JOFOC FBO Posting_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

AUTHORITY: FAR 16.505(b)(2)

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for an Exception to Fair Opportunity.”

This document is a Justification for an Exception to Fair Opportunity for the Department of the Interior, Interior Business Center, Acquisition Services Directorate, Division 2; Client: Executive Office of the President (EOP), Office of National Drug Control Policy (ONDCP).

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

This is a follow-on requirement to existing task order D15D00159, which was awarded, on a firm-fixed-price (FFP) basis, competitively against National Institutes of Health (NIH), Information Technology Acquisition and Assessment Center (NITAAC) Contract Number HHSN316201200028W. The period of performance for the current task order ends on July 14, 2020. The Government intends to award this follow-on requirement as a FFP type contract to ICF Incorporated, LLC.

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

The Office of National Drug Control Policy (ONDCP), Drug-Free Communities (DFC) Support Program requires the acquisition of IT commercial services to enhance, maintain, and support the DFC Grant Oversight System known as DFC Me. The development of this system was intended to serve as a web-based technology platform to enhance ONDCP’s oversight of the DFC grant program. The current system ensures compliance with the DFC grant’s terms and conditions, facilitates the required reporting of core measures data, and strengthens ONDCP’s two-way communication with DFC coalitions in support of the National Drug Control Strategy (NDCS).

According to the Drug-Free Communities Act passed by Congress in 1997, there are specific data collection requirements enumerated. Included in the statute, is language that states there will be, “assurances that the entity conducting an evaluation shall have experience - in gathering data related to substance abuse among youth or in evaluating the effectiveness of community anti-drug coalitions”. Due to this congressional requirement for ongoing data collection, the DFC Program can not have any disruption in the collection or analysis of data from coalitions.

Any change in vendor during this critical time may increase delays and risk meeting congressionally mandated reporting requirements. The estimated value of the 3-year contract (base year plus 2 option years) is $1,350,000.

4. Identification of the exception to fair opportunity (see 16.505(b)(2)) and the supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited. If the contracting officer uses the logical follow-on exception, the rationale shall describe why

PR/SOL/CONTRACT # TBD

the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value).

FAR 16.505(b)(2)(i)(C) – The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

The DFC Me system is a large web-based data collection platform for DFC-funded community coalitions that was created specifically for ONDCP and its grant program. Any interruption in service to this customized system would significantly impact over 700 community coalitions, a $101 million-dollar Federal grant program which has strong support in Congress. The DFC Program is ONDCP’s flagship youth substance use prevention program and directly supports the Trump Administration’s National Drug Control Strategy (NDCS). Given our country’s opioid and addiction epidemic, a disruption in tracking of compliance with the grant award’s key terms and conditions would be detrimental. Also, significant changes in the tracking of strategies and activities that are being implemented with Federal grant dollars would be potentially harmful to the program and to the millions of Americans working to prevent youth substance use. As reported in the latest DFC National Evaluation End-of-Year Report, in FY 2018, 62.8 million Americans lived in a DFC-funded community where coalitions are working to address youth substance use prevention.

There are multiple critical factors in the DFC Program’s transition and critical statutory requirements that directly impact our ability to recompete this contract, therefore an exception is requested.

First, the Substance Abuse and Mental Health Services Administration (SAMHSA) is the current day-to-day program management partner for the DFC program’s over 700 grant award recipients. Effective October 1, 2020, the Centers for Disease Control and Prevention (CDC) will be the new partner and take on all management functions. This is only the second time in the 20-year history of the program that a major transition such as this has taken place. One of the main challenges presented in this transition is the necessity to run the DFC Me system simultaneously between SAMHSA and CDC to allow community coalitions to continue to submit required data to the DFC program.

In addition, the DFC Me system contains key grant recipient programmatic data that is part of the DFC grant recipient’s official grant file (i.e., progress reports required in FY 2020 continuation applications). As a result, it is essential that the DFC Me technology system be operating in a highly efficient and reliable fashion. The DFC Program cannot risk losing or experiencing delays in access to key DFC grant recipient information by neither ONDCP, SAMHSA, nor CDC program staff.

Also, in the midst of the transition, SAMHSA is ramping down their FTE count, while CDC will be bringing on new hires for program project and grants management officers. It will take a considerable amount of time to train the new staff on all aspects of the DFC program. It is imperative that we continue to have in place an experienced and knowledgeable vendor to train the new DFC staff at CDC.

