JA_MSW_Affiliation_FINAL SIGNED_16APR21 REDACTED 15FEB22.pdf

CUI

(See FAR 2.101 and 3.104-4)

Control No: 21-HRCO-288

Sole Source Justification and Approval Review Document Under FAR 13.501

Program/Equipment: Master of Social Work (MSW) Program University Affiliation Services in support of the U.S. Army Department of Graduate Education at the U.S. Army Medical Center of Excellence (MEDCoE).

Authority: Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5.

Amount: The total estimated value of the contract is $1,205,790.41 which reflects the maximum amount of dollars that can be obligated under the resulting contract.

Prepared by: Michael E. Martinez

Budget and Logistics Manager Email: michael.e.martinez.civ@mail.mil

DSN: 471-6466

Date:

Contracting Officer: Laura J. Applewhite Contracting Officer Email: david.j.libby.civ@mail.mil

DSN: 808-217-5838

Date:

Technical: LTC Matthew S. Douglas Associate Dean of Administration Email: matthew.s.douglas2.mil@mail.mil

DSN: 471-7100

Date:

Requirements: Michael E. Martinez Budget and Logistics Manager Email: michael.e.martinez.civ@mail.mil

DSN: 471-6466

Date:

Reviews: I have reviewed this justification and find it adequate to support sole source.

Program Manager:

Typed Name: Michael E. Martinez

DSN: 471-6466

MARTINEZ. Digitally signed by

MARTINEZ.MICH

AEL.EDUARDO.1

Signature:

DUARDO.1

069844592

069844592 Date: 2021.04.13 10:58:04 -05'00'

MICHAEL.E

mailto:michael.e.martinez.civ@mail.mil mailto:david.j.libby.civ@mail.mil mailto:matthew.s.douglas2.mil@mail.mil mailto:michael.e.martinez.civ@mail.mil

Legal Counsel:

Typed Name: Justin R. Dalton

DSN: 450-5858

Command Advocate for Competition:

Typed Name: Liza J. Esmond

DSN: 471-4093

ESMOND by

Sole Source Justification and Approval Under FAR 13.501

1. Contracting Activity: U.S. Army Medical Command (MEDCOM) Health Readiness Contracting Office (HRCO), Joint Base San Antonio-Fort Sam Houston, Texas78234.

2. Description of Action: The US Army Medical Center of Excellence (MEDCoE) Department of Graduate Education (DGE) is requesting the approval for a sole source contract for the procurement of university affiliation services for the Master of Social Work (MSW) Program.

An acquisition plan is not required because this procurement does not meet the threshold at

Defense Federal Acquisition Regulation Supplement 207.103(d)(i)(B).

3. Description of Supplies/Services: The Government requires non-personal services of an accredited university who can proffer a Master of Social Work (MSW) degree to students who successfully complete the foundation and an advanced concentration phase of the MSW Program. The support will include services, materials, and qualified personnel to proffer applicable degrees to students that meet established curricular requirements, enrollment of qualified students to the various programs, administrative support in creating/storing/providing student transcripts, and certifying MEDCoE DGE Faculty as this is a degree proffering requirement derived from University Accrediting Bodies such as Southern Association of Colleges and Schools (SACS).

Period of Performance: 1 February 2022 to 31 January 2027 Total Value: $1,205,790.41. Funds will be provided on each individual task order; anticipated funds are Operation and Maintenance, Army (OMA) funds.

4. Authority Cited: Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5:

Unusual andcompelling urgency

Exclusivelicensing agreements

Industrial mobilization

Other: 10 U.S.C. 2304(c)(1), as implemented by FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Reason for Authority Cited: The Code of Federal Regulations Title 34 part 602.1 (34 CFR 602.1) the U.S. Department of Education (USDE), the Council for Higher Education Accreditation (CHEA), and the Association of Specialized and Professional Accreditors (ASPA) govern the accrediting body associated with the identified program covered under this requirement. The Council on Social Work Education (CSWE) is the only authorized agency to provide the required accreditation certifications to the program. These academic accrediting organizations provide for the continuity of degree production and licensure/certification standing to provide graduates with a degree to meet their clinical professional accrediting body requirements via board processes. Due to the significant impact of transitioning to a different university the University of Kentucky (UofK) is in the unique position to provide continuity of instruction and support with uninterrupted program implementation.

