HSPD 12 LIMITED SOURCE JUSTIFICATION 10202020 AL 1124.pdf

LIMITED SOURCES JUSTIFICATION FOR MULTIPLE AWARD

SCHEDULE (MAS) ORDERS FAR 8.405-6(a)(1)(i)(A)

1. Identification of the agency and the contracting activity and specific identification of the document as a limited source justification.

This requirement is in support of GSA, Office of Mission Assurance (OMA)

1800 F Street, NW Washington, D.C. 20405. The contracting activity is Office of Internal

Acquisition (OIA), 1800 F Street NW, Washington, DC 20405.

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

The Government is seeking to award one Labor Hour non-competitive “bridge contract” to

Deloitte Consulting LLP to acquire Homeland Security Presidential Directive -12 (HSPD-12) and ICAM Support Services.

The period of performance for this bridge contract is four months.

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

Reference attached Performance Work Statement (PWS) for the complete description of the supplies and/services required to meet the agency’s need.

The Independent Government Contract Estimate (IGCE) is attached.

4. The authority and supporting rationale (see FAR Part 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

Check one:

FAR 8.405-6(a) Justifications for Limiting Sources

(A signed copy of this justification document must be posted to www.fedbizopps.gov for 30 days within 14 days from the date of award)

✓ / FAR 8.405-6(a)(1)(i)(A) - An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

In accordance with 41 U.S.C. 253(c) and/or 10 U.S.C. 2304(c), GSA has determined that the

DocuSign Envelope ID: C3C36012-D693-4C63-B5FB-76A128962B4F http://www.fedbizopps.gov/ procurement requires a sole source in order to satisfy the Agency’s need.

Considering the required time and cost to complete this procurement, it is determined that it is in the best interest of the Government to establish a contract, without using competitive procedures, for the continued performance of the services described below because an urgent and compelling need exists for the continued performance of these services. In short, the urgent and compelling need is that without the continued provision of the below-outlined services GSA will be unable to process and issue GSA

Personal Identity Verification (PIV) cards for GSA employees and contractor employees, meaning these individuals will be unable to access GSA physical space and computer systems, which will severely compromise GSA’s mission by causing these individuals to be unable to work on GSA assignments.

Deloitte Consulting, LLP is the incumbent contractor in performing the Homeland

Security Presidential Directive 12 (HSPD-12) and Identity Credentialing Access

Management (ICAM) Services for GSA and the Office of Mission Assurance (OMA).

At this time, Deloitte Consulting is the only source capable of immediately responding and providing the required continued support. This firm possesses the required background investigation in compliance with all Security regulations that support the

HSPD-12 and ICAM program. This means the Government would not have to wait for personnel background investigation to be processed for another Contractor. Each background investigation is different but depending on the contractor it can take several weeks to months to get a background investigation for a contractor. Since

Deloitte was recently performing the task, the service processes are already established and the Government may conveniently proceed to work and meet its goals and objectives until the GAO protest is resolved.

By contrast, competitively awarding a bridge contract for these required services would require significant time during which GSA would not be able to perform the critical services described below.

GSA Nationwide is reliant upon the HSPD-12 and ICAM services to support the following Agency programs:

1 - Provide IT technical and software engineering support for the maintenance and operation of the GSA Credential and Identity Management System (GCIMS). The

GSA Credential and Identity Management System (GCIMS) manages the issuance and lifecycle of GSA’s Personal Identity Verification (PIV) credential, the GSA Access

Card. Currently GCIMS manages data for over 70,000 active GSA personnel with almost 600 privileged users agency-wide. GCIMS manages the GSA credentialing and contractor background investigation processes. In addition, GCIMS acts as the authoritative source on Employee and Contractor staff information for several partner applications including systems for access management and Continuity of Operation

Plan (COOP) emergency notification, HR Links, Monster, Active Directory (AD), Salesforce, Google, eQIP, NP2, Managed Services Office (MSO), One-Time Password

(OTP), and InSite to name a few. GCIMS provides data transfer to FBI, OPM, DCSA, etc. to transmit and obtain information. GCIMS is the data hub for GSA personnel information.

a. Impact from the absence of contractor services:

Adjudication/background investigation results for candidates, new staff and existing staff will not be available for making hiring decisions, and granting building and IT application access; OCIO will not be able to provide GSA account and computers to GSA personnel as they cannot verify background investigations and will not be able to work provide the necessary GSA tools to do their jobs; GCIMS may not be able to continue operating at all, if operational problems occur; GSA staff will not be able to request GSA Access Cards for new and existing GSA staff with the FAS HSPD12 Managed Service Office; GSA staff will not be able to record new and updated information like status, contact information, email, GSA Access Card status, eQIP status, HR data, etc.

used by a number of other IT application, e.g. GSA Staff Directory on

InSite, Google, HR Links, Monster/GSAJobs, NAAS, etc; ability to provide and obtain data pertaining to background investigation performed by Office of Personnel Management (OPM); and HSPD-12 program will not be able to respond to IG audit that have strict deadlines and requests.

