUD’s IT Infrastructure and general support services capabilities and investments which support the enterprise and end-user operational environments and facilitate HUD’s ability to preserve, review, and produce electronically stored information (ESI) to meet the legal and business requirement of HUD. The DCIO IOO enterprise and end-user operational environments are a hybrid environment consisting of both on-premises and cloud capabilities and investments.

The requirement for O&M services include providing, maintaining, improving, and securing HUD’s virtual and physical enterprise IT infrastructure, IT enterprise services, and IT enterprise operational support resources.

The components or elements of the requirement are end-to-end lifecycle support for HUD’s portfolio of eDiscovery and infrastructure portfolio of capabilities and investments across HUD’s IT enterprise environment, to include physical colocation data centers, cloud SaaS, IaaS, PaaS, DaaS, VDI, and IaaC environments, and within the HUD regional, field, and satellite offices and at HUD Headquarters (HQ)

It is anticipated to be competed unrestricted, via Fair Opportunity procedures on the General Services Administration’s (GSA) Alliant 2 Governmentwide Acquisition Contract (GWAC), which is a Multiple Award, Indefinite Delivery, Indefinite Quantity (IDIQ) contract. The estimated total value for the entire POP – 5 years (60 months), to include option periods is $XXXXXXXXXXX.

Additional salient characteristics of the proposed acquisition strategy are listed in table 3 below:

Table 3: Proposed Acquisition Strategy Acquisition Strategy

Contract Type Business Category

Period of Performance

(POP)

Total Estimated Value

Task Order under GSA Alliant 2

GWAC; FAR

Part 16.505 (Fair Opportunity)

FFP

Unrestricted

One-year based period and four one-year optional Periods (60 months)

Total POP:

XXXX, 2024 –

June 26, 2029

$XXXXXXXXXXX

4. Applicable Statutes/Regulations. 15 U.S.C. 657q, Consolidation of contract requirements and FAR Subpart 7.107-2, Consolidation.

5. Results of Market Research. Market research outreach efforts were limited due to in-house knowledge of firms that have the capability of providing the services required. All the firms identified are large businesses that are required to team with small business to adhere with the FAR based on the dollar value of this requirement. There are no opportunities for an 8(a) direct award due to the dollar value of the requirement and no known small businesses that have the capability to provide the services. Multiple resources were used to identify sources capable of rendering the required services. Each resource is discussed in more detail below.

a. Sources Sought Announcements. An initial Sources Sought Announcement was posted to SAM.gov during July 2023 to determine the technical capability of large and small businesses to provide the required services. Responses were due on August 7, 2023. A total of 25 vendors responded to the notice, fourteen (14) of which were large businesses and eleven (11) small businesses. Upon competition of the capability assessment, all 11 large businesses were determined capable. None of the small businesses respondents were determined capable of performing 50% of the work required.

Table 4: Vendors Responding to Sources Sought – August 7, 2023 No. Vendor Business Category

Alliant 2

GWAC

(Yes / No)

1 Onyx Government Services, LLC Small - SDVOSB No 2 AccelGov, LLc Small – SBA JV No 3 KOAR Cloud Solutions, LLC Other Than / Large No 4 Peraton Inc. Other Than /

Large Yes

5 NTT DATA Services Federal Government, LLC

Other Than / Large Yes

6 Amazon Web Service Other Than / Large No 7 Digital Management, LLC (DMI) Other Than / Large Yes 8 Ventech Other Than / Large No https://sam.gov/opp/d1f3353054474970965c0ca1864e0851/view

9 Warren Development LLC (dba

PRO-VIZION)

Small – WOSB No

10 Ernst and Young LLP Other Than / Large No 11 Four Points Technology, LLC Small - SDVOSB No 12 Koniag Data Solutions, LLC (KDS) Small – 8a No 13 Netlogic Solutions Small – SDVOSB No 14 OST Inc Other Than / Large No 15 General Dynamics Information

Technology (GDIT), LLC Other Than / Large Yes

16 Deloitte Consulting LLP Other Than / Large

Yes

17 Accenture Federal Services LLC Other Than / Large

Yes

18 Guidehouse Inc. Other Than / Large Yes 19 IBM Other Than / Large No 20 Command Cyber Solutions Small – 8a No 21 Paragon Technology Group, Inc. Small – VOBS No 22 MicroTechnologies LLC Small – SDVOSB No 23 Exclusive IT Tech Small - WOSB No 24 Science Applications International

Corporation (SAIC) Other Than / Large Yes

25 IT Hub, Inc Small - EDWOSB No

b. The GSA website for GWACs and NITAAC websites were researched for Vendors, In particular, GSA’s Alliant 2 Contract identified 38 large businesses and 1 small business – Alaskan Native Corporation Owned Firm. See Table 5 below.

