I_4 SF_1014_JEFO Rev review Final 3.22.21 (OITA Dir) PAS.pdf

DEPARTMENT OF THE TREASURY

SF 1014 - JUSTIFICATION FOR AN EXCEPTION

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Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505 Tracking No.

1. Identification of the requiring activity and the contracting activity:

The requiring activity is the Internal Revenue Service, Information Technology, Enterprise Services. The contracting activity is the IRS Procurement Office.

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

This is a Justification for an Exception to Fair Opportunity for a bridge contract to continue mission critical services for Enterprise Architecture (EA) CORE support services until the competitive follow on can be awarded. The EA CORE support services are expected to be awarded using the GSA Alliant best in class contract. The award will be a firm fixed price task order against the GSA Alliant 2 contract. Period of Performance: Base Period: 3/27/21 – 10/26/21; Option Period 1: 10/27/21 – 12/26/21; Option Period 2: 12/27/21 – 2/26/22; Option Period 3: 2/27/22 - 3/26/22 2.b Name of the vendor. Booz Allen Hamilton 2.c Requisition No.: 50001-17135, 50001-17136, 50001-17137, 50001-17138, 50001-17139, 50001-18571, 50001-18621, 50001-18622 2.d Bridge contract: X Yes ☐ No 2.e Brand name: ☐ Yes X No 3.a A description of the supplies or services required to meet the agency’s needs: Contractor support is required to assist the Enterprise Architecture Office (EAO) in translating the IRS’s business vision and strategy into an Enterprise Architecture (EA) strategy and tool that can be used by business and IT managers to plan and manage their investments for business and technology solutions. The Contractor shall provide support and services in the following general areas:

Enterprise Architecture Planning and Management; Enterprise Architecture Strategy and Planning;

Enterprise Architecture Design and Support; Standards and Technology Management. Services are also required in the following areas: Development of strategy, process improvement, governance documents, analysis, architecture/design support for new common services; Develop a roadmap for the migration of legacy applications to a service-based application environment and, plan and conduct lab-based prototyping and proofs of concept in support of a broad range of IRS technological objectives. Contractor services are needed to continue the Architecture and Engineering services being performed under the current contract Alliant Task order 2032H5-18-F- 01163. The current contract was awarded in September 2018 with a performance of period (POP) which expired on 9/26/19. The task order was subsequently extended through 3/26/20. A new Bridge Task Order was executed for 12 months pursuant to FAR 16.505(b)(2)(i)(A) and the current POP ends 3/26/21. The proposed contract action is for an additional 12-month extension ending 3/26/22.

3.b Includes IT: X Yes ☐ No NAICS: 541519/PSC:D303G 3.c IGCE/Estimated dollar value:

Base Period 3/27/21 -10/26/21 $28,127,516 Option 1 10/27/21 - 12/26/21 $8,386,606 Option 2 12/27/21 - 2/26/22 $8,386,606 Option 3 2/27/22 - 3/26/22 $4,193,303

Total ONE Year 3/27/21 - 3/26/22 $49,094,031

4.a Identification of the exception to fair opportunity being used:

X FAR 16.505(b)(2)(i)(A) – The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

☐FAR 16.505(b)(2)(i)(B) – Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

☐ FAR 16.505(b)(2)(i)(C) – The order must be issued on a sole-source basis in the interest

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Treasury Standard Form – 1014 (Rev 5/18) of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order ☐ FAR 16.505(b)(2)(i)(D) – It is necessary to place an order to satisfy a minimum guarantee.

☐ FAR 16.505(b)(2)(i)(E) – For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

☐ FAR 16.505(a)(4) – The requirement is for an item peculiar to one manufacturer.

