EFO - EBS SLOA Development Support - Final redacted.pdf

EFO - Technical Order Distribute and Print Gateway system (TODPG) Support Services

Administration Services (MOCAS) Conditional Payment Notification (CPN) added complexity to the project. These requirements sessions with MOCAS included more SLOA changes for their Accounting Pre-Validation Module (APVM) scheduled for a Fall 2022 go-live. DLA is engaged with another external partner Defense Civilian Pay System (DCPS) requiring extensive testing for SLOA. Details included how to properly stage testable data in our testing environment and how to conduct a valid end to end test of the “to be” solution. Due to added complexity of the current and future work needed under SLOA Phases 2 and 3 with the system partners listed above, it is critical to the DLA Financial Statement of Assurance (FSA) audit in FY22. The aforementioned MOCAS changes could not be clarified until the end of May 2021, delaying risk and impact assessment across EBS. These changes cannot be deferred because SLOA must meet the Office of the Secretary of Defense (OSD), Undersecretary of Defense (Comptroller) mandated compliance by October 2022. The second major unforeseen circumstance is with Defense Civilian Pay System (DCPS). The emerging requirements which finalized in August 2021 must be implemented to protect Personally Identifiable Information (PII). This potential security vulnerability must properly stage testable data to prove and conduct a valid end to end test of the “to be” solution in production. This functionality must also be implemented under SLOA to meet the OSD mandated compliance by October 2022.

It is also in DLA’s best interest to keep Development efforts separate from Sustainment for Internal Use Software auditing and traceability. Having a separate Development task order will ensure all funding on contract is capital. A sole source award to Accenture is required to complete phases two and three and provide DLA with a usable Single Line of Accounting solution. Accenture’s unique integration expertise, background of EBS Production Support, and advanced specialized knowledge is required to meet the Federal mandated implementation of SLOA by the end of FY22.

Furthermore, issuing this task order is the most efficient and economically prudent manner of fulfilling this Agency requirement for a workable Single Line of Accounting (SLOA) solution.

The expertise regarding the technical details and functional configuration of EBS is essential to ensure interoperability between the existing production system and SLOA. Detailed knowledge of EBS is required to implement EBS modifications that must comply with U.S. Department of Treasury’s SLOA requirement. OSD published a mandate of SLOA capability for all DoD systems by October 1, 2022. The design/development discussions with our external system partners are at high risk of implementation failure if a vendor is unfamiliar with these partners and their current business processes. Additionally, the MOCAS CPN retirement solution of October 1, 2021, creates significant auditability risks for DLA. The J8 BPAs only alternative will be to manually process hundreds of transactions each week. EBS represents a unique combination of software components run only by DLA. Accenture is best positioned to help DLA mitigate risk by providing skills and knowledge needed to support this unique combination of solution components. J6 leadership is demanding “more for less” and cannot risk failure or slow delivery while another integrator takes months or even years to hire and onboard-proposed resources, await clearances, and slowly get up to speed. Accenture is the only vendor capable of meeting the MOCAS CPN requirement by October 1, 2021 and the October 2022 OSD mandate for DLA.

Accordingly, this modification must be issued on a sole-source basis to Accenture in the interest of economy and efficiency.

EFO - Technical Order Distribute and Print Gateway system (TODPG) Support Services

5. A DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND REASONABLE:

As the Contracting Officer, I hereby determine that the anticipated cost to the Government will be fair and reasonable. It is anticipated that the Government will use various price analysis techniques including, but not limited to: (1) Comparison of proposed prices to historical prices paid; (2) Comparison of proposed prices with independent Government cost estimates; and (3) Comparison of proposed prices obtained through market research for the same or similar items.

6. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION:

N/A.

7. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS THAT LED TO THE EXCEPTION TO

FAIR OPPORUNITY BEFORE ANY SUBSEQUENT ACQUISITION FOR THE

SUPPLIES OR SERVICES IS MADE:

EBS Program’s requirement for SLOA Development could not have been assessed at the time of acquisition plan for the follow-on Task Order SP4709-21-F-0079. While the requirement for SLOA development could not be reasonably forecasted at the time of solicitation and award of the follow-on, they were identified as a logical follow-on to the services provided under the original award. The period of performance for the task order SP4709-21-F-0079 award is as follows:

08/01/2021 - 01/31/2022 (Base) 02/01/2022 - 01/31/2023 (Option Period 1) 02/01/2023 - 01/31/2024 (Option Period 2) 02/01/2024 – 07/31/2024 (Option Period 3)

8. CERTIFICATIONS.

Technical Certification: I hereby certify that the support data provided for which I am responsible and which form a basis for this justification are complete and accurate.