FBO_FEPP_Support_Staff_Bridge_Justification_and_Approval.pdf

Justification and Approval for

Other Than Full and Open Competition

1. Contracting Activity: Procurement Support Office (PSO), Defense Human Resource Activity, 4800 Mark Center Drive, Suite 07G12, Alexandria, VA 22350-1300.

2. Authority By Statute(s): 10 USC 2304(c)(1), FAR 6.302-1 – Only One Responsible Source and

No Other Supplies or Services Will Satisfy Agency Requirements.

3. Description of Services: The Government has a requirement for a bridge contract to provide personnel and support services for the Family and Employer Programs and Policy (FEPP) Full

Time Support Program within all 50 States, Territories, and the District of Columbia. This bridge is limited to 120 days to ensure coverage during the protest period and to allow for a brief transition period if required after GAO renders their decision. These services are critical to prevent the loss of essential productivity supporting three key Department of Defense (DoD)-wide missions:

o Yellow Ribbon Reintegration Program (YRRP): Promotes the well-being of National

Guard and Reserve members, their families, and communities by connecting them with resources throughout and beyond the deployment cycle. This congressionally mandated program has impacted the readiness, resilience, and reintegration of more than 1.6 million

Service members and families since 2008.

o Employer Support of the Guard and Reserve (ESGR): Through its nationwide network of more than 4,600 volunteers, develops and promotes supportive work environments for

National Guard and Reserve members through outreach, recognition, and educational opportunities that increase awareness of applicable laws and resolve employer conflicts.

ESGR influences more than 145,000 employers, briefs more than 400,000 Service members annually. ESGR also addresses more than 16,000 Uniformed Services Employment and

Reemployment Rights Act (USERRA) inquiries and mediates more than 2,300 USERRA cases each year with a 77% resolution rate.

o Employment Initiative Program (EIP): Through its program entitled Hero2Hired (H2H), supports the readiness, retention, and reintegration of National Guard and Reserve members and spouses by actively identifying and engaging in employment-related policies and initiatives; enhancing individual career readiness; matching National Guard and Reserve members with employment opportunities; and facilitating access between employers and supported job seekers. H2H results in 9,259 direct hires every year.

These three programs are mandated by statute, regulatory guidance, and policy:

YRRP: Public Law (PL) 110-181, Sec. 582, as amended by PL 111-383, Sec. 583 and PL 114-92, Sec. 551; DoD Instruction 1342.28, DoD Yellow Ribbon

Reintegration Program

ESGR: 38 USC, Chapter 43 (pertaining to USERRA); DoD Directive 1250.01, National Committee for Employer Support of the Guard and Reserve; DoD

Instruction 1205.22, Employer Support of the Guard and Reserve; DoD Instruction

1100.21, Voluntary Services in the DoD; DoD Instruction 1205.12, Civilian

Employment and Reemployment Rights of Applicants for Service Members

(pertaining to USERRA)

EIP: PL 110-181, Sec. 582, as amended by PL 111-383, Sec. 583 and PL 114-92, Sec. 551

4. Description of Action: A firm fixed price bridge contract of 120 days is planned with a total estimated value of $ 5.2 Million. This performance period encompasses the GAO protest review period.

5. Reason for Authority Cited: Interactive Government Holdings (IGH) is the only vendor that can immediately satisfy the staffing requirement for 170 trained Full Time Support contract personnel dispersed in all 50 states, three U.S. territories, and the District of Columbia. Awarding a sole source bridge contract to IGH prevents a gap in service for the government. These services must continue and only IGH can perform the required services. To hold a competition would take, at a minimum, 180 days. The solicitation and evaluation process would take at least 90 days. Once an award is made, it would take an additional 45 days to bring staff on board, assuming a vendor could find 170 FTEs willing to accept a short term position. Based on previous programmatic experience, prospective employees will not sign-on for short-term periods of employment. The financial loss of productivity during a 45-day start-up of a vendor other than the current incumbent amounts to approximately $1.5 million dollars. Given the nature of a

120-day bridge, it is highly unlikely that a staff of 170 FTEs could be recruited, trained, and fully operational in support of the FEPP mission. By then, GAO would have rendered their decision.

