IBC_Consolidation_Determination_(PBGC)_Procurement_Department_Acquisition_Support_redacted_1.pdf

CONTRACT CONSOLIDATION DETERMINATION AND FINDINGS

Project Name: Pension Benefit Guaranty Corporation (PBGC) Procurement Department Acquisition Support

Solicitation Number: 140D0422Q0250

Agency and Contracting Activity Points of Contact:

Jigisha Patel, Acquisition Division Chief PBGC Procurement Department, 1225 I St. NW, Washington, DC 20005-4026

Heather Watroba, Contracting Officer Acquisition Services Directorate Division I, Branch IV Interior Business Center

The purpose of this memorandum is to serve as documentation, in accordance with FAR 7.107- 2(a) and DOI-AAAP-0094 v03, of the contract consolidation determination and findings deemed appropriate to award a consolidated order on behalf of PBGC for Procurement Department Acquisition Support.

Description of the Procurement Action:

Department of Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD) is a shared service provider within the Department of the Interior providing assisted acquisition services on behalf of the Pension Benefit Guaranty Corporation (PBGC). PBGC protects the retirement incomes of over 34 million American workers in private sector defined benefit pension plans. A defined benefit plan provides a specified monthly benefit at retirement, often based on a combination of salary and years of service. PBGC was created by the Employee Retirement Income Security Act of 1974 to encourage the continuation and maintenance of private sector defined benefit pension plans, provide timely and uninterrupted payment of pension benefits, and keep pension insurance premiums at a minimum.

The Procurement Department (PD) is responsible for the acquisition of all goods and services used by the PBGC to accomplish its mission. PD supports nine (9) PBGC offices; Office of Benefits (OBA), Office of Chief Financial Officer (OCFO), Office of General Counsel (OGC), Office of Equal Employment Opportunity (OEEO), Office of Information Technology (OIT), Office of Inspector General (OIG), Office of Management and Administration (OMA), Office of Negotiations & Restructuring (ONR), and Office of Policy and External Affairs (OPEA).

The purpose of this procurement is to assist the PD with planning and administering all functional areas of the Corporation’s procurement program, the Contractor shall provide cradle-to-grave acquisition support; policy, compliance, training, support; systems assistance;

general reporting, communications, and organizational support; and requirements development support for PBGC program customers. These services shall be performed in accordance with Federal Acquisition Regulation (FAR), the PBGC FAR Supplement (PBGC FARS), and agency directives. Support will be provided by the following tasks:

Task 1 – Pre-Award Acquisition Support Task 2 – Post-Award Acquisition Support Task 3 – Program Acquisition Support Task 4 – Communications, Reporting and Organizational Support Task 5 – Policy Support

Support for these five task areas will be accomplished through the issuance of a single Request for Quotation (RFQ) against the General Service Administration (GSA) Multiple Award Schedule (MAS) 541611 Management and Financial Consulting, Acquisition and Grants Management Support, and Business Program and Project Management Services. Use of the GSA MAS 541611 schedule is in the best interest of the government because it covers the scope of these requirements and contains a pool of highly qualified vendors that have already been shown capable of performing this work. The proposed labor rates on this schedule have also been determined to be fair and reasonable. The applicable NAICS code is 541611 and the size standard is $16.5 million. The applicable Product Service Code (PSC) is R707 Support

– Management – Contract/Procurement/Acquisition Support.

Pre-Award Acquisition Support is provided by Jefferson Consulting Group, contract number GS-00F- 120DA/16PBGC19F0073. This contract was competed in 2019 by PBCG’s contracting office.

The solicitation was released full and open against the GSA MAS Schedule utilizing FAR 8.405- 2(c)(3)(iii)(B), . Jefferson Consulting Group is a woman-owned small business. The total contract value is $10,688,866.97. The current period of performance expires in September. The contract has options through 2024, but PBGC does not intend to exercise the option so PBGC can pursue one contract that will include both pre and post award support as well training and policy support, program support, and systems administration support.

carrying out PBGC’s mission and this procurement strategy provides for maximum participation by small business as it will be set aside for small business.

Results of Market Research

The DOI Contracting Officer (CO) and PBGC conducted market research using GSA’s rapid Market Research as a Service (MRAS) Tool. The results of the rapid MRAS are based on robotic process automation using key word searches through the requirements document.

The results identified the GSA MAS Schedule 541611 as the appropriate schedule for this type of work. The results provided a summary of the number of vendors on that schedule. There are over 1800 small business vendors capable of providing these services identified on the GSA MAS 541611 schedule.

In terms of impact of consolidation on the marketplace, there should be minimal impact.

Acquisitions for procurement support are typically competed as cradle to grave acquisitions.

It is not typical to have two separate contractors providing pre-award and post-award work.

There is often some overlap in the work, and it is helpful to have consistency with the contractors working on those procurements. The vendors in this field will not be impacted by one procurement versus two, as this procurement will be competed among small business vendors.

PBGC provided a list of capable vendors based on their past competitions for procurement support contracts. PBCG also reviewed the GSA Schedule pricing list for various companies on GSA MAS 541611 to review capabilities. The CO conducted market research on USASpending.gov and in FPDS to determine if the selected vendors can support a contract of this size and scope. The CO sorted by the relevant NAICS and PSC codes listed above to compile a list of contracts of similar size and scope.

Finally, the CO reviewed market research conducted by DOI for a similar acquisition support contract under solicitation number 140D0421Q0218. The market research was conducted in June 2021 and was for similar services, As part of the Request for Information (RFI), DOI asked the vendors five questions one of which provide the largest number of FTE’s your company has ever supported on a contract. The question is directly relevant to this procurement because PBGC anticipates having about 18 FTEs to support this contract. The responses to the FTE questions are shown in Table C below. Table C below also provides a list of contracts for acquisition support services for each vendor at a dollar value comparable to this procurement. The vendors on this list responded to DOI’s RFI for 140D0421Q0218 and were identified capable vendors.

PBGC has also found these vendors to be capable of performing this work.

Any negative impact by the acquisition strategy on contracting with small business concerns has been identified:

No negative impacts on small business concerns have been identified as this will be a small business set aside. There are multiple small business vendors on the GSA schedule. The market research conducted on the GSA MAS 541611 schedule identified the vendors listed above as capable of performing these services.

Steps taken to include small business concerns in the acquisition strategy:

This procurement will be issued against GSA MAS Schedule 541611 as a small business set aside. While the list above shows an array of socio-economic business types, the team does not recommend further setting this procurement aside. PBGC would like to allow all of the small businesses identified above the opportunity to bid on this procurement. This procurement will require many contractor resources so the company will need the ability to recruit, train, manage, and retain this large staff. The market is very competitive for mid to high level tier acquisition professionals. While the government is confident it will receive adequate competition, the quantity of quality candidates is limited.

Consideration, Facts, and Reasoning Supporting the Determination:

PBCG previously had one cradle to grave contract for procurement support. The re-compete of that contract was split into two contracts for pre-award and post-award support. Prior history has shown that the one contract provides the agency with better support than they are receiving under two contracts. In order to operate their procurement shop effectively and efficiently, PBGC would like to consolidate these requirements back into one requirement.

Summary:

Consolidation of the work for these task areas into one GSA Order is justified and yields substantial benefits to the Government as documented above. These benefits are essential to meeting PBGC’s mission. Finally, based on the market research and given that the work will remain within the same community of vendors that are currently performing the work, there is no negative impact on the small business community due to this consolidation. Given the outlined benefits and rationale, AQD respectfully requests approval of this Determination and Findings supporting consolidation of the two above-referenced contracts.