EOP Limited Source justification redact_Redacted.pdf

Senior Acquisition Concurrence:

I have reviewed this justification and conclude that it is accurate and complete to the best of my knowledge and belief.

NARA Competition Advocate Approval:

I have reviewed this justification and hereby certify that it is accurate and complete to the best of my knowledge and belief. In accordance with FAR 8.405-6(a) and NARA 501, I approve this justification.

I. IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY,

AND SPECIFIC IDENTIFICATION OF THE DOCUMENT AS A "LIMITED-

SOURCES JUSTIFICATION."

See Page 1.

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

The National Archives and Records Administration intends to restrict competition based on an urgent and compelling need. This justification is to modify an existing BPA order for NARA’s support of the presidential transition, which was competitively awarded under NARA’s Information Technology Augmentation Services (ITAS) blanket purchase agreement (BPA). The action establishes an expedited delivery of critical milestones and tasks associated with the timely transfer and remediation of Presidential Records Act (PRA) data from the Executive Office of the President (EOP) to NARA’s Electronic Records Archive (ERA).

III. A DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET

THE AGENCY’S NEEDS (INCLUDING THE ESTIMATED VALUE).

NARA requires software integration and technical application support services, to identify, inventory, acquire, and transport unclassified electronic PRA records from systems designated by NARA and the EOP 45, in mutually-agreed upon formats and metadata that meet archival and technical acceptance criteria specific to NARA’s ERA EOP archival system. The Vendor shall transfer these electronic records into a staging environment stood up by the Vendor for this transition, validate the SIP packages, and then deliver and stage them for ingest into ERA EOP.

NARA’s original timeline estimated task order completion in 15 months to transfer all the data and stand up the EOP 45 instance in AWS.

However, in order to fulfill NARA’s obligations under 44 U.S.C. 2205 to respond to search and access requests immediately following the end of an administration, NARA requires physical and logical custody of presidential records be transferred to NARA no later than six (6) months and the records be indexed and searchable by end of July 2021, as described in the Memorandum of Agreement (MOA) with EOP. The compressed timeline allows for archival searching on validated data much sooner than originally contemplated by the original award.

The estimated value of the modification is approximately $1,148,380.

IV. THE AUTHORITY AND SUPPORTING RATIONALE (SEE 8.405-6(a)(1)(i) AND

(b)(1)) AND, IF APPLICABLE, A DEMONSTRATION OF THE PROPOSED

CONTRACTOR'S UNIQUE QUALIFICATIONS TO PROVIDE THE REQUIRED

SUPPLY OR SERVICE.

Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C.

4104) and Title 40 U.S.C. 501 - Services for Executive Agencies as implemented by FAR 8.405-6(a)(1)(i)(A), An urgent and compelling need exists, and following the procedures would result in unacceptable delays. This acquisition is conducted under the authority of the Multiple-Award Schedule Program.

V. A DETERMINATION BY THE ORDERING ACTIVITY CONTRACTING

OFFICER THAT THE ORDER REPRESENTS THE BEST VALUE

CONSISTENT WITH 8.404(d).

This requirement is for services and support that are available on GSA schedule. GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable.

Additionally, the prices and hourly rates offered by Team XLA under the BPA were determined to be fair and reasonable at the time of BPA award. NARA will evaluate the labor categories and hours to determine the total price increase is reasonable.

VI. A DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG

SCHEDULE HOLDERS AND THE RESULTS OR A STATEMENT OF THE

REASON MARKET RESEARCH WAS NOT CONDUCTED.

On October 23, 2020, NARA competitively awarded task order 88310321F00013 to XL Associates, Inc. (XLA), the Team Lead and its Teaming Partner1, Sapient Government Services, Inc. (Sapient), for supporting the EOP 45 presidential transition. Competitively awarding a new task order, for work that is substantially similar to the existing task order, so close to a one-term presidential transition, creates a large technical and legal risk that NARA will not satisfy its obligations under the PRA for a timely transfer. Thus market research was not conducted, as an urgent and compelling need exists to accelerate the timeline.

VII. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION.

Not Applicable.

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

REMOVE OR OVERCOME ANY BARRIERS THAT LED TO THE RESTRICTED

CONSIDERATION BEFORE ANY SUBSEQUENT ACQUISITION FOR THE

SUPPLIES OR SERVICES IS MADE.

1 The BPA was issued to XLA. XLA does not have any direct technical involvement in the performance of work under this task order, its role is administrative. Sapient is performing 100% of the technical work.

NARA will work with current and future administrations to set procedures and policies to support iterative transfers of PRA records to the custodial custody of NARA minimizing the impact of impromptu actions and or constraints limiting NARA's ability's to execute agency strategic goals and missions in support of the Presidential Records Act.

IX. THE ORDERING ACTIVITY CONTRACTING OFFICER'S CERTIFICATION

THAT THE JUSTIFICATION IS ACCURATE AND COMPLETE TO THE BEST

OF THE CONTRACTING OFFICER'S KNOWLEDGE AND BELIEF.

See page 1.

X. EVIDENCE THAT ANY SUPPORTING DATA THAT IS THE

RESPONSIBILITY OF TECHNICAL OR REQUIREMENTS PERSONNEL (E.G.,

VERIFYING THE GOVERNMENT'S MINIMUM NEEDS OR REQUIREMENTS

OR OTHER RATIONALE FOR LIMITED SOURCES) AND WHICH FORM A

BASIS FOR THE JUSTIFICATION HAVE BEEN CERTIFIED AS COMPLETE

AND ACCURATE BY THE TECHNICAL OR REQUIREMENTS PERSONNEL.

XI. FOR JUSTIFICATIONS UNDER 8.405-6(A)(1), A WRITTEN DETERMINATION

BY THE APPROVING OFFICIAL IDENTIFYING THE CIRCUMSTANCE

THAT APPLIES.