JOFOC.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

REQ. NO. ZEROREQ-OCIO-20-0067

1. Nature and/or description of the action being approved.

Noncompetitive modification to increase the maximum value of Indefinite-Delivery, Indefinite-Quantity (IDIQ) Contract No. NRC-HQ-11-C-33-0059 (“the contract”).

2. A description of the supplies or services required to meet the agency’s needs (including estimated value).

Under the contract, CGI Federal, Inc. (“CGI Federal”) provides maintenance and operation (M&O) for NRC’s legacy systems.

The NRC requires an increase in the maximum value of the contract by $20,069,395 for CGI Federal to perform the following services until the NRC awards successor acquisition(s) in Fiscal Year (FY) 2021:

A) ADAMS Re-platform Support; Estimated Value: $6,623,308

The NRC requires CGI Federal to support the operation of NRC’s current IBM FileNet-based Document Management, Records Management and Case Management systems while also migrating the Case Management systems and applications to new, low code/no code, hosted solutions that the NRC intends to procure in the future by separate procurement(s). A low-code/no-code development platform is a visual software development environment that allows developers to drag and drop application components, connect them together and create a mobile or web app with little of no programming.

CGI Federal is currently accommodating the NRC’s new requirements for automated workflows using the low code/no code hosted solutions while concurrently supporting the IBM-based components through FY 2021.

B) Transformation Initiatives; Estimated Value: $1,404,314

The NRC requires CGI Federal FEDERAL to support the NRC’s transformation initiatives through better management of “big data.” This includes utilizing NRC’s instance of IBM’s proprietary Watson Analytics platform, Records Management retention schedules and automation of currently manual and/or inefficient business processes.

C) Cloud Assessment and Migration; Estimated Value: $4,616,978

The NRC has been planning the move of various ADAMS components to Cloud services for the past few years. Due to the current maturity level of the NRC’s Azure tenant, opportunities have moved from theoretical to practical as CGI Federal began work developing cloud-based applications. Taking a cue from the NRC’s current push towards more and more cloud native applications the NRC requires the Contractor to continue prioritizing and developing cloud-based applications.

The Contractor’s experience and expertise supporting other NRC enterprise applications in the cloud, coupled with expertise in ADAMS application and architecture, are critical in meeting this Agency mandate.

D) Data Analytics; Estimated Value: $1,003,339

CGI Federal configured the NRC’s Content Analytics suite of tools, IBM’s Watson. This tool is still used to interpret raw text within ADAMS documents to decipher patterns, trends and anomalies that would otherwise take humans significantly more hours and effort to glean and present.

The NRC requires the Contractor to further configure Watson to mine text from documents in the ADAMS Main Library and provide visualization tools for risk informed decision makers to view relationships that would otherwise remain hidden.

Through this analysis of raw data, NRC subject matter experts will then make informed conclusions about component(s) failures or more significantly, highlight areas for additional study that could reveal the likelihood of incidents before they even happen.

E) Information Collections Support; Estimated Value: $1,003,339

The NRC requires the Contractor to continue to support a wide variety of administrative functions such as managing Rulemaking artifacts and Federal Register Notices information collections as well as maintaining the Intranet and Project Management support.

F) Improved Document Management; Estimated Value: $1,404,314

The NRC requires the Contractor to continue ongoing work to automate and improve the way information is obtained, disseminated, reviewed, revised, approved and published using workflow automation tools. Specifically, they are expected to expand applications developed to improve the efficiency of document processing through the NRC’s Document Processing Center such as the Document Tracking System (DTS) and the concurrence and electronic signature process.

G) Ongoing Upgrades and System Changes; Estimated Value: $3,010,464

As the NRC's of official document repository, the number and complexity of requests to interoperate with ADAMS has increased. The NRC requires the Contractor to continue to support such requests, including but not limited to the following:

• Improve the efficiency of ADAMS data distribution to the NRC’s Storage Area Network (SAN) to reduce storage and retrieval costs.

