ID08160022_FINAL_SIGNED.pdf

CAAS - NDAA - Limited Sources Justification - 5jan16 FINAL (1)

LIMITED SOURCE JUSTIFICATION

In Accordance With (IAW) FAR 8.405-6(c)

1. Identification of the agency and contracting

Requiring Agency:

Defense Commissary Agency (DeCA) Acquisition Management (LEA) 1300 E. Avenue Fort Lee, VA 23801-1300

Contracting Activity:

General Services Administration (GSA) Rocky Mountain Region 8, Denver Federal Center, Building 41

6th and Kipling, Denver, Colorado, 80225

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

The General Services Administration (GSA) proposes to execute a Task Order under Federal

Supply Schedule GS-10F-0253V to the firm of The Boston Consulting Group (BCG). This action is accomplished in accordance with FAR 8.405-6(c), and is a follow-on to a work effort previous executed by GSA on behalf of the Department of Defense (DoD). The original task order requirement was spurred by a mandate by the U.S. Congress, which via National Defense

Authorization Act (NDAA) of 2015, directed the Secretary of Defense (SecDef) to timely submit a report to both the Military Compensation and Retirement Modernization Commission (MCRMC) and to the Senate and House Armed Services Committees. This contract action was accomplished by the GSA, at the request of the DoD, via the Defense Commissary Agency (DeCA). The purpose of the task order was to evaluate the effects of commissary business reforms such as variable pricing, private label, and other commissary cost initiatives on the military resale

(commissary and Exchange) and ultimately the benefit provided to patrons. The original contract action was executed via Task Order GSQ0815BP0002. This was a fully competitive action under

FAR Part 8.405 which involved the issuance of a solicitation to a total of eight highly qualified

Schedule holder contractors. As a result, three (3) proposals were received and an award was made on 29 Jan 2015 to the Best Value proposal submitted by BCG. The result of that Task Order work effort was a Study Report which the SecDef submitted to the MCRMC and both Armed

Services Committees in 2015.

Based on a review of the resulting Report generated by the original task order in Sep of 2015, the

Congress mandated via National Defense Authorization Act (NDAA) 2016, signed into law on

November 25, 2015, that the SecDef accomplish an additional work effort requiring DoD to build on the previous assessment conducted by BCG through new data and analysis to test and evaluate the impact of the aforementioned reforms. DoD must submit mandated reporting requirements which include an action plan with supporting documentation by March 1, 2016 in preparation to exercise that plan for pilot programs to test the benefit of the critical reforms.

This limited source justification is for DoD/DeCA requirement to complete the additional work requirements noted above and further defined in Paragraph 3.

3. A description of supplies or services required to meet the agency's needs (including estimated value):

The Office of the Under Secretary of Defense – Personnel & Readiness [OUSD (P&R)], based on supplemental requirements from the U.S. Congress, requires additional analysis, outlines, and reports based upon the Study Objectives previously completed by the firm of BCG. This action is for non-personal services to provide expertise to assist the Defense Commissary Agency (DeCA) in business transformation to develop plans for pilot programs that include conducting market basket methodology. The work includes production of a plan to obtain budget-neutrality for the defense commissary system and the military exchange system, while maintaining the same level of benefit that it currently provided commissary and exchange patrons today. In development of the

Plan, the services shall include the development of:

(1) Market Basket Methodology

In addition, support to provide education and briefings to the stakeholder community on recommendations for DeCA and an explanation of the report findings and plan are required. Most briefings will be in either the Washington DC area or Ft. Lee, Virginia and may include high level

DoD representatives (civilian and military), congressional members, congressional staffers, and military organizations. The contractor will be expected to address the overall findings and be able to respond to questions related to specific study objectives and recommendations contained in the final report and plan. This effort is expected to entail no more than 4 total briefings.

The period of performance will be for a period of approximately three (3) months ending May 15, 2016, with an estimated value of . The period of performance is for the initial plan as well as after-action items for follow up and briefings with stakeholders. It is noted the initial deliverable under this action is due on February 15, 2016, to meet Congressional imposed reporting requirements and deadlines.

4. The authority and supporting rationale:

FAR 8.405-6(a)(1)(i)(C) – In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

The original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order was not issued under sole-source or limited-sources procedures. In the interest of economy and efficiency, the new work described herein has been determined to be a logical follow-on to the original Federal Supply Schedule order.

To accomplish this work, DeCA needs support from a firm with experience and detailed knowledge in DeCA’s business model and private sector retail specific to the reforms developed and suggested in the original task order; detailed understanding of the content, recommendations, methodology, underlying assumptions and data used in the September 2015 through THE BOSTON CONSULTING GROUP; a dedicated senior team with expertise in these areas in order to rapidly translate the recommendations to tangible actions and plans as early as February 15, 2016.

BCG is the only known firm with the requisite commercial and government experience, and the background in-depth knowledge regarding this overall requirement based on their previous work in the original task order to complete the new work effort within the accelerated time period mandated by NDAA 2016. Specifically, the plan and reporting is due not later than 01 Mar 2016. To ensure the

March 1, 2016 deadline is met, DoD/DeCA will need to receive any and all expert input, analytics, and insights no later than February 15, 2016. After the report is submitted, DoD/ DeCA requires follow-on actions which may include briefings, supplemental data, etc to support the initial plan.

