F11_LSJ_for_SAM_Posting_1.pdf

Department of the Interior Bureau of Safety and Environmental Enforcement

LIMITED SOURCES JUSTIFICATION (LSJ)

Federal Supply Schedule Program - FAR 8.4

(Mandatory for Acquisitions > SAT) (Optional for Acqs. ≤ SAT)

This acquisition is being conducted under the authority of the Multiple-Award Schedule Program pursuant to Title III of the Federal Property and Administrative Services Act of 1949 and Title 40 U.S.C. 501, Services for Executive Agencies [FAR 8.405-6(c)(1)].

1. Bureau and Contracting Activity [FAR 8.405-6(c)(2)(i)]

2. Description of Supplies or Services [FAR 8.405-6(c)(2)(iii)]

3. Requisition No.

4. Cost Estimate (including options)[FAR 8.405-6(c)(2)(iii)]

5. Name of Proposed Source(s)

6. REQUESTING OFFICE CERTIFICATION

I certify that this recommendation contains the information required by FAR 8.405-6(c) and its contents are accurate.

Date:Phone No:Signature:Requesting Office Rep. (Name &Title)

7. ACQUISITION OFFICE CERTIFICATION

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

Signature: Phone No: Date:Contracting Officer (Name)

Identify the authority being used to justify restricting consideration to a limited number of vendors [FAR 8.405-6]. Provide a narrative justification associated with the respective authority. Refer to block number 12 for additional justification details.

8. FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

9. FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of responding due to the unique or specialized nature of the work.

10. FAR 8.405-6(a)(1)(i)(C) – The new work is a logical follow-on to an original FSS order or BPA, and the original order or BPA was placed in accordance with applicable FSS ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

11. FAR 8.405-6(b) – An item peculiar to one manufacturer is required.

12. JUSTIFICATION (Attach additional pages if needed)

(a) Nature and/or description of the action being approved [FAR 8.405-6(c)(2)(ii)] [Prepared by Program Office]

(b) Determination by the Acquisition Office Contracting Officer that the order represents the best value consistent with FAR 8.804(d) [FAR 8.405-6(c)(2)(v)] [Prepared by Contracting Officer]

(c) Description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted [FAR 8.405-6(c)(2)(vi)] [Initiated by the Program Office and finalized in collaboration with the Contracting Officer]

12. JUSTIFICATION CONTINUED (Attach additional pages if needed)

(d) Statement of the actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for supplies and services is made [FAR 8.405-6(c)(2)(viii)] [Initiated by the Program Office and finalized in collaboration with the Contracting Officer]

(e) Any other facts supporting the justification [FAR 8.405-6(c)(2)(vii)] [Prepared by the Program Office and Contracting Officer]

Highlight

14. Competition Advocate (Name & Title)

APPROVE

DISAPPROVE

(Phone No.)

(Date)

15. Head of the Contracting Activity (Name & Title)

(Date)

(Phone No.)

(Signature)

(Signature)

(Signature)

APPROVE

DISAPPROVE

16. Departmental Senior Procurement Executive (Name & Title) APPROVE

DISAPPROVE

(Phone No.)

(Date)

O ve r $7

,0

O ve r

$1 m ill io n

O ve r $7 m ill io n (Signature)13. Chief of the Contracting Office (Name & Title)

APPROVE

DISAPPROVE

(Phone No.)

(Date)O ve r

SA

T

APPROVALS [FAR 8.405-6(d)]

INSTRUCTIONS FOR COMPLETING FORM

Block No.

Identify Bureau initiating the requirement and Acquisition Office processing the requirement.

- Bureau of Safety and Environmental Enforcement (BSEE), or Bureau of Ocean Energy Management (BOEM)

Provide a clear, concise description of the product(s) and/or service(s) to be procured, including the delivery schedule and/or the period of performance (including all option periods). Always include the estimated value of the order or BPA in Section 4 below. This provides the reviewing and approving official with a better understanding of the scope, magnitude, and complexity of the requirement.

