JA_6.302-1_W912EQ-11-C-0008_Redacted.pdf

Control No. HNC-16-160677

Justification Review Document for Other Than Full and Open Competition

Program/Equipment: Operations and maintenance services for Corps of Engineers Financial

Management System (CEFMS).

Authority: 10 U.S.C. § 2304(c)(1) as implemented by FAR 6.302-1, “Only One Responsible

Source and No Other Supplies or Services Will Satisfy Agency Requirements”.

Amount: , six (6) month extension from 3 April 2016 to 2 October 2016

Prepared by:

Contracting Officer:

Name: PH:

Title: Date:

Email:

Technical Representative:

Requirements Representative:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Ma nager:

Name:

Signatu re:

Lega l Counsel:

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PARC-WIN CONCURRENCE:

HQ USACE Technical:

Signature: Date:

HQ Legal Counsel:

Signature: Date:

Justification Review Document for Other Than Full and Open Competition

For

Corps of Engineers Financial Management System (CEFMS)

1. Contracting Activity: U.S. Army Corps of Engineers (USACE), Huntsville Engineering and Support Center (CEHNC) located at 4820 University Square, Huntsville, AL 35816-1822.

2. Description of Action: The purpose of this justification is to obtain approval for a modification to contract W912EQ-11-C-0008, extending the period of performance for an additional 6 months under the authority cited in FAR 52.217-8 – Option to Extend Services.

On 11 March 2011, the Memphis District Contracting Office (MVM) awarded contract

W912EQ-11-C-0008 to GPS Information Guidance LLC (GPS), a small business concern, to provide operations and maintenance services on the Corps of Engineers Financial Management

System (CEFMS). This firm-fixed priced contract was funded with Corps of Engineers revolving funds. MVM transferred contract W912EQ-11-C-0008 to CEHNC for administration on 31 July

2013.

3. Description of Supplies/Services: The U.S. Army Corps of Engineers Finance Center (UFC) mission is to provide responsive, professional operational finance and accounting day-to-day support for USACE worldwide. This includes the full range of customer services, payments, disbursing, accounting, and financial reporting for Civil Works and Military Programs appropriated funds, and Revolving & Trust funds. The UFC is responsible for performing research, analysis, and development, installation and systems maintenance for CEFMS. The UFC has the principal responsibility for setting the strategic direction and providing overall operating finance and accounting functions of the USACE. The UFC accomplishes this mission with a dedicated, professional staff of accountants, accounting technicians, information management personnel, and various other support personnel.

The six month extension, estimated at , will extend the contract performance period from 3 April 2016 to 2 October 2016. Total contract value of all periods of performance, to include the extension, is estimated at $45,688,977.97. This 6-month extension period was not evaluated at the time of award. Army Corps of Engineers Revolving Funds are currently available on Purchase Request and Commitment (PR&C) W916TX60494425 to fund this extension, IAW FAR 52.217-8, Option to Extend Services, at the rates previously negotiated in the current period of performance of the contract. Although these rates were previously determined to be fair and reasonable at the time of contract award, this extension period will be analyzed for fair and reasonable pricing based upon the anticipated level of effort and labor mix.

CEFMS is a Government-Off-The-Shelf (GOTS) software application developed by the UFC using commercial software and services. The system was deployed in 1995 and is the primary means of executing financial transactions within USACE. The CEFMS application requires constant management and maintenance in order to respond to executed public law, stake holder requests, and changes in the underlying Commercial-Off-The-Shelf (COTS) software and hardware.

4. Authority Cited: 10 U.S.C. § 2304(c)(1), as implemented by FAR 6.302-1, “Only One

Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements”.

5. Reason for Authority Cited: Failure to maintain the CEFMS will have an adverse impact to life and safety for the Department of Defense, military, civilian and contractor personnel.

USACE manages the numerous critical missions that affect the life and safety of Americans.

CEFMS is the primary financial management system for funding these missions, paying invoices for contract deliveries or contract performance, and paying USACE Government employees.

While the CEFMS application is robust and highly effective, it requires constant maintenance similar to any other complex software solution. CEFMS experienced 407 critical problem reports of the course of 2015. These were errors that would have resulted in the unavailability of

CEFMS, the inappropriate application of funds, the failure to apply funds in a timely manner, they failure to pay invoices, the failure to pay employees, and a host of other critical functions.