Table 5: GSA Alliant 2 GWAC Contractors

Vendor

Socio-Economic Indicators (only relative codes will appear for a contract)

Small Business

Other Than Small

Business

Small Disadv

Alaskan Native

Corporation Owned Firm s o D an

ACCENTURE FEDERAL SERVICES LLC o

ACTIONET INC o

AGILE DEFENSE, LLC o

AMERICAN SYSTEMS CORPORATION o

BAE SYSTEMS TECHNOLOGY SOLUTIONS &

SERVICES INC. o

BOOZ ALLEN HAMILTON INC o

BY LIGHT PROFESSIONAL IT SERVICES LLC o

CACI, INC. – FEDERAL o

CAPGEMINI GOVERNMENT SOLUTIONS LLC o

CGI FEDERAL INC. o

COGNOSANTE CDS, LLC o

DATA NETWORKS, INC. s d an

DATA SYSTEMS ANALYSTS INC o

DELOITTE CONSULTING LLP o

DIGITAL MANAGEMENT LLC o

ECS FEDERAL, LLC o

EMPOWER AI, INC. o

GENERAL DYNAMICS INFORMATION

TECHNOLOGY, INC. o

GUIDEHOUSE DIGITAL LLC o

ICF INCORPORATED, L.L.C. o

INTERNATIONAL BUSINESS MACHINES

CORPORATION o

JACOBS TECHNOLOGY INC. o

KBR WYLE SERVICES, LLC o

LEIDOS, INC. o

LOCKHEED MARTIN CORPORATION o

MANTECH ADVANCED SYSTEMS

INTERNATIONAL, INC. o

MAXIMUS FEDERAL SERVICES, INC. o

NTT DATA SERVICES FEDERAL GOVERNMENT,

LLC o

PARSONS GOVERNMENT SERVICES INC. o

PERATON INC. o

PLANNED SYSTEMS INTERNATIONAL INC o

REI SYSTEMS, INC. o

SALIENT CRGT INC o

SCIENCE APPLICATIONS INTERNATIONAL

CORPORATION o

SERCO INC o

SMARTRONIX, LLC o

SOS INTERNATIONAL LLC o

TELOS CORPORATION o

TYTO GOVERNMENT SOLUTIONS INC o

In considering the sources sought and GSA GWAC Alliant 2 vendors, Market Research indicates that the following five (5) large business vendors could support HUD’s consolidated requirements:

Peraton Inc. Peraton is a system integrator on Alliant 2, GSA’s premier enterprise GWAC.

It provides flexible access to customized IT solutions. It provides all required services with consistent superior past performance ratings. It’s able to successfully provide surge capacity when required. Substantial operations in every state in the Northeast region. Scope of services-comprehensive, integrated IT Services Solutions, including ancillary, non-IT components and new technologies that emerge during the contract life cycle. Empower customers with:

- Agile software development and DevSecOps

- System modernization and integration

- Advanced analytics

- Cloud computing to transform IT infrastructure

- Managed IT services to design, deliver, and support quality IT infrastructure

- Cyber security solutions to manage today’s threat landscape

Leidos Inc. Leidos is a premier solutions integrator with proven experience supporting government and commercial organizations. They have partnerships in place with Microsoft, AWS, ServiceNow, and Cisco. Through the Alliant 2 GWAC Leidos provides IT solutions through performance of a broad range of services, which may include the integration of various technologies critical to the services being acquired. The foundation of the scope is built on the most current Federal Enterprise Architecture (FEA) Reference Models. As the definition of IT changes over the lifecycle of the contract with the evolving FEA and the Alliant 2 GWAC scope will be considered to coincide with the current IT definition at any given time. Services include:

- Cloud Computing

- Digital Trust and Identity Integration and Management

- Network Operation, Infrastructure, and Service Oriented Architecture

- Support Services (Security, Systems, and Forms Management, Communications)

- Integration Services

- Controls and Oversight

- IT Operations and Management

- IT Help Desk

- Virtualization

- Web Application & Maintenance

- Web services

Leidos maintains ISO 9001:2015, AS9100 Rev D, ISO 27001:2013, ISO 20000-1:2011 registrations as well as CMMI credentials at maturity levels 3 and 4.

