JA for Accountant re.pdf

JUSTIFICATION AND APPROVAL FOR EXPEDITED PROCEDURES PACKAGE

TO: Julie Lamadrid, Contracting Officer

CC: Deborah Broderick, Agency Competition Advocate

FROM: Morgan J. Brady, Office Director, Office of Financial Management

DATE: November 14, 2022

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. 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.

RECOMMENDATION

I recommend you approve this justification for use of other than full and open competition pursuant to the EPP for Afghanistan, approved on December 9, 2021. 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 for Afghanistan.

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

This is a request to approve a United States Personal Services Contract (USPSC) award to

XXXX XXXXX for an estimated cost for one (1) base year1 of $155,102. Under this action

1 For PSCs being hired with a U.S. duty station, all funding must be provided in FYs 2022 and FY 2023, 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 provides an exception for PSCs but only if they are funded in FY 2022 and FY 2023. Consult with OFM and RLO on the availability of authority for funding these

PSCs in FYs 2024 and beyond.

XXXX XXXXX will provide accounting services for USAID/Afghanistan further detailed below in item #3. Performance will commence on or about January 2023, following the completion of onboarding processes. This is a remote work position to be carried out from continental United

States (CONUS) while agency exception is provided due to ADS 309man.

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

This position is located in the Office of Financial Management (OFM) for USAID/Afghanistan for an estimated cost for one (1) base year of $155,102. The accountant is responsible for a variety of financial management tasks on the budgeting and accounting aspects of the

USAID/Afghanistan’s development assistance program and internal operations. The incumbent performs complex accounting duties in designing, planning, analyzing, evaluating, and entering data into specialized and fully-automated accounting systems. The incumbent assists the Chief

Accountant in developing and implementing procedures to ensure obligations do not exceed funds available as well as the appropriate budgeting.

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 December 9, 2021.

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, XXXX XXXXX has served in this highly specialized role for over seven (7) years. 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, XXXX XXXXX worked with autonomy and was responsible for providing expert advice on accounting and financial transactions, including the coordination and preparation of budget developments and time and attendance management in support of USAID/Afghanistan.

After the evacuation from Afghanistan, and with exceptions not relevant here, all FSNs, including XXXX XXXXX, were relocated to the United States and began the process of immigration. They are now eligible for USPSCs. All of the FSNPSCs, however, were terminated. As such, these FSNs employees could no longer work for USAID/Afghanistan and their portfolios are being attended to by one USDH, one PSC, and one FSN on temporary loan from another Mission. Due to the volume of work, only the most critical items are being 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 dedicated 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.

A full and open competition solicitation would impair the OFM’s ability to meet the demanding needs within the office at this time. The Mission’s immediate need is a compelling urgency and any postponement in award will cause unacceptable delays in fulfilling the agency's requirements. The position was solicited to all former (174) FSNs for expressions of interest in providing the services highlighted in the solicitation and a total of ten (10) applicants expressed interest in this position.

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 $155,102 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 XXXX

XXXXX’s 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.

A total of ten (10) offerors expressed interest in this position.

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 complete and accurate in accordance with EPP for

Afghanistan.

_____________MJB____________________ 11/14/2022

Morgan J. Brady, Office Director Date

13. Resident Legal Office Clearance:

JPower Clear 11/14/2022

John Power, Legal Advisor 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.

Julie Lamadrid, Contracting Officer Date