The CEFMS Product Management Team (PMT) must also respond to new public laws, regulatory changes, and stakeholder requests in order to maintain a compliant and efficient system. For example, on December 27, 2015, President Obama signed a law that closed the Base

Realignment and Closure (BRAC) accounts from 1990 and 2005 and transferred the unobligated balances into the BRAC 2014 account. The CEFMS PMT had to 72 hours from the time notice was received to deobligate the 1990 and 2005 accounts, move the funds into the 2014 account and revise the CEFMS application to bill all future transactions against the 2014 account. This change also required the addition of new fields to track the funds from the 1990 and 2005 accounts. The CEFMS application was modified 444 times over the course of 2015 due to such changes.

On average, CEFMS must be modified or changed 2.3 times a day to meet mission requirements.

Some of the missions that will be impacted are listed below:

a. USACE operates and maintains approximately 700 dams nationwide. USACE dam safety professionals carry out a dam safety program to make sure these projects deliver their intended benefits while reducing risks to people, property and the environment through continuous assessment, communication and management. USACE dams contributed to $485 billion in damages prevented from 2004 to 2013, with $13.4 billion in damages prevented in 2013.

b. USACE Levee Safety Program works to better understand, manage, and reduce the flood risks associated with levees by inspecting and assessing more than 2,500 levee systems nationwide, and using the data to prioritize action. These preventative measures are necessary to avoid damage in flood zones.

c. Contractors are our force-multiplier during a disaster response. USACE counts on them to help us meet mission requirements quickly and completely. The Corps of Engineers has pre-awarded contracts for major emergency response missions, such as bottled water, packaged ice, debris, and temporary roofing. These contracts are part of the

Advanced Contracting Initiative (ACI). ACI provides depth to the Corps’ ability to respond quickly and effectively. Without reliable operation of CEFMS, USACE contractors and personnel would be unable to respond quickly and effectively to disasters nationwide, resulting in more risk to those impacted.

d. USACE employs more than 35,000 professionals across a multitude of disciplines.

These professionals perform a variety of roles, many critical to the safety of the nation.

CEFMS is the method for tracking and transmitting time and attendance to the Defense

Financial and Accounting Services (DFAS).

e. CEFMS is the only means in USACE for tracking and obligating funds on contracts. It is the only means of recording payment of invoices and without a dependable financial management system, fiscal law violations are highly probable. An unstable CEFMS application could result in an increase in over payments, under payments, interest charges, and Anti-Deficiency Act violations that would impact USACE’s overall budget and reduce funds available for other critical programs.

CEFMS is critical to the proper functioning of USACE as a whole. Failure to successfully maintain CEFMS would result in the inability to process funds across USACE resulting in failure to fund contracts, pay invoices, and pay employees. This would shut down USACE operations across the globe, impacting the Department of Defense, employees and hundreds of agencies.

Therefore, it is critical that the incumbent contractor remain in place during this extension period to ensure continued service and support to these critical systems.

The challenge faced by UFC is finding qualified and capable software programmers that can maintain CEFMS. The CEFMS application was developed using the Oracle Forms platform and deployed in 1995. The initial contract was issued by the General Services Administration (GSA) on behalf of the UFC to develop CEFMS and was focused primarily on the bare-bones production environment. CEFMS was then expanded from 1996 to 1999. The expansion and maintenance of CEFMS was divided by GSA into six separate contracts held by five contractors.

1. ATS - CEFMS Reporting

2. Borklund - CEFMS Software Maintenance (various CEFMS modules)

3. GPS - CEFMS Software Maintenance (various CEFMS modules) & Database

Administration

4. GPS – Corp of Engineers Enterprise Management Information System (CEEMIS)

Software Maintenance & Database Administration

5. Gradkell Systems, Inc. (GSI) - CEFMS Software Maintenance (various CEFMS modules)

6. Jones Automation, Inc. (JAI) - CEFMS Software Maintenance (Electronic Signature)

These contracts did not require design documentation to be generated nor provided as a deliverable. The competitive acquisition for the current contract, W912EQ-11-C-0008, was executed by MVM and consolidated the maintenance and development of CEFMS in order to unify the code development across all sectors of the CEFMS system with future requirements for modernization of the application in mind. However, the software documentation requirement was not clearly expressed in the PWS and not considered in the associated level of effort and pricing for the contract. This decision left insufficient information available for a new contractor to properly evaluate the capabilities needed to immediately provide the requirement, or calculate associated costs. While the oversight was realized in FY13, the majority of the system had already been developed and the Government estimate to produce original design documentation exceeded the available budget for FY13 and FY14. Initial funding to produce the design documents became available in FY15 resulting in the initiation of the Legacy Code Assessment project documented in Paragraph 7. The lack of documentation and the shrinking market base of programmers experienced with the undocumented modules of the CEFMS application, are the predominant limitations on competition for this requirement at this time.

