JA Audit FS Bridge 2 W91CRB19C0030 Final signed 08 17 23 redact_Redacted.pdf

Justification Review Document for Other than Full and Open Competition - FAR Part 6

Program/Equipment: Army Audited Financial Statement Compilation and Publication Services to prepare, compile, and publish the U.S. Army’s General Fund, Working Capital Fund, and Civil Works Fund annual fiscal year-end September 30 Financial Statements. The program obtains services from a Certified Public Accounting Firm (CPA) for preparation and publication of the Army’s audited annual financial reports, compilation assistance, and review of monthly and quarterly financial statements, financial data analysis, and audit related tasks.

Authority: 10 U.S.C. 3204(a)(1) as implemented in Federal Acquisition Regulation (FAR) 6.302-1(a)(2), Only One Responsible Source and No Other Supplies or Services will Satisfy Agency Requirements.

Prepared by: Susnaia Baker DSN: (571) 256-6470 Service Acquisition Program Manager Email: susnaia.m

Contracting Officer: Alexandra Bryant DSN: (410) 278-6470 Contracting Officer Email: alexandra.c.bryant.civ@army.mil

Technical Representative: Ryan Lindner DSN: (317) 442-4869 Acting Director, Financial Operations Reporting Email: ryan.lindner.civ@army.mil

Requirements Representative: Susnaia Baker DSN: (703) 697-4670 Contracting Officers Representative Email: susnaia.m.baker.c l

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

on the reports, a new contractor would, at the very least, have to be willing to accept the results of the predecessor company. A new contractor may not be able to rely on work performed by another contractor and instead need to recreate the three (3) preceding quarterly reports. This re-work would add at least thirty days to the process and be a duplication of costs already incurred by the Government, which would not be recovered through competition.

Moreover, this work cannot be severed into distinct tasks and given to another contractor in short suspense. This is because the process for collecting the information to be used in the financial reports relies on general ledger account mapping, hundreds of system algorithms, current and historical interpretation, and application of various regulatory rules. Another vendor would require a substantial transition time to examine the system and attain competency.

Additionally, Kearney, as the incumbent contractor, is responsible for assisting with financial data analysis and remediating financial reporting audit findings of the reporting period. Millions of transactions feed into the data needed to compile the financial statements. This data comes from financial systems, manual and automated data calls from DoD and other Federal Agencies (e.g., Treasury Department, U.S. Department of Health and Human Services (HHS), Veteran’s Affairs (VA), Department of Transportation (DOT), Department of Labor (DOL), and General Services Administration (GSA)) and must be analyzed and verified within very compressed time schedules. These processes are mandated by Office of the Under Secretary of Defense (OUSD) and the OMB. The contractor must have the knowledge and expertise to assist in obtaining the financial information, enter the required data into DFAS or OUSD system(s), as required, for processing and publication. These additional tasks of analyzing financial data and remediating findings of the reporting period are pivotal to supporting the Army’s overall audit efforts and progress toward a positive audit opinion. Again, another vendor would require a substantial transition time to examine the system and attain competency.

As well, there is the possibility that the current contractor will need to handle an upsurge in workload in the near year. In FY 2022, for instance, the Army already had over deployed in more than across six continents, and Army leadership relies on accurate financial reports to make informed decisions to support these missions. These monthly, quarterly, and fiscal year-end financial statements are prepared within approximately five (5) days after the period ends which are aggressive timelines. Yet, with it is anticipated that more financial reporting will be required as the Department of Defense (DoD) and the Army . This potential additional workload would still have to be performed with the contract’s current tight deadlines.

Attempting to award a short-term contract for the period to any source other than the current contractor would require an additional time-consuming procurement cycle, mobilization of resources, and transition time. There is inadequate time to compete a new contract, hire personnel, and train new staff to ensure completion and accuracy of the year-end financial reports. A new vendor could be starting from the ground up and may not have the experience, detailed level of understanding of the financial reporting process, and effective structure of processes and personnel to be able to successfully perform requirements in short suspense. If a potential new vendor is unable to gain a level of confidence with the existing structure that anchors the process, then that vendor would be unable to rely on it to compile the financial

C support effort without a break in service. Kearney’s expertise, CPA credentials, and continued service under this contract allows it to assist in obtaining and entering the required data into DFAS or OUSD system(s) as required for processing and publication.

There is no competitive action that could be accomplished to meet the 20 August 2023 deadline.

The competitive follow-on requirement has a total projected cost of and a five-year period of performance, which is significantly more than the cost of increasing the contract ceiling for the proposed contract extension. And the follow-on contract will not be awarded until

The time required to complete full and open competition procedures in the interim for this proposed extension period would result in unacceptable delays in fulfilling the agency’s requirements and an unacceptable break in service. Knowing that Army contract consolidation efforts are in process, the Army cannot risk losing continuity of effort by taking time to compete an effort that will not be sustained with a new vendor to fill the gap between the current contract end and the follow-on contract vehicle.

Only the current contractor, Kearney, has the prior experience, detailed level of understanding of the financial reporting process, and effective structure of processes and personnel in place to complete the required FY 2023 publication. Kearney is also strategically poised to begin the reporting requirements for the upcoming end of fiscal year which is required to be prepared for 30 September 2023. A period of performance and ceiling increase modification of the contract is in the best interest of the Government. For the reasons outlined above, Kearney is the only contractor capable of providing continuity of operations to ensure the FY 2023 audited financial statements are completed and published on time.

6. Efforts to Obtain Competition: In accordance with Defense Federal Acquisition Regulation Supplement (DFARS) 205.205-71, DFARS 206.302-1(d), and DFARS Procedures, Guidance, and Information (PGI) 206.302-1(d), a sources sought notice for this proposed extension effort was published 11 July 2023 on SAM.gov. A total of four (4) responses were received; however only Kearney was deemed capable to meet the Government’s requirement for a 20 August 2023 start date. As detailed in the Market Research section of this document, the remaining three (3) respondents were not capable of meeting the short-term readiness requirement for this extension.

Effective competition, either limited or full and open, is not expected for this specific action.

a. Effective competition: Because this is a sole source action, effective competition is not applicable. The follow-on contract will be awarded using full and open competitive procedures.

b. Subcontracting competition: Subcontracting opportunities will be achieved by Kearney, and the vendor itself is not a small business. The base contract contains the clauses 52.219-8 Utilization of Small Business Concerns, and 52.244-5 Competition in Subcontracting.

7. Actions to Increase Competition: Competition requirements will be met for the replacement requirement. A new contract action has been initiated to re-compete this work. The barriers that

11. Technical 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.

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 hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable based upon price analysis as described in FAR 15 404-1(b) As a part of this basis certified cost or pricing data will not be

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

Approval

Based on the foregoing justification, I hereby approve the modification of contract W91CRB-19- C-0030 to extend the period of performance by up to 12 months, with a resulting increase to the

The modification will be made on an other than full and open competition basis pursuant to the authority of 10 U.S.C. 3204(a)(1) as implemented in FAR Subpart 6.302-1(a)(2), Only One Responsible Source and No Other Supplies or Services will Satisfy Agency Requirements. The award is subject to availability of funds, and provided that the services and property herein