JnA-QA Prgm Spt Bridge.pdf

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

NEGOTIATION SENSITIVENEGOTIATION SENSITIVE

March 2023 NEGOTIATION SENSITIVE Page 1 of 5March 2023 NEGOTIATION SENSITIVE Page 1 of 5

NOTE: If a Justification was approved for the preceding acquisition, a copy of the approved Justification for the predecessor action must be included in the staff package for approval of the instant Justification. This applies to Justification staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor Justification will be used as a reference document by the approving official.

Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )

Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan? Yes No

Funding level for this acquisition: >SAT and < $750K > $750K and < $15M

Contracting Activity: AFDW/PKS

Purchase Request / Local ID Number: TBD

Program / Project (and PE, if applicable): QA Program Support

Program Type (PEO or Other Contracting): Other Contracting

Authority: AFFARS 5313.501 - 10 U.S.C. 3572, Implementation of Simplified Acquisition Procedures (41 U.S.C. 1901)

AFFARS 5313.501 - 10 U.S.C. 3403, Special Emergency Procurement Authority (41 U.S.C. 1903)

Estimated Contract Cost (including options): $584,987.68 Justification Type: Class Individual

COORDINATION ( AFFARS 5306.304(a)) Sign and Save Procedure

** The text in the signature blocks below is editable, including the title.

** To remove a row, click the "X" next to the signature block. CAUTION: Once removed, it can only be restored by downloading the BLANK FORM again.

Date

12 Mar 2024

Project Lead / Program Mgr / Requiring Activity Michael D. Hayes

SAF/FMF / 720-635-7995

Signature

X

Date

14 Mar 2024

Local Legal Reviewer Gretchen A. Bundy-Ladowicz

AFDW/JA / 919-672-3558

Signature

X

APPROVAL (AFFARS 5306.304(a) )

Date

21 Mar 2024

Contracting Officer Deanna J. Kerkhoff

AFDW/PKS / 720-635-7995

Signature

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 NEGOTIATION SENSITIVE Page 2 of 5March 2023 NEGOTIATION SENSITIVE Page 2 of 5

I. Contracting Activity.

Department of Air Force Air Force District of Washington/PKS 1500 W. Perimeter Road, Suite 2750 Joint Base Andrews, MD 20762

II. Nature and/or description of the action being processed.

This bridge action supports a four-month extension of services to the SAF/FMF Quality Assurance (QA) Program Support commercial services contract, FA7014-21-C-0039. This extension is accomplished via contract modification to Assent Advisory Group, LLC for a 31 March 2024 - 31 July 2024 period of performance.

Assent Advisory Group, LLC is currently operating under a six-month option provided for by the contract's FAR Clause 52.217-8, Extension of Services (period of performance 27 September 2023 - 30 March 2024).

During acquisition planning for the follow-on QA Program Support effort, the Government team encountered unexpected delays due to significant organizational turnover and limited resources to address numerous competing priorities, along with requirement approval system functionality issues. Furthermore, the team's assessment of market research conducted originally indicated that a non-competitive approach under FAR

19.1406 would be most prudent for the follow-on contract. However, upon receiving counsel from the Air Force District of Washington (AFDW) Small Business Office on 4 March 2024, the team discovered a subtle oversight in regulatory analysis that necessitated shifting gears to pursue a competitive award.

In order to ensure fairness and promote competition to the maximum extent practicable while meeting mission requirements, the Government acquisition team now intends to competitively award a follow-on contract.

Doing so, however, requires a four-month extension of the current contract to ensure mission continuation while allowing time to solicit, evaluate offer(s) and award the follow-on with adequate contract transition time.

III. Description of supplies/services required to meet agency needs.

The Office of the Deputy Assistant Secretary for Financial Operations (SAF/FMF) requires continued support for QA Program Execution and Program Management Methodology (PMO) across the Department of the Air Force (DAF). This includes meeting all SAF/FMFCQ Quality Assurance Program requirements and sustainment/enhancements for the Quality Assurance Review Tool (QART), as they are identified through the Configuration Control Board (CCB) and other Air Force requirements.

