Limited_Sources_Justification_TFBSO_Audit_FINAL-Redacted.pdf

LIMITED SOURCE JUSTIFICATION

FOR FEDERAL SUPPLY SCHEDULE (FSS) AWARD (FAR 8.4)

Washington Headquarters Services, Financial Management Directorate

TASK FORCE FOR BUSINESS & STABILITY OPERATIONS PERFORMANCE (CLOSURE)

AUDIT SUPPORT

1. Contracting Agency and Activity. The Washington Headquarters Services Acquisition Directorate, on behalf of its Financial Management Directorate (FMD)

2. Nature of Action Being Approved. This document sets forth the justification and approval to contract by means other than full and open competition. Moreover, WHS AD intends to restrict competition to four (4) small businesses and ultimately award a single competitive task order under the GSA Financial and Business Solutions (FABS) Schedule, SIN 520-7, Financial and Performance Audit services.

Re: FAR 8.405-6.

3. Description of Services. This requirement is for an independent closure audit of the Task Force for Business and Stability Operations (TFBSO) supporting Afghanistan in order to provide validated and fully supported forensic documentation of TFBSO’s operations from inception to closure (FY2011 through FY2014).

Background: The Task Force for Business and Stability Operations (TFBSO) to support Afghanistan began operations in FY2011. The mission was to create economic opportunities for the people of Afghanistan. Through these activities and by working with dedicated teams of both U.S.

Government and business leaders in support of the economic line of operation, the Task Force was expected to deliver economic development capabilities in an agile and efficient manner in order to enhance and accelerate reconstruction efforts.

The legislative authority for this mission expires on December 31, 2014. Operations have been extended to March 31, 2015 to accommodate the orderly closure of TFBSO. As a result, a closure audit is necessary to verify compliance with the authorities granted in the original legislation and subsequent legislative authorities enacted which extended the activities of the program.

The review will be based on legislative authorizations and financial documentation focused on the financial aspects of TFBSO operations. The results of the examination report will be used to validate compliance with legislative and fiscal guidelines. Further, the report resulting from this effort provides a summary and detail document to respond to audit or other formal inquiries from government activities which assisted TFBSO throughout its operation.

Scope: The overall project and scope of this requirement is to examine program documentation, supporting the operational and financial aspects of TFBSO to ensure they were compliant with legislative and fiscal guidelines. The contractor will be required to review documentation to see that TFBSO financial transactions were conducted in accordance with the National Defense Authorization Acts for FY 2011 through FY 2014 and with DoD fiscal guidance in applicable directives, regulations, or applicable policy memoranda. In addition, the contractor will review audits of TFBSO which were conducted by the Special Inspector General for Afghanistan Reconstruction (SIGAR).

The Government requires a team of auditors with at least one Certified Public Accountant (CPA) to complete this audit no later than 31 March 2015. Auditors must have experience in conducting audits for the Department of Defense.

4. Estimated Dollar Value. $505,600

5. Statutory Authority. FAR 8.405-6 (a) (1) (A), “An urgent and compelling need exists, and following the procedures would result in unacceptable delays;”

6. Rationale Supporting Use of Citation in No. 5. The TFBSO mission is a high profile activity with direct national defense implications and close Congressional oversight. TFBSO operations have been authorized year by year in the annual National Defense Authorization Act (NDAA) based upon tactical and strategic assessments of the National Command Authorities and Theater Commanders. It is now clear that no decision will be taken to extend TFBSO operations for another year, in fact and as of the date of this document, no NDAA has been enacted for FY2015 to confirm this fact and we have no choice but to proceed with closure. All audit work must be complete by March 31, 2015 which precludes employing the normal lengthy competitive process for contracts.

TFBSO operations have been extended to March 31, 2015 to accomplish an orderly closure of the activity. Audit activities will have to be conducted parallel with operational closure in order to assure access to the personnel and documents, audit work must begin before the end of first quarter FY2015 and finish before the end of second quarter FY2015.

Closure must begin immediately to meet the expiration of the Mach 31, 2015 extension period.

Audit work must be conducted concurrent with the operational closure of TFBSO in order to meet Congressional reporting and testimony requirements.

7. Other Information.

A closure audit must be performed to assure leadership that information reported to Congress, in particular the financial activities, are supportable by validated forensic documentation. Time constraints require the audit to be performed concurrently with the operational closure.

These records must be available to the affected commands and activities, WHS and its service community are included, for the audits and/or agreed upon procedure reviews to be conducted in the third quarter of FY2015. All audit work must be completed before the end of the second quarter to meet this firm audit timeline. Without this audit, the risk to a successful DoD audit of the activities increases to an unacceptable and unmanageable level.

8. The Efforts to Identify Additional Sources Including the Market Research Conducted. Market research was conducted by posting a sources sought synopsis to the Government Point of Entry (www.fbo.gov). The market research requested information to best support an expeditious decision to meet the firm program deadlines performance requirements. Additionally, respondents to the market research were asked to provide tailored capability statements addressing the particulars of the proposed effort, with appropriate documentation supporting claims of organizational and staff capability and a statement attesting to the firm’s independence of all material aspects of the TFBSO to include any affiliation with any prime or subcontractor related to the TFBSO.

Due to TFBSO’s expectancy to dissolve completely by 31 Mar 2015 the requirement needs to be completed prior to this date. As a result of this market research and the urgency associated with meeting program deadlines, the Contracting Officer (CO) has determined to procure this http://www.fbo.gov/ requirement on a restricted basis to the four (4) small businesses who responded to the sources sought synopsis. Therefore as a Small Business Set-Aside, Labor Hours Task Order under the GSA Financial and Business Solutions (FABS) Schedule, SIN 520-7, Financial and Performance Audit. The CO will ensure that the final negotiated price under this task order is fair and reasonable in accordance with applicable FAR, DFARS, and other agency guidance.

9. Actions to Overcome Barriers to Competition. This procurement is expected to be a one-time requirement to meet a specific, short-term need. Therefore actions to increase future competition are not likely because there are no planned acquisitions for, or related to, this requirement; and none are likely to develop. However, should the need arise to procure future acquisitions of a similar nature, the market research suggests this type requirement is prime for future competition and the information garnered from this procurement will be used to formulate definitive requirements for a competitive firm-fixed priced arrangement in accordance with the applicable DoD guidance.

10. Posting Requirements. Upon award, the Contracting Officer will meet the requirements of FAR 8.405-6(2) including any exceptions taken.

11. Recommendation and Certification from Program Office Based on the above, I recommend this acquisition be conducted on a limited source basis. I certify that technical data which form a basis for this justification, that are the responsibility of technical or requirements personnel are complete and accurate.

Assistant Director Date

Accounting, WHS/FMDA

11. Certifications and Approval from the Contracting Officer:

a. I have determined that the order represents the best value to the Government consistent with FAR 8.404(d) based on the information contained in this justification and other information available in the contract file.

b. This justification is accurate and complete to the best of my knowledge and belief.

12. Approvals

Reginald O. Solomon Date Contracting Officer