4.b Supporting rationale:

The Enterprise Architecture Office (EAO) is seeking a bridge task order to continue the support under the current contract, Task order 2032H5-18-F-01163 until a new competitive award can be made. Under this contract, the contractor, Booz Allen Hamilton (BAH), has been providing support under the best in class GSA Alliant contract since 2018. The contractor has the experience, institutional knowledge and skills to perform under the proposed bridge task order while the IRS completes a new a competition for this critical support. The competitive procurement package was recently submitted to the contract activity because of a combination of unanticipated events and challenges prevented an earlier submission which is discussed in further detail below. Therefore, there is a need for a new one (1) bridge task order beginning March 27, 2021 to provide continuous support until the competitive award can be completed and awarded in the first quarter of FY22.

Enterprise Architecture Program serves a critical role in ensuring that IRS business strategies are guided by sound investments in Information Technology. Enterprise Architecture (EA) is mandated by laws and Federal OMB Directives and serves as a primary decision point for all investments in IT.

The EAO must continue to update the EA to reflect changes driven by legislation, i.e., Taxpayer First Act (TFA), CARES Act (COVID-19) and unanticipated emergencies, such as the pandemic, potential and actual cybersecurity threats to taxpayer data, and on-going challenges to resources, so the EA can be used to make informed decisions with respect to business and IT investments. The TFA, in particular, requires a complete overhaul in the way IRS operates and provides services to taxpayers as well as to modernize the agency. Unacceptable delays or lapses in contractor support will detrimentally impact the EAO’s ability to deliver the EA and all of the associated artifacts and functionality timely. The IRS needs to ensure continuity of services so EAO can meet the deadlines imposed by multiple legislative actions identified above as well as unanticipated challenges and threats. Lack of continuous contractor support will also adversely impact EA’s ability to support the current 2021 filing season and prepare for the 2022 filing season, and impair our agency’s ability to deliver on the IRS Modernization Plan commitments, facilitate a phased reduction of the IT footprint and planned system retirements, including the retirement of the Individual Master File (Congressional Mandate). The EAO must continue its efforts in translating the IRS’s business vision and strategy into an Enterprise Architecture (EA) strategy and tool that can be used by business and IT managers to plan and manage their investments for business and technology solutions across the Enterprise, to ensure that the solutions are consistent with the IRS’s target architecture, so the IRS does not invest in solutions that cannot be maintained.

Because of the challenges identified above, there have been a number of extensions to the incumbent contract. The first bridge from September 27, 2018 - September 26, 2019, was required due to the early termination of the TIPSS IDIQ agency contract and because the TIPSS contract vehicle could not accommodate a five (5) year POP. Due to the essential nature of the services, a 5-year performance period was required. Simultaneously, the Department of Treasury mandated the use of Best-In-Class (BIC) vehicles, which resulted in a major acquisition strategy change to the

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Treasury Standard Form – 1014 (Rev 5/18) acquisition re-competition efforts, because of the inflexibility of the TIPSS vehicle. After additional market research and consideration of several BIC vehicles, the EAO elected to use GSA Schedule 70. Subsequently, after several months, the agency discovered that although GSA Schedule 70 has several BIC vehicles, the one required to award this particular requirement was not under its purview. Unfortunately, this event accompanied by a Government shutdown precluded the opportunity to make an award, and the Task Order was extended for the period of September 27, 2019 – March 26, 2020. During the second extension’s performance period, there were changes in the following, 1) procurement personnel; 2) new EA leadership and 3) a General Legal Service (GLS) legally insufficient finding for the Performance Work Statement (PWS).

The new EA leadership came on board and required sufficient time to review requirement documents to ensure they met the extensive mandates of the Taxpayers First Act, CARES Act and navigate substantial challenges induced by the COVID pandemic. This resulted in a second Bridge from March 27, 2020 to March 26, 2021, to cover the critical changes. While procurement was adapting to a realignment and staffing challenges, EAO was reacting to the impact of major and wide-ranging legislative changes affecting the IRS EA including IT Modernization, issuance of the Taxpayer First Act, growing need for Cloud support, improved architecture security practices and most recently, system retirements along with difficulty in developing legally sufficient documents. The combination of these events contributed to the delay in submitting a procurement package for the re-competition.

