JA Limited Source Justification_PPMS_LSJ Policy Final_signed.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Program & Project Management Support (PPMS) Agency: Centers for Medicare and Medicaid Services Acquisition Year: FY 2025 Author: Jerry Mills – COR Jeremy Garvin - CO

1. Description of Action:

Nature

☐ New Requirement ☒ Follow-On Order ☐ Modification of Existing Purchase Order / Contract Number

Contract Type ☒ Firm-Fixed Price ☐ Time and Materials ☐ Cost Plus Fixed Fee (CPFF)

☐ Term ☐ Completion

☐ Cost Plus Award Fee (CPAF) ☐ Other:

Total Projected Cost / Price: $ 7 , 4 0 0 , 9 8 2 . 8 6

Funding Source (s):

0511: Program Operations Direct: Disc, Project #’s 000707, 000231, 000787, 000788, 000231, 000629, 000623 8389: Medicaid Program Integrity Direct: Disc Project # 000786

Name of Proposed Contractor:

Noblis 14425 Penrose Place, Suite 280 Chantilly, Virginia 20151

The General Services Administration (GSA) Multiple Award Schedule contracts include ordering procedures described at FAR 8.405. The procedures provide for sole source task orders conducted under the procedures described at FAR 8.405-6, such as the order described in this justification.

This justification supports the award of a new task order to continue PPMS beyond the expiration of the current order providing these services. CMS originally awarded task order GS-35F-0590W/75FCMC21F0019 to Noblis on 02/26/2021. CMS awarded the order using the competitive procedures described at FAR 8.405-2. The period of performance (including all options) is from May 1, 2021 through April 30, 2025. The total dollar amount obligated to date is $80,433,809.06.

2. Description of Supplies or Services:

The contractor provides development and coordination of tactical and strategic plans and deploys technical approaches and solutions that address high-priority initiatives and solves digital and organizational transformation throughout CMS.

PPMS provides services to support evolving priorities under the new Administration as CMS and the new Chief Information Officer (CIO) are still developing a 100-day plan and an agency-level CMS IT Strategy. PPMS includes cost optimization opportunities and analysis to identify areas where the agency can have a meaningful impact in support of the IT Strategy. This analysis leverages PPMS's expertise in areas like data analytics, visualization, and process improvements to identify potential areas for cost savings and efficiencies across CMS's IT operations and initiatives. By aligning cost optimization efforts with the new CIO's vision/priorities and the CMS IT Strategy, the outcome will provide valuable insights and recommendations to drive cost-effective IT modernization and strategic initiatives.

The solicitation requirement is 250283J.

3. Authority:

☒:ORDER AGAINST FSS: Authority of the Multiple Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501, Services for Executive Agencies;

and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6.

Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405- 6(c)(2)(iv).

☐ An urgent and compelling need exists, and following the procedures would result in unacceptable delays (FAR 8.405-6(a)(1)(i)(A));

☐ Only one source is capable of providing the supplies or services required at the level or quality required because the supplies or services are unique or highly specialized (FAR 8.405-6(a)(i)(B)); or ☒ 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 (FAR 8.405-6(a)(1)(i)(C)); or ☐ An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. (FAR 8.405-6(b);

CMS is actively working on a competitive re-procurement of PPMS services, with the goal of awarding a new contract by May 1, 2025. However, CMS has more recently undertaken a significant shift in priority with the new presidential administration, and as a result CMS has decided it is now of paramount importance to focus on https://www.acquisition.gov/sites/default/files/current/far/html/Subpart%208_4.html https://www.acquisition.gov/sites/default/files/current/far/html/Subpart%208_4.html evolving CMS’ IT strategy with greater emphasis on cost-efficiency. To ensure continuity, CMS must award a logical follow-on task order. The PPMS Logical Follow-On would provide the necessary time to reevaluate the current contract scope, deliverables, and timeline to drive optimal value and efficiency. The anticipated period of performance for this follow-on task order is one year (May 1, 2025 through April 30, 2026). The additional time will allow CMS to finalize the re-compete and ensure an award by May 1, 2026.

Although the administration initiatives are new, this is a continuation of existing services. Awarding this follow-on task order to the incumbent, Noblis, is the most economical and efficient approach. Competing and transitioning to a new contractor at this stage would not be practical due to the additional time, costs, and risks involved. Specifically:

• Conducting a full competition would require significant CMS resources to solicit, evaluate, and award a new contract. Additionally, based on CMS procurement lead times, a competitive process would take approximately 105 days, making it impossible to complete before May 1, 2025.

• A competitive process would be unlikely to generate cost savings, as transitioning to a new contractor would require additional expenditures for knowledge transfer, onboarding, and transition-out activities.

The current contractor is already fully operational and familiar with the needed work, reducing the need for costly ramp-up efforts.

• Any transition at this stage would pose significant performance risks, as a new contractor would require time to gain the expertise needed to maintain uninterrupted PPMS operations.

• The scope of the logical follow-on contract is substantially less than the legacy contract under which PPMS has been recently performed. The decrease in scope is primarily due to the following areas being removed from the PPMS services: ISPG Software & Cloud Security Program Development; CPI Project Management and Support; and CPI Agile Implementation Support.

To bridge this gap, CMS proposes awarding a follow-on task order to Noblis Inc. to continue essential PPMS functions beyond the current period of performance.

4. Market Research:

CMS has performed market research which consisted of an RFI posted on GSA EBuy, using existing requirements and documented the findings in a market research report. Once the scope of the future PPMS effort is finalized, CMS will use the current market research supplemented with new market research.

5. Actions to Increase Competition:

While leveraging the follow-on extension associated with this contract, CMS will continue to monitor the marketplace to inform its market research it will conduct to support the future procurement. Future competition is anticipated for any contract to follow the logical follow-on contemplated in this justification.

6. Any other facts supporting the justification: N/A

Approvals:

1. Program Office Certification: This is to certify that portions of this justification have been developed by the undersigned program office personnel, including supporting information and/or data verifying the Government’s minimum needs, schedule requirements and other rationale, which form the basis for this Limited Source Justification.

Contracting Officer Representative (COR) / Date

Program/Project Manager (P/PM) / Date

2. Contracting Officer Certification and Best Value Determination:

This is to certify that the justification for the proposed acquisition has been reviewed and that to the best of my knowledge and belief, the information and/or data provided to support the rationale and recommendation for approval, is accurate and complete.

By my signature below, after review of the relevant documents, I have determined that the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d), and constitutes a fair and reasonable price. The basis for my determination is as follows:

The estimated price for this procurement appears to be fair and reasonable, as it is based on the historical data gathered from the previous contract over a five (5) year period and Noblis’ current GSA MAS contract pricing. GSA has already determined its MAS pricing to be fair and reasonable; however, the Contracting Officer will seek further price discounts and will perform price analysis on the quoted pricing to determine it fair and reasonable.

Contracting Officer / Date

3. CMS Competition Advocate Approval

I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

Name / Date

4. Head of Contracting Activity (HCA) Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

_N/A__________________________________________________

5. Office of Small and Disadvantaged Business Utilization

_N/A________________________________________________

6. OGC Legal Review

_N/A________________________________________________

7. HHS Competition Advocate Approval

_N/A__________________________________________________

8. Senior Procurement Executive (SPE) Approval

Based on the foregoing justification, I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

_N/A_______________________________________________