JOFOC_CSAVR Spring 2023.pdf

1. IDENTIFICATION:

UNITED STATES DEPARTMENT OF EDUCATION

Office of the Chief Financial Officer Contracts and Acquisitions Management

JUSTIFICATION FOR

OTHER THAN FULL AND OPEN COMPETITION

Agency: U. S. Department of Education Program Office: Office of Special Education and Rehabilitative Services (OSERS)

2. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED:

Vendor: Council of State Administrators of Vocational Rehabilitation (CSAVR)

Approval to fund the registration fees for the CSAVR Spring Conference.

Background for the CSAVR Conferences

The CSAVR holds two conferences each year (Spring and Fall). These are the only vocational rehabilitation conferences where the OSERS Rehabilitation Services Administration (RSA) grantees (i.e., state administrators of vocational rehabilitation agencies) are strongly encouraged to attend and most of them do attend. Additionally, the conferences provide a platform for a wide array of state vocational rehabilitation agency staff and other grantees from across the country to share best practices and advance projects that encourage continuous improvement of the programs RSA administers. The grantees also share information and news related to RSA’s programs. In conclusion, by attending the CSAVR conferences, RSA staff can not only maintain, but enhance communication with the grantees and provide technical assistance. RSA has consistently sent staff to the Spring and Fall conferences each year.

The Spring conference agenda includes:

1. General session (1): Program and Fiscal Foundations

2. General session (2): Period of Performance

3. General session (3): Match (Part 1): Taking the Mystery out of Match and Making

Match Work for You

4. General session (4): Match (Part 2): Taking the Mystery out of Match and Making

Match Work for You

5. General session (5): Effective Expenditure of Funds

6. General session (6): State Agency Panel

7. General session (7): Rate-Setting Guide and Methodologies

This document contains proprietary or procurement sensitive information related to the conduct of a federal agency procurement and shall not be disclosed to any person other than a person authorized by the Contracting Officer to receive such information.

This document contains proprietary or procurement sensitive information related to the conduct of a federal agency procurement and shall not be disclosed to any person other than a person authorized by the Contracting Officer to

8. General session (8): Contracts and Contract Monitoring

9. General session (9): Managing the DSA-DSU Relationship

10. General session (10): Fiscal Forecasting

11. General session (11): Spending Strategies

12. General session (12): Fiscal Monitoring Lessons Learned

13. Meetings with RSA Liaisons (Days 1 & 2)

14. Wrap-up & Action Plans

3. DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY'S

NEEDS:

RSA’s mission is to “provide leadership and resources to assist state and other agencies in providing vocational rehabilitation and other services to individuals with disabilities to maximize their employment, independence, and integration into the community and the competitive labor market.” Attending and participating in a conference that 1) includes many of the RSA grantees, who share important information and news related to the RSA programs; 2) affords an opportunity to provide technical assistance and enhance our communication with the grantees is of upmost importance to us. It’s critical for RSA to continually improve their programs to better serve our customers (i.e., effectively carry out the RSA mission).

Registration amount: Total cost for 35 employees $13,140 ($2,760 per group rate (4 groups of 8 employees); $700 per non-group employee (3 employees)). Period of performance is 04/17/2023 – 04/19/2023.

Note: RSA has consistently sent staff to the CSAVR conferences each year. Due to the number of employees attending the Spring conference, a purchase order is needed.

4. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION: check one

6.302-1, only one responsible source and no other supplies or services will satisfy agency requirements X 6.302-2, unusual and compelling urgency 6.302-3, industrial mobilization; engineering; developmental, or research capability; or expert services 6.302-4, International agreement 6.302-5, authorized or required by Statute 6.302-6, national security 6.302-7, Public interest

5. CONTRACTOR'S UNIQUE QUALIFICATIONS OR NATURE OF THE ACQUISITION

REQUIRES USE OF THE AUTHORITY CITED:

This document contains proprietary or procurement sensitive information related to the conduct of a federal agency procurement and shall not be disclosed to any person other than a person authorized by the Contracting Officer to

Conferences attended by RSA should be relevant to their work and provide the opportunity to enhance the mission. The conference agenda content, RSA liaison meetings, etc. will maximize knowledge-sharing and interactions with our grantees to meet our need of effectively carrying out RSA’s mission.