The QART enables every base Financial Management (FM) squadron throughout the DAF to conduct independent reviews of functional work in Military Pay, Civilian Pay, Accounting and Budget. These reviews provide an avenue to detect and prevent fraud, ensure compliance, enable process improvement, act as an Inspector General liaisons, and provide the building blocks for Financial Improvement and Audit Readiness (FIAR) compliance. In addition to maintaining the tool, the contractor provides help desk support and is responsible for onboarding, training and offboarding the FM Quality Assurance Managers (QAM) assigned to every base in the Department of the Air Force in the QART tool.

The QA Program Support contractor is also responsible for the development and support of DAF FM operational metrics; development and support of the Payment Integrity Information Act (PIIA) Post Pay Review Tool and Risk Assessment Plan; on-going revision of the Manager's Internal Control Toolset (MICT) DAF-wide self-assessment program; administration of the revision to AFI 65-202, Administration of a FM QA Program; updating mandatory QA reviews and DAF-wide QA Plan; and facilitating and briefing DAF-wide QA topic training sessions, MAJCOM/FLDCOM/AFIMSC monthly meetings, and QA conferences. These efforts all form the foundation of the DAF FM QA Program.

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 NEGOTIATION SENSITIVE Page 3 of 5March 2023 NEGOTIATION SENSITIVE Page 3 of 5

Sustaining QA Program success is highly dependent on the contractor's depth of knowledge and experience working with DAF FM processes, paired with web-based analytic site creation skills. It is important to note that the DAF/FMF team is not resourced to carry out or train others to perform these tasks. Thus, a gap in service would ultimately bring each of these functions to a halt, significantly reducing the effectiveness and efficiency of the DAF FM mission.

For example, a gap in service would render every Comptroller squadron in the DAF unable to leverage QART functionality. QAMs would be forced return to isolated, manual workload processing with no means to standardize methods, understand the impact of their reviews, or gain cross-feed insights. Likewise, DAF FM leadership would have no reliable way to gauge effectiveness of decisions impacting compliance or DAF-wide root cause and trend analyses. This would hinder communications across the enterprise, as there is no other process established to gather and communicate relevant QA metrics or analyses to the Secretary of the Air Force or throughout the bases. Service-wide accountability and transparency of taxpayer dollars would be severely hindered.

Likewise, the PIIA Post Review Tool enables validation of over 20,000 Military Pay, Travel Pay and Civilian Pay transactions. Its effectiveness in removing risk of improper payments is recognized by OUSD(C), DoDIG, and OMB. A gap in service would result in regression to an enormous and unsustainable amount of manual workload needed to validate thousands of transactions.

Accordingly, the contractor's ability to meet the Government's schedule (thereby averting a gap in service) is a crucial, material aspect of this requirement. As previously stated, the Government does not have the manpower resources to train new personnel on these functions, and the contractor must be able to provide the full capability required in the current FA7014-21-C-0039 Performance Work Statement (PWS) by 31 March 2024.

This modification is valued at $584,987.68.

IV. Statutory authority permitting other than full and open competition.

As authorized in 10 U.S.C. 3572, as cited in FAR 13.501(a).

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

The nature of this acquisition is such that only Assent Advisory Group, LLC is capable of meeting the Government's immediate QA Program Support schedule and performance requirements. Not only is Assent Advisory Group, LLC the creator of the QART and PIIA tools with in-depth knowledge and experience managing the tools and DAF FM processes, but they also already have the personnel in-place to accomplish the stated objectives by 31 March 2024.

Being able to satisfactorily carry out the QA Program Support duties detailed in Section III above and in the current contract's PWS requires extensive relevant experience, training and familiarization with both DAF- and base-level initiatives. There is currently insufficient time to allow adequate transition between the incumbent contractor and any other successor while averting a disruption in services. Absent this formal transition, the Government risks a sizeable gap in service as the follow-on awardee attempts to learn and perform the required services with virtually no compulsory guidance or support from the incumbent.