• Develop an interface between document ingestion/compliance/disposal functions and new products that fulfil Freedom of Information Act (FOIA) requests, Case Management and Record holds

• Expand and improve the auto population function of ADAMS to streamline document feeds from Electronic Information Exchange (EIE) and the Document Processing Center (DPC),

• Develop a Realtime data feed from ADAMS to Reactor Program Systems (RPS) with Part 50 and Part 52 metadata enhancing the value and availability of RPS data, and

• Develop a bulk loader to automatically find and modify properties of 700K documents in ADAMS and subsequently publish them to public Web-based ADAMS.

H) Potential Transition to a Successor Contractor; Estimated Value: $1,003,339

The Contractor may be required to provide support until work under this contract is transitioned to successor Contractor(s) via either competition among the NRC’s Global Infrastructure and Development Acquisition (GLINDA) GSA Federal Supply Schedule Blanket Purchase Agreement (BPA) awardees or by other appropriate means in FY 2021. These efforts will include Preparation and Planning; Migration; Verification – Post Migration; and Maintenance upgrade, stabilization, and support for open source platforms and applications deployed or scheduled for deployment in either production, test, or development environments.

The estimated value of these remaining requirements is $20,069,395. The current maximum value of the contract is $90,000,000; accordingly, the NRC intends to increase the maximum value of the aforementioned IDIQ contract to $110,000,395 so that the remaining requirements can be satisfied under the applicable task orders under the contract.

3. An identification of the statutory authority permitting other than full and open competition. 41 U.S.C. 3304(a)(1)

4. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Over the past nine years CGI Federal has maintained ADAMS and related applications and is uniquely qualified to operate, maintain and provide user support for these programs. They demonstrated a deep understanding of both the data and code by migrating the original ADAMS FileNet Content Services platform to the current P8 platform while keeping databases synchronized on both platforms.

CGI Federal further demonstrated a thorough understanding of the programs, processes, data and their interrelationships through streamlining and automating the ADAMS Software Development Lifecycle (SDLC) using a recently acquired suite of DevOps tools. DevOps is a set of practices that combines software development (Dev) and IT operations (Ops), which shortens the SDLC development life cycle and provide continuous delivery with high software quality.

Based on guidance received from the Chief Information Officer in 2018 to re-platform ADAMS components to a “low code/no code” solution, CGI Federal is currently migrating IBM Case Manager process automation components to more modern, easier to manage tools. The Contractor’s in-depth understanding of existing programs and data simplifies this migration and maximizes O&M resources. It is impractical for another contractor to transition, get up to speed, and perform the required tasks given NRC’s plans to compete and award a GLINDA BPA Call for ADAMS O&M support in FY2021.

5. A description of the efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR

5.202 applies.

The NRC intends to post Special Notice on beta.sam.gov regarding its intent to solicit, negotiate and award a noncompetitive modification to the contract to complete the work noted above and to increase the maximum value of the contract to allow that work to be completed. The NRC will address any responses received based on that notice before proceeding with this modification.

6. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The fixed hourly rates in the contract have already been determined to be fair and reasonable and separate fair and reasonable determination(s) will be made for new work under the contract. The contracting officer will perform a separate fair and reasonable pricing determination for any new task orders or modifications to existing task orders for the remaining work and will only award them if the anticipated cost and prices are determined to be fair and reasonable.

7. A description of the market research conducted (see FAR Part 10) and the results, or a statement of the reasons market research was not conducted.

Due to the current Contractor’s in-depth, extensive and well-established experience with, and knowledge of the NRC’s automation needs and tools and technologies in use, no market research was conducted.

8. Any other facts supporting the use of other than full and open competition.

Even if another contractor could potentially become proficient in supporting NRC’s ADAMS system, it is impractical to do so given that the ADAMS support is being recompeted in a few months (FY2021). A noncompetitive modification to the contract to increase the maximum value will enable the NRC to ensure the continued operational stability of ADAMS and smooth transition to a follow-on contractor.

9. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

None.

10. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The Acquisition Management Division (AMD) will continue to closely scrutinize any subsequent requests for acquisition of similar services and will ensure that any restrictions to competition are adequately supported and documented. AMD will also fully compete the successor contract.

11. Certifications

This is to certify 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.

Contracting Officer’s Representative

Gary Young

This is to certify that the justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer

Joseph L. Widdup

APPROVAL:

Competition Advocate

Eleni Jernell