JA_-_GSA_Limited_Source_-_0623-CA18-0015_signed.pdf

UNITED STATES OF AMERICA

Federal Trade Commission

WASHINGTON, D.C. 20580

JUSTIFICATION AND APPROVAL

GSA SCHEDULE TASK ORDER UNDER FAR PART 8.405-6 – LIMITED SOURCE

OCIO – PR 0623-CA18-0015

Information Technology Source Selection (ITSS) Support

1. Identification of agency and contracting activity.

Requiring Agency: Federal Trade Commission (FTC)

Office of the Chief Information Officer (OCIO) 600 Pennsylvania Ave, NW Washington, DC 20580

Ordering Activity: Federal Trade Commission (FTC)

Financial Management Office/Acquisitions Division (FMO/AD) 600 Pennsylvania Ave, NW Washington, DC 20580

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

This action is a new GSA task order to Noblis, Inc. as a follow-on and continuation of a current GSA task order with Noblis, Inc. for ITSS Support due to expire on 11/13/2017. The current task order (29FTC116F0010) has a period of performance of 9/30/2016 to 11/30/2017 and can no longer be extended itself. The work requirements still remain incomplete and we need this follow-on task order to complete the current work requirements and to include options for additional work requirements as needed. The period of performance for this new follow-on action is 1-year from 11/14/2017 to 11/13/2018.

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

The required services includes AcquTrak subscription tool and professional source selection support services for up to 6 months to conclude the current source selection support action and then an option for additional professional source selection support tasks for up to another 6 months.

The services required to meet FTC’s need include the following:

• Providing professional services to support the completion and implementation of ITSS contract and task orders.

• Providing post-award support and implementation assistance.

• Providing access to AcquTrack evaluation tool to complete technical evaluation.

The specific tasks include: identifying and documenting high-level requirements for the BPA;

assisting in developing detailed requirements for the task orders; assisting with developing source selection strategies and plans; assisting the technical and price evaluation teams by providing technical subject matter expertise; providing subscription and support for Acqutrak tool for the evaluation team to record comments and evaluation related data; and assisting with evaluation reports and briefings.

The estimated value for this new follow-on work per the IGCE is not to exceed $525,186.03.

4. The authority and supporting rational and, if applicable, a demonstration of the proposed contractor's unique qualifications to provide the required supply or service.

Authority Citation:

The following selected limited source authority citation(s) (is/are) cited to justify limiting the source of this singular acquisition action in accordance with FAR part 8.405-6(a)(1)(i).

(A) An urgent and compelling need exists, and following the procedures would result in unacceptable delays;

(B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized; or

(C) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

Supporting Rationale:

The incumbent contractor, Noblis, has been supporting the FTC in developing and executing a strategic approach to better align future IT support services with OCIO’s strategic plan. In order to accomplish this, Noblis supported the OCIO in developing a strategic approach to obtain services under a Blanket Purchase Agreement (BPA) and associated task orders.

At the time of initiating this action we were just days away from the contract’s expiration and we were far from completing the work requirements to meet our mission objective. We are unable to extend the current contract because we had already completed the original period of performance and have used the 52.217-9 Option to Extend Services. We had a legitimate urgent and compelling need to put in place another contract instrument to continue the required support services as incurring any delays would prove to be detrimental to our mission objective and work accomplishment and potentially be very costly especially after having already invested just over $1M in this important effort. Over the past year Noblis, Inc. has become highly integral to this mission and work effort and due to this experience and contribution they have become singularly and uniquely qualified possessing highly specialized knowledge and capabilities to continue on to complete all the work requirements at a level of sufficient satisfaction within onerous time and cost restraints. It does not make any good business sense to stop the work part way through a technical evaluation of an important acquisition and lose all the work efforts invested thus far along with the synergistic momentum of the team cohesion and productivity acquired to recompete this effort which would ultimately incur additional delays and costs. It does, however, make great business sense to quickly build upon the ongoing work momentum and award a follow-on GSA task order to Noblis, Inc. to continue with their efforts and work requirements through to completion with delay or much additional costs.