CACI Inc. CACI-Alliant 2 represents GSA’s next generation GWAC vehicle for comprehensive information technology (IT) solutions though customizable hardware, software, and services solutions purchased as a total package. Alliant 2 provides flexible access to customized IT solutions from a large, diverse pool of industry partners that includes a $75 Billion program ceiling.

The scope of the Alliant 2 GWAC includes any and all components of an integrated Information Technology (IT) solution, including all current and any new technologies which may emerge during the life cycle of the Contract. These include:

- Cloud Computing

- Digital Trust and Identity Integration and Management

- Network Operation, Infrastructure, and Service Oriented Architecture

- Support Services (Security, Systems, and Forms Management, Communications)

- Integration Services

- controls and Oversight

- IT Operations and Management

- IT Help Desk

GovCIO (formerly Salient CRGT). GovCIO offers:

o Cyber Security to protect end-to-end IT environment;

o Digital to connect with users through end-to-end digital experiences;

o Management & Mission Services to achieve sustained execution excellence;

o Data Management to build a connected, intelligent enterprise.

o IT Modernization-to create a dynamic enterprise to enable organizations to evolve.

Services include:

- Service Access Delivery

- Back Office Services

- Service Platform and Infrastructure

- Support Services (Security, Systems, and Forms Management, Communications)

- Component Framework

- Service Interface and Integration

- Controls and Oversight

GovCIO maintains ISO 9001:2015, ISO 27001:2013, ISO 20000-1:2011 registrations as well as CMMI credentials at maturity levels 3.

Deloitte Consulting LLP. Government agencies can work hand-in-hand with Deloitte, a trusted government advisor and a top federal IT contractor with experience serving all 15 US Federal Cabinet level departments. Establishing a viable long-term strategic relationship with a demonstrated Deloitte leader in the government IT community. Deloitte allows for long-term planning of large-scale program requirements. Deloitte’s contract scope is aligned with the Federal Enterprise Architecture (FEA). Services include:

- Service Access Delivery

- Back Office Services

- Service Platform and Infrastructure

- Support Services (Security, Systems, and Forms Management, Communications)

- Component Framework

- Service Interface and Integration

- Controls and Oversight

Deloitte maintains ISO 9001, ISO 20000 and CMMI credentials at maturity levels 3.

c. Small Business Administration (SBA) Dynamic Small Business Search (DSBS) Database Search. Due to the nature of this requirement, it is essential that any vendor submitting a proposal for this requirement have substantial experience and expertise in integration, deployment, operation, maintenance, and eDiscovery. As a result of the DSBS search, no small businesses were found capable.

The Office of the Chief Procurement Officer – OCPO (NOF) conducted a search on the SBA DSBS Database at http://dsbs.sba.gov. The search parameters used were NAICS Code “541511” and keywords: “IT Enterprise Infrastructure, End Users Operations Environment, eDiscovery, Data Centers and Cloud Services, and Custom Computer Program Services.” Results of the search rendered a total of 40 profiles matching the criteria in Table 6 below:

Table 6: SBA DSBS Database Search Parameters http://dsbs.sba.gov/

Keywords Search for NAICS Code 541511 Criteria No. of Small Businesses

IT Enterprise Infrastructure 3 End Users Operations Environment 0 eDiscovery 12 Data Centers and Cloud Services 0 Custom Computers Program Services 25 Total 40

Small Businesses’ Subject Matter Expertise was found for providing support services regarding IT Enterprise Infrastructure, eDiscovery, and Custom Computer Program Services. However, no expertise with respect to End Users Operations Environment, and Data Centers and Cloud Services were found amongst small businesses. Hence, there is a lack of confidence that any small business would be capable of performing the consolidation of requirements.

d. Other Sources Considered. Other sources used for market research included: GSA’s Repository, review of acquisition history, and interviews with knowledgeable Government personnel.

However, the sources yielded few results, and the Government did not have sufficient data from these sources to report any additional sources found.

