04.06_Limited Source Justification (Managed Care Advisors).pdf

OFFICE OF ACQUISITION MANAGEMENT

LIMITED SOURCES (CLASS) JUSTIFICATION

Orders or BPAs Exceeding the Simplified Acquisition Threshold

J&A-20-0022

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This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity.

The U.S. Department of Homeland Security (DHS), U.S. Immigration and Customs Enforcement (ICE), Office of Acquisition Management (OAQ), on behalf of the Office of Human Capital (OHC) to award an order in pursuant to FAR 8.405-6(a), Limiting Sources.

2. Nature and/or Description of the Action Being Approved.

(a) Type of action: Hybrid Contract

(b) Amount the current J&A is justifying: $412,263.78

(c) Brief Description: OAQ intends to procure, on a sole source basis, workers’ compensation medical case management services.

Managed Care Advisors, Inc.

7700 Old Georgetown Rd. # 750 Bethesda, MD, 20814-6100

It is the intent of the Office of Human Capital (OHC) to obtain continued workers’ compensation medical case management services for the ICE Workers’ Compensation Program (WCP).

Approval is being requested for a hybrid labor hour (LH) and firm fixed price (FFP) contract to Managed Care Advisors for continued service support under GSA Schedule GS-02F- 0128W. OHC is requesting approval of this LSJ for an award bridge contract to support existing level of effort. No new work or change to scope is anticipated. The Government shall use O&M FY20 appropriated funds.

The basis for limiting the sources for this acquisition is to avoid a lapse in service while the current service is being re-competed. The WCP is better served by a follow on service with the current vendor, Managed Care Advisor until an award can be made.

The period of performance requested is a three-month base and three (3) 1-month option periods beginning February 1, 2020 thru July 31, 2020.

3. Description of Supplies/Services

In accordance with agency objectives, the government has a need to procure a full range of Workers’ Compensation Medical Case Management. The estimated dollar value of this procurement is $405,973.92.

http://uscode.house.gov/

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The estimated labor hours and base year will be funded with FY20 O&M dollars. O&M funding will also be used for any option periods exercised.

Base Period 02/01/2020 – 04/30/2020 $199,601.55 Three 1-month Options 05/01/2020 – 07/31/2020 $212,662.23 Total Contract Value (Base + Extension) $412,263.78

4. Authority and supporting rationale and a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(a)(1)(i)(C) In economical interest and efficiency, the service is a follow-on to an order that was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original BPA was not issued under sole-source or limited-sources procedures.

The current vendor is uniquely qualified to continue providing these services to OHC on an uninterrupted basis. The current vendor has been granted Authority to Operate (ATO), which provides authorization to operate information systems that store or transmit personally identifiable information to be use by their system. When the ATO was issued it took 18 months to get approval, any delay, even at half this time, would severly impact critical mission operations. Issuing a new solicitation and awarding new calls would likely end with the same result while duplicating cost, effort, and time.

In addition to the above, failure to award this short term bridge to Managed Care Advisors will result in loss of service which is a direct link to the “Presidential POWER Initiative:

Protecting Our Workers and Ensuring Reemployment”. Any discontinuance of these services will lead to: 1) negative impact on workers’ compensation case review; and 2) worker’s compensation case statistics.

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

The Contracting Officer (CO) has determined that issuing a follow on contract for this service represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs. The current rates were already determined to be fair and reasonable at the time of award. In addition, this modification will be placed in accordance with FAR 8.404-Use of Federal Supply Schedules and the U.S.

General Services Administration (GSA) has already determined the pricing of GSA schedule contracts to be fair and reasonable.

6. Any other facts supporting the limited-sources justification. Additional facts may be stated in this section. If there are no additional facts, you must state that here.

None.

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7. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made.

ICE is working with the DHS Strategic Sourcing Program Office to create a vehicle that can support all of the DHS Components. DHS had anticipated award of a new BPA in Sepember 2019, but unforeseen issues have caused a delay in award.

It is the policy of this office to follow the requirements of FAR 8.405-1 and 8.405-2 when making FSS program procurements. However, the specific requirements can only be met in this situation bylimiting sources in accordance with FAR 8.405-6.

8. Technical and Requirements Certification.

I certify that the facts and representations under my cognizance which are included in and form the basis for this justification are complete and accurate.

Name, position title of technical or program manager of requisition activity Date

9. Contracting Officer Certification and/or Approval

For orders exceeding the simplified acquisition threshold, but not exceeding $500,000, the ordering activiy contracting officer’s certification that the justification is accurate and complete to the best of the of the ordering activity contracting officer’s knowledge and belief.

Richard Meier Date Contracting Officer Office of Acquisition Management U.S. Immigration and Customs Enforcement

10. Approval.

Angela L. Avery Date IOSD Unit Chief Office of Acquisition Management U.S. Immigration and Customs Enforcement