JA_3_July_2019_(002)_Ver_2_080719_Final_Signed_Redacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND

OPEN COMPETITION (OTFAOC)

Federal Acquisition Regulation (FAR) Part 6 Justification & Approval (J&A), Supporting Procurements under FAR Part 12, and FAR Part 15

Purchase Request Number: 821913765 Follow on Contract Number: HC1028-14-C-0028 Procurement Title: Defense Commissary Agency (DeCA) Time and Attendance System Estimated Value:

Statutory Authority: FAR 6.302-1/Defense FAR Supplement (DFARS) 206.302-; Only on responsible source and no other supplies or services will satisfy DeCA’s requirement, 10 U.S.C.

2304 (c)(1).

JUSTIFICATION FOR OTFAOC

Justification for OTFAOC Number:

Upon the basis of the following justification, I Grant Greer as the Approval of the Justification authority In Accordance With (IAW) with FAR 6.304(a)(1), hereby approve the use of other than full and open competition of the proposed contractual action pursuant to the authority of FAR 6.302-1.

1. REQUIRING AGENCY AND CONTRACTING OFFICE:

a. Requesting Agency: DeCA 1300 E Avenue Fort Lee, VA 23801

b. Contracting Activity: Defense Information Systems Agency (DISA), Defense

Information Technology Contracting Organ10ization

(DITCO)-PL8312

2300 East Drive Scott Air Force Base, Illinois 62225-5406

2. NATURE/DESCRIPTION OF ACTION(S):

a. This procurement is for a bridge action for the time and attendance system under contract HC1028-14-C-0028. These services will be extended by 12 months to allow for integration of the Defense Agencies Initiative (DAI) system.

b. The period of performance (PoP) will be September 29, 2019 through September 28, 2020. The total estimated cost is Fiscal Year 2019 Operations and Maintenance Funds are provided under Military Interdepartmental Purchase Request number The applicable North American Industry Classification System code is 541512, with a size standard of $25,500,000.

3. DESCRIPTION OF SUPPLIES/SERVICES:

DeCA’s current contract (HC1028-14-C-0028) is sustaining DeCA’s Time and Attendance System (TAS). The TAS is DeCA’s investment in a practical and proven technology that meets DeCA’s functional and technical requirements from September 29, 2014 to September 28, 2019 and subsequently built DeCA’s knowledge that provides an advantage over other vendors in the market. The GHG Corporation (GHG) provides all personnel, helpdesk support (Tier I, II, and III), hardware, hardware maintenance, software, software maintenance (e.g., patches, upgrades, code changes, salutes, mandates, directive, policy code changes), site surveys, site preparation, installation, de-installation, trade-in, test data, data conversion, and training to DECA’s Contiguous United States (CONUS) and Outside Continental United States (OCONUS) locations.

In addition, GHG’s solution captures the TAS information, validates and corrects data, and generates certifications per Defense Finance and Accounting Services’ (DFAS) Defense Civilian Pay System (DCPS) requirements in a manner that enables DeCA to realize its expected business outcomes. The TAS support under HC1028-14-C-0028 supports DeCA employees at both CONUS and OCONUS locations who are paid via DFAS’ DCPS. The TAS enables employees at all levels to interact for time capture, reporting payroll exceptions, and submitting time and attendance data with or without access to a personal computer (PC) via a web application. The system has a bi-directional interface with DCPS and one-directional interfaces with two DeCA systems – the DeCA Electronic Records Management and Archive System (DERMAS) and the Enterprise Data Warehouse (EDW).

Sixty percent of DeCA employees paid via DCPS have either intermittent or part-time work schedules, which results in frequent schedule changes and related exception data. Currently, DeCA uses TAS automated process to record time and attendance (T&A) data and to support payroll actions for approximately 14,000 employees worldwide at stores, central distribution centers (CDCs), area offices, and headquarters.

This bridge will include the FAR 52.217-8 Option to Extend Services clause in the event additional support for the current TAS is required during implementation and testing of the new TAS system.

4. IDENTIFICATION OF STATUTORY AUTHORITY:

In accordance with FAR 6.302-1 and DFARS 206.302-1, Only one responsible source and no other supplies or services will satisfy the agency requirements, 10 U.S.C. 2304 (c)(1).

The original contract was not previously issued under sole-source or limited-sources.

Additionally, IAW FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements. Specifically, under FAR 6.302-1(a)(2)(iii), services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in--(A) Substantial duplication of cost to the Government that is not expected to be recovered through competition, or (B) Unacceptable delays in fulfilling the agency’s requirements. (See 10 U.S.C. 2304(d)(1)(B)).