2. Credentialing services for issuing and maintaining GSA Access Cards for employees and Contractors. GSA employees and contractors (that need routine access to buildings or IT access) obtain a GSA Access Card. The GSA Access

Card provides access to government buildings and also provides logical access to GSA computers and applications. There are many steps and processes involved in obtaining the GSA Access Card. This process is heavily reliant on

GCIMS processes and work done by Deloitte.

a. Impact from the absence of contractor services: New employees and contractors will not receive GSA Access Cards and existing GSA staff will not be able to replace their cards or update their certificates, creating security problems for the staff to access all GSA buildings, the

GSA network, and therefore most GSA IT applications. GSA staff will not be able to update certificates and not be able to log into IT or

Physical Access Systems (PACS). The interruption of services will have a negative impact on GSA Nationwide as GSA personnel may not be able to accomplish their jobs if they are unable to access government buildings and facilities, and also unable to access GSA computers and applications. Without the GSA Access Card, this increases the security vulnerability of GSA.

3. Background Investigation Services. The investigation is necessary for an individual to begin working as a GSA employee. For GSA employees, background investigation is completed by Personnel Security and provided to the HSPD-12. For contractors, HSPD-12 team processes requests and assists throughout the whole background investigation. The background investigation is needed for Contractors to start work on a GSA contract.

a. Impact from the absence of contractor services: It will significantly reduce the number of employees processing contractors with their background investigations by approximately 75%. It will cause a huge

(an immense) workload backlog of contractors waiting for background investigation clearances to be processed which will directly impact on-boarding of personnel. This will cause severe delays or stop in work for many organizations such as PBS, FAS, OCIO, and other SSOs and would prove to be detrimental to the agency.

Deloitte has the unique qualifications enabling them to perform the required HSPD-12 and ICAM tasks where no other contractor can, because Deloitte’s services are currently integrated into all of the work processes. It would be impossible to hire another contractor to pick up the work, because another contractor would not be able to start the work and perform these integrated tasks immediately. Another contractor would have to be trained to do the work and that would take 3-6 months to accomplish.

Additionally, Deloitte would be the one that would have to do the training.

Deloitte delivers programming for GCIMS, provides processing of HSPD-12 supporting Background Investigations, works to support OPMs eQIP application, provides credentialing services for issuing and maintaining GSA Access Cards for employees and contractors, provides logical access and physical access, provides identity management for MSO services and support throughout the country, provides

IT and Technical Support, and provides Project Management support. These uniquely integrated processes allow for services to continue for the next four months. No other contractor would be able to pick up and start work immediately. Another contractor would lack these unique qualifications and expertise, and would not be able to work within the required timeframe to ensure continuity of the required services. Given the very short time available for project ramp up and the urgent need for continuity of service, Deloitte is the only source capable of responding.

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

The Government intends to Sole Source the procurement via a “Bridge Contract”. Therefore, all pricing, terms and conditions shall remain the same as already established under Deloitte

Consulting’s GSA Schedule Task Order 47HAA020F0195. The pricing under task order

47HAA020F0195 was discounted less Deloitte Consulting’s Schedule contract GS-35F-0617Y under Category 541519PIV HSPD-12. The discounts range from 13% to 37% less than the

Schedule contract pricing.

The estimated cost for the four month “bridge contract” is consistent with Deloitte’s pricing under their recent award (Task Order 47HAA020F0195). The labor rates remain the same.

Based on the foregoing, the Contracting Officer has determined that the anticipated price to the

Government under the Bridge Contract will be fair and reasonable.

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.

Market research was not conducted in accordance with FAR Part 10. However, market research was performed under the task order 47HAA020F0195.

GSA has an urgent need for a “bridge contract” for the HSPD-12 and ICAM support services in order to maintain continuity and avoid an interruption of services to the Government until the

GAO protest is resolved. Therefore, market research was not conducted.

7. Any other facts supporting the limited sources justification.

None

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

GSA received a GAO protest on October 2, 2020. A ‘STAY’ was requested. Based on this fact a “bridge contract” is needed to avoid a disruption of the HSPD-12 services and continue to support GSA’s mission.

Program/Technical Official Certification:

I hereby certify and accept the responsibility that any and all supporting data provided above or used to justify the above request for a sole source procurement (e.g., verifying the Government’s minimum needs, schedule requirements, and/or other rationale for other than full and open competition) is accurate and complete to the best of my personal knowledge and belief.

PHIL AHN

Contracting Officer’s Representative’s Signature

Date

PHIL AHN

Project Manager’s Signature

Date

Contracting Officer’s Certification:

I hereby certify that the information contained in this Justification for Other than Full and Open

Competition, is accurate and complete to the best of my knowledge.

ANITA M. LITTLE

Contracting Officer’s Signature

Date

In accordance with Office of Internal Acquisition policy, One Level Above Contracting Officer’s

Review and Approval (required for all actions over $250,000).

I hereby certify that the information contained in this Justification for Other than Full and Open

Competition, is accurate and complete to the best of my knowledge.

KATASHA WHITE

One Level Above Contracting Officer’s Signature

BRIDGETTE OVERBEY

OIA Director

NICHOLAS WEST

Competition Advocate

10/21/2020