4 Include all applicable options and system life-cycle costs.

Include more than one source as a proposed vendor, unless you are citing FAR 8.405-6(a)(1)(i)(B). For example, if the procurement is based on unusual and compelling need, you must still contact as many potential sources as is practicable unless the justification for urgency contains detailed documentation to show that it is not practicable under the circumstances to solicit additional sources.

6 & 7 Obtain certification from the requesting office and contracting officer prior to submitting for approval.

8-11

Check the box next to the justifying authority. Only one authority can be cited.

- Include an explanation of the contractor's unique qualifications, the nature of the acquisition that requires the use of the same vendor as part of a logical follow on, or the reasons for urgency and an explanation of how using the procedures would result in unacceptable delays. This is the most important part of the LSJ because it demonstrates that the prospective contractor has unique qualifications and/or specialized capabilities or expertise that is not prevalent elsewhere on the schedules. If the order contains a brand name specification, the ordering activity must show evidence that the Request for Quotation and the following information was posted on GSA e- Buy. You must explain what unique qualifications and special capabilities the vendor possesses.

- When FAR 8.405-6 (a)(1)(i))(A) is cited, provide data, estimated cost, or other rationale as to the extent and nature of the harm to the government following schedule procedures would cause.

- When an urgent or compelling need exists, discuss the nature of the urgency. Discuss how any follow-on work will be competed (mandatory). Also, provide supporting rationale and a concise description of the extent, nature, and impact of the unacceptable delay.

- When FAR 8.405-6 (a)(1)(i)(C) is cited for logical follow on, include an estimate of the duplicative cost and methodology used to formulate the estimated cost.

- The justification on pages 3 and 4 must be clear and concise as to how the cited authority is related to the acquisition.

- When applicable, include documentation that demonstrates the prospective vendor's unique qualifications to provide the required supply of service.

12(a)

Describe the type of action being issued, e.g., Federal Supply Schedule (FSS) order or blanket purchase agreement (BPA) for supplies, services not requiring a statement of work, or services that require a statement of work. Also, identify the contemplated contract type, i.e. firm fixed price, time and materials, etc. Provide sufficient information so the reviewer clearly understands the proposed approach under consideration.

12(b) The Contracting officer needs to determine, after considering the level of effort and the mix of skills available for the tasks needed, that the proposed order or BPA represents a reasonable total price and will be the best value for the government. Include explanation of what techniques will be used to determine prices fair and reasonable.

INSTRUCTIONS FOR COMPLETING FORM

Block No.

12(c)

Market research requires collecting and analyzing product/service information on the technical capabilities and prices/costs from appropriate FSS contracts. If market research was not conducted, the reasons why it was not conducted should be stated.

If above the SAT, a copy of the proposed LSJ prepared in accordance with this guide; if an exception permitted by 8.405-6(b)(3)(ii) exists, documentation of the exception should be provided here in lieu of the E-buy posting.

12(d)

Describe actions taken, or that will be taken, to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required, including challenges to restrictive data markings, data rights, preparation of a performance based work statement, etc. If planning a competition, include the estimated date when the competitive procurement will occur. If this is a follow-on order, state the measures initiated to eliminate or reduce competitive barriers.]

12(e) Provide any additional documents that will support the justification.

If any person required to sign-in these blocks does not approve, the procurement shall not proceed any further and the justification shall be returned to the requisitioner through the contracting officer. All signatures required on the form (as applicable to the particular acquisition) must appear in order for the procurement to proceed.

13-16

Department of the Interior Bureau of Safety and Environmental Enforcement

LIMITED SOURCES JUSTIFICATION (LSJ)

Federal Supply Schedule Program - FAR 8.4 (Mandatory for Acquisitions > SAT)(Optional for Acqs. ≤ SAT) This acquisition is being conducted under the authority of the Multiple-Award Schedule Program pursuant to Title III of the Federal Property and Administrative Services Act of 1949 and Title 40 U.S.C. 501, Services for Executive Agencies [FAR 8.405-6(c)(1)].

