JEFO 26-225 Data Migration_Redacted.pdf

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Data Migration Support
Solicitation number
N0018925FZ224P00011
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About this file

This is a Justification for an Exception to Fair Opportunity (ABOVE SAT) document for a Navy procurement action.

The Assistant Secretary of the Navy, Financial Management & Comptroller (ASN FM&C) is seeking to modify an existing task order under the FIP IV IDIQ multiple award contract (MAC) to award additional Data Migration Support services to Deloitte and Touche LLP. The modification will add a firm fixed-price CLIN for Data Migration Support with a five-month period of performance, increasing the total contract value from an unspecified baseline. The services support the Navy's ERP+ program, a comprehensive enterprise-wide business process transformation and modernization effort across the Department of Navy to replace legacy ERP systems with SAP S/4HANA. The modification addresses an unforeseen surge in data migration work volume resulting from major programmatic developments involving integration of legacy data through the Advana and Palantir Foundry platforms. The required services include establishing data cleansing rules, standards, metrics, and governance structures; leading data profiling and validation activities; automating cleansing tasks through UiPath; and performing financial reconciliation to ensure audit readiness. Funding will be provided through Navy Operations & Maintenance (O&MN) appropriations.

The justification invokes the exception under FAR 16.507-6(b)(2), asserting that only Deloitte is capable of providing the required services because they are unique or highly specialized. The rationale emphasizes that Deloitte is the incumbent performing closely aligned work under task order N0018925FZ224 (which was competitively solicited but received only one quote) and possesses irreplaceable knowledge of both the customized legacy architecture and incomplete future-state design. The document argues that engaging a new vendor would create duplicative costs, administrative overhead, schedule delays, and coordination risks given Deloitte's concurrent responsibility for End-to-End Process Design and Solutions Design activities that directly drive data migration requirements. The contracting officer has determined the anticipated cost to be fair and reasonable. Future new work or requirements will be solicited competitively to all original MAC IDIQ holders, and the Government will continue to pursue small business opportunities.

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Source Selection Information See FAR 2.101 and 3.104

Document # 26-225

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

(ABOVE SAT)

1. Identification of Requiring Activity and Contracting Activity.

The requiring activity is the Assistant Secretary of the Navy, Financial Management & Comptroller (ASN (FM&C)), Washington, DC. The contracting activity is NAVSUP Fleet Logistics Center (FLC) Norfolk, Contracting Dept., BUMED/FM&C Directorate.

2. Nature and description of contract action.

This acquisition is conducted under the authority of 10 U.S.C. 3406(c)(5). This action is an exception to the fair opportunity process to be awarded as a modification to an existing task order. The placement of a new Firm Fixed-Price CLIN on an existing order is anticipated.

This procurement action is to modify the ERP+ functional support services currently performed by Deloitte and Touche LLP. (hereinafter Deloitte) under Contract N0018922DZ017, Task Order N0018925FZ224, solicited on a competitive basis but ultimately received only one quote. This modification will procure additional support and add a Firm fixed-price Data Migration Support CLIN with an approximate value of , increasing the contract total from to .

The proposed acquisition is to issue a modification to an existing Task Order issued to Deloitte.

The sole focus of this modification is additional Data Migration Support to assist with an unforeseen increase in work volume required to prepare to migrate the entire legacy systems into ERP+. ERP+ is a holistic business process transformation and change management campaign across the DON to re-engineer business processes based upon the software standards and leading practices of SAP S/4HANA, the next-generation software replacing the legacy Navy ERP ECC system. Rather than a technical upgrade, ERP+ represents an enterprise-wide modernization effort to align financial management, logistics, and supply chain functions. To meet this need, the DON requires specialized FTEs to serve as Data Subject Matter Experts (SMEs) to lead the data cleansing approach for ERP+, focusing on improving data integrity and cutover readiness across critical transactional and master data domains, including Trial Balance and General Ledger data. These FTEs will lead critical activities including profiling data, establishing cleansing rules, standards, metrics, and triage criteria, overseeing and directing cleansing activities, and implementing centralized corrective and preventive actions prior to cutover. They will also automate repeatable cleansing tasks through UiPath and validate outcomes through reconciliation, dashboards, mock loads, and iterative refinement, all under a structured governance and controls framework.

This surge support is necessitated by major programmatic developments that make the migration process significantly different and far more complicated than originally intended. Specifically, legacy data is now being filtered through the Advana and Palantir Foundry platforms, which introduces unforeseen technical and architectural integration complications. The state of the underlying legacy data is also a significant risk, and there is a likelihood that a substantial volume of the data must be corrected. To address these challenges, the DON must establish robust data systems, cleansing rules, standards, metrics, and governance structures proactively before systemic issues are actively spotted. If these preparations are not executed correctly, the data will fail to migrate, forcing stakeholders and end-users to navigate and maintain two separate, fragmented systems simultaneously until all issues are resolved. Without the additional support, the migration would proceed in a possibly compromised, problematic state, which would threaten the DON's ability to sustain its audit readiness goals.

