IAGO_LSJ_Redacted.pdf

Limited-Sources Justification (LSJ) For orders or BPAs exceeding the Simplified Acquisition Threshold

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), Immigration and Customs Enforcement (ICE), Office of Acquisition Management (OAQ), proposes to enter into a contract pursuant to FAR 8.405-6(a), “Limiting Sources.”

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

DHS intends to limit the number of sources solicited to award a new task order pursuant to FAR 8.405-6(a) for the procurement of services under ICE Air and Ground Operations (IAGO).

The Contractor for these services is Guidehouse LLC (Guidehouse). The business address for this company is: 1800 Tysons Blvd., 6th Floor, McLean, Virginia 22102-4257.

The initial requirement was competed on a full and open basis under Mission Oriented Business Integrated Services (MOBIS) - Schedule 874. Guidehouse LLC (formerly PricewaterhouseCoopers Public Sector LLP) was awarded the two-year task order under HSCEDM-15-F-00085. Guidehouse LLP identified numerous transportation improvement opportunities pertaining to acquisition, fleet management, data collection, and reporting standardization. To continue developing and implementing these improvements, the Government awarded follow-on Task Order HSCEDM-17-F-00094 to Guidehouse LLP on September 27, 2017. The Government awarded this Task Order pursuant to FAR 8.405-6(a)(1)(i)(C) due to new work being identified as a logical follow-on. There is a continuing need for some of the activities on the previous contracts, specifically the acquisition and operations management and the data management portions of work, which will involve nationwide deployment of the Business Intelligence tool and transitioning ICE’s 24 Areas of Responsibility into regular utilization of the tool.

3. Description of Supplies and/or Services.

ICE Enforcement and Removal Operations (ERO) continues to face numerous oversight and logistics challenges related to managing ground, air, and fleet operations across its transportation network, mitigation of which require flexible, scalable Ground Transportation Operational Support Services to provide ground transportation operational and data management support.

In Phase One of the Guidehouse contract, Guidehouse conducted a Current State Assessment of the ERO Transportation network. In Phase Two Guidehouse conducted an Analysis of Alternatives (AoA) to identify and recommend several opportunities within four areas of focus (Air Charter Operations, Ground Acquisition Process, Fleet Acquisition and Management, and Commercial Air Operations) based on the net efficiency benefit and ease of implementation. In Phase Three, ERO asked Guidehouse to develop an implementation plan and roadmap for the opportunities. Guidehouse created detail implementation plans for each prioritized opportunity detailing the tools and techniques required to achieve anticipated benefits. The Implementation http://uscode.house.gov/

Plan and Roadmap plan includes the following areas: Goals and Anticipated Benefits, Timeline / Savings Schedule, Enabling Capabilities, Framework / Processes and Performance Indicators.

The purpose of the solution frameworks is to enable ERO to achieve the following benefits on an ongoing basis:

• Operational efficiencies: Reduce and eliminate inefficiencies in transportation operations and reduce costs.

• Increased understanding of transportation operations and requirements: Enhance transparency and accountability over ERO transportation processes and view transportation in conjunction with other ERO mission areas (e.g., custody).

• Budget transparency and planning: Develop, execute, and defend budgets more effectively based on enhanced data collection techniques and understanding of data.

• Government oversight inquiry response: Respond to inquiries from the Office of the Inspector General (OIG) and other oversight authorities through increased visibility and traceability of data.

• Identification of continuous improvement opportunities: Leverage the results of implementation to achieve future quantitative / qualitative benefits.

These benefits are contingent upon ERO successfully implementing the approved solution frameworks. Guidehouse was asked to begin implementing some of the solutions and ERO created five task areas to accomplish this: Acquisition and Operations, Data Management, Data Enhancements, Business Improvements, and Fleet Management.

For the Acquisition and Operations task area, Guidehouse collected and conducted transportation analysis, and supported transportation acquisitions by reviewing all materials, applying the analysis, and making recommendations.

For the Data Management and Data Enhancements task areas, Guidehouse developed an automated G-391 data collection process for the transportation contracts and an IAGO Business Intelligence (BI) Tool to promote visibility into ground transportation operations. Other data sources such as FFMS, PRISM, JP Morgan, and Sunflower were also collected and ingested into the tool. The IAGO BI Tool is used to conduct the analysis for all ground transportation acquisition activities and is used by CORs, COs, and the ERO Contract Management Unit (CMU) for enhanced contract management.

For the Business Improvements task area, Guidehouse was asked to develop a new contract review process for ERO to improve oversight and budget management. For the Fleet Management task area, Guidehouse developed an IAGO Fleet Tool for ERO field offices to manage their fleet more effectively.

