A18_DF_Consolidation_Marketing_ADs_Video_Final_2_CRF081212024_MCO_Signed_Redacted_1.pdf

services will enhance efficiency and improve the quality of services. Seeking resolution for non-conforming services will also be addressed more efficiently and expeditiously when having to communicate with the same Contractors. This can further aid in establishing performance measures on new call orders to identify, prevent, and ensure non-recurrence of similar defective services experienced in previously awarded call orders.

(2) Reduce Contractor’s administrative time and effort: Having a BPA can save Contractor’s time and effort because they will be aware and familiar with the BPA ordering procedures, will become more experienced with performing FCG requirements and increase their capability to better handle, quickly respond, and sustain work surges from FCG.

(3) Result in better terms and conditions: Having a BPA in place will also ensure that each call order will include the terms and conditions of awardee’s GSA contract and further include additional terms and conditions applicable to the BPA. Also, since GSA prices have already been determined fair and reasonable and the CO will review each offeror’s BPA pricing at the time of award, the Government may be able to get better pricing by asking for additional discounts at the call order level.

(4) Reduce Procurement Acquisition Lead Time (PALT): The use of a BPA will also result in a shorter PALTs compared to procuring services as standalone contracts. Currently it takes AQD less than 45 days to award a BPA call order valued at $4M. The AQD’s PALT for competitive contracts valued between $150K - $10M can take between 90 - 180 days to award, and FSS orders for services can take between 60 - 180 days to award. Therefore, the PALT for a standalone requirement can take up to 180 days to award without a BPA in place.

Quantifiable Benefits

(5) Acquisition Cost Savings: Call orders under the new requirement are estimated at approximately $ each. To process a BPA call order will require the preparation, review, and approval of the Statement of Work (SOW), Independent Government Estimate (IGE), solicitation, and award documents. The estimated Government time and effort required to award one BPA call order is $4,614.40. FCG projects at least four requirements a year for the next five years for a total of 20 call orders for the life of the BPA. The total acquisition cost for 20 call orders is estimated at $92,288.00. To process a standalone contract valued at $ will require the preparation, review and approval of the SOW, IGE, Sources Sought Notice (SSN)/Request for Information (RFI), Market Research Report, Acquisition Plan, Determinations and Findings to use T&M/LH, solicitation, and award documents. The total acquisition cost per stand-alone contract is estimated at $30,801.12 and for 20 stand-alone contracts is estimated at $616,022.40.

Compared to the alternative approach of procuring these services as stand-alone procurements, the Government will save $523,734.40 in administrative/personnel cost as a result of this consolidation.

7. Any alternative contracting approaches and rationale for rejection:

a. An alternative contracting approach is to procure the media advertising and video production services as standalone requirements; however, this approach is rejected because it will duplicate the Government’s acquisition efforts by having to repeat pre-award processes and the recreation of required pre-award documents. The duplicate efforts will greatly increase the PALT of these requirements. As noted in Section 6, it is estimated to cost the Government $523,734.30 more in administrative/personnel cost when utilizing standalone contracts versus a BPA. Additionally, this approach will not provide the non-quantifiable benefits that will be obtained by acquiring the services as BPA call orders therefore this alternative contracting approach is rejected.

b. Another alternative contracting approach is to establish an Indefinite Delivery/Indefinite Quantity (IDIQ) however, this approach is also rejected because the PALT to award a $55.5M IDIQ will require the use of FAR Part 15 formal procedures which will be much longer than to award a BPA utilizing FAR Part 8 procedures. Establishing a BPA against GSA Schedule contracts rather than an IDIQ will streamline the procurement process, improve administrative efficiency, eliminate unnecessary contract redundancy, and reduce performance risk due to contracting with fully vetted and qualified GSA Contractors.