In accordance with the Chief Financial Officers Act of 1990 and Federal Financial Management Improvement Act of 1996, DeCA is mandated transition its financial business system’s legacy accounting systems – Defense Business Management System and Standard Financial System to a DAI End-to-End Capabilities.

5. DEMONSTRATION OF CONTRACTOR’S UNIQUE QUALIFICATIONS:

(a) Description of events.

GHG was competitively awarded an implementation and sustainment contract including options years to provide implementation of the TAS and day-to-day support and maintenance of these programs under contract HC1028-14-C-0028. GHG is DeCA’s TAS legacy program developer and is critically involved in the current program interfaces; they have the current knowledge to support DeCA’s current TAS. GHG is the only source capable to provide the needed support that has the corporate knowledge and expertise for overseeing execution without interruption to the schedule. DeCA estimates it would incur a minimum of a 12-month delay, and likely a one-year delay in schedule if award for follow-on support were not made to GHG. In addition to schedule delays, it is anticipated that there would be a substantial increase in cost.

GHG developed a customized forms module, which strictly aligned with DeCA’s payroll business rules. GHG’s customized form module converted our manual payroll process into an automated process which enable employees to submit their own time and attendance exceptions request data (e.g. leave request, DeCA work schedule establish/change request, request for overtime authorization, Pay and Leave Adjustments/Corrections, and Claim For Creditable Time in a Travel Status) for supervisor’s validation and approval. GHG’s customized automated forms module includes classroom Train-the-Trainer instructions, DeCA specific Users Guides, Training Aids, and classroom videos.

GHG’s specific DeCA business rules proprietary software coding and electronic Timekeeping CAC Units (eTCUs) T&A input device allowed the DeCA store level employees to switch from a paper handwritten timesheet to an automated eTCU input device for their T&A data submission (aka 608 timekeeping units at Commissary Store and Central Distribution Center levels worldwide). To include software installation, hardware deployment and installation, training, and hardware and software maintenance.

In addition, GHG’s specific DeCA business rules proprietary software coding and eTCU T&A input device solution captures time and attendance information, validates and corrects data, and generates certifications per DFAS and DCPS requirements in a manner that enables DeCA to realize its expected business outcomes. The TAS environment has a unique dependency structure both within and external to the DeCA environment. The existing bi-directional interface with DCPS and one-directional interfaces with DERMAS and EDW make TAS a diversely integrated and unique solution. This basic structure and the TAS solution itself are inherently complex in nature and difficult to imitate.

(b) Justification.

(1) Minimum Government requirements.

In July of 2001, Secretary of Defense issued a memorandum to the Department of Defense (DOD) establishing the Financial Management Modernization Program (FMMP) under the sponsorship of the USD-Comptroller. The Director of the Business Transformation Agency (BTA) of the DOD began carrying out the initiative for financial management transformation in the Defense Agencies. The BTA Director mandated that DeCA eliminate or replace its financial management systems that are duplicative, redundant, and/or fail to comply with the standard set forth by the Chief Financial Officers Act, Federal Financial Management Improvement Act, U.S.

Standard General Ledger’s accounting standards, and the U.S. Government Standard General Ledger (GAO 1997).

DAI represents the BTA’s effort to modernize Defense Agencies’ financial management processes by streamlining financial management capabilities, eliminating documented material weaknesses, and achieving financial statement auditability. DAI is intended to be a standardized financial management solution set for DeCA, as well as, other Agencies and field activities within the DoD.

This justification is to bridge the services identified above services until the implementation of the DOD mandated DAI system through September 29, 2019. This bridge effort is necessary to continue support for DeCA’s current TAS system until the Defense Logistics Agency (DLA) subscription service for DOD mandated DAI TAS is implemented. DeCA requires uninterrupted execution of the Agency’s TAS Legacy Programs.

(2) Proposed sole source contractor.

The current contractor GHG is the only sources that can fulfill this requirement without risk of a substantial break in service until the DOD mandated DAI system is implemented. It would not be logical or efficient for the Agency to compete this short-term bridge contract. This logical follow-on is in the best interest of the Government, in the interest of economy and efficiency, as it makes more sense to continue with the current contractors until the implementation of the DAI system.

Further, the current contractor is the only contractor capable of fulfilling these necessary requirements in the necessary timeframe, without risk of a substantial break in service/support. On-boarding another contractor for such a short duration before the requirement comes to an end is not economical, as it would significantly increase the risk to the Government, due to the added transition time required. The current contractor is the only firm that will not incur unacceptable delays and unnecessary costs, which would negatively impact mission accomplishment.

