GSQ1117BJ0028_Draft_JOFOC.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

GSQ1117BJ0028

1. Requiring Activity: Government National Mortgage Association Contracting Activity: GSA/AAS/FAS Contract Number: GSQ1117BJ0028 (ID11160047)

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

The Government National Mortgage Association (Ginnie Mae) hereby requests a modification to contract GSQ1117BJ0028 to procure subscriptions to major publications. Subscriptions include (but are not limited to) Inside Mortgage Finance; Inside FHA/VA Lending; Inside MBS & ABS;

American Banker; Asset Securitization Report; The Bond Buyer; National Mortgage News;

Bloomberg Government; Wall Street Journal Digital; Leadership Directories; New York Times;

Politico Pro and Congressional Quarterly. These publications are used to provide Ginnie Mae executive staffs with a summary of important news, several of these publications are mandatory for Ginnie Mae operations.

3. Description of supplies or services required to meet Ginnie Mae’s needs:

Ginnie Mae require access to all of these publications/subscriptions in order to monitor current legislation and stay informed of upcoming hearings, access full written testimony and stay abreast of other important topics in the mortgage backed securities industries. Although this is a pass-through function for the vendor, not obtaining these subscription services Ginnie Mae staff would not be able to perform key monitoring functions which would inhibit their abilities to effectively identify potential issues in Ginnie Mae pools and potential performance problems with specific issuers.

Funding:

The estimated cost to procure these items in the base year of the contract is estimated to cost $175,401.59.

4. Identification of the statutory authority permitting other than full and open Competition:

41 USC 253 (c) (2) (FAR 6.302-1) – Only one responsible source and no other supplies or services will satisfy agency requirements.

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The contract was awarded to Home Front Communications, on June 26, 2017, and because these services are just a pass-through for the vendor it would be in the best interest of the Government to move forward with modifying the existing contract since the vendor already has agreements with several of the service providers for the subscriptions services.

The solicitation, from which the contract was awarded, included a line item for Clips/Subscription services. After award of the contract, the newly appointed Technical Monitor discovered that the resulting award contained for Clips and Subscriptions Services (0004, 1004, 2004, 3004 and 4004 for a base and 4 (12)-months option periods. In additional there was a task included in the work statement (2.2.4 Task-Four) for Clips and Subscription Services. However, only funding for Clips had been included in the contract at time of award. These subscription services are a necessity to Ginnie Mae for it all the organization to monitor issuers and stay informed of industry trends and information concerning the housing market. In addition these services are utilized by Ginnie Mae’s senior management.

6. A description of the efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a FEDBIZOPPS notice was or will be published as required by FAR 5.2, and, if not, which exception under 5.202 applies.

Efforts will be made to advertise for additional sources of interest. The requirement for notice to potential sources, for example through publication in FedBizOps pursuant to FAR Subpart §5.2, is specifically exempted for contract actions subject to the conditions of unusual and compelling urgency, in which the Government would be seriously injured by the delays that such notice requires. The exemption is specifically provided in FAR §5.202(a)(2).

7. The Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable. The Government will compare the prices submitted for this modification to the existing contract action and to the Independent Government Cost Estimate to determine the proposed cost to be fair and reasonable. It has been determined by the Contracting Officer that the contract will be modified to include an open market line item for the subscription services.

The cost to continue this effort is estimated to cost $175,401.59.

8. A description of the market research conducted (see FAR Part 10) and the results or a statement of the reason market research was not conducted:

Pursuant to FAR Parts 10 and 12, comprehensive market research is currently being conducted during the acquisition planning stage for the re-competition action. An RFQ will be posted in the near future to solicit competitive offers for this CLIN.

9. Any other facts supporting the use of other full and open competition:

In case of an emergency, Ginnie Mae must be able to access all vital records needed to continue with business operations. Ginnie Mae must have access to the documents 24/7 as required by HUD, NIST and NARA regulations.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

Due to the unusual and compelling urgency of this requirement, a listing of sources was not sought for this extension. As such, there is no listing of sources being provided.

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the services or supplies are required.

Ginnie Mae requests this unusual and compelling urgent action to address the short time period needed to complete final stages of the acquisition process. This request is required to maintain the continuity of services and minimize programmatic, financial and operational risks.