6. DESCRIPTION OF EFFORTS MADE TO ENSURE OFFERS ARE SOLICITED FROM AS

MANY POTENTIAL SOURCES AS PRACTICABLE:

Extensive market research was first conducted using the GSA Schedules (Note: Council of State Administrators of Vocational Rehabilitation/CSAVR is not on the GSA Schedule). I narrowed the search to “vocational rehabilitation”, “state administrators”, and “training”. I reviewed 10 contracts, but they either provided services related to software, engineering, industrial hygienist, environmental technicians, Web design, IT, health care, etc.; or trainings related to inspectors, environment, business/project management, leading teams, EEO, COR, acquisition, etc.

Market research was then conducted via the Open Market. The search was narrowed to “vocational rehabilitation conferences 2023”, “rehabilitation conferences 2023”, and “vocational rehabilitation training”. The results were limited. I reviewed the Institute of Knowledge Management’s World Disability and Rehabilitation Conference 2023; American Congress of Rehabilitation Medicine (ACRM) 2023; and National Rehabilitation Association’s Disability Employment Summit. The first two conferences are focused on rehabilitation research. The last is focused on advocating for rights and the promotion of high quality, ethical, collaborative practices in the rehabilitation field. Neither are specific to vocational rehabilitation or the law requirements.

Our office would like to maximize the training experience for our employees and the CSAVR provides the best-suited conference to meet our needs through the specialized agenda and target audience as mentioned previously.

7. DETERMINATION BY CONTRACTING OFFICER THAT THE ANTICIPATED COST

TO THE GOVERNMENT WILL BE FAIR AND REASONABLE:

We did a historical price comparison of the same procurement of this conference in FY22 (EDOSE22PC000065). Although there is a slight increase in the individual/group rates, the cost to the government is fair and reasonable.

8. DESCRIPTION OF MARKET SURVEY AND RESULTS, OR STATEMENT WHY

MARKET SURVEY WAS NOT CONDUCTED:

Please see number 6 for market research details.

9. OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION:

This document contains proprietary or procurement sensitive information related to the conduct of a federal agency procurement and shall not be disclosed to any person other than a person authorized by the Contracting Officer to

None.

10. SOURCES, IF ANY, WHICH HAVE EXPRESSED IN THE ACQUISITION IN WRITING:

11. STATEMENT OF ACTIONS, IF ANY, TO REMOVE OR OVERCOME BARRIERS TO

COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION FOR THE SUPPLIES OR

SERVICES:

12. CONTRACTING OFFICER (CO) CERTIFICATION THAT THE JUSTIFICATION IS

ACCURATE AND COMPLETE TO THE BEST OF THE CO'S KNOWLEDGE AND

BELIEF, AND THIS PROCUREMENT IS NOT A RESULT OF A LACK OF PLANNING

OR EXPIRATION OF FUNDS:

I hereby recommend that this justification be approved. I certify that this justification is complete and accurate to the best of my knowledge.

Digitally signed by CLARISSA

RYAN

Date: 2023.02.15 09:17:28 -05'00'

Clarissa Ryan Date Contract Officer

Program Office Certification:

This is to certify that the data supporting this justification is the responsibility of the program office personnel, including verifying the Government's minimum needs or schedule requirements or other rationale for limited sources (pursuant to 8.405-6) or for other than full and open competition justification (pursuant to 6.303-2(b)) which form a basis for this justification, and that such data and rationale are accurate and complete.

Susan Wilbur Date Management Program Analyst

CLARISSA RYAN

This document contains proprietary or procurement sensitive information related to the conduct of a federal agency procurement and shall not be disclosed to any person other than a person authorized by the Contracting Officer to

Chief of the Contracting Office Certification:

This is to certify that the data supporting this justification is the responsibility of the undersigned program office personnel, including verifying the Government's minimum needs or schedule requirements or other rationale for limited sources (pursuant to 8.405-6) or for other then full and open competition justification (pursuant to 6.303-2(b)) which form a basis for this justification, and that such data and rationale are accurate and complete.

Approved:

Joseph Gibbs Chief of the Contracting Office Date