Over the past five years, numerous additional changes have taken place with public law and

USACE policy affecting the structure of CEFMS. This has created an even larger gap in the technical data available to the commercial marketplace. Without current experience in the specific CEFMS application environment, there are no means by which to transfer the knowledge of how the 25,000 forms that comprise CEFMS should operate. Without this crucial information, no other contractor can reasonably provide the level of performance necessary to ensure CEFMS remains operational and error free at this time.

6. Efforts to Obtain Competition: HNC conducted market research from 25 January 2016 to

28 March 2016, as described in detail in paragraph 8, to determine the competitive nature of this requirement. As part of the market research, CEHNC conducted a Request For Information

(RFI). Ten firms responded

. These ten firms were assessed for their ability to meet the immediate needs of this requirement based upon their documented work history, understanding of USACE financial business process, and the underlying software that comprises the CEFMS application. The results of the evaluation of the ten firms revealed that only the incumbent can continue performing these services without a risk of mission failure. GPS has a good understanding of the CEFMS application, USACE financial business processes and has a satisfactory performance record. Additionally, awarding a contract to the incumbent’s subcontractor Gradkell Information Systems directly presents a risk because they are only currently tasked with the responsibility for a small portion of the CEFMS source overall code and have not performed any of the required Oracle and Unix database management functions. In addition, they expressed the inability to increase their current capacity to serve as a prime contractor and meet the requirements of 13 CFR 125.6, Prime Contractor Performance

Requirements.

7. Actions to Increase Competition: UFC began planning for the re-compete of the CEFMS maintenance in February of 2015. Initial market research indicated that the two primary factors affecting competition are the lack of software design documentation and the obsolete nature of the programing language in which CEFMS was built. UFC began planning a group of acquisition activities to reduce the impact of these factors.

UFC developed a phased acquisition approach to mitigate each factor. Phase I will provide the documentation necessary to describe the current CEFMS application. Phase II will convert the

CEFMS application code to a more modern platform. The end result will be a more robust application with a larger market for experienced developers which will lead to a more competitive environment for CEFMS maintenance and development. These acquisitions phases are detailed below. A timeline for these phases is included in Attachment 1.

a. Phase I – The first step in modernizing CEFMS is to document current capabilities.

UFC has planned two acquisitions to facilitate this effort.

Legacy Code Assessment – The purpose of this acquisition is to evaluate the current application and production environment in order to provide an estimate of the time and cost to fully document the current code, as well as provide a detailed template to which all future design documents will adhere.

n. Award is anticipated in April of 2016.

Design Documentation – The purpose of this acquisition is to build upon the Legacy

Code Assessment and provide documentation of the entire CEFMS application code.

This will aide in both the development of a modernization plan and implementation of that plan by providing a means of protecting the current functions of CEFMS. This is acquisition that is anticipated to start in 4QFY16 and be completed no later than 4QFY17.

b. Phase II – This phase focuses on planning and executing the modernization of CEFMS and will result in the delivery of a modernized CEFMS application. It is comprised of two acquisitions.

Modernization Plan Development – This acquisition will build upon the previous two acquisitions and provide a path forward for modernizing CEFMS. It will include estimates on cost, recommended labor mix, timeline and a product mix to produce a next generation CEFMS application. Market research is ongoing to determine the availability of Oracle service providers and assess the impact of organization conflicts of interest following Phase I. This acquisition is anticipated to start in 1QFY17 and be completed by 2QFY17.

CEFMS Modernization – This acquisition will implement the modernization plan that will convert CEFMS from the antiquated Oracle Forms platform into a more modern platform with long term support. acquisition that is anticipated to start in 1QFY18 and continue through 4QFY19 as necessary.

This requirement will facilitate a competitive environment from this point forward.

CEHNC considered two acquisition approaches for continued support for CEFMS after the proposed six month extension. These courses of action are detailed in Attachment 2. Based upon this analysis we have determined that it is in the best interest of the Government

It ensures that there is no risk of mission failure because no transition period is necessary and it bridges the gap from no software design documentation to full documentation. Additionally, this approach will allow further mitigation of risks as we work with the customer to further define the PWS requirements for the future state of CEFMS, foster more interaction with industry to incorporate software development best practices and create a programmatic product roadmap which outlines key development initiatives for the CEFMS system by fiscal year.

