JA - Interim Data Management Support Services Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

Justification for Exception to Fair Opportunity

Exceeding the SAT FAR 16.505(b)(2)(ii)(B)

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1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Immigration and Customs Enforcement (ICE), Office of Acquisition Management (OAQ), prepared this justification for an exception to fair opportunity on behalf of Office of the Chief Financial Officer (OCFO).

2. Nature and/or description of the item/service being procured and anticipated cost:

(a) Type of action: Firm-fixed-price (FFP) contract

(b) Amount the current J&A is justifying: $908,740.00

(c) Brief Description: OAQ intends to procure, on a sole souce basis, Data Management Support Services. The service provider below is the only company that has the experience and knowledge to immediately provide the needed Data Management Support Services through the imminent migration activities.

Terathink Corporation 11955 Freedom Drive Suite 780 Reston, VA 20190-5687

3. Description of Supplies / Services.

OCFO is requesting an interim contract to replace Task Order HSCEMS-17-F-00071 for Data Management Support Services which expires on April 11, 2020. The current vendor assisted ICE with a data management and data cleansing strategy to prepare the agency for Financial Management System Modernization by providing support for ICE's creation of an accessible data repository and integrated data model containing all historical financial data.

The ICE Financial Data Model (FDM) provides ICE and DHS component subscribers, including the U.S. Citizenship and Immigration Services, the Departmental Management and Operations Office, Federal Protective Services, the Office of Biometric Identity Management, the Science & Technology Directorate and the Countering Weapons of Mass Destruction Office, with the ability to access and analyze data in support of the Financial Management System Modernization. The data derived from the current task order must remain active while ICE completes certain migration activities and transitions to a new, competitively-issued contract.

OCFO is requesting data management and data cleansing strategic activities support for the period of April 12, 2020 through November 12, 2020. The estimated cost for this support is $908,740.00. These services are required to facilitate ICE OCFO’s mission to ensure ICE has access to efficient and effective financial transaction processing.

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ICE facilitated the development of the FDM. The contractor shall leverage the progress made to date, and continue to support federal staff in their completion and maintenance of the archive, including:

• Program Management and Support

• ICE Financial Data Archive Solutions

• Functional and Data Analysis

• Data Modeling

• Data Quality Assessment

• Data Cleansing

• Data Loading and Validation

• Maintaining a Data Dictionary

• Automation

4. Statutory Exception and rationale for its use:

Exception:

☐ FAR 16.505(b)(2)(i)(A). The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

☒ FAR 16.505(b)(2)(i)(B). Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized. [Explain why supplies or services are unique].

☐ FAR 16.505(b)(2)(i)(C). The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order. [For logical follow-on, the rationale shall describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value)]:

☐ FAR 16.505(b)(2)(i)(D). It is necessary to place an order to satisfy a minimum guarantee.

☐ FAR 16.505(b)(2)(i)(E). For orders exceeding the simplified acquisition threshold, a statute expressly authorizes that the purchase be made from a specific source.

Rationale:

ICE / OAQ intends to procure Data Management Support Services in accordance with FAR 16.505(b)(2)(i)(B). The vendor, Terathink, is uniquely able to continue providing these services to the OCFO’s Office of Financial Management (OFM) on an uninterrupted basis and to allow sufficient time for ICE to complete migration work, compete a new contract, and transition to the new contract. Issuing a new solicitation and / or seeking a new awardee at this time will interfere with ICE's migration work and result in an unacceptable delay.

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Task Order HSCEMS-17-F-00071 ends April 11, 2020.

During the phase of the period of performance of Task Order HSCEMS-17-F-00071, the vendor assisted ICE in completing two important products: the data model and the data dictionary. By supporting ICE in completing the two products, the vendor developed a full understanding of OFM’s current financial transaction services, volumes and resource requirements, and the agency’s strategy to support its six (6) agency level customers; described in paragraph 3. As OFM is a financial transaction services provider, it is critical to have a specific understanding of the services that the office provides and its requisite levels of effort to build accurate forecasting models. The vendor develops and gains this knowledge over a period of 2.5 years by interacting with the agency’s personnel and customers of the OFM. As a result, the team continues to provide and create sample queries to support the Government.

Recently, ICE’s Office of the Chief Information Officer required the migration of the financial model. The current environment was a temporary cloud environment, which allowed the agency to move its data out of the data centers. Today, the agency is prepared to migrate its FDM to a new cloud environment. Therefore, the agency needs the vendor to support this migration by further refining and validating the data model in the new environment. In conjunction with the migration to a new cloud environment, ICE is also migrating from an Oracle solution to a postgresql solution. The new architecture environment is necessary to execute the next contract.

During this phase, the vendor will capture all required interfaces, application, security/privacy, data layers; and further define the integrated technical strategy. These activities will guide pre-engagement, engagement and post engagement activities as well as system implementation and post-migration support.

It is critical that ICE successfully complete both migrations, and the incumbent contract is the only available source to support such efforts. The contractor has already begun supporting ICE's migrations, and the contractor is the only source that has the experience and knowledge to immediately support the efforts through the imminent migrations.

Furthermore, any delays to this project will effect the six (6) agency level customers and schedule for the next phase of the contract. Agency level customers provide ICE OCFO OFM with the trust and money to execute its Financial Systems Modernisation (FSM) activities. The current vendor understands each component’s data and the ICE FDM. This information is necessary to prepare each customer toward its respective data cleansing activities during post-migration. In addition, a schedule delay will effect the recompete, which the agency plans to execute in November 2020.

The Government understands that fair and open competition is important to the vendor community. As such, the Government, in conjunction with this J&A, is preparing a new acquisition. The new acquisition shall open this work to industry and comply with all acquisition standards to compete this new requirement. The purpose of this J&A is to allow the Government to extend its services through November 12, 2020, to allow sufficient time to transition the data model into a new hosting environment and to help ensure a smooth transition to a new contract.

The Government anticipates the award of and transition to a new contract no later than mid- November 2020.

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5. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Government will determine the fair and reasonabless of the anticpated price using historical data and a comparison of the Independent Government Cost Estimate.

6. Any other facts supporting the justification.

N/A

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

OCFO / OFM anticipates releasing a competitive solicitation for the required services in the fourth quarter of FY20. An award is anticipated in the first quarter of FY21 so that a new contractor can have sufficient time to transition by the November 12, 2020 expiration of this contract.

8. DHS intends to post this requirement on FedBizOpps pursuant to FAR

16.505(b)(2)(ii)(D).

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9. Technical/Requirements Personnel Certification.

Pursuant to FAR 16.505(b)(2)(ii)(B)(9), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the justification, are accurate and complete.

10. Contracting Officer Certification and Approval

Pursuant to FAR 16.505(b)(2)(ii)(B)(8), I certify that this justification is accurate and complete to the best of my knowledge and belief and hereby determine that the circumstances for an exception to fair opportunity exist:

Contracting Officer

11. Approval.

Procuring Activity Advocate for Competition