In conclusion, the Government was unable to identify two or more small businesses capable of providing the required services. Further, based on the results of the market research described above, the Government lacks confidence that a small business would be able to perform 50% of the work required.

Furthermore, personal knowledge and experience indicates that there is no impact of consolidating contract requirements on small businesses unable to compete as prime contractors because prior separate requirements has all been awarded to large businesses.

6. Alternative Contracting Approaches Involving a Lesser Degree of Consolidation, and Rationale for Rejection. After consideration of the following alternate approaches, the Government has determined that consolidation would be the most beneficial approach.

a. Use Government personnel to perform some or all of the technical/support services.

Although this approach could eliminate the need to procure some or all of the services, this alternative was not selected because there are insufficient resources for the Government to support the depth and scope of this effort. OCIO (IOO) does not possess, and is unlikely to obtain, the number of billets necessary to provide the services organically.

Additionally, OCIO (IOO) does not have personnel with the highly specialized knowledge required under this effort which would lead to an unacceptable quality of service. Therefore, this alternative was not pursued.

b. Re-competing the previous requirements separately (Status Quo). Re-competing the previous requirements separately are an alternative approach to meeting this Government need.

However, by not consolidating the requirements, OCIO (IOO) would not be positioned to reduce costs and eliminate duplicative IT environments, increase state-of-the-art business practices, strengthen cyber security, and optimize network capabilities. Furthermore, maintaining the status quo of multiple orders would result in nonconformity with IT reform objectives and would provide inadequate and inconsistent support and continuity of the capability modules intended for the consolidated effort.

The requirement is now significantly greater in scope and value than the previous requirements. Additionally, multiple orders necessitate additional PMO, financial and contracting resources to support post-award administration, surveillance, reviews, processes, and documentation. Additionally, managing five separate contracts could negatively impact the mission as it could lead to increases in the time needed to identify, prevent, mitigate, and remediate support when necessary.

Additionally, procuring the services separately would increase the risk of duplication of work as the contractors would be providing essentially the same services and would need to harmonize their approach, with the Government as the integrator, to provide capabilities that could be seamlessly implemented onto a single EA. Coordination between contractors in such a manner could lead to disagreements, performance issues, delays, or a poorly constructed end-product.

For these reasons, this alternative was not pursued.

7. Benefits of Consolidation. In accordance with FAR 7.107-2(c), the benefits of consolidation may include cost savings or price reduction or may also include other benefits, regardless of whether quantifiable in dollar amounts.

As discussed in detail in the paragraphs below, the Government has considered the benefits of this consolidation, which include: (a) criticality of the action to the Agency’s mission or success, (b) improved management and quality control, (c) reduced time management and administration, (d) reduced Procurement Action Lead Time (PALT) and ancillary resources, (e) quality improvements that will enhance performance or efficiency, and (f) better terms and conditions.

a. Criticality of the Proposed Action to the Agency’s Mission or Success. HUD is mandated by the Clinger-Cohen Act and by OMB Circular A-130 to develop and enforce a single enterprise architecture. EA is also a key E-Government component in the progress of the President's Management Agenda. Consolidation of the existing IT O&M Services contracts into a unified EA task order contract under a single provider is to be achieved by FY25 is aligned with the mandates. In fact, Consolidation of IT functions into a single EA effort, will enable OCIO (IOO) to reduce costs and eliminate duplicative IT environments, increase state-of-the-art business practices, strengthen cyber security, and optimize network capabilities.

b. Improved Management and Quality Control. The PMO’s role in quality assurance surveillance is a vital aspect to the health and success of an order as the Government and contractor work together towards the same or similar goals. The visibility of this requirement is high due to the IT reform objectives established in the Clinger-Cohen Act and OMB memorandum. Considering the nature of this requirement and the demand that is anticipated during the life of this contract, it is mission critical for management and quality control to be a major consideration. Therefore, the Government considered the benefits of management and quality control that could be achieved through consolidation of these efforts.