It is noted that other firms may be able to use BCG’s September 2015 Report to gain the expertise noted above, develop a team of experts, and develop the currently required plan, but BCG would be the logical company in the interest of efficiency and economy to pursue this follow-on in the timeframe needed. The time and effort involved for another firm to gain/research the in-depth knowledge to present a plan to Congress in such a short time frame is not efficient or economical;

nor is it realistic. The estimated time to acquire a new contractor, and for them to possess the fundamental knowledge level required to support this effort is approximately 3-4 months. Any other vendor would have to be provided sufficient time to review the reports in order to accomplish the new work being requested which would cause a delay in the required reports. It is economical and efficient to the government for the follow-on order to be placed with BCG due to the expertise and in-depth knowledge BCG has of the requirement to provide the best possible service in the timeframe required. BCG possesses a detailed knowledge of DeCA's business model, including topics such as detailed understanding of the content, recommendations, methodology, underlying assumptions and data used in the congressionally mandated study submitted to Congress in September 2015. The reports are time sensitive to Congress and the

GAO; therefore, it is imperative that BCG continues the analysis as they have first-hand knowledge of what was accomplished along with the final recommendations. It is illogical and impractical to assume another vendor other than BCG would provide seamless support and meet the strict and very short timelines imposed upon the SecDef by the Congress and be able to deliver the required analysis and reports. There would be substantial duplication of costs as any firm other than the incumbent would find it necessary to evaluate reports, documentation, processes and familiarize themselves with the past 12 months of effort. Additionally, time is not available for any other firm other than the incumbent to accomplish the new work.

The Contracting Officer has determined that it is in the best interest of the Government to have the existing vendor, BCG, perform the new work as a logical follow-on task order under the referenced authority.

Alternatively, FAR 6.302-1(a)(2)(iii) would allow DoD to pursue a contract with the original source in the case of a follow-on contract for the continued provision of highly specialized services when it is likely that award to another source would result in 1) substantial duplication of cost to the Government that is not expected to be recovered through competition, or 2)

Unacceptable delays in fulfilling the agency’s requirements (also reference 10 USC 2304(d)(1)(B) for authority). This provision does not require both causes to be present, but only one or the other;

in this case, both are present.

It is not efficient nor in the best interest of the agency to pursue a standalone contract outside of a

Schedule contract when the infrastructure and authority exist to satisfy these circumstances through a limited source justification for a logical follow-on.

There is no evidence of contract mismanagement as the agency was tasked with providing quick turnaround times for various deliverables as mandated by the Congress. Therefore, the authority given under FAR 8.405-6(a)(1)(C) is prudent and applicable.

5. Determination by the Contracting Officer the Order Represents the Best Value.

The Task Order for the work described herein represents the best value consistent with FAR

8.404(d). The work which will be placed under the BCG’s Federal Supply Schedule will be based within the limits and at the rates specified in the Schedule’s pricing to include rates negotiated with the previous task order which was competitively priced. The new Task

Order will ensure that there is not an unacceptable delay in producing the final reports and providing the required briefings to the U.S. Congress which are time sensitive.

6. A Description of Market Research Conducted OR A Statement of the Reason

Market Research was Not Conducted.

An RFI was published and made available on GSA eBuy to 1,313 schedule holders under SIN

874-1 Integrated Consulting Services on December 30, 2015. All previous companies that proposed on the original task order were distinctly marked to ensure receipt of the RFI. The

RFI outlined the original anticipated scope of work, which included change management and a category review, not identified in paragraph 3 above. Nine responses were received; eight which declined to provide a quote and a direct response from BCG outlining their qualifications for the logical follow-on task order. No other responses were received. After the

RFI closed, the customer revised the scope of work to that identified in paragraph 3. Despite the scope change, it is not anticipated that more firms with superior technical and past performance experience would be available in the market sector. Even if new firms have recently emerged, it would be impossible for any firm to become fully competent to the past twelve months of research and proposal development achieved during the original task period to meet the new requirement. FAS has communicated with the client regarding other potential sources to accomplish the requirement in the accelerated timeline, and there is no confidence any other firm would be capable of meeting mandated deadlines without a significant and costly effort. Moreover, BCG’s response to the RFI has identified that the firm is capable of quickly providing a quote and will meet schedule as they are privy to all the data, processes, and information generated under the previous tasks. BCG remains the firm for a logical follow- on order capable of meeting the current deadlines.

7. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome

Any Barriers that Led to Restricted Consideration.

This procurement is expected to be a one-time requirement to complete the congressionally mandated March 1, 2016 report and subsequent after- action items. FAS & the client have worked together to further define the DeCA’s immediate requirement which entails items noted in paragraph 3, thus limiting this “follow-on” order to the government’s minimum needed requirements. After the plan is developed there is a known requirement to implement and assess the pilot programs.

and belief.

8. Any Other Facts Supporting the Justification.

N/A

9. TECHNICAL/REQUIREMENTS PERONNEL CERTIFICATION:

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms the basis for the justification, are accurate and complete to the best of my knowledge

06 Jan 2016

Date

Director, Acquisition Management (DeCA)

10. CONTRACTING OFFICER’S CERTIFICATION:

I certify this justification is accurate and complete to the best of my knowledge and belief.

1/6/16

NICOLE HAINES Date Contracting Officer