1. Bureau and Contracting Activity [FAR 8.405-6(c)(2)(i)]

2. Description of Supplies or Services [FAR 8.405-6(c)(2)(iii)]

3. Requisition No.

4. Cost Estimate (including options)[FAR 8.405-6(c)(2)(iii)]

5. Name of Proposed Source(s)

6. REQUESTING OFFICE CERTIFICATION

I certify that this recommendation contains the information required by FAR 8.405-6(c) and its contents are accurate.

Date:

Phone No:

Signature:

Requesting Office Rep. (Name &Title)

7. ACQUISITION OFFICE CERTIFICATION

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

Signature:

Phone No:

Date:

Contracting Officer (Name) Identify the authority being used to justify restricting consideration to a limited number of vendors [FAR 8.405-6]. Provide a narrative justification associated with the respective authority. Refer to block number 12 for additional justification details.

8. FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

9. FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of responding due to the unique or specialized nature of the work.

10. FAR 8.405-6(a)(1)(i)(C) – The new work is a logical follow-on to an original FSS order or BPA, and the original order or BPA was placed in accordance with applicable FSS ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

11. FAR 8.405-6(b) – An item peculiar to one manufacturer is required.

12. JUSTIFICATION (Attach additional pages if needed)

(a) Nature and/or description of the action being approved [FAR 8.405-6(c)(2)(ii)] [Prepared by Program Office]

(b) Determination by the Acquisition Office Contracting Officer that the order represents the best value consistent with FAR 8.804(d) [FAR 8.405-6(c)(2)(v)] [Prepared by Contracting Officer]

(c) Description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted [FAR 8.405-6(c)(2)(vi)] [Initiated by the Program Office and finalized in collaboration with the Contracting Officer]

12. JUSTIFICATION CONTINUED (Attach additional pages if needed)

(d) Statement of the actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for supplies and services is made [FAR 8.405-6(c)(2)(viii)] [Initiated by the Program Office and finalized in collaboration with the Contracting Officer]

(e) Any other facts supporting the justification [FAR 8.405-6(c)(2)(vii)] [Prepared by the Program Office and Contracting Officer]

14. Competition Advocate (Name & Title) (Phone No.)

(Date)

15. Head of the Contracting Activity (Name & Title) (Date) (Phone No.)

(Signature) (Signature) (Signature)

16. Departmental Senior Procurement Executive (Name & Title) (Phone No.)

(Date) Over $750,000 Over $15 million Over $75 million (Signature)

13. Chief of the Contracting Office (Name & Title) (Phone No.)

(Date) Over

SAT

APPROVALS [FAR 8.405-6(d)]

INSTRUCTIONS FOR COMPLETING FORM

Block No.

Identify Bureau initiating the requirement and Acquisition Office processing the requirement.

- Bureau of Safety and Environmental Enforcement (BSEE), or Bureau of Ocean Energy Management (BOEM)

Provide a clear, concise description of the product(s) and/or service(s) to be procured, including the delivery schedule and/or the period of performance (including all option periods). Always include the estimated value of the order or BPA in Section 4 below. This provides the reviewing and approving official with a better understanding of the scope, magnitude, and complexity of the requirement.

Include all applicable options and system life-cycle costs.

Include more than one source as a proposed vendor, unless you are citing FAR 8.405-6(a)(1)(i)(B). For example, if the procurement is based on unusual and compelling need, you must still contact as many potential sources as is practicable unless the justification for urgency contains detailed documentation to show that it is not practicable under the circumstances to solicit additional sources.

6 & 7 Obtain certification from the requesting office and contracting officer prior to submitting for approval.

8-11 Check the box next to the justifying authority. Only one authority can be cited.- Include an explanation of the contractor's unique qualifications, the nature of the acquisition that requires the use of the same vendor as part of a logical follow on, or the reasons for urgency and an explanation of how using the procedures would result in unacceptable delays. This is the most important part of the LSJ because it demonstrates that the prospective contractor has unique qualifications and/or specialized capabilities or expertise that is not prevalent elsewhere on the schedules. If the order contains a brand name specification, the ordering activity must show evidence that the Request for Quotation and the following information was posted on GSA e-Buy. You must explain what unique qualifications and special capabilities the vendor possesses.

