ID15160011_Mod_15_J&A_for_Logical_Follow-on_for_FSD_2019-03-05_Signed.pdf
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General Services Administration
JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY
UNDER IDIQ CONTRACTS
GWAC CONTRACT# GS00Q09BGD0027, TASK ORDER: GSQ1516IA0016, ITSS ID# ID15160011
MODIFICATION 15
The General Services Administration (GSA) makes this Justification for the issuance of an Exception to Fair Opportunity pursuant to Federal Acquisition Regulation (FAR) 16.5.
1. Identification of Agency and Contracting Activity:
Agency:
General Services Administration (GSA) Federal Acquisition Services (FAS) Integrated Award Environment (IAE) Office of Systems Management (OSM) 1800 F Street NW Washington, D.C. 20405
Contracting Activity:
GSA, Region 5 Federal Acquisition Services (FAS) Contracting Division 230 S Dearborn Street, Floor 3300 Chicago, IL 60604
2. Nature and/or Description of Action Being Approved:
An extension to the current combination Firm-Fixed-Price (FFP)/ Cost Plus Award Fee (CPAF) task order issued under the Alliant GWAC is contemplated for helpdesk services to support the Federal Service Desk
(FSD).
GSA intends to enter into negotiations for an extension under the current task order to the incumbent contractor, Perspecta Enterprise Solutions LLC, for helpdesk services for FSD.
3. Description of Supplies/Services and Estimated Value:
The General Services Administration’s (GSA), Integrated Award Environment (IAE) office seeks to procure help-desk services from the current contractor, Perspecta Enterprise Solutions LLC, for a one-year base and two six-month option periods.
The FSD is the primary point of contact for all IAE customer support. FSD is a support center that receives calls, chats and web-forms from both domestic and international members of the federal acquisition and assistance community. Presently the FSD manages on average 36k contacts a month. Currently, FY 2019 customer contact volume is estimated to be 500k with another significant increase planned in FY 2020.
IAE is in the process of migrating all of its FSD supported systems/sites into a single system/site called
SAM.gov. The new SAM.gov will provide federal government agencies and contractors with a shared IT system to manage the acquisition and grants-making process from solicitation through closeout. The goals of the SAM.gov are to (1) create a simpler, common, integrated IT service that promotes competition, transparency, and integrity; (2) increase data sharing across the government and with the public to enable better decisions in procurement, logistics, payment, and performance assessment; and (3) take a unified approach to obtaining modern tools to leverage investment costs across the federal government for award-related IT services. Those stand-alone systems included in the migration to SAM.gov are:
● Catalog for Federal Domestic Assistance (CFDA) Note: already transitioned,
● Contractor Performance Assessment Reporting System (CPARS) (including PPIRS),
● Electronic Subcontracting Reporting System (eSRS),
● Federal Awardee Performance and Integrity Information System (FAPIIS.gov),
● Federal Business Opportunities (FBO),
● Federal Procurement Data System – Next Generation (FPDS-NG),
● Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS),
● System for Award Management (SAM), and
● Wage Determinations OnLine (WDOL).
Customer support from the FSD during the transition to the new SAM.gov is imperative to promote consistency for stakeholders that rely on the IAE systems. A highly functioning contact center is necessary to transition users through changing system processes and functionality such as advanced searches, account creation, role migration, data entry, report generation, and data exchange. There are complex rules around user access and entity registration which the FSD supports. In excess of 90% of the contacts under the current contract are related to SAM.gov. A real driver of the need for this procurement is support for the 500,000 entities registered in SAM.gov who will be required to migrate to the new platform in FY 2020.
Expertise from Perspecta, and the tools that are currently in place, will ensure a smooth transition of key systems during the contract period.
The estimated cost to retain the current contractor for an additional one year term is $16,840,231 and including two additional six-month option periods the total is $34,374,724.
http://www.esrs.gov/ https://www.fbo.gov/ https://www.fpds.gov/fpdsng_cms/index.php/en/ https://www.fsrs.gov/ https://www.fsrs.gov/ http://www.wdol.gov/ https://www.sam.gov/ http://www.esrs.gov/ http://www.wdol.gov/
4. Identification of the Exception to Fair Opportunity and Rationale:
This Justification is being prepared as required by FAR 16.505, Exception to Fair Opportunity Process.
The order must be issued on a sole-source basis in the interest of economy and efficiency as a logical follow-on to an order already issued under the contract, provided that all the contractors were given fair opportunity to be considered for the original order (FAR 16.505(b)(2)(i)(C)).
A fair opportunity to compete was given under the original task order GST0013AJ0137 for this requirement which was solicited under the Alliant GWAC and two (2) proposals were received and evaluated on a trade-off basis. The task order number was subsequently updated to GSQ0516BM0154 and later GSQ1516IA0016 following the transfer of Contract Administration from FEDSIM to Region 5. Extensive market research was completed in support of the initial competitive source selection that chose Perspecta Enterprise Solutions LLC (formerly named, Hewlett Packard Enterprise Services) as the Government’s FSD contractor.
The relationship between the original competed order and this follow-on is logical and in the best interest of economy and efficiency. Also, as described below, maintaining the current FSD contractor is critical due to:
● Retain Knowledge During Transition - The knowledge required to support the planned migration of
WDOL, FBO and SAM systems into beta.SAM.gov
● Security Clearances and Personnel Training - The time required to obtain security clearances for new hires and for personnel training
● Technical Build-out Schedule - The technical build-out required in beta.SAM.gov to support the integration of helpdesk services into a single site.
Retain Knowledge During Transition
The incumbent currently provides a team of trained experts with current and extensive knowledge on these complex applications and their related workflows and business rules. During the next twelve months, CPARS, WDOL, FBO and SAM are scheduled to migrate to beta.SAM.gov impacting both pre-award and post-award phases of the award process for procurement and financial assistance.
Perspecta has significant experience addressing two key issues during a transition: account setup and role migration. They provided support to 500,000 users during the transition to beta.SAM.gov and CFDA. These same skill sets would be required for the CPARS, WDOL, FBO, and SAM transitions.
Readiness for the transition of each system requires months of preparation and each system has its own unique intricacies that require extensive problem-solving to ensure when the transition is transparent and problem-free. Bringing on new customer support would be impractical and costly while transitioning these systems.
Due to the timing of the revised IT modernization schedule, which overlaps the FSD transition schedule, concurrently hiring and training an entirely new service center team would not be practical or possible while at the same time transitioning hundreds of thousands of user accounts and roles.
Leveraging the incumbent’s knowledge and experience during these changes is the best option for meeting our user community needs and avoiding serious consequences to the government-wide awarding of contracts and grants. Retaining the current contractor during this period due to their unique and in-depth knowledge of IAE’s applications and business processes will enable federal and civilian customers to expediently resolve tickets which is in the best interest of the government. The contractor’s level of expertise cannot be easily or economically duplicated. Changing contractors for the follow-on period introduces significant program disruption risk on several high priority investments and is not a viable alternative.
Security Clearances and Personnel Training
The average time required to hire and clear an individual, based on our experience, is four (4) months.
Compounded is the need to process multiple new hires with limited GSA security resources, OPM backlogs, and an estimated eight (8) months after award to have a fully staffed team. The incumbent contractor already has costly, government-cleared Tier 2S security clearance and trained staff available to provide services until such time as the government can re-compete this contract. Agents maintain a high level of system knowledge with constant training and refresher courses. Except for attrition hiring, no additional unforeseen training for the incumbent contractor would be required. Additionally, a provider will be expected to handle surges in staffing required during key transitions. Perspecta has demonstrated a capability to support surges as needed (e.g. notarized letter processing) and is the only contractor who will be surge-ready in early FY 2020. The current contractor drives economical value to the government through its seasoned trained agents and its retention of cleared employees at all levels.
Technical Build-out Schedule
The government intends to replace the FSD, with what will be called SAM.gov Customer Services (SCS), that will be a support center for a single platform in modernized SAM. SCS will serve as the primary point of contact for IAE system users.
The development work to support the integration of helpdesk services into beta.SAM.gov requires the following:
● Development work required by the new contractor to transfer historic data, build and test interfaces between the SAM.gov Customer Service (SCS) contractor, and SAM.gov will require approximately six (6) months based on the estimate of the work.
● Authorization to Operate (ATO) to address security assessments for its new system and platform would take approximately three (3) months after development is completed.
● Concurrently, substantial development work by the government development teams on the beta.SAM.gov site after award of the new contract is expected to take six (6) months.
The technical build-out is expected to take a total of nine (9) months. Due to the numerous improvements IAE intends to make to leverage technology and integrate with beta.SAM.gov under the new SCS contract, the expected transition time has increased dramatically from previous helpdesk transitions. The technical build-out will require resources from both the new contractor as well as IAE design, development and security teams. Further, a fully developed infrastructure which includes a ticketing system, business rules, and operational reporting, are in place that have been able to handle the current surges in workload and encountered challenges. To fully integrate the user experience with beta.SAM.gov will require design, development and testing of new functionality. For example,
● critical development includes user-specific data from the ticketing system displayed in the logged-in user workspace, initiation of chats, submittal of webforms from beta.SAM.gov;
● integration of the new ticketing system with JIRA to assign and resolve Tier 2 and Tier 3 tickets;
and
● sharing of certain user data profiles for creation of tickets.
Until this technical work is completed, any new contractor will be unable to provide a fully integrated solution. Due to unknowns regarding any new contractor’s technical approach to the integration, it is prudent to continue existing services from Perspecta until the new contractor’s technology is fully implemented and tested.
In summary, it is critical Perspecta remain under contract with the government during the transition as they are the only provider currently cleared, trained and staffed to support our customers during critical system transitions and stand up of the new contract. The relationship between the original competed order and this follow-on is logical as the anticipated work closely aligns with the work the contractor currently performs and in the best interest of economy and efficiency as award to a new contractor at this time would cause undue complexity with no realistic return on investment of time and resources.
5. Determination that the Anticipated Cost is 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 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 extended period of performance (a one-year extension/base period with two six-month options) is approximately $34,374,724.