Contractor’s Unique Qualifications:

As Noblis has been involved since the inception of this project, and has supported the development of OCIO’s strategy for ITSS, it has the institutional knowledge of FTC as well as an intimate knowledge of the all facets of this project to ensure ITSS implemented as planned.

Noblis is currently providing technical expertise and advisory support to assist the technical evaluation teams complete proposal evaluation and document its findings and recommendations.

It is also providing subscription to its AcquTrak tool for the evaluation teams to systematically and accurately document comments, consensus findings, and consensus reports. The FTC plans to complete the source selection process over the next three to four months, during which time Noblis’ advisory support is essential in ensuring that the evaluation team personnel accurately and thoroughly document their rationale and prepare all supporting documents to ensure a timely award. In addition, continued subscription and support for Noblis’ AcquTrak tool is critical since it has been used as the only mechanism for the source selection teams to draft and maintain source selection sensitive information; and is the secure repository for all offeror proposals. The access to the tool is essential until the award for the BPA and the task orders is complete. Once the awards are complete, Noblis’ assistance is required to complete ITSS implementation through transition of work to the BPA and subsequent task orders. If the FTC does not award to Noblis, there will be significant consequences to the OCIO’s support contracts, which will affect the entire Agency’s mission. Risks include the following:

• Without AcquTrack subscription and support, the work on ITSS BPA will stop, since the evaluation team will no longer have access to a secure tool that contains evaluation team comments, findings, reports, and offeror proposals. The work stoppage will result in significant delays to award the BPA and its associated task orders. These delays will further impact other mission critical contracts that are expiring and were planned to be competed and awarded under the BPA, thereby completely derailing the OCIO’s strategic plan implementation.

• In the absence of AcquTrack, the FTC would need to find another tool to continue the evaluation process. This will have significant impact to the schedule due to the time required to obtain approval and accreditation of the tool associated with information security and FedRAMP requirements. In addition, the FTC personnel would need training and support for the tool, which will require further government expense.

• If the FTC were to recompete its requirements for ITSS support, there would be additional unacceptable delays not only because of the time required to compete but also because of knowledge gap that would be created if a different vendor were selected.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR Part 8.404(d).

As it is that GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable and that Noblis, Inc. has offered an additional 10% discount off their schedule pricing rates it is determined that this new GSA task order to Noblis, Inc. represents best value to meet the urgent needs to accomplish the subject ITSS Support mission requirements.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

There was no comprehensive market research conducted for purposes of seeking competiton because this action is a follow-on to a current GSA Schedule task order to Noblis, Inc. Market research was conducted to verify Noblis, Inc. still holds an active GSA Schedule contract, actively registered with SAM and not on the excluded parties listing.

7. Any other facts supporting the justification.

N/A.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

N/A.

9. The ordering activity contracting officer's certification that the justification is accurate and complete to the best of the contracting officer's knowledge and belief.

Contracting Officer’s Certification:

As evidenced by my signature herein I hereby certify that this justification for limited source is accurate and complete to the best of my knowledge and belief.

10. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the government's minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

Contracting Officer’s Representative’s (COR) Technical Certification:

As evidenced by my signature herein I hereby certify that any supporting data that is of my responsibility for which is to form a basis for this justification herein is complete and accurate.

11. For justifications under 8.405-6(a)(1), a written determination by the approving official identifying the circumstance that applies.

As evidenced by my signature herein I hereby determine that (A) an urgent and compelling need exist to continue the ongoing ITSS Support, (B) Noblis, Inc. is uniquely qualified to continue their support through to completion and (C) this action is a logical follow-on to a current GSA Schedule task order and therefore, it is genuinely sound and good business sense in the best interest of the FTC mission to award this action to Noblis, Inc.

12. General Public Notice Posting Requirement:

Within 14 days after award of this GSA Task Order this justification and approval for this limited source action will be electronically posted at the GPE http://www.fedbizopps.gov for a minimum of 30 days in accordance with FAR Part 8.405-6(a)(2)(i)(B) (1)and (3).

13. Certifying and Approving Signatures:

Technical Representative Signature:

Shabbir Kundi Date

OCIO COR

Approving Official’s/Contracting Officer’s Signature:

Paul Brinckhaus Date FMO/AD Contracting Officer http://www.fedbizopps.gov/