8. Market Research: CEHNC conducted market research from 25 January – 28 March 2016 using phone calls, Internet research and an RFI, W912DY-16-RFI-CEFMS, posted on

FedBizOpps on 4 March 2016 with a closing date of 14 March 2016. The RFI resulted in a total of ten timely responses, including the incumbent and their subcontractor. The ten vendors were queried a second time regarding their experience with Oracle Forms. Five of the ten vendors were able to provide details relating to their capabilities with Oracle Forms specifically. UFC, in conjunction with CEHNC, reviewed the responses to the RFI and determined that only the incumbent for the current contract, GPS Information Guidance, LLC is able to satisfactorily provide the services without a risk of mission failure

The only other potential source, Therefore, the incumbent contractor, GPS Information Guidance, LLC, located at 4835

University Square STE 21 Huntsville AL 35816, is the only currently known company that can provide the full range of operations and maintenance of CEFMS to meet the urgency of this action.

9. Interested Sources: At this time, several vendors have expressed interest as described in paragraph 8 above. These vendors will be contacted for competitive acquisitions related to the modernization phases and future acquisitions of this nature.

10. Other Facts:

a. Procurement History.

i. Contract numbers and dates of last several awards: Contract W912EQ-11-C-0008 was executed in 2011 by MVM on Naval Support Activity Mid-South. The contract was awarded to GPS Information Guidance LLC to conduct CEFMS maintenance and support.

HNC assumed responsibility for this contract in 2013 at the inception of the CEHNC

Information Technology Solutions program. There have been a total of eleven (11) modifications executed which consisted of three (3) administrative mods, four (4) funding adjustments, and the exercise of four (4) option years.

The below table depicts the periods of performance and dollar values of the current contract.

Period of

Performance Dollar Value

Base Year 3 Apr 11 – 2 Apr 12

Option Year 1 3 Apr 12 – 2 Apr 13

Option Year 2 3 Apr 13 – 2 Apr 14

Option Year 3 3 Apr 14 – 2 Apr 15

Option Year 4 3 Apr 15 - 2 Apr 16

6-Month Extension 3 Apr 16 – 2 Oct 16

Total

Table 1.

ii. Competitive status of these actions (competitive, sole source, limited source, etc.): The acquisition was competed as a small business set-aside.

iii. Authority previously used for less than full and open competition: N/A

iv. If a justification was prepared to support the procurement made before this one, a summary of the contents of paragraph 7 of the justification for that procurement and an explanation of the results: N/A

v. If any prior award was accomplished by full and open competition, a detailed explanation of the changed circumstances: N/A

vi. An explanation of any unusual patterns which may be revealed by the history, (e.g.

several consecutive, urgent buys): MVM relayed that this requirement was being outsourced to GSA prior to their taking it over. CEHNC is not aware of the existence of any unusual patterns which may be revealed by previous acquisitions.

vii. If a justification was prepared to support the procurement made before this one, briefly describe the circumstances justifying the buy and whether there have been any significant changes: N/A.

b. Acquisition Data Availability: Performance work statements, and purchase descriptions will be made available upon request.

c. Subcontracting Competition: This is acquisition will be conducted as a small business set aside. As such, no subcontracting plan is required. The requirements of 13 CFR 125.6 –

‘Limitations on Subcontracting’ do apply.

Encl:

1. Attachment 1- CEFMS II Modernization Timeline

2. Attachment 2- CEFMS Courses of Action Timeline

11. Technical Certification: “I certify the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.”

12. Requirements Certification: “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.”

13. Fair and Reasonable Cost Determination: “I determine that by applying cost analysis techniques described at FAR 15.404(c) to the cost proposal which will be required from the contractor, the Government will obtain a fair and reasonable price for the requirement described herein.

14. Procuring Contracting Officer Certification: “I certify this justification is accurate and complete to the best of my knowledge and belief.”

Title: ITS Project Manager

Date: 31 March 2016 Signature:

Title: ITS Program Manager

Title: Contracting Officer

Title: Contracting Officer

APPROVAL

Based on the foregoing justification, I hereby approve the extension of the CEFMS support contract to GPS Information Guidance, LLC., on an exception to fair opportunity basis pursuant to the authority of 10 U.S.C. § 2304(c)(1), as implemented by FAR 6.302-1, “Only

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

Requirements” for the total estimated amount of , subject to availability of funds and provided that the services herein described have otherwise been authorized for acquisition.

Jacqueline C. Woodson Special Advocate for Competition

U.S. Army Corps of Engineers

Date

WOODSON.JACQUE

LINE.C.1049241530

Phase I

Phase II

Jan May Sep 2017 May Sep 2018 May Sep 2019 May Sep

Attachment 2