Consequently, no other vendor can immediately replace the existing contractor without a severe and unacceptable degradation in overall support. For this reason, it is also not feasible for any portion of the work to be segregated to allow for competition without the four-month extension. The incumbent contractor, Assent Advisory Group, LLC, is familiar with the requirement and environment, and has a fully qualified staff in-

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 NEGOTIATION SENSITIVE Page 4 of 5March 2023 NEGOTIATION SENSITIVE Page 4 of 5 place.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

On 1 May 2023, the Government acquisition team posted a Sources Sought synopsis on the U.S. General Services Administration (GSA) website. The team also issued a Request for Information (RFI) on the Governmentwide Point of Entry (GPE), SAM.gov, on 20 December 2024. Both of these efforts were geared towards establishing the acquisition strategy for the full follow-on QA Program Support contract as described in Section II above. And even though this immediate effort for a four-month extension of services excludes competition, the subsequent competitive follow-on contract acquisition strategy is intended to ensure that offers are solicited from as many potential sources as practicable.

Additionally, the notice required by FAR Subpart 5.2 was provided for the extension and will be provided for the follow-on competition.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

Adequate data exists to determine a fair and reasonable price in alignment with the methodologies laid out at FAR 13.106-3(a)(2). This includes: comparison of the proposed price with prices found reasonable on previous purchases; and comparison to an independent Government estimate.

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

In addition to the Sources Sought synopsis and RFI addressed in Section VI above, the Government team performed market research using the following methods: Internet searches, a one-on-one industry session, contacting known sources of services, and a review of recent market research on similar requirements. The vendors that expressed interest by responding to the GSA and SAM.gov notices are listed in Section X below.

Based on the market research conducted, the Contracting Officer has reason to believe two or more offers will be received in response to the follow-on contract solicitation once adequate contract award and transition timelines are established. As previously described, another vendor cannot immediately replace the existing contractor without a severe and unacceptable degradation in overall QA Program Support, which would jeopardize federal Government assets. Accordingly, no other contractor can provide the services without an unacceptable interruption in service at this time.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

This requirement fulfills an existing Government need. An extension to the existing QA Program Support contract is the most advantageous and only practical method of fulfilling this need, price and other factors considered. It is in the best interests of the DAF and of the public to allow continued support under the current contract for four months, allowing adequate time for follow-on competitive solicitation, award and contract transition.

X. List of any sources that expressed, in writing, an interest in the acquisition.

In response to the 1 May 2023 GSA Sources Sought synopsis, the following nine vendors expressed interested in the follow-on effort: Barrow Wise, Business Performance Systems, IBS Government Solutions, Infotech Innovations, Michael Shannon Consulting, Significance, and Ascension.

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 NEGOTIATION SENSITIVE Page 5 of 5March 2023 NEGOTIATION SENSITIVE Page 5 of 5

In response to the 20 December 2024 SAM.gov RFI, the following four vendors expressed interest in the follow-on effort: Assent Advisory Group, ACES Group, Redhawk Administrative Services, and SRR International.

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

This requirement's sole purpose is to continue services under the current contract for the minimum amount of time required to allow for competitive award and contract transition. The extension represents only the necessary length of time required to allow for this.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by my signature above, I certify that any supporting data contained herein, which is my responsibility, is both accurate and complete.

Remove the Guidance pages below.

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items March 2023 Page of International Agreement Competitive Restrictions (IACR) March 2023 Page of NOTE: If a Justification was approved for the preceding acquisition, a copy of the approved Justification for the predecessor action must be included in the staff package for approval of the instant Justification. This applies to Justification staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor Justification will be used as a reference document by the approving official.

Is this a new or amended J&A Document?

Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan?

Funding level for this acquisition:

Authority:

Justification Type:

COORDINATION ( AFFARS 5306.304(a)) ** The text in the signature blocks below is editable, including the title.

** To remove a row, click the "X" next to the signature block. CAUTION: Once removed, it can only be restored by downloading the BLANK FORM again.

APPROVAL (AFFARS 5306.304(a)) NOTE: A signature block will appear here based on the funding level selected above.

(See "Specific Guidance for Completing this Template" below.)