- When FAR 8.405-6 (a)(1)(i))(A) is cited, provide data, estimated cost, or other rationale as to the extent and nature of the harm to the government following schedule procedures would cause.- When an urgent or compelling need exists, discuss the nature of the urgency. Discuss how any follow-on work will be competed (mandatory). Also, provide supporting rationale and a concise description of the extent, nature, and impact of the unacceptable delay.- When FAR 8.405-6 (a)(1)(i)(C) is cited for logical follow on, include an estimate of the duplicative cost and methodology used to formulate the estimated cost.- The justification on pages 3 and 4 must be clear and concise as to how the cited authority is related to the acquisition.- When applicable, include documentation that demonstrates the prospective vendor's unique qualifications to provide the required supply of service.

12(a) Describe the type of action being issued, e.g., Federal Supply Schedule (FSS) order or blanket purchase agreement (BPA) for supplies, services not requiring a statement of work, or services that require a statement of work. Also, identify the contemplated contract type, i.e. firm fixed price, time and materials, etc. Provide sufficient information so the reviewer clearly understands the proposed approach under consideration.

12(b) The Contracting officer needs to determine, after considering the level of effort and the mix of skills available for the tasks needed, that the proposed order or BPA represents a reasonable total price and will be the best value for the government. Include explanation of what techniques will be used to determine prices fair and reasonable.

INSTRUCTIONS FOR COMPLETING FORM

Block No.

12(c) Market research requires collecting and analyzing product/service information on the technical capabilities and prices/costs from appropriate FSS contracts. If market research was not conducted, the reasons why it was not conducted should be stated.

If above the SAT, a copy of the proposed LSJ prepared in accordance with this guide; if an exception permitted by 8.405-6(b)(3)(ii) exists, documentation of the exception should be provided here in lieu of the E-buy posting.

12(d) Describe actions taken, or that will be taken, to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required, including challenges to restrictive data markings, data rights, preparation of a performance based work statement, etc. If planning a competition, include the estimated date when the competitive procurement will occur. If this is a follow-on order, state the measures initiated to eliminate or reduce competitive barriers.] 12(e) Provide any additional documents that will support the justification.

If any person required to sign-in these blocks does not approve, the procurement shall not proceed any further and the justification shall be returned to the requisitioner through the contracting officer. All signatures required on the form (as applicable to the particular acquisition) must appear in order for the procurement to proceed.

13-16 Policy 008 – Limited Sources Justification Form

Department of the Interior (DOI), Bureau of Safety and Environmental Enforcement (BSEE), Acquistiion Management Division

8605 WESTWOOD CENTER DR STE 300

VIENNA VA 22182

The DOI has established aggressive timelines for HRSD deployment to align with broader digital transformation goals, workforce modernization mandates, and compliance with federal directives such as OPM’s Human Capital Framework and the President’s Management Agenda. These requirements necessitate accelerated implementation to avoid disruption in service delivery and to ensure readiness for upcoming fiscal year planning cycles.

Initiating a full and open competitive acquisition process at this stage would result in unacceptable delays that directly conflict with DOI’s mandated deployment schedule. The time required for solicitation, evaluation, and award under competitive procedures would significantly hinder the department’s ability to meet its internal milestones.

It will be a firm fixed priced modification and pricing will include only labor pricing and it will be in accordance with the Contractor's GSA Schedule. FAR 8.404(d) states, 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."

TextField4: Market research was not conducted because the required services are highly specialized and only one source is capable of meeting the Governments needs. NuAxis implemented the HRHD at BSEE and plans to use the same/similar specifications at the other DOI Bureaus. BSEE has prior experience with the proposed source and has determined that no other vendor can meet the technical specifications or performance requirements within the required timeframe of 6 months.

TextField5:

Once HRHD is setup and deployed at the DOI bureaus, DOI plans to competitively issue a new task order to maintain the HRHD modules at the bureaus.