The period of performance for Data Migration support is five (5) months. The Government Estimate for Data Migration Support is .

This effort will be funded with the corresponding Fiscal Year Navy Operations & Maintenance (O&MN) appropriations. These funds are expected to be available in the corresponding fiscal year.

4. Identification of the Exception to Fair Opportunity and Supporting Rationale -

The statutory authority that permits not providing each awardee a fair opportunity to be considered for each order exceeding the micro-purchase threshold issued under a multiple award contract is 10 U.S.C. 3406(c)(5), as implemented by FAR 16.507-6(b). The applicable exception to the fair opportunity process for this justification for the award of an order exceeding the simplified acquisition threshold is:

The exception to the fair opportunity process is FAR 16.507-6(b)(2), Only one awardee is capable of providing the services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

Deloitte is currently doing ERP+ support on contract N0018925FZ224, which is a follow-on to contract N0018924FZ713. Both task orders were competitively solicited on the FIP IV IDIQ contract vehicle. Deloitte was the only firm that submitted a proposal in response to the solicitation for current task order N0018925FZ224.

The addition of these services is an urgent necessity driven by an unforeseen increase in the volume of data migration work. Prior to transitioning legacy financial data into the new system, mapped to the requirements of the new system and corrected of critical underlying abnormalities or transaction-level errors). This is an effort currently underway on the current task order, and this modification expands the scale of the existing data migration support. This expansion aids in the timely delivery of a comprehensive, automated data cleansing framework that maintains data integrity before the ERP+ transition. This is a complex because the data is now being filtered from the legacy system through two other data platforms/applications (Advana and Palantir Foundry). While this arrangement offers the best way of achieving also presents unique architectural and integration complications. Furthermore, there is significant risk regarding the state of the underlying legacy financial data. This legacy financial data may have underlying issues at the transaction level ( abnormal, etc.) that would prevent it from flowing cleanly into S/4HANA in an audit-ready state.

To mitigate these risks, the DON must establish robust systems, data cleansing rules, standards, metrics, and governance frameworks before systemic migration issues are actively spotted

As the incumbent, Deloitte is uniquely positioned to immediately support this expanded workload because they are already performing closely aligned data mapping, cleansing, and migration services as instructed in the Data Management section in the PWS under contract N0018925FZ224. Under the current contract, Deloitte is responsible for executing pre-migration data cleansing, evaluating and correcting transactions at the balance and document level within government-furnished environments, like Advana and Palantir Foundry, and leading the complex financial reconciliation of migrated data back to legacy Navy ERP trial balances. Furthermore, their active scope of work includes designing automated data migration solutions, building data catalogues to manage system interfaces, and developing process automation capabilities using robotic process automation tools like UiPath. Because the Deloitte team is actively executing these exact technical activities on the ground today at a smaller scale, it would be illogical to award to another vendor to perform the same activities. Doing so would result in duplicative contract management and startup costs as well as introduce an unnecessary seam between two vendors that would be fundamentally be doing the same work.

Data migration is not an isolated task; it is fundamentally linked to the business process and solutions design activities. Specifically, Deloitte's team is currently leading the End-to-End (E2E) Process Design and Solutions Design tasks, meaning they are designing the target system requirements. These requirements directly dictate how the legacy data must be mapped and cleansed. Introducing a separate vendor to perform just this data cleansing and migration sub-task would create a highly fragmented environment. The Government would be forced to manage an additional, highly complex layer of coordination between two different firms. This would introduce significant administrative overhead, increase government oversight costs, and create substantial risks of schedule delays due to misaligned communication. Executing this as a modification to Deloitte's existing task order avoids a costly duplication of effort, provides seamless alignment between requirements design and data execution, and represents the most efficient and economical approach for the Government.

Deloitte is the only awardee possessing this dual knowledge of both the deeply customized legacy architecture and the incomplete future-state design. Onboarding a new vendor to decipher this highly customized environment under Task Order N0018925FZ224 would require a lengthy and cost-prohibitive knowledge transfer process. A new vendor would spend the majority of the performance period simply learning how to safely navigate process Deloitte already has learned and performed, causing unacceptable schedule delays and thereby guaranteeing a failure to meet

5. Determination of Fair and Reasonable Cost.

In accordance with FAR 16.507-6(d)(2)(v), the contracting officer has made the determination that the anticipated cost to the Government will be fair and reasonable.

6. Any other facts supporting the justification.

This procurement uses a MAC and will be solicited and awarded in accordance with FAR Subpart 16.507.

7. Actions Taken to Remove Barriers to Competition.

The additional support was given to the incumbent because as stated above, they are the only awardee capable of providing the required services. The incumbent company was chosen out of five (5) MAC IDIQ holders. The incumbent, who was the only quoter when the task order was competitively solicited, is completing a continuation of their prior work, which was extended due to unforeseen circumstances. Any new work or requirements will be solicited to all companies that originally competed for this MAC IDIQ contract. The Government will also continue to look for Small Business opportunities on this contract when available.

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