The EAO now requires additional time to process the follow-on competitive award and transition services between the incumbent and successful offeror utilizing a BIC vehicle.

Therefore, this bridge will allow the IRS sufficient time for the source selection process and a transition period permitting the adjudication of contractor employee security clearances and obtaining government provided equipment for new contractor employees. The Contractors must have staff like access clearance, which necessitates an average 4-6 months with another month for IRS equipment (laptops/badges) so they can be fully operational, and all documentation can be shared securely between IRS and the contractor. The incumbent contractor, BAH, has the working knowledge, expertise, and security access which in the immediate term cannot be met by any other vendors without major disruption and lapse in crucial services. This task order is being structured to allow for adequate time to complete the acquisition process for the new competitive award. The bridge contract will be structured with a seven (7) month base period, two (2) month option 1, two (2) month option 2 and one (1) month option 3 for a total of 12 months. Option period 1 will be used to continue support services while the new vendor obtains security clearances (if required) and the second option period will be used for the transition to the new vendor. The third option will be available for use if additional time is needed to obtain security clearances. Both vendors will work side by side to facilitate the transition.

Efforts to re-compete the follow-on contract are currently underway with the release of the solicitation planned for the third quarter of the current 2021 fiscal year and award anticipated in the first quarter of the 2022 fiscal year. Based on the limited time remaining prior to the expiration of the current contract along with the technical knowledge and security clearances required, the agency concludes that BAH is the only viable source capable of maintaining continuity of services, given its experience and large qualified workforce. The contract will be awarded using GSA Alliant 2 contract vehicle. Any interruption in service would adversely affect several governmental systems at the IRS, Treasury Departmental levels, Federal Government level and will impact the ability of the IRS in supporting any future additional legislation that

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Treasury Standard Form – 1014 (Rev 5/18) may arise in the near term. For example, the EAO is leading the development of the architecture for the Customer Account Data Engine (CADE2) program. Any delay to CADE2 will have a ripple effect and delay the IRS’ ability to implement the program timely. All downstream applications support by CADE2 will be impacted by the delay. This interruption will also negatively affect the IRS Modernization Projects, which include Cloud, Application Programing Interface, and Taxpayer First Act. The IRS will not be able to deliver the promised improvements to the taxpayers for FY21 and the would delay the delivery of improvements. All these programs depend on EA in order to be successful.

5. A determination 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 a comparison of the proposed prices with the Independent Government Cost Estimate (IGCE) and past pricing which was solicited under a competitive requirement in 2013. The rates in the GSA Alliant 2 contract were also determined fair and reasonable by GSA as part of the award under the Alliant contract. In addition, the contracting officer will request discounts off the current GSA Alliant 2 pricing.

6.a Any other facts supporting this justification: N/A

6.b Attachments: ☐ Yes X No

7. A statement of the actions, if any, the Requiring Activity and Contracting Activity may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies and services is made:

The Contracting Activity is planning to issue a competitive solicitation in the 3rd quarter of FY 2021. As a result, approval of this Justification provides the Government the necessary time to complete the solicitation and evaluation process and make a new award against an existing GSA contract by November 2021.

8. Certifications and Approvals:

8.a Program Office Certification (Requiring Activity). I hereby certify that any supporting information and data provided (e.g., the Government’s minimum needs or requirements, or other rationale for the limited sources) and which form the basis for this justification for an exception to fair opportunity, are accurate and complete to the best of my knowledge and belief.

Name: Kim Novak Date:03/11/2021

Signature:

8.b Contracting Officer Certification and Approval. I certify this justification for an exception to fair opportunity is accurate and complete to the best of my knowledge and belief.

Therefore, unless additional approvals are required as prescribed below, as the authorized contracting officer for this acquisition, I hereby approve the processing of this requirement based on the authority specified in 4.a above.

Name: Patricia Session Date:03/11/2021

Signature: 7VRMB Digitally signed by 7VRMB