ID15160003_J&A_2018-12-11_Signed.pdf

GSA, FAS, R5 Page 1

General Services Administration (GSA)

JUSTIFICATION AND APPROVAL

JUSTIFICATION FOR EXTENSION OF CONTRACT

CONTRACT# GS15Q16IAC0001, Modification 11, ITSS ID# ID15160003

The General Services Administration (GSA) makes this Justification and Approval (J&A) for Other Than Full and Open Competition orders pursuant to Federal Acquisition Regulation (FAR) 6.302.

1. Identification of Agency and Contracting Activity:

Agency:

General Services Administration (GSA) Federal Acquisition Services (FAS) Office of Systems Management (OSM), Integrated Award Environment (IAE) 1800 F Street NW Washington, D.C. 20405

Contracting Activity:

GSA Region 5 Contracting Division 230 S Dearborn Street, Floor 3300 Chicago, IL 60604

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

This approval is being requested for a firm fixed price, sole source extension of D&B’s current contract under GS15Q16IAC0001. This extension is necessary so that the government can transition SAM.gov entity validation services from the current Dun & Bradstreet (D&B) subscription services to a new contract which has an anticipated award date in December, 2018. See Section 11, below, for more details. This contract extension will provide for continuation of Dun & Bradstreet (D&B) subscription services for the Data Universal Numbering System (DUNS) Number, which currently serves as the government-wide “unique entity identifier” used to identify a specific commercial, nonprofit, or Government entity, and associated unique entity validation services. The transition period is uncertain but not likely to take less than one year. Therefore, this non-competitive request is for a potential period of performance of two (2) years and is comprised of a one-year base period and two (2) six-month option periods. The GCE (Government Cost Estimate) amount of the effort is $39,430.443.00.

3. A Description of Supplies/Services Required to Meet Agency’s Need:

GSA IAE seeks to procure D&B Subscription Services with expanded data rights. Under this contract, the assignment of a unique entity identifier and initial objective verification (validation) of entity-provided information against authoritative sources for data associated with the unique entity shall occur within 24 hours. Entity validation services shall include:

1. Address Standardization – a properly formatted and postal service-recognized address, to include international addresses

2. Address Verification – the stated address must be tied to a business entity, established at that specific location

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3. Business Legitimacy – established as entity name + Address Standardization and verification that is independently verified from a specified number of independent data sources

4. Confirmation of the existence of and/or assignment of a unique identifier formatted as a 9-digit numeric value

5. Corporate Hierarchy – maintained and updated with changes for the duration of the contract

6. Customer Support - helpdesk services to assist with aspects of unique entity identifier assignment and entity validation

4. An Identification of the Statutory Authority Permitting Other Than Full and Open Competition:

The authority under which this J&A is made is pursuant to FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

This Sole Source contract will be awarded pursuant to the authority of 41 United States Code (U.S.C.) 3304(a)(1) as implemented by FAR 6.302-1.

5. A Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Requires Use of the Authority Cited:

GSA intends to enter into negotiations for an extension on the current contract to D&B, the incumbent contractor for subscription services related to the unique entity identifier (currently, the DUNS Number) and associated entity validation services.

This contract ensures individual agencies don’t have to separately contract for identical validation services. The contract provides software to facilitate data exchange, matching, and direct integration that supports information collection from multiple and varied sources. It enables federal entities to attain a single business profile which can then be used to drive business decisions. In addition, the current contract also provides programmatic management and call center support services. All contracts, grants, loans, and other spending activity reported in GSA IAE systems are currently tied to D&B information.

Though regulatory changes and government data right expansions have occurred to enable future competition, until programmatic and system changes occur within GSA IAE systems, and those of other government agencies, to permit an entity identifier other than the DUNS Number, D&B will need to remain under contract with the government during the transition period as they are the only provider of the DUNS Number and its associated entity validation services.

6. A Description of Efforts Made to Ensure that Offers are Solicited From as Many Potential Sources as Practicable:

In accordance with FAR 5.202(a)(11), the proposed contract action is made under the terms of an existing contract that was previously synopsized in sufficient detail to comply with the requirement of 5.207. The notice of intent to sole source notice was published in Federal Business Opportunities on 27 April 2010 with a response data of 11 May 2010.