Transferring services to another university would facilitate changing out the MSW program’s entire curriculum, program platforms and support services. Though the program is not independently accredited it would still have to submit a “Notification of Substantive Change” to CSWE notifying them of falling under a new university. If CSWE were to not accept the change and deny the acceptance of said change the impact on the Program would be catastrophic in that they would no longer be able to fulfill their mission of producing Military Social Workers.

1) Additionally, supporting a transition process would require additional personnel and faculty to present new curriculum during the transition period should an affiliation contract change. This change would place an undue manpower burden on the existing program’s faculty and staff. There would also be additional costs related to the necessity of hiring temporary, contract faculty and staff that would be needed to support the extra workload that would exist during a concurrent transition period and executing the current curricular instruction. A minimum of 2 Adjunct Professors and 1 Phase 2 Education Coordinator would be required to meet these challenges. The added cost of a faculty services contract would range upwardsof $305,000.00. These changes across curriculums and platforms related to a transition to another university also jeopardizes current relationships with community organizations needed to facilitate the programs needs due to the changes across curriculums.

2) The aforementioned burden will be increased, as it is anticipated that in FY22 an increase in MSW’s student population from 24 to 30 students resulting in the need to split the number of classes and increasing the number of instructors in many cases. The addition of transitional activities would adversely affect the quality of the education the MSW students would receive if the existing faculty and staff were expected to attempt to transition to a new curriculum simultaneously with maintain current instructional standards.

3) Further, as the Army MSW program’s accreditation is linked to the affiliated university program, a newly awarded university would be required to submit a Substantive Change Notification to CSWE addressing the addition of the Army Program as a “satellite program” of that university at JBSA Ft. Sam Houston, TX. This action runs the risk of the notification being denied or placing the Army program in a Candidacy/Probationary status which would severely compromise the integrity and validity of the programs education platform. Traditionally, a program changing university is not done and there is no specific guidance or doctrine to address this type ofshift.

4) The risk of FOC (Full and Open Competition) acquisition strategy is threefold–

- MEDCOE (Grad School and MSW) lack additional resources to change to a newuniversity curriculum while delivering the existing one for the current enrolled population

- degraded academics due to fixed faculty at MEDCOE and field sites required to administer two programs and appoint faculty between both institutions including new MOU/MTA processes

- damage to program quality including faculty standing (or trust) and institutional support that matter to clinical professional standards; results in lower applications or quality applicants

5) The interests of the government are best served with the existing host university where there isn’t a recurring threat of affiliation loss predicated on known inability to develop and then execute simultaneous materials between two universities. The Graduate School is only resourced and programmed to execute one curriculum per program, which requires continuous and regular updates by their limited faculty.

6) Upon entering university academic contracts where the government is the executor, we are committed as an all-or-none with that university alone based on institutional support. The scrutiny of accreditation, at both the university and professional level, is unduly increased by the requirement of the same faculty teaching competing curricular requirements, for the same degree, from different universities within the same facility.

7) Where a distinct government need arises: degree advancement, improved accreditation, or some other element exists; the Graduate School is compelled to express this via Contracting to the host and then open to other institutions with their periodic contract renewals as a FOC. We retain a COR, Mr. Martinez, to assist should that condition arise. It has happened twice in 25 years. But otherwise, the academic and medical professional standard is not to move programs between universities – it isn’tdone.

8) Our existing academic requirement constitutes a one-of-a-kind relationship/one responsible source that supports SSJ versus FOC. Changing of “brands”, e.g. the copyright syllabi of the University of Kentucky for the opportunity to develop and simultaneously deliver the new copyright syllabi of Baylor University, would compromise the integrity and continuity of the existing MSW program on several levels. The MSW could not perform the conditions of a new university affiliation contract without application of additional resources that are currently not programmed, present, or funded. Currently, the MEDCoE Masters of Social Work Program is only accredited by the CSWE through the University of Kentucky’s Masters of Social Work Program. Accreditation is granted to the Army-UK MSW Program for the duration of the University’s Program’s accreditation. In light of all the supporting factors described above, the University of Kentucky is the only source capable of providing the required university affiliation services.

