JA_v5 Redacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION > SAT

Sole Source

Credit Recommendation Services American Council on Education

HS0021-20-Q-0001

Control Number: 20-02JA

FOR OFFICIAL USE ONLY

PROCUREMENT SENSITIVE

SOURCE SELECTION SENSITIVE

REFERENCES:

• In accordance with FAR 6.303, for acquisitions of commercial items exceeding the simplified acquisition threshold the contracting agency is required to prepare a sole source justification using the format at FAR 6.303-2, as provided below.

DOCUMENTATION:

(1) Identification of the agency and the contracting activity.

Requiring Activity Defense Counterintelligence and Security Agency (DCSA) Center for Development of Security Excellence (CDSE) 938 Elkridge Landing Road Linthicum, MD 21090

(Legacy) National Background Investigation Bureau (NBIB) National Training Center (NTC) 133 Rebecca Lane Slippery Rock, PA 16057

Contracting Activity

DCSA Office of Acquisitions (AQ) 27130 Telegraph Road Quantico, VA 22134

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

The purpose of this document is to obtain necessary approvals for a sole source acquisition in accordance with FAR 6.302- 1(a)(2)(iii). Competition is limited to only one responsible source and no other supplies or services will satisfy agency requirements.

The procurement strategy is to issue an open market Request for Quote in accordance with FAR Part 12 Acquisition of Commercial Items and FAR 13.5 Simplified Procedures for Certain Commercial Items.

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The CDSE Education Division currently offers a security curriculum comprised of 17 advanced and graduate-level courses designed specifically to develop leaders for the Department of Defense (DoD) security community. Additionally, legacy NBIB has two courses, taught by the National Training Center (NTC), which also supports the development of leaders for DoD security community.

As part of DCSA’s continuing effort to increase the professionalization of the security community, it is essential that individuals who successfully complete certain courses also have the benefit of receiving credit recommendations that may be accepted as college credit equivalents at certain colleges and universities.

Credit Recommendation Services American Council on Education

HS0021-20-Q-0001

Control Number: 20-02JA

FOR OFFICIAL USE ONLY

Contractor support services are required to assist DCSA to obtain college credit recommendations for courses it has developed as part of its security curriculum. Current services are being provided, on a sole source basis, by the American Council on Education (ACE) under contract HS0021-15-P-0008, which expires December 31, 2019. Legacy NBIB recently awarded contract HS0021-19-P-0025, with a one year period of performance beginning July 1, 2019 through June 30, 2020. The contract was fully funded to support the one year performance period. Consequently, the legacy NBIB requirement is being consolidated with the CDSE effort and will be executed as a single sole source action.

Estimated Dollar Value:

The total estimated price for this acquisition is $274,325.83 (average cost of Independent Government Cost Estimate (IGCE)).

The estimated base period of performance is $37,761.83. The period of performance is for a 12-month base period (CDSE portion) and a six-month base (legacy NBIB portion) plus four 12-month option periods.

This requirement will be funded using Fiscal Year (FY) 2020 Operations & Maintenance ((O&M) (Appropriated Funds)) for the CDSE portion for a base period of January 15, 2020 through December 31, 2020. Working Capital (Non-Appropriated) funding will be provided by legacy NBIB to support the six (6) month base period of performance, beginning July 1, 2020 through December 31, 2020.

(4) An identification of the statutory authority permitting other than full and open competition.

10 U.S.C. 2304(c) authorizes the Department of Defense (DoD) to contract without full and open competition under certain circumstances. For this acquisition, other than full and open competition is permitted per FAR 6.302-1. FAR 6.302-1 states that “When the supplies or services required by the agency are available from only one responsible source, or, for DoD, NASA, and the Coast Guard, from only one or a limited number of responsible sources, and no other type of supplies or services will satisfy agency requirements, full and open competition need not be provided for.”

ACE has provided college course recommendation services in the past to CDSE under contract HS0021-11-P-0143 and currently under contract HS0021-15-P-0008. Identical services are being provided to legacy NBIB via the NTC under contract HS0021-19-P-0025. Consequently, the consolidated procurement of the existing services represents the most cost effective approach for DCSA and an operational impact and degradation of services could result if this effort is competed. A sole source award to ACE will ensure continuity of operations without interruption.

(5) A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

CDSE conducted an extensive study of accrediting agencies, finding three organizations that provide regulatory evaluations:

American Council on Education (ACE), Council on Occupational Education (COE), and National College Credit Recommendation Service (NCCRS). The Council on Occupational Education (COE) accredits post-secondary occupational institutions, but does not offer college credit recommendations to students. COE has a focus in the trade skills and can recommend credit for certifications in those trade skills, but CDSE requires an organization that can recommend higher education credits. The National College Credit Recommendation Service (NCCRS) is affiliated with University of the State of New York and the New York State Education Department. The NCCRS does not offer vocational credit recommendations which represents many of the CDSE training division courses that are closely aligned with job performance requirements. The NCCRS has limited experience evaluating federal government training and education programs. Their list of organizations does not include those that provide security training and education offerings similar to CDSE. Additionally, NCCRS is regionally aligned, while CDSE requires an organization that is spread nationally, allowing full use of the credit recommendations by students at a diverse set of colleges and universities. ACE is the only major higher education association to represent all types of US accredited, degree-granting, public and private institutions. ACE has extensive experience and member organizations who

Credit Recommendation Services American Council on Education

HS0021-20-Q-0001

Control Number: 20-02JA

FOR OFFICIAL USE ONLY

offer security training and education programs similar to CDSE. Their experience in evaluating defense security training and education programs allows for CDSE curriculum to be evaluated by subject matter experts in defense security. It is critical that any organization selected provide college credit recommendations and have experience in reviewing course content used in the defense security industry.