I. Contracting Activity.

II. Nature and/or description of the action being processed.

III. Description of supplies/services required to meet agency needs.

IV. Statutory authority permitting other than full and open competition.

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

X. List of any sources that expressed, in writing, an interest in the acquisition.

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

XII. Certification by the Contracting Officer.

XIII. Certification by the technical/requirements personnel.

Specific Guidance for Completing this Template

I. Contracting Activity. (FAR 6.303-2(b)(1))

Fully identify the contracting agency and organizational activity responsible for the proposed contracting action.

II. Nature and/or description of the action being processed. (FAR 6.303-2(b)(2))

State whether the action will be awarded as a new contract or by modification to an existing contract (identify contract number) and identify the type contract planned (FAR 12.207 and DFARS 212.207).

An individual Justification cannot be used to support more than one contract irrespective of the quantities or the dollar value stated therein. If a proposed contract will contain unpriced options (including NTE prices), those options must be supported by a separate Justification prior to option exercise or the Justification supporting the basic contract must be a Class Justification. For Class Justification situations (covers more than one contract) where the number of contracts in the class can be identified: (1) Provide a brief general description of actions; (2) identify the supplies and services that are being acquired; and (3) for each contract in the class identify the contractor, estimated value, type of contract and rationale for contract length, and estimated award date. Where the same information applies to more than one contract within the class, it need only be stated one time.

III. Description of the supplies/services required to meet agency needs. (FAR 6.303-2(b)(3))

Specifically describe the supplies and/or services to be acquired, the total estimated value of the acquisition - including options (provide cost estimate by year and, for class Justifications, by contract action), and the estimated delivery dates/periods of performance If commodities are being procured, provide quantities. All contract line items (CLIN) -- e.g., technical data, support equipment, support services, etc. -- should be listed. If all of the ancillary requirements associated with a particular item are not specifically described in the Justifications, those ancillary requirements cannot be included in the resulting contract and would require a second Justification. Also, state the type of appropriation (e.g., 3010, 3400) that will be used to fund each requirement listed.

If approval for more than one fiscal year requirement is needed, give the rationale for this request. Generally, the scope of these actions is limited to current requirements only, so that actions may be taken to facilitate competition for out-year requirements.

In some cases, there are no feasible actions that could develop future competition, and it is reasonable to seek approval for more than one fiscal year's requirements.

For ID/IQ or requirements contracts, use the maximum dollar value of the total estimated orders as the estimated Justification dollar value.

IV. Statutory authority permitting other than full and open competition. (FAR 6.303-2(b)(4)) V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority). (FAR 6.303-2(b)(5)) Provide, in narrative form, a detailed explanation supporting and clearly relating to the conditions described by the FAR for using the particular authority cited. This section is normally the most detailed part of the justification as the essence of the justification is presented here. For acquisitions that include both supplies and services, separately justify the use of the authority for the services and supplies.

Contracting without providing for full and open competition shall not be justified on the basis of lack of advance planning by the requiring activity or concerns related to the amount of funds available (e.g., funds will expire) (10 U.S.C. 3204) VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

(FAR 6.303-2(b)(6))

Describe all efforts taken (or to be to be taken) to ensure that offers are solicited from as many potential sources as practicable under the circumstances. Although Market Research is covered in Section VIII, the information in Section VI should correlate with the Market Research described in Section VI. The following issues should be addressed in this paragraph:

Sources Sought Synopsis (used as part of market research). If a sources sought synopsis was issued, state the date the synopsis was issued and a brief description of its content. If any responses were received, describe in detail the results of the screening process and the rationale for determining the unacceptability of any synopsis respondents. Reference FAR 13.105, Synopsis and Posting Requirements.

Other Actions. In this paragraph, discuss any other actions taken or planned to facilitate competition for this acquisition. The discussion should include actions tried or considered even if the actions were unsuccessful. If the efforts were unsuccessful, so state and describe why.

Qualifying Country Sources. If qualifying country sources have expressed interest, but are to be excluded, provide supporting rationale.

