HSSCCG-17-F-00023_LSJ_PM_Framework_FBO.pdf

Limited-Sources Justification (LSJ) For

Performance Management Framework

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LSJ No.: FY16-0465

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Citizenship and Immigration Services (USCIS), Office of Contracting (CON) proposes to award an order pursuant to FAR 8.405-6(a), Limiting Sources.

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

USCIS intends to limit the number of sources solicited pursuant to FAR Part 8.405-6(a) for the procurement of Performance Management Framework to proposed contractor:

Contractor: PDRI 650 Third Avenue, South Suite 1800 Minneapolis, MN 55402-4300

The requirement is to provide continued services at the level of quality required with little or no interruption in services. The contractor currently provides the Office Human Capital and Training (HCT) with core training initiatives and critical support during the Implementation of the Performance and Learning Management System (PALMS). A break in service would severely impact the USCIS mission.

3. Description of Supplies/Services.

Provide consulting and training on various Leadership and Development issues as it relates to Human Resources. Consultants shall support HCT Program Managers in the areas of Performance Management, Mentoring, Peer-to-Peer Networks, Coaching, Career Development, and Leadership Development. Training shall be in the form of Leadership Webinars, Quarterly Book Club on leadership topics, and completion of user training for PALMS. The contractor is responsible for creating and delivering training.

POP: Three-month bridge contract 10/07/2016 through 01/06/2017 Cost: $252,401.83

4. Authority and supporting rationale.

This acquisition is being conducted under the authority of the Multiple Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive

Performance Management Framework

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Agencies, in accordance with FAR 8.405-6, ‘Limited sources justification and approval. An award will be made as a logical follow-on pursuant to FAR 8.405-6(a)(1)(i)(C) utilizing the vendor’s Federal Supply Schedule contract # GS-35F-360CA. USCIS is in the middle of its PALMS implementation, in which PDRI is a key component of the training required for the successful rollout. Due to the background investigation process, which takes at least 60 days, no other vendor would be positioned to start services on October 7, 2016 when the current Task Order ends. USCIS is in the process of recompleting these requirements using the OASIS Small Business strategic sourcing vehicle. However, the solicitation has been delayed due the process of rewriting the requirement into a Performance Based Acquisition. The anticipated award date of the new contract is 11/1/2016.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

The contracting officer has determined that issuing the proposed Task Order to PDRI represents the best value and will result in the lowest overall cost alternative, considering price and administrative costs, to meet the Government’s needs for a period of three (3) months. This order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.” The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates.

Discounts to these GSA schedule rates will be requested.

6. Market Research was conducted as it pertained to the determination of best procurement Approach. Personnel Management Consulting services were researched through GSA Schedule 847-1. Consulting services were found to be widely available. Four large and two small vendors capable of providing these services were identified. The following consulting firms were viewed from GSA Mission Oriented Business Integrated Services (MOBIS), Schedule 874-1 and price lists were pulled to obtain an estimate of Cost:

PDRI – GS10F-0059K – (Large) Sevatec - GS-10F-0413R – (Large) STG Int’l - GS-00F-153CA – (Large) T&T Consulting – GS-10F-0484Y – (8a) Binery – GS-00F-270CA – (WOSB)

Schedule holders were found to have comparable rates for the same type labor categories.

This requirement was determined to be a commercial service based on historical data and GSA Schedule pricing. This type of service is used by both Government and the Private Sector.

Additionally, the following information was also discovered during Market Research;

a. Invoices are typically processed within 30 days after confirmation of services being received.

b. Payment tends to be Net 30 days.

c. Contract financing is not normal for this type of procurement.

d. There are no unique laws which pertain to this industry.

Performance Management Framework

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e. With regards to training, over the past few years there has been an increase of on-line class and distant learning experiences.

7. Any other facts supporting the limited-sources justification.

The current vendor has also been a primary driver of our leadership development webinars that we offer as part of our Leadership Lessons program and the PALMS program user training.

Without this contractor support, both of these programs will suffer and potentially fail. For our Leadership Lessons program we would likely have to cease offering the webinars until the time we were able to acquire the needed support. It is a particularly critical period for PALMS as the go live date for the new system is October 1. There is much work to be done if the system is to have a successful implementation, and without the contractor support chances of a failed implementation greatly increase. PALMS user training is scheduled through October 26, 2016.

PALMS is going live on October 1 and the current contractor is an integrated part of the project team developing implementation strategies as well as supporting development and delivery of training for end users and the training-professional community. Without assistance from the Contractor during the October/November launch we will not have the resources to deliver the PALMS training or maintain the roll-out strategy. Ultimately, the launch of the DHS mandated PALMS Learning Management System (LMS) cannot succeed without support from this contractor.

Further, our Leadership Lessons program will have to be severely curtailed, and could potentially lead to failure of the Performance Management Framework. Webinars will need to be drastically reduced making it less likely supervisors will be able to attend due to scheduling conflicts. These webinars are part of our supervisory development efforts and also count towards completion of the DHS mandated 12x12 program. To the extent we are forced to reduce and cancel these webinars, additional burden is placed on supervisors as they try to meet the DHS requirements for development.

In sum, two of HCT’s core training initiatives are currently being supported by the current contractor. If there is a gap in services from the contractor, both of these efforts are at a high level of risk for failure.

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

The intent is to award this action to the current contractor (PDRI) supporting USCIS under the GSA Schedule 70, GS-10F-0059K. USCIS is in the process of recompeting this requirement as a competitive acquisition and expects to make an award within 90 days of the sole source award.

9. DHS intends to post this requirement on Fedbizopps pursuant to FAR 8.405-6(a)(2)(i).

Performance Management Framework

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10. Technical/Requirements Personnel Certification.

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

Jason P. Depasquale Date Technical Representative

11. Contracting Officer Certification and/or Approval *

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and complete to the best of my knowledge and belief:

S. Dale Allen Date Contracting Officer

*Note: In accordance with FAR 8.405-6(d)(1) for BPAs with an estimated value exceeding the simplified acquisition threshold, but not exceeding $700,000, the ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the ordering activity contracting officer’s knowledge and belief will serve as approval.

JASON P

DEPASQUALE

Digitally signed by JASON P DEPASQUALE DN: c=US, o=U.S. Government, ou=Department of Homeland Security, ou=USCIS, ou=People, 0.9.2342.19200300.100.1.1=100776471, cn=JASON P DEPASQUALE Date: 2016.10.19 08:49:24 -04'00' 10/19/2016 stephen.d.allen @uscis.dhs.gov

Digitally signed by stephen.d.allen@uscis.dhs.gov

DN:

cn=stephen.d.allen@uscis.dhs.gov Date: 2016.10.20 09:13:21 -04'00' 10/20/2016

Jason P. Depasquale Technical Representative

JASON P

DEPASQUALELE

Digitally signed by JASON P DEPASQUALE DN: c=US, o=U.S. Government, ou=Department of Homeland Security, ou=USCIS, ou=People, 0.9.2342.19200300.100.1.1=100776471,0.9 cn=JASON P DEPASQUALE cn=JASO Date: 2016.10.19 08:49:24 -04'00'0______________________________

Jason P. Depasquale T