6. Efforts to Obtain Competition: In an effort to obtain competition for this requirement, the Government posted a Sources Sought notice via the Government Point of Entry (GPE) www.beta.sam.gov on 06 August 2020 for 11 calendar days. No responses were received from industry.

7. Actions to Increase Competition: Efforts the Government has taken to increase competition for this requirement include posting a Sources Sought notice via the Government Point of Entry (GPE) www.beta.sam.gov on 06 August 2020 for 11 days. No responses were received from industry. Additional competition would require a new university to follow a process for reevaluating the program’s current accreditation which would involve submission of paperwork explaining why a change in university affiliation is being done and the possibility that CSWE representatives would do a site/location visit to ensure the program will not experience interruptions in continuity of education. These representatives, comprised of educators from other institutes of higher learning within that Program’s discipline, will review the Program’s curriculum, faculty to student ratios, space utilization, and overall quality of education. Once the representatives have completed their inspection they will submit their findings, with their recommendations to CSWE for their determination which is then sent to the US Department of Education and the Program for official notification. The entire process could take 6-12 months. The onus would be on the new university to ensure that CSWE accepts them and the graduate school as a satellite program, which creates risk to the IPAP program.

8. Market Research: Market research for this requirement was conducted within the last 12 months to determine the most suitable approach to acquiring the required services utilizing NAICS code 611310– Colleges, Universities, and Professional Schools. Market research techniques included GSA Advantage searches, a search of the SBA Dynamic Small Business Search (DSBS), phone calls to several universities and a combination of the costs of the previous services contracts coupled with a percentage increase based off of the average pricing indexes outlined by the US Department of Labor and Statistic’s Consumer Price Index (CPI) for standard annual cost of living increases as well as Education Cost percentages for the United States at the time of the estimate. GSA was not considered for this requirement due to the accreditation process stipulated by the Carnegie Classification of Institutions of Higher Education, which is required to provide services. An initial search utilizing NAICS Code 611310 and key phrases such as “university affiliation” was performed on the following website, Dynamic Small Business http://www.beta.sam.gov/ http://www.beta.sam.gov/

Search and the Quick Market Search, all hosted by the Small Business Administration (SBA). The results indicated no small business concerns within the market as universities are not for profit organizations.

There are no sources from the Federal Prison Industries, Inc., Government wide acquisition contracts, multi-agency contracts, and any other procurement instruments intended for use by multiple agencies, including blanket purchase agreements (BPAs) under Federal Supply Schedule contracts. Market Research conducted by the customer included research on Baylor University, Simmons College, and the incumbent, University of Kentucky. All three have recognized MSW programs that would support the Army’s need. Only Baylor and U of K are classified as a Doctoral University with Higher Research Activity (R1) or as a Doctoral University with Higher Research Activity (R2) by the Carnegie Classification of Institutions of Higher Education. Simmons College is not. Additionally, the Council on Social Work Education (CSWE) is the only authorized agency to provide the required accreditation certifications to the program. Currently, the MEDCoE Masters of Social Work Program is only accredited by the CSWE through the University of Kentucky’s Masters of Social Work Program. Accreditation is granted to the Army-UK MSW Program for the duration of the University’s Program’s accreditation.

University Address PH# 1 Baylor University 700 University Parks Drive

Waco, TX 76798

(254) 710-8594

2 Simmons University 300 Fenway, Boston

MA 02115

(617) 521-2000

3 University of Kentucky 500 S Limestone 109 Kinkead Hall Lexington, KY 40526-0001

(859) 257-9000

9. Interested Sources: To date, Baylor University has expressed an interest in the acquisition; however, UofK is the only university accredited by the CSWE.