A gap in service will have negative consequences for Reserve Component Service members and their families as outlined below. Award to a vendor other than IGH would disrupt the current contract productivity and momentum. Allowing a sole source bridge to the current incumbent allows critical deployment cycle support, reintegration, employment, and employer support services for Reserve Component members and their family members to continue.

o This contract impacts the overall ability of DoD to address the unemployment, under employment, reintegration, and USERRA rights concerns of Service members and their families; specifically:

YRRP: In terms of deployment readiness and reintegration, there are currently 22,700 activated National Guard and Reserve members around the globe supporting our national security interests. In 2008, Congress directed that YRRP – which is facilitated by contractors under this procurement – be responsible for successful Reserve

Component deployment cycle support and reintegration activities. Further, the contracted support provides each of the Reserve Components (Army National Guard, Army Reserve, Marine Corps Reserve, Navy Reserve, Air National Guard, Air Force

Reserve, and Coast Guard Reserve) with YRRP expertise designed to ensure consistent, high quality programs across all Services. Loss of the contracted full-time support staff will significantly limit the Services’ ability to conduct and evaluate congressionally mandated Service member and family readiness and reintegration events. On average, during a 120-day period, over 350 events are conducted that engage 31,800 Service members and their families. In addition, YRRP directly supports suicide prevention at each of its events throughout the deployment cycle. YRRP provides the one and only venue that allows National Guard and Reserve commanders to provide travel reimbursement to family members for their attendance. Thus, making it a unique and critically important tool in support of Service member and family well-being.

ESGR: ESGR carries out the mandates of USERRA by providing neutral, informal mediation for Service members and their civilian employers. During the course of an average 120 days, more than 4,400 USERRA inquiries and 650 USERRA cases are conducted by ESGR volunteer Ombudsmen and the national call center, which are supported by full-time staff provided through this contract. ESGR mediation results in

77% resolution rate within an average of nine calendar days, keeping many cases from routing to the Department of Justice (DOJ) or the Department of Labor (DOL) for formal resolution. Over the course of a year, these successful resolutions save the

Federal government $6.1 million (approximately $1.67 million over 120 days) through cost avoidance. The goal is to informally resolve cases within 7-14 calendar days depending on the type of USERRA issue involved (i.e. job termination case). For

ESGR’s outreach mission, during an average period of 120 days, the following metrics apply:

Events conducted: 1,755

Employers influenced: 39,800

Service members briefed: 113,558

ESGR Statements of Support obtained from civilian employers: 13,724

Employers recognized:

Patriot Awards presented to first-line supervisors: 2,873

Secretary of Defense Employer Support Freedom Award nominations; 2,864

(note: the nomination season for the Freedom Award is from 1

OCT-31 DEC. A break in service which would have a significant negative impact on the entire award program)

Volunteer support impact: In FY2014, ESGR volunteers documented 242,848 hours, which provided a return on investment of $5.74 million. Therefore, during a period of 120 days, 66,533 volunteer hours (equivalent to $1.5 million return on investment) may not be executed or documented due to a lack of administrative and logistical support.

EIP: EIP provides support to National Guard and Reserve members in the form of employment case management through the full-time support staff provided by this contract. Among 18-24 year old Service members, unemployment rates have dropped from 22% down to 14.5% over the past three years. However, this rate is still above the national average of 11.3%. Over the course of an average 120 days, EIP places 1,780 direct hires through the contracted full-time staff, their case management efforts, and the program’s established network of supportive employers. These efforts are vital to the maintenance of the All-Volunteer Force, as National Guard and Reserve members who cannot obtain or keep meaningful civilian employment are unlikely to remain in the

Service.

Without this sole source bridge of 120 days the following are potential consequences:

o In short, a break in performance will dismantle years of effort to build an effective partnership of programs that support and depend upon a variety of stakeholders, ranging from local ESGR volunteers to state governors, Federal agencies, and private industry.

These stakeholders rely upon YRRP, ESGR, and EIP as conduits to our National Guard and Reserve members, and the full-time support staff provided under this contract is the day-to-day linchpins of these programs in the field.

o A break in service is likely to cause significant attrition as the seasoned full-time staff seeks other employment. By virtue of the work they do and the networks they maintain, these staff members can avail themselves of other opportunities in short order.

Following the stay, these key vacancies will require time to fill and even more time to return to the full performance level.

o Following is a listing of many of the specific negative impacts a break in performance will cause. It is, by no means, an all-inclusive list, but provides some insight as to the magnitude of the impact:

Consistent conduct and support of YRRP events will be hampered, directly impacting the readiness and resilience of Service members and families preparing for deployments around the globe; post-deployment reintegration events will also be impacted, resulting in decreased opportunities for Service members and families to address critical concerns that could have long-lasting physical and behavioral health impacts. The YRRP Full Time Support staff members are the primary points of contact for distribution of policy, curriculum, marketing materials, and online tools from the DoD-level staff to the Services. They also provide direct feedback from

Service-level training events and deployment cycle support events in support of the

YRRP Center for Excellence (CfE) mission. Their input allows the CfE to accomplish its statutory mission to collect, evaluate, and propagate best practices in reintegration programs across DoD. The CfE also serves as the repository for lessons learned from current conflicts to inform decisions and resource requirements for the activation of Reserve Component forces in future conflicts.