As previously mentioned, ACE is currently providing college course recommendation services DCSA (CDSE and legacy NBIB). A consolidated contract for existing services represents the most cost effective approach for DCSA. A sole source award to ACE will ensure continuity of operations without interruption.

(6) A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies.

The Contracting Officer will follow the procedures in FAR 5.201 and FAR 6.305 in ensuring a Synopsis and the Justification required by 6.303-1 are properly completed. An open market Request for Quote (RFQ) will be issued to American Council on Education in accordance with FAR part 12 Acquisition of Commercial Items and FAR subpart 13.5 Simplified Procedures for Certain Commercial Items.

(7) A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The following is a high-level Government cost estimate: $282,257.50 for a period of performance of a 12-month base period (CDSE portion) and a six-month base (legacy NBIB portion) plus four 12-month option periods.

Contractor

Base Year

FY20

OY1

FY21

OY2

FY22

OY3

FY23

OY4

FY24

Total

ACE $42,321.50 $58,021.50 $61,921.50 $55,421.50 $58,021.50 $282,257.50

In determining a fair and reasonable price, the Contracting Officer will evaluate a more detailed breakdown from a formal Independent Government Cost Estimate (IGCE). The detailed estimate will provide the level of effort of individual service items identified above. The estimated price will be compared to established pricing on other Government contracts, such as the General Services Administration’s (GSA) Federal Supply Schedule (FSS) for similar services. Additionally, price comparisons will also be accomplished from as many other sources as possible, including commercially as well as any Government-Wide Acquisition Contracts (GWAC).

Based on market research, it is anticipated that open market pricing will be fair and reasonable.

Leveraging DSS’ current use of the Vendors services, along with open market price comparison, the contracting officer is confident in obtaining the best value for DCSA.

(8) A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

Market research was conducted using the ACE’s current published pricing in additional to the receipt of a market research quote and a Google search of agencies providing similar services. Although ACE is the sole provider for college credit recommendations, there are two other agencies researched, who provide similar services on the open market. The Council on Occupational Education (COE) and National College Credit Recommendation Service (NCCRS) wherein pricing was obtained via the published price lists on each agency’s website.

http://www.arnet.gov/far/current/html/Subpart%205_2.html#wp1107980 http://www.arnet.gov/far/current/html/Subpart%205_2.html#wp1107990 http://www.arnet.gov/far/current/html/FARTOCP10.html#wp266706

Credit Recommendation Services American Council on Education

HS0021-20-Q-0001

Control Number: 20-02JA

FOR OFFICIAL USE ONLY

(9) Any other facts supporting the use of other than full and open competition, such as:

The resulting analyst and market research is reflected in the table below:

Contractor

Base Year

FY20

OY1

FY21

OY2

FY22

OY3

FY23

OY4

FY24

Total

ACE $42,321.50 $58,021.50 $61,921.50 $55,421.50 $58,021.50 $282,257.50

COE $37,584.50 $52,684.50 $55,684.50 $50,684.50 $52,684.50 $255,872.50

NCCRS $33,379.50 $46,479.50 $46,479.50 $46,479.50 $46,479.50 $284,847.50

Total $113,285.50 $157,185.50 $164,085.50 $152,585.50 $157,185.50 $822,977.50

Average Cost $37,761.83 $52,395.17 $54,695.17 $50,861.83 $52,395.17 $274,325.83

Based on the results of the market research, competitors pricing for similar services is lower than the ACE pricing. However, as previously iterated, ACE is the only major higher education association to represent all types of US accredited, degree-granting, public and private institutions. Their experience in evaluating defense security training and education programs allows for DCSA’s curriculum to be evaluated by subject matter experts in defense security. Additionally, consolidation of the two efforts provides the Government with the efficiency of awarding one contract instead of the expense of awarding separate contracts to accomplish the same goal. A single contract for existing services represents the most cost effective approach for DCSA, other accrediting institutions do not meet the quality of ACE and an operational impact and degradation of services could result if another service is used.

(10) A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

Nothing to add to this section that has not already been articulated within this justification document.

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The total value of the previous requirement (HS0021-15-P-0008, valued at $53,850.00) was under the simplified acquisition threshold and did not include all J&A elements proscribed in FAR 6.303 as it was not required to under FAR 13.106-1(b)(1). As such, the market research detailed in this justification, in addition to the public posting of the Notice of Intent to Sole Source, demonstrates steps were taken to promote competition.

Credit Recommendation Services American Council on Education

HS0021-20-Q-0001

Control Number: 20-02JA

FOR OFFICIAL USE ONLY

HARPER.TWANA.E.12 Digitally signed by

29424803

HARPER.TWANA.E.1229424803

Date: 2020.01.09 18:41:56 -05'00'

CERTIFICATION

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.

Requiring Activity/Program Management Office Certification

Printed Name: John S. Hill

Title Education Division Chief Org. Code _ DCSA CDSE HILL.JOHN.S.1229 Digitally signed by HILL.JOHN.S.1229323233

Signature 323233 Date: 2020.01.09 16:23:13 -05'00' Phone Date

Contracting Officer Certification I hereby determine that the anticipated cost for this contract action will be fair and reasonable. I certify that this J&A is accurate and complete to the best of my knowledge and belief.

Printed Name: Twana E. Harper

Title Contracting Officer Organization Code DCSA-AQ

Signature Phone 410-689-1328 Date