Over the next six months, current acquisition activities and upcoming contract re-competes need to be supported, and the data collection and validation is too much of an effort to be supported by the current federal Project Manager. It is critical that this support continues without a gap for the next six months as ERO conducts market research, develops requirements, and awards a new competed contract to support these activities.

ERO will need the following over the next six months:

• Execute a series of support activities between OAQ and the field to utilize available BI Tool data to right-size and right-type ground transportation contracts. Activities include but are not limited to conducting transportation analysis on historical usage, reviewing RFIs, SOWs, RFPs, cost breakdown, recommendations for efficiencies and standardization.

• Support continued IAGO BI Tool SharePoint site and Tableau dashboards to oversee data collection of contractor G-391 ground transportation data, FFMS, JP Morgan, PRISM, and Sunflower data and perform validation and analysis.

• Support the pilot activities to automate manual transportation processes in ERO field offices.

• Support the ERO ground transportation request process, conduct analysis on all new transportation requests, and develop materials for the ERO IAGO Working Group and ERO IAGO Executive Council.

The current Guidehouse LLC contract ends September 24, 2018. The contract is a Firm-Fixed Price Contract. The estimated value of the work described herein is $849,600.00. The period of performance for this work would occur from September 25, 2018 through March 24, 2019.

This action allows Guidehouse to continue its aid of implementing the IAGO solution frameworks and establish a ground transportation management capability while allowing ICE sufficient time to conduct market research and develop and award a competitive procurement.

Period of Performance Monthly Unit Price Number of Months Total Price

September 25, 2018 – March 24, 2019

Six $849,600.00

4. Authority and supporting rationale.

8.405-6(a)(1)(i)(B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

Guidehouse is a highly skilled consulting vendor providing management, technology, and risk consulting. The work performed by Guidehouse on the previous contracts lays the groundwork for the implementation and deployment of a nationwide data collection and analysis tool for the agency’s use. At this juncture, introducing a new contractor would not only substantially duplicate costs to the Government, but also unacceptably delay fulfillment of agency requirements Guidehouse can immediately and fully support all these activities for the proposed six month term without any interruption in service while the Government proceeds with competitively procuring these and related services. Given the steep learning curve associated with ERO transportation operations proficiency and Guidehouse’s experience with this data and creation of a unique tool for the agency, it is clear that Guidehouse has the proven ability to successfully deliver lasting improvements in transportation network performances and efficiencies.

Guidehouse has gained extensive knowledge of and experience with all ERO transportation contracts, air and ground operations, G-391 data collection, reporting, and fleet management. Guidehouse possesses full knowledge and expertise in validating and consolidating the transportation data collected from various sources (e.g. G-391 contractor templates, Sunflower, JP Morgan, FFMS, etc.) into the IAGO Business Intelligence Tool. ERO requires Guidehouse’s unique experience with the immigration transportation subject matter and its skill level to continue to effectively implement these critical services.

Forty-five transportation contracts are currently under review. Of those 45 transportation contracts, ten are a high priority and will need to be supported over the next six months. A gap in this support would result in missed recommendations for right-sizing the contracts and efficiencies. This expertise is also needed to support the new ERO transportation contract review/approval process with transportation analysis and recommendations for the IAGO Working Group and IAGO Executive Council which consists of the ERO Assistant Directors.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d).

Services offered on the Guidehouse GSA schedule are priced at hourly rates and at a fixed period of performance for the task order. GSA has determined that the fixed-price services and rates offered at hourly rates, under the Guidehouse GSA contract are fair and reasonable. Therefore, the Government is not required to make a separate determination of fair and reasonable pricing.

However, after reviewing the proposed pricing and labor rates/categories of the current GSA schedule, the Government has determined that the rates proposed by Guidehouse are fair and reasonable. By placing an order against the Guidehouse GSA schedule, the Government has concluded that the services provided by Guidehouse, concerning this task order, is the best value to the Government.

6. Description of Market Research Obtained.

Although there might be upwards of five or more of other vendors who could perform these services, any transition time would take upwards of three months. Therefore, ICE has created a tentative schedule to procure these services through competition – see Section 7.

7. Any Other Facts Supporting Limited Sources Justification.

ICE anticipates issuing an Request for Proposals near the end of the first quarter of Fiscal Year 2019, which will result in a competitively awarded contract in the following months.

8. 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 anticipates a new competed contract to take over the data collection and analysis work. The six months of support by Guidehouse will provide the Government with adequate time to conduct market research, issue a request for proposal, and to compete and award a new contract.