GHG is the requirements developer for the DeCA’s TAS program and they are responsible for maintaining under this current contract. The incumbent’s personnel have the corporate knowledge of the modernization of DeCA’s systems, and the historical continuity critical to uninterrupted implementation. The longevity and corporate expertise of the incumbent personnel for fulfilling the modernization cannot be overstated. The impacts of changing personnel would be catastrophic in terms of schedule and financially to the completion and fulfillment of the effort. In addition, GHG has business rules software coding that is proprietary to their company.

(3) Discussion regarding cause of the sole source situation.

This continuation of service by the incumbent is due to the DOD mandated implementation of the DAI system. There is a need to extend the current contract via bridge extension to allow for continued services until implementation of the DAI system can be made. Although other contractors could potentially perform this effort, there is not time available, nor would it be in the Government’s best interest, to conduct another competitive procurement for these short duration bridge extension.

In addition, it was identified that the current incumbent has proprietary software coding implemented into the TAS that would increase transition risk if competed. At the end of this bridge, the current TAS will be at end-of-life.

(4) Impact.

If other than an exception to full and open competition were pursued it would result in significant risk to DeCA including the execution of schedule and increased costs. A re-compete of the services ensure delay in accomplishing the mission, which ensures mission failure.

Without a bridge effort, critical operational sustainment of the current service requirements would cease, thus leaving DeCA without an operable TAS system. This would result in DeCA’s 241 commissaries, twelve central distribution centers (CDCs), area offices, headquarters, and off-site locations (e.g., employees conducting sales at National Guard and Reserve sites for a limited number of days) worldwide without an operable TAS. All of these ramifications are unacceptable in order to meet the Government’s mission.

It is in the government’s best interest to extend the existing contract until the implementation of the DAI system, because the depth of knowledge required to ensure the DeCA mission essential hardware/software solutions to perform optimally cannot be realized by inexperienced personnel. Given the short period of time between the end of the existing contract and the implementation of the DAI System is not cost effective or feasible to onboard a new contractor through a full and open competition.

6. FEDBIZOPPS ANNOUNCEMENT/POTENTIAL SOURCES:

A synopsis was posted to FedBizOpps notifying the industry of this requirement and our intent for a sole-source procurement. The notice was posted on June 13, 2019. It was posted for 15 days until June 28, 2019. DISA/DITCO received no inquiries IAW the posted synopsis about this procurement during the 15-day synopsis posting.

7. DETERMINATION OF FAIR AND REASONABLE COST:

The Government will utilize the various proposal analysis techniques described in FAR 15.404-

1. The contractor-proposed pricing will be compared to an Independent Government Cost Estimate, market research, and historical data to include other contracts for similar efforts.

Based on this analysis, the contracting officer will negotiate a fair and reasonable price. A further determination will be made by the Contracting Officer that the action represents a fair and reasonable cost to the Government by conducting both a technical and price evaluation as part of a fair and reasonable price determination.

8. MARKET RESEARCH: IAW DISA Acquisition Regulation Supplement, DARS 19.202(S- 91)(1)(i), a signed market research form is not required for bridge contract actions.

9. ANY OTHER SUPPORTING FACTS:

• Complexity: DAI has not deployed to an agency comparable to DeCA in size and complexity. There are currently ten agencies using DAI OTL. The largest is Missile Defense Agency at two sites with approximately 2300 employees on static work schedules. DeCA has about 14,000 employees worldwide, the majority working at store level representing a mix of full-time, part-time, and intermittent.

• First to Deploy: The agency would assume risk in being the first to deploy a baseline with significant changes. DeCA does not want to be on the bleeding edge of any deployment as DeCA’s workforce is not similar to those of some of the other organizations that will deploy DAI OTL.

Multiple Deployments: DeCA may have to implement DAI at least two times. The first implementation would be DAI OTL. The second, DAI Financials, would require the conversion of the financial documents created by DAI OTL if the account structure changes between DAI OTL and DAI Financials implementations.

10. LISTING OF INTERESTED SOURCES:

DITCO received no inquiries about this procurement during the 15-day synopsis posting on FedBizOpps (FBO) of interested sources displaying their technical capabilities to provide this service.

11. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME BARRIERS

THAT LED TO THE EXCEPTION TO FULL AND OPEN COMPETITION:

(a) Procurement History.

(1) HC1028-14-C-0028 awarded on September 29, 2014.

(2) FBO Open Market

(3) Large Business

(b) This requirement is at end-of-life, thus there is no need for this support after September 28, 2020.

(c) The previous procurement was awarded using full and open competition and the DOD mandated DAI system will be procured using a DLA subscription.

12. REFERENCE TO THE APPROVED ACQUISITION PLAN (AP): This action is below the regulatory threshold for an Acquisition Plan.