7. A Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable:

Based on the data gathered, the Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable. The expectation of reaching a fair and reasonable

GSA, FAS, R5 Page 3 price was determined through market research (based on previously negotiated pricing) in order to determine best value for GSA. The total amount of funding required for the total estimated period of performance (a one-year base period and two six-month option periods) is approximately $39,430.443.00.

8. A Description of the Market Research Conducted and the Results or a Statement of the Reason Market Research was not Conducted:

There was no additional Market Research conducted. The Government requires stability and continuity in the D&B Subscription Services from the existing contractor while the Entity Validation Services procurement is competed, awarded, and the Government prepares to transition to a government-owned entity identifier with separately competed, contractor-provided entity validation services.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition:

Please see 11. below

10. A Listing of the Sources, if any, That Expressed, In Writing, An Interest in the Acquisition:

To date, the Contracting Officer has not received any statements of interest regarding the proposed Sole Source effort, with the exception of the incumbent, Dun & Bradstreet, Inc.

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 Supplies or Services Required:

This contracting action is part of an on-going, multi-year planned strategy designed to move the Government out of the current non-competitive environment caused by vendor lock-in and into one that facilitates competition by being vendor-agnostic.

Two significant changes occurred in 2016 which enabled GSA to further explore alternatives related to D&B’s DUNS Number for uniquely identifying entities receiving federal funds. The first was a contractual change to the current D&B contract that expanded government data rights and the second was a regulatory change under FAR and Titles 2 and 48 of the Code of Federal Regulations (CFR) that promulgated the removal of any proprietary references to D&B and the DUNS.

The expansion of government data rights and the regulatory change to remove proprietary references in the FAR and the CFR were necessary steps to permit competition of entity validation services. Though these changes enabled competition, a period of government transition is required to enable both IAE and the downstream government systems that utilize the DUNS to make system and programmatic updates to be able to utilize an alternate unique entity identifier.

A competitive acquisition is well underway for entity validation services. A request for proposal was issued on August 31, 2018 under ITSS ID#15170001. Proposals were submitted on October 12, 2018. Award is expected in December 2018.

IAE determined that the best and most complete solution is to implement a new approach where entity validation services (EVS) are provided by the future EVS contractor and integrated within SAM.gov, utilizing the SAM Managed Identifier (SAMMI) as the unique entity identifier for

GSA, FAS, R5 Page 4 identifying and managing entities within SAM and other IAE systems and mapping to both the current, and any future, EVS providers’ identifier. The SAM Managed Identifier will be generated within SAM.gov, where entity information is currently collected today.

Transition to the SAMMI will allow for the decoupling of the unique entity identifier from the supporting entity validation services. With this approach, EVS providers can be agnostic and more easily transitioned at contract expiration without excessive government-wide transition costs and effects, allowing for the competitive procurement of entity validation services.

12. Technical Certification.

I justify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

NAME: Meredith M. Whitehead DATE: ____________________________

TITLE: Director, Business Operations Integrated Award Environment SIGNATURE: _______________________

13. Contracting Officer Certification.

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

NAME: Julie Green DATE: ____________________________

TITLE: Contracting Officer SIGNATURE: ______________________

GSA, FAS, R5

14. Legal Sufficiency Review. I have reviewed the foregoing justification and approval and deem it legally sufficient.

Name: Scott McCleary DATE: ____________________________

Title: Legal Counsel SIGNATURE: ______________________

Special Competition Advocate Approval (if applicable)

Based on the foregoing justification, I hereby approve the procurement of Dun and Bradstreet Subscription Services being procured on an other than full and open competition basis pursuant to the authority of 41 United States Code (U.S.C.) 3304(a)(1) ) as implemented by FAR 6.302-1.

Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

Approval is granted subject to the availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

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NAME: Anne Mesch DATE: __________________________

TITLE: Special Competition Advocate SIGNATURE: ______________________

Head of Contracting Activity Approval (if applicable)

I have reviewed this justification and approval for procurement of Dun and Bradstreet Subscription Services being procured on an other than full and open competition basis pursuant to the authority of 41 United States Code (U.S.C.) 3304(a)(1) as implemented by FAR 6.302-1.

Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, consistent with paragraph 4.

Name: Kim Brown DATE: ____________________________

Title: Head of Contracting Activity SIGNATURE: ________________________