EY EA - SoleSource Justification (Final).pdf

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

FOLLOW-ON TASK ORDER

TO CONTINUE WORK PERFORMED UNDER

CFP-15-Z-0015 / 9531CB19F0075

ENTERPRISE ARCHITECTURE AND INVESTMENT ANALYSIS

SERVICES

1.0 Agency Name & relevant office(s).

Consumer Financial Protection Bureau (CFPB); Office of Technology and Innovation (T&I)

2.0 Nature and/or description of the action being approved, the supplies or services needed, and estimated dollar value.

The proposed action is to issue a logical follow on task order to continue ongoing mission critical CFPB Enterprise Architecture and Investment Analysis Services until a new CFPB Enterprise Technology Services (ETS) Blanket Purchase Agreement (BPA) can be awarded. The work currently performed under BPA # CFP-15-Z-0015, task order # 9531CB19F0075 will be continued under a logical follow-on task order.

The Contractor has been providing Technical Support Services in order to maintain, further develop and communicate current state and targeted Enterprise Architectures (EAs) that fully describe CFPB operations and are used to align Information Technology (IT) strategy, plans, projects, services, systems, and technologies with the mission, goals, capabilities, structure, and processes. There is a continued need for these services. Under the follow-on task order, the contractor shall:

Continue to review project solutions to ensure they effectively integrate with current and planned CFPB operations, maximize the reuse of CFPB operational components, and maximize collaboration with other CFPB initiatives that share common development and operational components.

Assist in the execution of effective change management processes that play a key role in T&I’s governance structure. This includes capturing and prioritizing change requests, providing EA updates to change requests, providing guidance to participants and publishing metrics.

Employ federal government and industry-recognized strategies to assist with development of business cases, cost benefit analysis, return on investment analysis, total cost of ownership analysis, project/program costing and tracking for new and existing projects.

Justification and Approval for Other than Full and Open Competition Enterprise Architecture and Investment Analysis Services

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Support the development of artifacts necessary to achieve CFPB Investment Review Board (IRB) and Office of Technology and Innovation (T&I) Technology Investment Review Board (TIRB) approval.

Provide analysis of T&I operations and the existing portfolio of CFPB current and planned initiatives and make recommendations regarding the initiation, continuation, and termination of projects to maximize support for strategic goals and prioritized operational improvements. Include the adoption and reporting of Federal IT Acquisition Reform Act (FITARA) and Technology Business Management (TBM) as applicable to T&I and Chief Information Officer (CIO) reporting.

T&I intends to award a logical follow-on task order with a base period of six (6) months and six (6), one-month option periods, to be exercised at the discretion of the Government. The Base period of performance will be August 31, 2021 to February 28, 2022 with six one-month options, potentially running through September 30, 2022, if all option periods are exercised. The estimated total value of the follow-on task order is $2,590,731.40, if all option periods are exercised.

3.0 Authority for other-than full-and-open competition.

This logical-follow on is conducted under the authority of FAR Part 8.405-6(a)(1)(C), which permits the placing of orders if “(i)n the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.”

The original BPA and task order referenced was placed in accordance with the Federal Supply Schedule (FSS) ordering procedures. The BPA was competed amongst GSA Schedule Holders, and the task order was further competed amongst all BPA holders. Competition and source selection procedures were carried out according to FAR Part 8.4. The existing BPA has expired and therefore no new orders can be issued against it. CFPB cannot issue an in-scope modification and place additional funding on this order. Performance by a new contractor for the limited performance period duration would result in technical inefficiencies and a substantial duplication of transition costs in bringing a new contractor up to speed. A logical follow-on task order is therefore necessary to economically and efficiently continue this mission critical T&I support.

This follow-on order will replace CFP-15-Z-00015 / 9531CB19F0075, awarded to Ernst & Young for Enterprise Architecture and Investment Analysis Services.

The task order provides CFPB mission-critical services for Enterprise Architecture and Enterprise Governance. These functions are central to the operations of CFPB and the Bureau’s mission

3 | P a g e would be directly impacted if a gap in services were to occur. Mission critical functionality includes:

1. Facilitation of project governance boards. The Enterprise governance team in coordination with the CFPB project management office including project approvals, kickoffs, monitoring, and approval for operational readiness. Without this function, projects across T&I and CFPB will not be able to be governed and will critically damper their ability for success.

2. Facilitation of change management meetings. Any changes to production require proper documentation, facilitation of change control boards, and approvals to be released to production. The Enterprise Governance team facilitates this function and without the change control board production updates would either not be authorized to be complete, or they would be made without appropriate vetting resulting in negative outcomes and outages caused in production.

3. Ownership of Configuration Management plan and Configuration Management Database. The Enterprise Architecture team owns the CFPB wide configuration management plan and configuration management database. This includes an understanding and updates to all existing technology, interfaces, and data between systems at CFPB. Without this function continuing, the data within the configuration management database would be out of date and CFPB would fail audits. In addition, CFPB would not be able to understand the technology in place and how to appropriately monitor it.

