Perkins JOFOC Signed.pdf

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JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

FAR citation 6.302-7, Public Interest

Federal Student Aid (FSA) is proposing to enter into a new, fixed-price non-competitive contract with the incumbent Educational Computer Systems, Inc. (ECSI) located at 1200 Cherrington Parkway Suite 200 Moon Township, Pennsylvania 15108 for the continued servicing of federally held Perkins loans. This proposed action will allow ECSI to continue operations and maintenance, thereby avoiding any disruption to services due to the current contract and Task Order (ED-FSA-13-D-0003-91003123F0306) expiring on July 31, 2024.

1. Identification of agency and contracting activity

United States Department of Education (ED), Federal Student Aid (FSA).

2. Nature/Description of Action Being Approved

The Federal Perkins Loan Program was a campus-based program where loans were made by participating schools using a combination of ED and institutional funds. The Federal Perkins Loan Program was discontinued on September 30, 2017, and the last new Perkins loan was disbursed on September 30, 2018.

Today, many schools continue to service their Perkins portfolios and retain the funds collected. From time to time, schools will assign Perkins Loans to ED and its Perkins Loan servicer to manage and service them when either the loan defaults or the school determines it is not in its interest to continue to service its Perkins portfolio. Defaulted Perkins Loans assigned to ED are immediately transferred to ED’s Debt Management and Collection System (DMCS) for servicing.

The agency head has determined that a lapse in service is not in the public’s interest. The sole source bridge contract to ECSI will ensure continuation of critical services while FSA issues a recompete small business set-aside solicitation and provides the ultimate awardee with time necessary to transition-in to continue servicing federally-held Perkins loans and allow the incumbent to execute decommissioning work. The requested contract will include the same services included in the expiring contract. These services include onboarding of Perkins loans from schools leaving the Perkins program. Loan servicing actions will also include monthly billing, communications with borrowers, and payment processing. Additionally, they will provide early-stage default management and transfer to the long-term default program. The period of performance for the sole source bridge contract is a 6-month base period with two 3-month options.

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

In order to meet FSA’s needs, ECSI will need to maintain an efficient, effective, and responsive IT platform and support Perkins loan servicing by meeting the below outcomes.

a. Providing a solution that meets all regulations and compliance standards.

b. Implementing effective default aversion tools to prevent delinquent borrowers.

c. Maintaining a 99% system availability (not including scheduled maintenance outages).

d. Reporting accurate loan data within stated/required time frames to be established between Federal Student

Aid and Servicer.

e. Reporting to NSLDS of Perkins loans and loan activity per ED Servicer data provider instructions.

f. Successfully transferring Defaulted borrowers to DMCS for servicing.

g. Receiving assigned loans from schools for servicing.

h. Continuing with the current cybersecurity requirements.

The estimated value of the proposed action, including options, is $19,587,184 and includes the full complement of Perkins services. The estimate is based on historical loan servicing rates with commensurate price adjustments to allow for inflation.

4. An identification of the statutory authority permitting other than full and open competition.

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The action will be awarded in accordance with 41 U.S.C. 3304(a)(7), public interest.

5. A demonstration that the nature of the acquisition requires use of the authority used:

The use of this authority is supported by the agency head’s determination that a lapse in service is not in the public interest for this acquisition, and a full and open competition would result in a lapse in Perkins servicing, harming over 400,000 borrowers and endangering the portfolio, which is valued at over $2.6 billion. Without this sole source bridge contract, these Perkins borrowers will not receive billing statements, cannot make payments, will have no access to customer service representatives to answer questions, cannot receive counseling on repayment plans, and cannot receive payment forbearance or loan discharges.

6. Description of Efforts Made to Ensure That Offers are Solicited From as Many Potential Sources as is Practicable The approved Justification for Other than Full and Open Competition will be posted on SAM.gov within 14 days after contract award.

7. Determination of Anticipated Price Reasonableness

The Contracting Officer will determine that the final cost or price negotiated for this contracting action is fair and reasonable prior to award. This determination will be supported by Perkins historical pricing information.

Additionally, the Contracting Officer will review and compare other contracts and schedule prices for anticipated labor categories for similar services.

8. Description of Market Research Conducted

Federal Student Aid issued a RFI on November 20, 2023, to identify small businesses capable of supporting Federal Perkins Loan Program support services.

Four companies responded to the RFI:

a. Goldschmitt-CRI LLC.

b. Kingston Ward Advisory Group

c. RMS-Recovery Management Services Inc.

d. Precision Collective

Two companies, Goldschmitt-CRI LLC and Kingston Ward Advisory Group, were identified with existing platform solutions which could be modified to support Perkins. FSA met with both companies in February 2024 and further confirmed their ability to support Perkins. FSA’s subject matter experts estimated that the vendors would need extended time to modify the proposed platforms to obtain their Authorization to Proceed.

9. Other Facts Supporting Other Than Full and Open Competition.

There are no additional facts supporting the use of other than full and open competition.

10. List of Interested Sources for Perkins

a. Goldschmitt-CRI LLC

b. Kingston Ward Advisory Group

c. RMS-Recovery Management Services Inc.

d. Precision Collective

11. Actions to Promote Future Competition

Federal Student Aid has commenced procurement activities to recompete Perkins loan servicing as a small business competitive set-aside. The anticipated award is in September 2024.

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12. PROGRAM OFFICE CERTIFICATION OF ACCURACY AND COMPLETENESS

This is to certify that the portions of this justification developed by the undersigned program office personnel, including supporting information and data verifying the Government’s minimum needs, schedule requirements and other rationale for other than full and open competition, are accurate and complete.

Mathew Waggoner Date Program Manager, Student Experience and Aid Delivery (SEAD) FSA Program Sponsor

For Marc Piccolo Date Student Experience and Aid Delivery (SEAD) FSA Program Sponsor

John Kane Date Assistant Deputy COO Student Experience and Aid Delivery (SEAD) FSA Executive Sponsor.

13. ACQUISITIONS OFFICE CERTIFICATION OF ACCURACY AND COMPLETENESS

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Jackson McClam Date Contracting Officer US Department of Education, Federal Student Aid

APPROVING OFFICIAL’S DETERMINATION

Pursuant to FAR 6.304(b), the Agency Head’s Determination and Finding approval is the approval of this justification.

FSA Secretary Decision on Sole Sour