EOP_Justification_for_an_EFO_Approved_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

AUTHORITY: FAR 16.505(b) (2)

OASIS Order 140D0421F0483 / GS00Q14OADU209

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for an Exception to Fair Opportunity.”

This document is a Justification for an Exception to Fair Opportunity for the Department of the Interior, Interior Business Center, Acquisition Services Directorate, Division 2; Client: Executive Office of the President (EOP), Office of National Drug Control Policy (ONDCP).

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

This is an exception to fair opportunity firm-fixed-price task order under the One Acquisition Solution for Integrated Services (OASIS) Government wide acquisition contracts (GWAC) to be awarded to ICF Incorporated, LLC (ICF) via OASIS Contract No. GS00Q14OADU209, valid until September 02, 202 .

The period of performance for this exception to fair opportunity OASIS task order will be a 12-month base period plus one, six month option period. The estimated effective date for this task order is June 21, 2021.

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

The Office of National Drug Control Policy (ONDCP), Drug-Free Communities (DFC) Support Program, and the Comprehensive Addiction and Recovery Act (CARA) Program requires the acquisition of commercial data analysis and evaluation services. Both programs provide funding to community-based coalitions that organize to prevent and reduce youth substance use for alcohol, tobacco, marijuana, prescription drugs; and seeks to prevent opioid, methamphetamine, and/or prescription drug use/misuse among youth ages 12-18 in communities throughout the United States. This task order will provide ONDCP proper oversight of the effectiveness of the DFC and CARA grant programs to better understand youth substance use trends across America’s communities.

According to the Drug-Free Communities Act passed by Congress in 1997, there are specific data collection and evaluation requirements enumerated. Included in the statute is language that states there will be, “assurances that the entity conducting an evaluation shall have experience - in gathering data related to substance abuse among youth or in evaluating the effectiveness of community anti-drug coalitions”. Due to this congressional requirement for ongoing data collection, the DFC Program must not have any disruption in the collection, analysis, and evaluation of data from coalitions.

The purpose of the DFC National Evaluation and the CARA National Evaluation is:

to support an effective grant monitoring mechanism that provides the Federal Government with the expertise, system, functions, and products to collect, analyze and report data objectively; and to regularly monitor and measure data in order to demonstrate the progress of the DFC and CARA programs and its grantees.

PR/SOL/CONTRACT # TBD

DFC and CARA grantees are each required to participate in various aspects of data reporting related to the grants based on The Office of Management and Budget (OMB) approval. The various aspects of data reporting are identified below:

OMB’s Paperwork Reduction Act: OMB reviews and approves data collection instruments for grant award recipients. The purpose of the Paperwork Reduction Act is to reduce the total amount of paperwork burden the Federal government imposes on private businesses and citizens. The Act imposes procedural requirements on agencies that wish to collect information from the public. Every three years, the DFC and CARA Local Drug Crises progress reports are reviewed to determine where they can simplify reporting requirements and decrease burden on grant award recipients. The Contractor shall plan and budget for re-designs of current progress reports data collection instruments. Note: OMB approved the DFC and CARA Local Drug Crises program’s data collection instrument on January 6, 2020. The next reviews are scheduled to occur in 2023 and 2026.

DFC and CARA Progress Reports: For the DFC Program, grantees are required to submit data twice a year, in February and August, via an online data collection tool. The DFC semi-annual progress report includes descriptive information on the community served and coalition members; coalition accomplishments and challenges; assessment activities, etc. In addition, a main emphasis of the semi-annual progress report is reporting on the strategies and activities within the Seven Strategies for Community Change in which grantees engaged in during the prior 6 months. The progress report includes large amounts of open-text fields for the collection of qualitative data.

For the CARA Program, grantees are required to submit a progress report annually. Their first progress report was collected in January 2021. Similar to the DFC Program, the CARA progress report includes large amounts of open-text fields for the collection of qualitative data. A second progress report will be required on a future date to be determined that includes the same descriptive information as outlined above.

ONDCP and CDC staffs utilize the DFC and CARA Progress Reports to ensure DFC and CARA grantee compliance with the Statutory Eligibility Requirements, and to remain up to date on the progress of grantees for each program. The data provided can indicate new drug trends in various regions of the United States as well as inform Congress of the specific work being done in specific congressional districts. The DFC Program has been evaluated for over a decade. However, under the Performance Work Statement (PWS), the CARA Program will be evaluated for the first time.

DFC and CARA Four Core Measures

The following four Core Measures are required to be collected and reported every two years.

1. Past 30-Day Use

2. Perception of Risk or Harm of Use

3. Perception of Parental Disapproval of Use

4. Perception of Peer Disapproval of Use

For the DFC Program, the Four Core Measures are to be collected for four substances (Alcohol, Tobacco, Marijuana, and Prescription Drugs). For the CARA Program, the Four Core Measures are to be collected for three substances (Opioid, Methamphetamine, and/or Prescription Drug use/misuse). This data is critical in identifying the extent to which DFC and CARA funded community coalitions are successful in reducing youth substance use. This data is collected via the DFC Management and Evaluation (DFC Me) system. ONDCP currently has a contract for the development and management of the DFC Me system.

