FAR Part 8 LSJ (GRB-Lentech).pdf

LSJ Number: IQ I500-21-IQ-00012

LIMITED-SOURCES JUSTIFICATION FOR FEDERAL SUPPLY SCHEDULE

PROGRAM

Upon the basis of the following justification, prepared in accordance with Federal Acquisition Regulation (FAR) 8.405-6(c), I, as Contracting Officer, hereby approve the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3 pursuant to the authority of 41 U.S.C. 251 as implemented by FAR 8.405-6(a)(1)(i) (B). This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C. 251, et seq.

and 40 U.S.C. 501).

1. Identification of the agency and the contracting activity.

The requiring activity is the United States Agency for Global Media, Office of Human Resources. The contracting activity is the U.S. Agency for Global Media, Office of Management Services, Office of Contracts, Washington, D.C.

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

This acquisition is conducted under the authority of the Multiple Award Schedule Program (Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.) and Title 40 U.S.C. 501, Services for Executive Agencies). This is a limited source action to be awarded as a new Task Order from Federal Supply Schedules.

The placement of a firm fixed price order is anticipated.

3. A complete description of the supplies and/or services required to meet the agency’s needs.

The U.S. Agency for Global Media (USAGM) has a requirement to establish a web-based employee benefits enrollment and administration system. This system shall provide the retirement and benefits management core functions to the HR Line of Business (HRLoB).

The software shall combine native tools and capabilities for human resource specialists, managers, and employees into a common system. The application will bi-directionally communicate and integrate with the Agency’s payroll system, the human resource information system (HRIS), third-party benefits providers, and any other outside parties as necessary.

The requirement consists of three main separate and distinct aspects:

1. Hosting services and deliverables, Infrastructure - Hosting of the application hardware and associated Infrastructure as a Service (IaaS) in the Amazon Web Services Federal Risk and Authorization Management Program (FedRAMP) certified U.S. Government (USG) Private Cloud.

2. Hosting services and deliverables, Software & Middleware - The hardware, software, and middleware needed to host the application operating in a Software as a Service (SaaS) model.

In this model, it is assumed that the contractor will manage all hardware, software, and middleware associated with the implementation of the application, which will include the operating system software, database software, associated patches, and necessary middleware.

3. Federal Information Security Management Act (FISMA)/Federal Risk and Authorization Management Program (FedRAMP) compliance and deliverables - The contractor shall support the Security Assessment and Authorization (SA&A) of the software via continuous updates to the IT Security Continuous Monitoring records as defined in the Authorization to Operate (ATO) of the system overall. The contractor shall arrange for an Independent 3rd part Security Test and Evaluation (ST&E) and penetration (Pen) testing of the Platform, hosted production and test environments and produce an updated Security Assessment Report (SAR) from this audit for USAGM consumption. The contractor will also be responsible for updating any previous FISMA documentation deliverables with findings stemming from the ST&E-SAR & Pen Testing effort. The assessments (ST&E & SAR) will be repeated on an annual basis.

From within the FedRAMP approved Amazon Web Services USG Federal Private Cloud Environment, the contractor shall provide both a Production and a Development (test) environment for the platform. Further, the contractor shall provide the set-up/creation, continuous support, and management of all necessary data interfaces and interconnections – middleware – between the hosted environment, containing the platform, and the necessary third party environments. Additionally, the contractor shall provide database scanning/auditing services, to include periodic penetration testing to be conducted via an independent third party. Lastly, the contractor shall create, and support the development of any, and all necessary IT Security Accreditation and Certification Package(s), documents, and/or artifacts necessary for FedRAMP documentation as it relates to necessary FISMA compliance (further defined in the Security Assessments and Authorization Support & Information Security section of this document).

4. An identification of the LSJ rationale, and if applicable, a demonstration of the contractor’s unique qualifications to provide the required supply or service.

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.

Due to the operational business adaptions forced by the COVID-19 pandemic, USAGM now requires a secure and reliable means to electronically provide and manage a Federal benefits enrollments system. At current, most of the Agency’s workforce remains as a remote worker, and for a substantial number of Agency employees, remote work will become the expected standard for employment at the Agency. In order to extend a comprehensive service delivery model to the employee, the Agency must adopt the Government Retirement and Benefits (GRB) platform, as it is the only known and approved Office of Personnel Management (OPM) HR Line of Business (LoB) approved

Federal benefits platform that integrates with USAGM’s current HR system. In order to deliver the hosting of the platform, the Agency requires, Lentech, Inc. to provide the hosting services of the GRB platform. Currently, Lentech hosts and manages the Agency’s time and attendance system which automatically integrates with the Agency’s Department of Defense payroll provider, the Defense Finance Accounting Service (DFAS). Lentech has the necessary hosting security accreditation(s), and critical knowledge base of the DFAS interface protocols, knowledge that ultimately enables the contractor to support the Agency’s systematic connectivity, framework, and architecture;

allowing for interconnections with mission critical data systems. The knowledge, Lentech possesses of payroll integration requirements, will be critical in understanding and efficiently completing the requirements necessary to connect to the Agency’s HR information system, DCPDS, OPM data repositories, and third party benefits providers.

The Government’s expectation is that the vendor’s working knowledge affords a likely reduction in undue delays due to knowledge gaps during the implementation phase of the project.

Additionally, Lentech is currently providing Agency time and attendance hosting services within an Oracle database and application, similar to the requirements necessary for GRB hosting. As a result, the Government would be able to efficiently deploy this platform within a timetable with respect to other ongoing, mission critical projects that would be impacted by this effort. Further, other cost savings would be realized, as they relate to the Security Assessment and Authorization (SA&A) Support of the hosted platform due to the similarities observed within the hosting location of the time and attendance system.

For the aforementioned reasons, Lentech Inc. is the only vendor that currently possesses the necessary knowledge of Agency technical infrastructure and would assure the Government a reduction in duplicative efforts, thereby reducing the overall project costs and timeline to implement the service.

5. A determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d) and FAR 8.405-2(d).

GSA has already determined the prices of supplies of the schedule contracts to be fair and reasonable. The USAGM Contracting Officer will determine, using the procedures in FAR 8.405, that the order represents the best value and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government's needs. The Contracting Officer will also seek additional discounts before placing the order.

6. A description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted. A statement must be made that the supplies and services are available from the FSS.

The Office of Contracts Contracting Officer and the requiring activity Program Manager conducted market research for this requirement via Federal Supply Schedule holders. The results of market research indicate that the services are available via the Federal Supply Schedules.

7. Any other facts supporting the limited source justification.

Technical personnel who provided supporting data, which forms the basis for this justification have certified that the information is complete and accurate. This procurement uses a GSA Schedule and will be solicited and awarded in accordance with FAR Subpart 8.4.

8. A statement of the actions, if any, the agency will take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for supplies and services is made.

It is unlikely that additional sources for this service will become available. However, USAGM will work to identify any other potential sources that could meet the requirement in the future. If additional sources, which provides the same support becomes available, USAGM will conduct an open competition for future requirements.

9. 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 and evidence that the supporting data that form a basis for the justification have been certified as complete and accurate by technical/program personnel.

Certification

Acquisition Initiator:

I certify that the facts and representations under my cognizance, which are included in this justification and which form a basis for this justification, are complete and accurate.

Name Date

Contracting Officer:

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

Name Date