10. Other Facts:

a. Procurement History:

(1) Contract numbers and dates of previous contracts for the same requirement are as follows:

Contract Number Program Method of solicitation Awardee Date

W81K04-12-D-0011 Masters of Social Work (MSW) Program

Full and Open Competition

Fayetteville State University

(FSU)

01 April 2012 – 31 March 2017

W81K04-17-D-0001 Masters of Social Work (MSW) Program

Full and Open Competition

University of Kentucky

(UK)

31 October 2016 – 30 October 2021

(2) These contracts were solicited as full and open competition. Three other offerors submitted quotes in response to the solicitations. There is a risk of not being accepted by the CSWE due to affiliation with two different universities violates recent changes in the guidelines and bylaws set forth by the Southern Association of Colleges and Schools (SACS) and the Council on Social Work Education (CSWE) regarding the conduct of program administration. These changes prohibit this type of activity and could seriously jeopardize the approval of the aforementioned request. This was not a by factor to be considered during the award of the previous contract as it had yet to be implemented.

(3) Authority previously cited if less than full and open competition was used.N/A

(4) If a justification was prepared to support the procurement made before this one, a summary of the contents of paragraph 7 of the justification for that procurement and an explanation of the results. N/A

(5) If any prior contract for this requirement was accomplished using full and open competition, include a detailed explanation of the changed circumstances causing this action to now limit the sources. The Council on Social Work Education (CSWE) is the only authorized agency to provide the required accreditation certifications to the program. The MEDCoE Masters of Social Work Program is currently accredited by the CSWE through the University of Kentucky’s Masters of Social Work Program therefore making this university the only source capable of fulfilling the government’s requirement.

Accreditation is granted to the Army-UK MSW Program for the duration of the University’s Program’s accreditation. Additionally, this requirement had been accomplished using full and open competition since 2012 however a change of universities would be the same as a changing of “brands” with respect to curriculum syllabi. The University of Kentucky has a defacto copyright of their specific syllabi.

Aligning with another university would require the program to work two different syllabi, thus doubling the workload and manpower necessity. That, along with the added cost of contracting additional faculty to convert a different syllabi into a working curriculum would add undue burden and stress to the program and Department of Graduate Education.

(6) An explanation of any unusual patterns that may be revealed by the history, e.g., several consecutive, urgent buys. N/A

(7) If a justification was prepared to support the procurement made before this one, briefly describe the circumstances justifying the procurement and whether there have been any significant changes.

N/A

b. Other facts: N/A

11. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Typed Name: LTC Matthew S. Douglas Date:

Title: Associate Dean of Administration Signature:

DOUGLAS. Digitally signed

MATTHEW

.SCOTT.11

63958593

DOUGLAS.MATT

HEW.SCOTT.11

63958593 Date: 2021.04.14 09:02:21 -05'00'

12. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Typed Name: Michael E. Martinez Date:

L.EDUAR

DO.10698

44592

HAEL.EDUARD

O.1069844592 Date: 2021.04.13 10:58:30 -05'00'

13. Fair and Reasonable Cost Determination: The government will utilize a price analysis in determining the contractor’s proposed price for this effort to be fair and reasonable. This determination will be based on an analysis of the offer and the independent Government estimate, etc. As part of the basis, the contractor will be required to provide other than certified cost or pricing data.

This determination will be made using the following: audit: other: price analysis cost analysis IGCE

As a part of this basis, certified cost or pricing data is not required because the item and/or services being acquired are considered commercial.

Typed Name: Laura J. Applewhite Date:

Title: Contracting Officer Signature: APPLEW

Digitally signed by

HITE.LAUAPPLEWHITE.L AURA.J.100946

RA.J.100

9460752

13:55:27 -05'00'

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Typed Name: Laura J. Applewhite Date:

Title: Contracting Officer Signature:

APPLEW

HITE.LA

Digitally signed by

APPLEWHITE.L

AURA.J.1009460

URA.J.10 752

13:55:43 -05'00' 09460752

Approval Based on the foregoing justification, I hereby approve the procurement of Master of Social Work (MSW) Program University Affiliation Services on a sole source basis pursuant to the authority of the Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5, subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.

TYPED NAME: Liza J. Esmond Date:

Title: Command Advocate for Competition Signature: