J and A Chief Accountant.pdf

JUSTIFICATION AND APPROVAL FOR EXPEDITED PROCEDURES PACKAGE

TO: Sean Hofmann, Contracting Officer

CC: Deborah Broderick, Agency Competition Advocate

FROM: Joseph Chon, Office Director, Office of Financial Management

DATE: September 19, 2024

SUBJECT: Justification for Other than Full and Open Competition under the Expedited

Procedures Package (EPP) for Afghanistan.

1. This document sets forth the facts and rationale justifying the use of other than full and open competition.

Approval is requested for the justification for use of other than full and open competition pursuant to the authorities under the Expedited Acquisition and Assistance Procedures (EPP) for Afghanistan, approved on December 9, 2021 and extended on October 7, 2023 through December 8, 2025. Your approval of this J&A constitutes the justification for other than full and open competition as required by Tab 1 (D&F for the Authorization of Less than Full and Open Competitive Procedures in the Modification or Award of Contracts) of the EPP.

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

This is a request to approve a follow-on United States Personal Services Contract (USPSC) award to XXXXXXXX for a base period of one year with two option years1. Under this action XXXXX will provide high level financial management support in accounting. He will serve in a unique and highly specialist senior role and will be an expert on a broad variety of accounting and financial systems, the Agency's integrated automated financial system (Phoenix) and all matters relating to the technical aspects of the Mission program and Operating Expense (OE) budget, accounting payments, accounts receivable, and financial reporting. Performance will commence o/a October 2024 when all onboarding processes are completed. The place of work for this position is continental United States (CONUS).

3. Description of the supplies or services required, including an estimated value:

1 For PSCs being hired with a U.S. duty station, all funding must be provided in FYs 2022, FY 2023 and FY 2024, including funding for option years, unless authority is identified for funding after those FYs. Under FAA 636(a)(3), PSCs are hired to perform services abroad. FY 2022 CR Section 2401 and subsequent reauthorizations of Section 2401 Authority provides an exception for PSCs but only if they are funded in FY 2022, FY 2023 and FY 2024.

Consult with OFM and RLO on the availability of funding these PSCs in FYs 2025 and beyond.

XXXXXX will have primary responsibility to execute the budget, accounting, and payment functions for the Mission’s highly complex program and operating expense portfolio. In those capacities, the incumbent’s responsibilities and duties shall include, but not be limited, to financial management and oversight, analysis and reporting and risk management and internal control. Under financial management and oversight he will serve as the principal manager for the daily operations of all financial management systems, practices, procedures, and applicable problems and responsible for planning, directing, and administering a comprehensive accounting, payment, reporting, and budgeting system designed to provide senior Mission management with timely financial information for strategic decision making. He will also be assisting and advising the technical teams with the development of improved financial management systems and procedures at project implementation units, with views towards improving the internal control environment and monitoring over projects. In addition, he will oversee the coordination and implementation of the Mission’s annual Federal Managers’ Financial Integrity Act (FMFIA) assessment of risks and development of control techniques, review of management controls and ensure compliance with reporting requirements.

A complete position description is attached. The total estimated cost of the contract is $235,000.00.

4. Statutory authority permitting other than full and open competition:

AIDAR 706.302-70(b)(3) and 40 U.S.C. §113; see Action Memorandum titled “Expedited Acquisition and Assistance Procedures for Afghanistan” approved on December 9, 2021. On October 7, 2023, the EPP was extended through December 8, 2025.

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

The incumbent, XXXXXXX has served in this unique and highly specialized senior role for nearly a decade. He is an expert on a broad variety of accounting and financial systems, the Agency’s integrated automated financial system (Phoenix) and all matters relating to the technical aspects of the Mission program and Operating Expense (OE) budget, accounting, payments, accounts receivable, and financial reporting. In carrying out this role, worked with a lot of autonomy and was responsible for providing expert advice on foreign assistance financing, financial management operations, and the coordination and preparation of budget submissions -all in support of USAID/Afghanistan.

The mission continues to work on stabilizing the operations currently relying on the support from other missions through MOUs and ISCs. Due to the volume of work, only the most critical items have been attended to. Increasingly, this puts the Mission at operational and programmatic risk and is further magnified by the high rate of turnover in Foreign Service Officers (FSOs), absent the stabilizing presence of FSNs who provide continuity and knowledge transfer. This is particularly critical within the Office of Financial Management, where transactions exceed life-cycles beyond a decade and are required by statute to be continuously monitored and reported. Consequently, it is imperative USAID/Afghanistan employ a seasoned Chief

Accountant who will help ensure the Mission’s compliance with Federal financial regulations and provide continuity between FSO transfers.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable.

The initial award was made following a solicitation publicized to around one-hundred and fifty-one (151) former CCNPSCs.

7. A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The anticipated cost was calculated based on the classification grade and step range, including allowances. It is consistent with USAIDs Position Level and Market Value Determination and therefore is determined to be fair and reasonable. For this award the anticipated TEC amount is USD$235,000.00 for the one (1) year base period.

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

No formal market research was conducted, and the general costs of an offeror with XXXXXX background, coupled with his salary history are deemed fair. The skills available in the US labor market are well known through USAID's ongoing recruitment and screening processes.

9. Other facts supporting the use of other than full and open competition.

None.

10. Sources, if any, that expressed, in writing, an interest in the acquisition.

None.

11. The actions the Agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required:

Subsequent acquisition of services after completion of all option years or substantive changes to the statement of duties under a reorganized USAID/Afghanistan Mission will be solicited from as many potential sources as practical.

12. Technical or Requirements Personnel Certification:

In accordance with FAR 6.303, I hereby certify that the technical statements included above which form a basis for the justification are complement and accurate in accordance with EPP titled Expedited Acquisition and Assistance Procedures for Afghanistan approved December 9, 2021 (attached).

Technical Office Representative Date

13. Resident Legal Office Clearance:

Carson Thomas, Resident Legal Officer Date

14. Contracting Officer Certification:

In accordance with FAR 6.303, I hereby certify that the justification is accurate and complete to the best of my knowledge and belief.

Sean Hofmann, Contracting Officer Date