JA FAR Part 6 - WOSB_eCMS and iFAMS Training BPA_Redacted.pdf

DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

(1) Identification of the agency and the contracting activity, and specific identification of the document as a "Justification for Other Than Full and Open Competition."

This Justification and Approval (J&A) for Other Than Full and Open Competition is executed by the Strategic Acquisition Center (SAC), on behalf of the Department of Veterans Affairs (VA), Veterans Affairs Acquisition Academy (VAAA).

(2) Nature and/or description of the action being approved.

This activity proposes to negotiate a non-competitive award (sole-source) with Centeva, LLC; a Women-Owned Small Business (WOSB) for the procurement of Electronic Contract Management System (eCMS) and Integrated Financial and Acquisition Management System (iFAMS) Enterprise Training. The proposed action will be a single award Blanket Purchase Agreement (BPA) in accordance with FAR Part 13 with a five-year ordering period. Task Orders will be placed on a Firm Fixed Price (FFP) basis.

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The proposed action will continue to provide training support for the VA contract writing systems, eCMS and iFAMS. All acquisition offices across VA currently use eCMS, while iFAMS deployment began in 2020 and is currently anticipated to be completed by 2030, to be rolled out across all acquisition offices in waves. VAAA delivers the iFAMS training post-deployment to users new to the system or those that may need a refresher.

VA has multiple acquisition organizations that process daily operational procurement actions for a wide range of commodities and services critical to support VA’s mission.

The Office of Acquisition and Logistics (OAL), as part of its responsibility to provide oversight and management of the development of VA’s acquisition workforce, tasked VAAA with the mission to provide training to all acquisition users in both eCMS and iFAMS (post-deployment). This drives the need to continue the existing training program for all eCMS and iFAMS acquisition components and provide robust training to include testing applications and performing real-life examples within a training environment.

The total estimated value of the proposed action is $4,285,083.95 (inclusive of the five-year ordering period).

Strategic Acquisition Center (SAC)

(4) An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C.§ 3304(a)(5) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.302- 5 entitled, “Authorized or required by statute” - Sole source awards under the WOSB Program – 15 U.S.C. 637(m) (see FAR 19.1506).

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

The proposed source for this acquisition is Centeva, LLC, 155 Church Street, Suite 210, Logan UT 84321. Centeva, LLC is a certified WOSB and is technically qualified to provide the required training support services, a contractor must possess an in-depth understanding of eCMS and iFAMS as well as its interrelated technologies including the following acquisition environment systems: Federal Procurement Data System- Next Generation (FPDS-NG), Office of Research Compliance and Assurance (ORCA), GSA eBuy, Contract Opportunities on SAM.gov, and Forecast of Opportunities and Requirement Center for Excellence (FORCE). The contractor must possess extensive knowledge of the interface between eCMS and iFAMS as it applies to the day-to-day activities of the acquisition workforce as it pertains to interfaced and converted actions.

Centeva, LLC’s extensive knowledge and experience in delivering eCMS training to VA’s enterprise-wide acquisition workforce as well as their knowledge of iFAMS acquisition and the eCMS/iFAMS interface makes them uniquely qualified to fulfill this requirement.

In accordance with FAR 19.1506(b),

(1) The acquisition is assigned a NAICS code in which SBA has determined that WOSB concerns are substantially underrepresented in Federal procurement – The most appropriate NAICS for this action is 611420 - Computer Training is on SBA’s list of Eligible NAICS for WOSB program.

(2) There is not a reasonable expectation that offers would be received from two or more WOSB concerns (including EDWOSB concerns) based on the market research – Market research queries of SBA VetCert, GSA eLibrary, Dynamic Small Business Search (DSBS), System for Award Management (SAM) and Federal Procurement Data System – Next Generation (FPDS) found only one WOSB concern capable of providing

Strategic Acquisition Center (SAC) the required training which is Centeva. No other WOSB concerns were found; and

(3) The conditions of FAR 19.1506(c) are met:

(1) The anticipated award price including options will not exceed $4.5M

- The Independent Government Cost Estimate is $4.25M which is below $4.5M.

(2) Centeva, LLC has been determined a responsible contractor with respect to performance – Centeva has an active registration in SAM;

no exclusions; no records found in SAM Responsibility/Qualification (formerly FAPIIS); has satisfactory or higher performance ratings in the Contractor Performance Assessment Reporting System (CPARS); has a Low D&B Risk Score of 92 and Low D&B Supplier Stability Indicator and Supplier Evaluation Risk Rating; and

(3) Award can be made at a fair and reasonable price – Centeva holds a GSA contract with quoted prices which has already been determined fair and reasonable per FAR 8.404(d). Quoted prices for this action will be determined fair and reasonable using the price analysis techniques at FAR 13.106-3, including comparison with previous contract prices, published GSA pricing and comparison with the IGCE.

(6) A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under 5.202 applies.

In accordance with FAR 19.1506(b), a Contracting Officer shall consider a contract award to a WOSB concern (including EDWOSB concerns) eligible under the WOSB Program on a sole-source basis before considering small business set-asides, provided none of the exclusions at 19.1504 apply, and the conditions of 19.1506(b)(1)-(3) are met. None of the exclusions of 19.1504 apply and as stated in section 5 above all conditions of 19.1506(b) are met. A notice of the proposed action was synopsized on May 14, 2024, via the Government Point of Entry (GPE) in accordance with FAR Section 5.201, and the agency will make publicly available the justification required by 6.305(a) within 14 days after the contract award.

Strategic Acquisition Center (SAC)

(7) A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

No award shall be made until the Contracting Officer determines the cost to the Government to be fair and reasonable using the price analysis techniques at FAR 13.106-3.

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

Market research was conducted using SBA VetCert, GSA eLibrary, Dynamic Small Business Search (DSBS), System for Award Management (SAM) and Federal Procurement Data System – Next Generation (FPDS). A thorough review of the results found no SDVOSBs or VOSBs capable of providing the required training eCMS and IFAMS services. Further, these searches only found one WOSB (Centeva), one Small Business and one Large Business potentially capable of providing the required training. No other WOSB concerns were found.

(9) Any other facts supporting the use of other than full and open competition.

The Contracting Officer has determined that this proposed action meets all the requirements of 15 U.S.C. 637(m)(8). This acquisition is below the $4,500,000.00 threshold, Centeva, LLC is a responsible WOSB for performance of the services described herein, and the proposed contract can be awarded at a fair and reasonable price.

(10) A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

The notice of the proposed action was synopsized May 14, 2024, via the Government Point of Entry (GPE) to SAM.gov and no sources have expressed, in writing, an interest in this acquisition.

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

Future barriers to competition are unknown. If the program office requires these services past the period of performance of this BPA, extensive market research will be conducted to determine if the requirement can be competed.