8. Any negative impact by the acquisition strategy on contracting with small business concerns has been identified:

Based on market research, there are numerous small business concerns that could potentially meet the requirements. FAR 19.203(c) requires that a CO first consider a socioeconomic contracting program before considering a small business set-aside. The CO determined that the requirement could be solicited as a 100% WOSB set aside, and therefore, would not have a negative impact on small business participation due to the small business set-aside. Additionally, the WOSB vendors that were found potentially capable during the SSN will likely seek teaming and/or subcontracting agreements or use GSA MAS Contractor Teaming Agreements (CTA) with other small business to support this requirement.

As a result of reviews and discussions with Christopher Bell, Senior Small Business Specialist (SBS), Office of Small and Disadvantaged Business Utilization (OSDBU), it was recommended that the requirement be solicited as a small business set-aside with the intention of mitigating the impact of consolidation and allow for broader marketplace participation of Small Disadvantaged Businesses (SDBs). The CO has changed the strategy based on this and the requirement will be competed as a 100% small business set-aside.

9. Considerations, Facts, and Reasoning Supporting the Determination:

a. In search of potential small business sources for this BPA, market research included a search and review of the following Government databases and websites: DOI Historical Vendor Research Dashboard, Procurement List/Ability One, Federal Prison Industries (FPI)/UNICOR, Federal Supply Schedules (FSS), System for Award Management (SAM), and DOI-Wide Contract Solutions. None revealed an adequate number of potential sources in individual small business categories except FSS. An SSN was issued in April 2024 and revealed nine potentially capable small businesses, with six of them being WOSBs under GSA MAS 541810 (Advertising Services). This GSA MAS also shows 101 WOSBs that have contracts under this Schedule that can lead to even more competition. An SSN was also previously issued for media advertising services on the Government-Wide Point of Entry (GPE)/SAM.gov in June 2023. The SAM.gov SSN results revealed that there were three potentially capable small businesses which included one WOSB. Based on these findings, the CO has determined to set-aside this acquisition under the WOSB contracting program through GSA which will provide sufficient competition to adequately support the acquisition of a multiple-award BPA.

b. The CO was unable to consider setting-aside this acquisition under any other GSA small business socioeconomic program (i.e., Veteran, Service-Disabled Veteran-Owned Small Business (SDVOSB), small disadvantage business (SBD), Economically Disadvantaged-WOSB (EDWOSB), Historically Underutilized Business Zone (HUBZone), 8a, Minority-Owned) due to an insufficient number of potentially capable responses submitted by these small business socioeconomic groups and market research results. Although four Minority-Owned SB were determined potentially capable, a further review of the Minority-Owned SB sub-categories (i.e., Indian SB Economic Enterprise (ISBEE), Black American, Hispanic American, Asian Pacific American) revealed that the number of potentially capable was insufficient to support a multiple-award BPA. An additional search through the commercial open market/SAM.gov for other potential small business sources also revealed an insufficient number under the small business socioeconomic groups to adequately support a multiple-award BPA. Although, the SAM.gov search revealed five awards made to small businesses, in accordance with FAR 8.405-5, the preference programs of FAR 19 are not mandatory in this subpart; however, the CO may, at their discretion, set aside BPAs for any of the small business concerns identified in FAR 19.000(a)(3).

When setting aside BPAs, the specific small business program eligibility requirements identified in FAR Part 19 apply. In accordance with FAR 19.203(c) for acquisitions of supplies or services that have an anticipated dollar value exceeding the simplified acquisition threshold, the CO shall first consider an acquisition for the small business socioeconomic contracting programs before considering a small business set-aside. There is no order of precedence among the small business programs. The CO considered the result of market research and agency progress in fulfilling its small business goals. With the exception of the IBC small business goal, the current small business socioeconomic category goals of both IBC and DOI have all been met as of 7/9/2024.

Based on the above and the WOSB results obtained through GSA, the CO had determined that it is in the best interest of the Government to solicit and compete this requirement amongst WOSB GSA Schedule contract holders. Based on the OSDBU review mentioned, the CO will solicit and compete this requirement among small business GSA Schedule contract holders.