4. Approval for technology to ensure it is aligned with business needs and not duplicative.

The Enterprise Architecture team is involved in assessments of all projects before they are funded or initiated. This ensures that the projects are in line with CFPB roadmaps and technology choices are not duplicative.

5. Technology Evaluations. Enterprise Architecture works with all team’s technology decisions to identify and select the appropriate product to meet their requirements.

Without this function, teams would have to select their own technology, which will slow down their team’s resources and ability to deliver. It will also not enable CFPB to select the best technology for our needs.

6. Target Architecture and Roadmap. The Enterprise Architecture team develops the CFPB target architecture and roadmap for the CIO and for CFPB. This informs the CIO’s decisions on funding, prioritizations, and approvals for projects.

The objective of this follow-on task order is to provide continuous, uninterrupted, critical IT services as described above. Without contractor staff to maintain these systems and applications, CFPB would need to rely on in-house personnel, which is significantly limited, and which would require training and re-training, overtime, and/or compensation time for knowledge transfer. Given the expected short timeframe to implement such measures, and the resulting gap in service(s) that

4 | P a g e would ensue, dedicating CFPB personnel to manage and maintain the systems and applications (in addition to their standard responsibilities) is not a feasible alternative to a logical follow-on task order.

4.0 Best Value Determination.

In the interest of economy and efficiency, the Contracting Officer will negotiate the same rates currently being used by Ernst & Young on CFP-15-Z-0015/9531CB19F0075 for use under this order. Those rates have been determined to be “fair and reasonable,” and the contemplated order would represent the best value consistent with FAR 8.404(d). First, 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. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by FAR 8.405-2(d). Second, the original BPA Call was competitively solicited, evaluated, and awarded based on adequate price competition, where two or more BPA holders, competing independently, submitted priced offers that satisfied the Government’s expressed requirement. As such, I determine that using the same rates under this logical follow-on task order is fair and reasonable, and represents the best value to the Bureau for these services, as the work will continue at the rate the Bureau is currently paying without a gap in service or costly transition (in terms of both dollars and mission impact(s)).

5.0 A description of the market research conducted and the results, or a statement of the reason market research was not conducted.

Market research was not conducted for this order, as a delay in the Enterprise Technology Services (ETS) BPA award has necessitated the follow-on task order for continuing these services.

6.0 A description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was, or will be, publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies. Include a listing of sources, if any, that expressed a written interest in the acquisition as a result of the FBO posting.

A notice of intent to issue or a notice of award will be publicized either before or after award at the Governmentwide Point of Entry (GPE) website https://sam.gov/ in accordance with FAR 8.405-6 (a)(1)(C) and FAR 8.405-6(a)(2)(i).

7.0 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 is made.

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Multiple new BPA awards are planned with an anticipated award in Q1 of 2022. T&I will compete a new task order among the newly awarded BPAs. This follow-on task order will allow sufficient time for both transition and clearance of contractor personnel under a new order. If the new BPAs are not awarded in a timely fashion, T&I will pursue a competitive Task Order award via GSA.

In the interim, this follow-on order will provide sufficient time for the new award, clearance, and contractor transition. This follow-on order has been structured with a six (6) month base period of performance and six (6), one-month option periods, to be exercised at the discretion of the Government, to allow the CFPB to discontinue services under the logical follow on task order as soon as practicable.

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

Prior to the award of any follow-on order, CFPB Procurement will request a quotation, including pricing, for the duration of the order. The labor categories and pricing proposed by the Contractor will be verified to ensure they are consistent with the current Ernst & Young CFP-15-Z- 0015/9531CB19F0075 rates. At the time of both the original BPA and expiring task order awards, the Contractor’s pricing was deemed to be fair and reasonable based on competition, as well as data related to prices (such as market research, comparison of the proposed price with other vendors’ prices found reasonable, and comparison to the Independent Government Cost Estimate (IGCE)). An IGCE has also been created for comparison before award of this task order is made.

The Contracting Officer (CO) has determined that these prices, and the resulting estimated cost, represent the best value to the Government.

9.0 Approvals.

TECHNICAL/REQUIREMENTS PERSONNEL. All supporting data that is the responsibility of technical or requirements personnel, and which form a basis for the justification, are hereby certified as complete and accurate by the technical or requirements personnel.

Joy Brown: Date Title:

PROCUREMENT STAFF. To the best of my knowledge and belief, I certify that this justification is accurate and complete.

JOY BROWN

Digitally signed by JOY BROWN Date: 2021.08.25 14:40:05 -04'00'

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Name: Peggy Wright Date Title: Contracting Officer

Name: Caroline Coleman Date Title: Competition Advocate

Digitally signed by

PEGGY WRIGHT

Date: 2021.08.25 16:53:09 -04'00'

Caroline H Coleman Digitally signed by Caroline H Coleman Date: 2021.08.26 07:55:55 -04'00'