VII. Determination by the Contracting Officer that the anticipated cost to the government will be fair and reasonable. (FAR 6.303-2(b)(7))

Include a statement by the contracting officer that the anticipated cost will be considered fair and reasonable and provide the basis for this determination. The steps that will be taken to ensure the final contract price will be fair and reasonable are also described here. Describe the extent of cost or price analysis anticipated including the requirements for certified cost or pricing data, technical evaluations, and audits.

VIII. Description of the market research conducted and the results, or explain why market research was not conducted. (FAR 6.303-2(b)(8))

Generally, some form of market research should be conducted. Discuss any market research conducted pursuant to FAR Part 10 and describe results of that research. Market research is any effort undertaken to determine if sources capable of satisfying the agency's requirements exist and to determine if commercial items or non-developmental items are either available or can be modified so that they will satisfy the agency's needs. Market research should be focused not only on identifying alternate sources, but also on alternate equipment or substitutes that might fulfill the Government needs with only minor modification. Regardless of the approach used, the results should provide a high level of confidence that no other qualified sources exist.

When other exceptions from the requirement to obtain full and open competition are relied upon, the market research might be limited to an examination of the acquisition history and experience with the marketplace under previous acquisitions for the same or similar items.

If no market research was conducted, so state and provide the rationale.

IX. Any other facts supporting the use of Other Than Full and Open Competition. (FAR 6.303-2(b)(9)(i))

Provide any other facts supporting the use of other than full and open competition, including an explanation of why technical data packages, specifications, engineering descriptions, statements of work, statements of objectives, or purchase descriptions suitable for full and open competition have not been developed, are not being developed, are not being used, or are not available.

X. List of sources, if any, that expressed interest in the acquisition. (FAR 6.303-2(b)(10))

If a sources sought synopsis was done and all interested sources are included in Section VI, it is acceptable to state, “See Section VI above.”

XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required. (FAR 6.303-2(b)(11))

Describe any actions taken or to be taken to foster competition for future acquisitions of the supplies or services being acquired. Describe potential actions that could be taken to remove the barriers to competition that have been identified in the justification and include a milestone schedule, where available, for accomplishing these actions. For example, if a follow-on competitive acquisition is planned, so state and provide the planned award date, or state that the Government will attempt to acquire rights in technical data and computer software sufficient to compete follow-on acquisitions as a priced option in the contract action that is the subject of this Justification, or (if applicable) state how the Government intends to challenge nonconforming markings on technical data and computer software delivered to it under previous contracts so those markings can be removed in order that the technical data and computer software may be used in support of a follow-on competitive acquisition, or describe plans to qualify additional sources.

Address efforts to ensure competition for future spare parts and maintenance in support of systems or equipment covered by the justification, even when these acquisitions will be accomplished by other organizations. Include a discussion on available breakout data.

If no actions are planned, so state and provide reasons. If approval is sought for more than one year, explain why a sole source effort is required for the planned time duration.

For a non-competitive follow-on acquisition to a previous award for the same supply or service supported by a Justification citing the same authority, include a discussion of the actions planned to overcome barriers to competition established in the previous justification, the status of those actions, and the results of those actions. The approval authority shall determine whether the planned actions were completed. If the planned actions were not completed, the justification for the follow-on acquisition shall be approved by the approval authority one-level above the approval authority for the previous justification (see FAR 13.501(a)(2)). If the previous justification was approved by the Senior Procurement Executive (SPE), the approval remains at the SPE level.

[DFARS 213.501(a) and DFARS PGI 206.304(a)(S-70)(ii)] XII. Certification by the Contracting Officer. (FAR 6.303-2(b)(12))

As evidenced by his/her signature, the contracting officer has determined this document to be both accurate and complete to the best of his/her knowledge and belief.

XIII. Certification by the technical/requirements personnel. (FAR 6.303-2(c))

As evidenced by their signatures, the technical and/or requirements personnel have certified that any supporting data contained herein, which is their responsibility, is both accurate and complete.

Do You Need to "REDACT" Text?

This template is interactive and has special features. In its current state, it cannot be redacted. In order to redact any portion of this template, you must first convert it to a normal PDF file. Click here for instructions.

9.0.0.2.20120627.2.874785