Number of direct hires generated through EIP will decrease, and it is anticipated unemployment rates will increase throughout the National Guard and Reserve.

Employment Coordinators are a direct link between employers with job vacancies and job-seeking Reserve Component members within each state. Employment

Coordinators conduct outreach to employers and job seekers on a daily basis. Their services include career counseling, resume writing, interviewing skills, and skill matching. Over 120 days, they average 104 resume rewrites, 208 career counseling sessions, and 40 skill-matching mentoring sessions with employers and job seekers.

All information-gathering activities via the case management system will cease, impacting the overall mission and ability to report outcomes to senior DoD leadership. Employment Coordinators also conduct in-person outreach to Reserve

Component units during weekend training assemblies, reaching more than 1,000

Service members over 120 days. They also work with more than 220 employers over each 120-day period to assist them in loading job vacancies into the Department of

Veterans Affairs (VA) Veterans Employment Center web portal. In addition to the

VA, other partner agencies that depend on consistent services from the Employment

Coordinators will be negatively impacted. The initiative to tie the DOL American Job

Centers with Employment Coordinators to match the skills of unemployed Service members with their database of employers will be delayed. The ongoing effort to connect Service members with the USO’s Transition 360 Alliance will also be delayed. Both the DOL and USO efforts are force multipliers that will assist

Reserve Component members in remote areas; a break in the Employment

Coordinators’ performance will have a significant negative impact on these high visibility initiatives and the momentum they have achieved. Given the current rate of monthly job placements, approximately 1,780 Service members will not have the advocates they need to connect with employers over a 120-day period.

Full Time Support staff members are often the first contact for Service members and employers with USERRA inquiries. They, in turn, determine the availability of volunteer Ombudsmen, refer inquiries to the volunteer Ombudsmen in a timely fashion, and monitor case progress; ensuring cases are addressed within the 7-14 day timeline established by Headquarters, ESGR. Without full-time staff, case referrals and monitoring will cease. Volunteer Ombudsmen will be hampered in their ability to mediate USERRA cases; cases would then be referred to the Department of Justice or

DOL for formal resolution, taking an average of 45-90 days to resolve.

Day-to-day operational support and continuity for the majority of the state committees and offices will cease without Full Time Support presence; ESGR is a volunteer-based program and depends on full-time staff to provide daily management and coordination of tasks. The full-time staff members are the people who answer the calls, respond to emails, and conduct typical office functions at the Service and state levels in support of the FEPP mission. Turning to volunteers is not a viable option because of the limited availability of a typical volunteer, their lack of access to

DoD systems (i.e. CAC-enabled systems), and limited situational awareness of ongoing projects, key contacts, and standard operating procedures, causing committees to operate at a greatly diminished level.

Ongoing projects within YRRP, ESGR, and EIP will be delayed and could be completely derailed; all three programs are connected to the Administration’s efforts

(i.e. Joining Forces) to support Service members and families and, as a result, will be unable to maintain steady operations. Full Time Support staff serve as the primary point of contact for program activities at the Service, regional, and state levels.

Examples of their efforts include, coordination of ESGR sub-committee nominations;

coordination of volunteer travel (i.e. Defense Travel System orders, itineraries, vouchers); Volunteer of the Year nominations; coordination and conduct of new member orientation; oversight of the volunteer awards program; ordering of marketing and training collateral; oversight of the employer awards program;

management of the YRRP “EventPLUS” web portal; frequent (approximately 2,105 per 120-day period) event planning and coordination (e.g. “Bosslifts,” annual planning and award meetings, “Breakfasts with the Boss,” executive committee meetings, YRRP events and training, hiring fairs, Society for Human Resources

Managers conferences, chamber of commerce meetings, speaking engagements, “Statement of Support” signing events, “My Boss is a Patriot” award presentations, etc.); submitting volunteer identification card applications; monitoring and reconciling state General Fund Enterprise Business System accounts with the U.S.

Property and Fiscal Officer; maintaining state website content and social media platforms; and serving as liaisons with the Reserve Component units in each state.