6. Other Facts Supporting the Justification:
There are no other facts.
7. Statement of Actions:
The government is currently conducting market research and is evaluating marketplace capabilities for future contact center requirements. The government intends to separately pursue a competitive procurement for the replacement to the FSD, to be called SAM.gov Customer Services (SCS), that will be a support center for a single platform modernized SAM. SCS will serve as the primary point of contact for IAE system users.
The Government requires stability and continuity in the FSD services from the existing contractor, Perspecta, while the SAM.gov Customer Service (SCS) procurement is competed, awarded, and the government prepares to transition from the FSD to SCS.
8. Certification by Technical or Requirements Personnel:
I certify 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: Nancy Goode SIGNATURE: ___________________________ TITLE: Director, Outreach & Stakeholder Engagement Division DATE: ___________________________ GSA, FAS, Integrated Award Environment
9. Contracting Officer Certification:
I certify that this justification is accurate and complete to the best of my knowledge and belief.
NAME: Julie Green SIGNATURE: ___________________________ TITLE: Contracting Officer DATE: ___________________________
GSA, FAS, R5
10. Supervisory Contracting Officer Certification:
I certify that this justification is accurate and complete to the best of my knowledge and belief.
NAME: Eben Greybourne SIGNATURE: ___________________________ TITLE: Supervisory Contracting Officer DATE: ___________________________
11. Director, Contracting Division Certification:
I certify that this justification is accurate and complete to the best of my knowledge and belief.
NAME: Micky Mayes SIGNATURE: ___________________________ TITLE: Director, Contracting Division DATE: ___________________________
12. Legal Sufficiency Review:
I have reviewed the foregoing justification and approval and deem it legally sufficient.
NAME: Scott McCleary SIGNATURE: ___________________________ TITLE: Legal Counsel DATE: ___________________________
13. Special Competition Advocate Approval:
Based on the foregoing justification, I hereby approve the procurement of SAM.gov Customer Service services being procured on an other than full and open competition basis pursuant to the authority of as implemented by FAR 16.505(b)(2)(i)(C) issued on the basis of logical follow on consistent with paragraph 4.
Approval is granted subject to the availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.
NAME: Anne Mesch SIGNATURE: __________________________ TITLE: Special Competition Advocate DATE: ________________________________
14. Head of Contracting Activity Approval:
I have reviewed this justification and approval for procurement of FSD services being procured as an exception to the fair opportunity process as implemented by FAR 16.505(b)(2)(i)(C), consistent with paragraph 4.
I hereby certify that the Justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that the exception to fair opportunity is in accordance with the requirements, and is in the best interest of the Government.
NAME: Kim Brown SIGNATURE: __________________________ TITLE: Head of Contracting Activity DATE: ________________________________
| 2019-03-06T14:27:43+0000 | |
| Client IP: 159.142.31.93, Transaction ID: 2LlDMA2aCCQBv0pNhB5l4XbGCzk= | |
| eSignLive | |
| E-SIGNED by nancy.goode@gsa.gov, ID: b921106b-4a12-4e70-b065-2ab6aa7337e6 |
| 2019-03-06T13:57:37+0000 | |
| Client IP: 159.142.31.92, Transaction ID: 2LlDMA2aCCQBv0pNhB5l4XbGCzk= | |
| eSignLive | |
| E-SIGNED by julie.green@gsa.gov, ID: GILTF1kBB2M1 |
| 2019-03-06T15:09:17+0000 | |
| Client IP: 159.142.71.5, Transaction ID: 2LlDMA2aCCQBv0pNhB5l4XbGCzk= | |
| eSignLive | |
| E-SIGNED by eben.greybourne@gsa.gov, ID: 83c51765-052a-4824-8220-a4c559fe7255 |
| 2019-03-06T14:23:21+0000 | |
| Client IP: 159.142.71.1, Transaction ID: 2LlDMA2aCCQBv0pNhB5l4XbGCzk= | |
| eSignLive | |
| E-SIGNED by micky.mayes@gsa.gov, ID: 655f9ea0-53b7-4908-ae5e-5ea0d5bc82c3 |
| 2019-03-06T13:59:11+0000 | |
| Client IP: 159.142.71.5, Transaction ID: 2LlDMA2aCCQBv0pNhB5l4XbGCzk= | |
| eSignLive | |
| E-SIGNED by anne.mesch@gsa.gov, ID: 1ba00855-3957-4cc6-91d8-5fab97e68fa8 |
| 2019-03-06T14:02:34+0000 | |
| Client IP: 159.142.71.1, Transaction ID: 2LlDMA2aCCQBv0pNhB5l4XbGCzk= | |
| eSignLive | |
| E-SIGNED by scott.mccleary@gsa.gov, ID: d6483dc6-0412-40fc-8319-247293bdb989 |
| 2019-03-06T18:21:26+0000 | |
| Client IP: 159.142.71.4, Transaction ID: 2LlDMA2aCCQBv0pNhB5l4XbGCzk= | |
| eSignLive | |
| E-SIGNED by kim.brown@gsa.gov, ID: b3725d59-c46d-447d-b41c-99dc0b049fad |
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