Managing one contract with one contractor, versus five separate contracts with potentially two or more separate contractors, will allow OCIO (IOO) to implement processes and monitor the quality of performance for services being rendered more efficiently. Utilizing a single consolidated order will improve quality control as the Government will have increased availability to provide more thorough oversight and enforcement of acceptable levels of performance. It is also noted that the current contracts utilize similar skill sets, so consolidation would enable cross utilization of the workforce, would eliminate redundancies and duplication of effort, and would create greater efficiency with operations. Furthermore, if there were two awards made to multiple different contractors, the Government would have to serve in the role of integrator to ensure that both contractors are coordinating efforts concurrently and harmoniously. The Government would need to provide greater oversight over multiple contractors to ensure that conflicts do not arise, and should there be any conflict in the process, the ensure that conflicts do not arise, and should there be any conflict in the process, the Government would have to step in to mitigate.

c. Reduced Time Management and Administration. Managing and administering an order from the contracting office’s perspective is also an essential factor in the success of an order.

The consolidated approach will significantly reduce time, effort, and costs associated with carrying out the general administration, invoicing, oversight, management and enforcement of other terms and conditions that take place over the life of the order. Pursuing the issuance of a single consolidated task order would save significant time and reduce administrative burdens versus managing and administering multiple orders.

d. Reduced Procurement Acquisition Lead Time (PALT) and Ancillary Resources. Under a consolidated approach, there is a significant reduction in both the time and resources required during acquisition planning. The consolidated requirement will eliminate the need to develop multiple complete requirement packages, which would require competing multiple requirements, source selection procedures for multiple requirements, and award of multiple separate contracts/orders. Conversely, pursuing the issuance of a single task order would result in a significant reduction in PALT.

e. Quality Improvements that will Enhance Performance or Efficiency. Award of multiple contracts/orders increases the potential for duplication of effort as the contractors would be providing essentially the same services and would need to harmonize their approach in providing those services so that the capabilities can be seamlessly implemented onto a consolidated effort. Coordination between contractors in such a manner could lead to disagreements, performance issues, delays, or a poorly constructed end-product, with overall reduced efficiency. Additionally, the architecture supporting the capability modules is so meticulously integrated and intertwined that changes to one capability could cause negative ripple effects to the other capabilities. Therefore, having too many resources involved in the sustainment, maintenance and build-out of the new environments could have a substantial negative impact to the overall performance of the modules and the platform. As such, consolidation of the two requirements would support enhanced performance and greater efficiencies simply by reducing the number of resources involved.

For these reasons, consolidation of these efforts is essential for the Government to achieve the desired end result. Having a single contractor providing the services would eliminate the potential for disagreements between multiple contractors and would also greatly reduce the risk of malfunctions with the capability modules. Furthermore, having a single contractor supporting this effort would enable the company to implement industry best practices and be able to utilize their skill sets to efficiently streamline efforts and implement continuous improvement strategies to improve their performance throughout the life of the order. This would greatly benefit both the Government and the contractor as it would foster a stronger relationship throughout the life of the order, a win-win environment.

f. Better Terms and Conditions. A consolidated approach eliminates the potential for any inconsistencies or conflicts in the terms, conditions, and requirement descriptions which may occur across multiple contracts/orders. Inconsistencies in such a manner could result from policy changes (if award of the four separate requirements occurred at different times) or it could also result from differences in contractor approach to meeting the stated requirements (if awards were made to multiple separate contractors, their proposed approach and acceptance of terms and conditions may be incongruent across the multiple contracts/orders). Contractors accept different levels of risk and therefore may not agree to the same post- award terms and conditions or process changes to support a harmonized process between the multiple contracts/orders. Due to the architectural integrity involved in ensuring the current capabilities, as well as the capabilities intended to be built, are coordinated and can be seamlessly transitioned to the EA environment, incongruent terms, conditions and processes could be detrimental to the success of this requirement. Furthermore, inconsistencies in terms and conditions could result from version control issues for any documentation being incorporated into the contracts. While feasible, it would still become an added challenge to ensure that all five contracts mirror each other where they need to mirror, so that there are no detrimental effects resulting from inconsistencies between the efforts. As such, a consolidated management approach will ensure consistency in the support to be provided and oversight required.

DETERMINATION

Upon the basis of the findings above, I hereby determine, pursuant to the authority of 15 U.S.C.

657q and FAR 7.107-2(b), that the proposed consolidation of the requirements is necessary and justified in that the benefits of the consolidation acquisition strategy substantially exceed the benefits of each of the other possible contracting approaches discussed in paragraph 6 above.

For: JIMMY FLEMING-SCOTT Chief Procurement Officer