HSCG23-15-D-PTT173JARedacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. 2304(c)(7)

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.3 and in accordance with the requirements of FAR 6.303-1, the justification for the use of the statutory authority under FAR Subpart 6.3 is offered with the following facts and rationale required under FAR 6.303-2 as follows:

1. Agency and Contracting Activity.

The United States Coast Guard (USCG), Office of Contract Operations, Formal Contracts Division I (CG-9121), proposes to modify contract HSCG23-15-D-PTT173 for support on a basis other than full and open competition.

2. Nature and/or Description of the Action being Approved.

The USCG has a requirement to continue the marketing and enrollment management support for the U.S. Coast Guard Academy (CGA) under the current firm-fixed-price (FFP) Indefinite Delivery Indefinite Quantity (IDIQ) contract (HSCG23-15-D-PTT173).

IDIQ contract HSCG23-15-D-PTT173 was awarded on a competitive basis to Paskill, Stapleton, and Lord Inc. with a maximum value of $2,791,852.00 and an ordering period of 06/30/15 – 06/29/2020. The total value of the contract will be increased by an additional $690,000.00 for year four ordering period.

(a) The USCG intends to modify IDIQ contract HSCG23-15-D-PTT173 to increase its maximum value.

(b) The current contractor is Paskill, Stapleton, and Lord Inc. 1 Roberts Avenue, Glenside, PA.

(c) Firm-fixed-price contract modification.

(d) The current contract total value is as follows:

Original amount awarded on a competitive basis: $2,791,852.00 Additional amount added to maximum value: $690,000.00 New total maximum value: $3,481,852.00

The following table is a detailed breakdown of the added value:

CLIN Description From: By: To:

Maximum Value: $2,791,852.00 $690,000.00 $3,481,852.00

(e) Type of funding: Services will be funded using Operating and Maintenance funds allocated to the Admissions Division of CGA.

(f) Year of funding: The maximum value increase will be funded using FY 2019 monies and obligated through task orders.

3. Description of Supplies/Services.

The U.S. Coast Guard Academy requires continued support under the current contract (HSCG23-15-D-PTT173) for admissions marketing and enrollment management support services. This support includes but is not limited to:

Market Research, Assessment, and Strategy Formation: This includes market research, assessment of marketing, recruiting, enrollment operations, and recommend strategies, campaigns, programs and initiatives to improve operations and meet enrolment goals.

Creative services: Creates, designs, and produces brochures, publications, DVD, video, presentations, photographic services, and film processes.

Web Design: Design and maintain Academy website design.

Lead Generation: Strategy formation, creative development, production and execution of student search, direct e-mail campaigns, electronic e-mail campaigns, electronic lead generation, media placement, and advertisements.

Communication Sequencing and Integration: Communication sequencing of direct e-mail, customizing web content, and social media.

4. Identification of Statutory Authority Permitting Other Than Full and Open

Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C.

2304(c)(1) implemented by the FAR Subpart 6.302-1 entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Demonstration that the Nature of the Acquisition Requires Use of Authority Cited.

In accordance with FAR 6.302-l(a)(2)(iii)(B), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, for DoD, NASA and the USCG, services may be deemed to be available only from the original source in the case of follow on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in unacceptable delays in fulfilling the agency's requirements.

The CGA requires the support of a full-service admissions marketing and enrollment firm with the personnel, material, and equipment needed to consult, research, plan, create, design, produce, place, and measure the effectiveness of lead generation plans, search campaigns, and communication plans.

The contract solicitation was developed in 2014 and awarded in 2015. The market research at the time drove the estimated value of the services included on this requirement. As technology has changed over the last four years, so has the strategy and methods of reaching and interacting with potential students. For this reason, the CGA reached its maximum value sooner than expected. Recruiting and attracting the best candidates is a continual challenge that continually changes. From 2016-2018 successful new marketing, outreach, and recruiting initiatives were launched to keep pace with the changes in how students access information and communicate with each other. These new initiatives included digital search methodologies, videography, photography, and the replacement of the CGA’s legacy website.

The CGA is currently conducting market research for the follow-on contract. The CGA does not have the resources to administer the current contract, develop the new requirements for the planned follow-on contract, and conduct a third procurement to provide these services currently being provided under the current contract. Furthermore, having two contracts to provide admissions marketing and enrollment management support services simultaneously would create two different strategies that would limit flexibility, add additional responsibility and work to current staff, create confusion of responsibilities, and create vague objectives for the CGA Admissions Department.

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

A survey of the market place revealed that no other sources would be able to continue services under these circumstances. The USCG utilizes the Department of Homeland Security Acquisition Planning Forecast System (APFS) to help industry identify procurement opportunities as early in the acquisition process as possible. The USCG published APFS Record F2019045564 to notify and update industry of the forecasted opportunity of the follow-on contract. Furthermore, a Coast Guard representative attended the annual American Marketing Association Higher Education Conference to better understand the current business market place.

7. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable.

The contracting officer determines that the anticipated price(s) will be fair and reasonable based on the current contract, which was determined to be fair and reasonable.

Furthermore, fair and reasonableness may be based on comparison of prices compared to historical prices paid, current price lists, and catalogs

8. Description of Market Research.

Market research was conducted prior to award of HSCG23-15-D-PTT173. GSA and DHS Strategic Sourcing Vehicles are unable to meet the requirement. Market research is currently on going and is being conducted for the follow-on requirements.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

This justification for other than full and open competition does not extend the ordering period of the contract.

10. A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

While attending the annual American Marketing Association Higher Education Conference, initial market research revealed several vendors interested in the forecasted follow-on opportunity. The following vendors expressed a verbal interest in a follow-on opportunity: Carnegie Dartlett, Westford, MA; Creative Communication Associates, Troy, NY; Paskill Stapleton & Lord, Glenside, PA;

Media Cross; and Vision Point Marketing, Raleigh, NC.

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 Supplies or Services Required.

The Government intends for a follow-on contract and plans to solicit as a 100% Small Business set-aside. Therefore, there are no barriers to future competition.