Metrics gathering and reporting for DoD and congressional requirements will be compromised, resulting in incomplete or inaccurate information for senior leaders to use in decision-making and policy development. Required routine reports compiled and submitted by Full Time Support staff, from which senior-level reports are developed, will cease because the Full Time Support Staff collect and organize the information before applying the data to generate the reports. Examples of routine reports include, Planning-Evaluation- Performance Reporting System (provides real-time performance data for all aspects of ESGR’s mission, including military outreach, employer outreach, ombudsmen services, volunteer participation, funding execution, etc.); Annual Spending Plan (provides the annual, phased spending plan in accordance with the budget guidance provided by Headquarters, ESGR); Request for

Funds (provides data on emerging spending requirements that deviate from the

Annual Spending Plan to inform Headquarters, ESGR, budgetary decisions); Event

Request (request Headquarters, ESGR, approval to expend funds in support of state committees’ operational activities); YRRP Quarterly Report (provides roll-up of attendee and event demographic data from each Service to the YRRP CfE); Employer

Coordinator Case Management Report (provides real-time data on job seekers and employers, to include Defense Manpower Data Center information, that allows

Employment Coordinators to manage Service member contact history, resumes, etc.);

Employment Coordinator Roll-Up Report (provides number of career counseling sessions, resume assistance, job referrals, Service members and employers contacts, direct and indirect hires, etc.); and Member Management System (contains volunteer contact information, hours, training, awards, positions, and qualifications).

Processing and review of the Secretary of Defense Employer Support Freedom

Award (the Federal government’s highest honor for employers’ support of their

National Guard and Reserve employees) nominations will be severely curtailed

(nomination season is 1 OCT-31 DEC, review season is 1 JAN-12 FEB). Full Time

Support staff coordinate the efforts of the state committees to vet, edit, rank, and submit the state committees’ nominations for consideration to the National Review

Board. Duties include outreach to Reserve Component units and points of contact to gather nominations, cross-checking employers nominated for accurate information and previous award recipient status, and coordination with Headquarters, FEPP, and staff to prepare certificates of nomination for more than 2,000 nominees each year.

Failure to gather, edit, vet, and submit these nominations will compromise the entire award process that historically garners Secretary of Defense attendance and White

House participation (through the hosting of award recipients and declaration of ESGR week via Presidential proclamation).

These programs have the interest of state and national leadership (e.g. Governors, state Adjutants General, Reserve Component Chiefs, members of Congress); a break in performance will generate significant turmoil amongst these stakeholders. These stakeholders routinely contact the full-time staff for assistance and information; a gap in service will leave those requests for assistance and information in limbo, raising the issues to the headquarters level and placing an additional burden on an already depleted headquarters staff.

Retention of National Guard and Reserve members is anticipated to decrease; history has shown that if a member’s participation is an impediment to attaining or retaining civilian employment they will leave the National Guard or Reserve. The Full Time

Support staff coordinates and support the work of volunteers who mitigate retention issues through military outreach, employer outreach, and ombudsman services.

Military and employer outreach and education events will decrease without the administrative support of the full-time staff. Full Time Support staff plan events, process the travel orders/vouchers, track the volunteer hours, and provide the logistical support that facilitate volunteer participation, upon which these outreach events rely and could not occur without the full-time staff actions.

Collaborative relationships with state and Federal agencies that exponentially expand our offerings will be put at risk; these stakeholders (e.g. DOL, VA, Reserve

Component Chiefs, state Adjutants General, etc.) will doubt our reliability to provide consistent services. Without Full Time Support manning, there will be no consistent, reliable point of contact for these organizations to call upon to access

FEPP programs at the state level.

Collaborative relationships with non-government organizations (e.g. U.S. Chamber of

Commerce, USO, Society for Human Resources Managers, veterans service organizations, Blackstone Group, etc.) will be put at risk; the mutually beneficial work being conducted in support of Service members and employers will be jeopardized. Without Full Time Support manning, there will be no consistent, reliable point of contact for these organizations to call upon to access FEPP programs at the state level.

Established employment networks, which rely heavily on long-term, professional relationships, will be severed because there will be no Employment Coordinator in place to maintain and build them.

A break in service of the Full Time Support contract will result in a very obvious cessation of support activity (as detailed above) for ESGR volunteers, Service members, families, and employers. Due to the nature of FEPP’s network of volunteers, some of whom are influential members of their local and state communities, combined with the impact of these programs on Service members, families, and employers, the potential for both media and political interest and probability of attempted intervention is real; the ensuing inquiries could burden an already depleted headquarters staff.

6. Effort to Obtain Competition: The bridge requirement is being awarded to IGH. A notice of the

Government’s intent to award on a sole source basis for this bridge requirement will be posted on the Federal Business Opportunities website (fbo.gov).

7. Effort to Remove Barriers To/Increase Competition: Competition was received on the initial solicitation. A competition is not viable for this bridge because these vital services need to continue and only one contractor can perform the work.

8. Market Research: N/A

9. Interested Sources: Interactive Government Holdings (IGH). IGH holds the current contract for FEPP’s Support Staff requirement. IGH is the only source capable of performing for the

120 day bridge contract and has a proven record of support within its current contract obligation and demonstrates the competencies and financial strength to assume the size of the required

FEPP contract.