The DFC and CARA National Evaluation Contractor shall work closely with the DFC Me team to ensure data collection process (from grant funding to grant closeout).

Coalition Classification Tool (CCT): The CCT is a survey instrument designed to capture information on coalition performance and characteristics with regards to four key areas:

1. Coalition Development and Management

2. Coordination of Prevention Programs/Services

3. Environmental Prevention Strategies

4. Capacity Building

For DFC, the CCT is conducted every year in August. The CCT is not required for CARA grant award recipients.

The Contractor shall properly manage and maintain the data sets from all previous DFC National Evaluations. FY 2021 will be the first year the CARA Program will undergo a National Cross Site Evaluation.

The estimated dollar value for this action is $1. M. A Request for Quote (RFQ) will be issued after the approval of this justification.

4. Identification of the exception to fair opportunity (see 16.505(b)(2)) and the supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited.

a. The following fair opportunity exception applies to this acquisition.

FAR 16.505(b)(2)(i)(B) – Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized (to include brand name in accordance with 16.505(a)(4)).

b. Supporting Rationale.

The initial phase of the project was competed among all vendors included in Oasis Pool 2 utilizing FAR

16.505 procedures. Two quotes were received and ICF was selected for the requirement.

ICF has the specialized resources, capacity, and unique technical experience to perform the services necessary to ensure the success of these two programs. Specifically, ICF possesses the unique technical experience, expertise and understanding of EOPs data collection processing system, DFC Me. This experience and understanding is imperative as the vendor must work closely with the DFC Me team to facilitate a successful data collection process.

ICF has distinctively qualified expertise and experience in dealing with the substance use prevention field. ICF is most familiar with the DFC program and possesses specialized in-depth knowledge and experience in this unique data collection from highly diverse community coalitions that face a myriad of challenges in delivering high quality evidence-based prevention services to youth in their local communities.

Over the past 10 years, while providing support services to the DFC program, ICF has illustrated that it possesses the inherent ability to address the unique cultural competencies in working within these communities that have varying levels of sophistication in collecting and reporting data. Furthermore, ICF’s 10 years of previous technical experience make it uniquely qualified to properly manage and maintain the datasets from all previous DFC National Evaluations.

ICF’s extensive past experience subsequent knowledge gains has facilitated ICF to acquire the ability to determine the unique characteristics that are found in grantees that are successful in preventing and/or reducing youth substance use.

On April 14, 2021 a Sources Sought/Request for Information was posted via Sam.gov under Contract Opportunities. No responses were received by the response due date, April 20, 2021. Furthermore, on May 03, 2021 a Notice of Intent was posted to Sam.gov under Contract Opportunities with no responses received by the response due date, May 18, 202 .

This is the first time this exception to Fair Opportunity - FAR 16.505(b)(2)(i)(B) – Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized (to include brand name in accordance with 16.505(a)(4)) has been used for this requirement.

An exception to fair opportunity task order for the period of performance of one 12-month base plus one six month option period is necessary as it would ensure the program’s success and provide adequate time to compete this requirement with full and open competition.

As justified above, it is imperative to ensure the success of DFC and CARA Program that this exception to fair opportunity task order be awarded to ICF as this vendor possesses the specialized resources, capacity, and unique technical experience and is the only source capable of providing the services at the required level.

5. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The contracting officer will make a separate determination as to the fairness and reasonableness of the price through price analysis. The following information will be utilized during price analysis: (1) the independent government cost estimate, (2) historical data from the existing task order, Task Order D16PD00001 and (3) ICF’s current Oasis contract rates will be utilized during the price analysis.

6. Any other facts supporting the use of other than full and open competition, such as:

None.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The exception to fair opportunity task order will include a transition plan to assist with on-ramping a potential new vendor which mitigates programmatic impacts associated with transitioning contractors.

The plan should include some overlap to ensure full knowledge transfer. Upon completion of this task order, the intent is to compete this requirement with full and open competition. The Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable a future competitive re-competition of this effort.

8. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

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

L. Christine Quintana Date Contracting Officer Division 2 Branch 1

9. Requirements personnel certification.

I certify that the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

Helen Hernandez Date Contracting Officer Representative

6/2/21

6/2/21

LYDIA

QUINTANA

Digitally signed by LYDIA

QUINTANA

Date: 2021.06.02 13:25:14 -04'00'

HELEN

HERNANDEZ

Digitally signed by HELEN

HERNANDEZ

Date: 2021.06.02 13:37:25 -04'00'

10. Reviews and Approvals

Concur

Date

Date

Melissa Onyszko Branch Chief (Acting) Division 2 Branch 1

MELISSA ONYSZKO

Digitally signed by MELISSA

ONYSZKO

Date: 2021.06.02 14:36:52 -04'00'

Rebecc Fena tzke Division Chief Division 2

Approve

ABNER DEVALLON Digitally signed by ABNER DEVALLON Date: 2021.06.02 17:39:50 -04'00'

REBECCA FENTZKE Digitally signed by REBECCA FENTZKE Date: 2021.06.03 07:52:07 -04'00'