Second, the DFC Program statute requires the collection of data related to substance use among youth and evaluating the effectiveness of community anti-drug coalitions. The next DFC data collection reporting cycle begins August 1, 2020. This is a critical time in the DFC Program’s national evaluation process, data from February and August Progress Reports are analyzed and a DFC End-of-Year Report is published. In August, over 700 DFC-funded community coalitions will be accessing the DFC Me system for data entry. Losing the Subject Matter Expertise (SME) on this customized system during this crucial reporting period may negatively impact DFC coalitions’ ability to report on the effectiveness of this flagship grant program to Congress.

The DFC Program is currently evaluated by a DFC National Evaluation Team (Task Order D16PD00001), also housed with the same contractor that developed the DFC Me Grant Oversight System. Over the last five years, the incumbent’s staff (ICF Incorporated, LLC) for both contracts have needed to work in a highly collaborative fashion and have access to each other’s systems to significantly improve the user experience and quickly respond to technical data issues. The DFC National Evaluation team was integral in the development of this system.

During the initial requirement gathering meetings, the National Evaluation Team played a central role in identifying the requirements to build a system that could accurately provide ONDCP real-time data reporting and tracking. The system was also built to ensure grant recipient compliance with the program’s terms and conditions. One of the most important terms and conditions relates to the data visualized in the system that directly informs the DFC National Evaluation, hence the work is deeply interwoven.

In addition to the interrelationship between the National Evaluation Team and the DFC Me platform, there is also a high degree of collaboration that exists in identifying best practices in the field that can be replicated by other coalitions through advanced training. This seamless interaction is essential in developing data driven content that strengthens the ability of local communities to deliver positive results in reducing youth substance use. The reason for this success is due to the extensive experience that the vendor delivers on both the evaluation and technical aspects of DFC Me.

Lastly, due to the novel Coronavirus (COVID-19) outbreak, OMB on March 19th issued guidance to departments and agencies that provides agencies with additional flexibilities for grants affected by the outbreak. The memo, among other key functions, authorizes agencies to extend financial, performance and other reporting to reduce burden to grant recipients. As ONDCP determines how it will implement OMB’s guidance, a change in the reporting system used by the over 700 DFC-funded community coalitions would be an added burden.

The solicitation for the DFC Me Grant Oversight System contract was issued by the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD) on behalf of ONDCP. The competitive acquisition was for a Firm-Fixed Price (FFP) Task Order issued against the National Institutes of Health (NIH), Information Technology Acquisition and Assessment Center (NITAAC). ONDCP’s IT Director strongly recommended NITAAC’s Government-Wide Acquisition Contracts (GWACs) as the vehicle because it provided both general and health specific IT products and services from a group of pre-screened, highly-qualified companies that have already been verified for integrity and expertise.

The ONDCP received four proposals for the competitive acquisition. With DOI’s guidance, the DFC program’s staff spent three weeks thoroughly reviewing, discussing, and evaluating each of the proposals received. ICF’s Technical Proposal and Price Proposal met all the requirements identified in the Performance Work Statement (PWS) to build the technology system in ONDCP’s PWS with minimal risks. The contract was awarded in November 2014 after a thorough competitive process. This will be the first re-compete of the original contract.

For performance under the task order, all physical and logical access to the EOP complex requires approval by the White House Personnel Security Division (PSD). All contractors, who require access to the EOP must have been subject to a favorably adjudicated background investigation. All contractor personnel shall have at least a background investigation using a Standard Form 86 (SF-86).

All awardees on the NITAAC contract vehicle were given a fair opportunity to be considered for the original task order. The incumbent, ICF International, has successfully performed the required services for the Government under this task order since November 2014. The DFC Program’s primary concern is potential negative impacts to the over 700 community coalitions across the country during this critical time in the DFC Program’s management. Moving forward with a new vendor, during this critical time in the program’s management cycle, significantly increases the risk of coalitions experiencing disruptions in their ability to track compliance with DFC grant terms and conditions and the inability to use the DFC Me system to track activities being implemented with Federal dollars or during a critical reporting period. In August 2020, coalitions are required to submit data for all work completed since February 1, 2020 (6 months of grant implementation). In addition, the transition timeline and the impacts of COVID-19 on grant award recipients present significant challenges to over 700 funded communities – at a time when OMB is requesting we provide administrative relief to grant recipients. Awarding this task order non-competitively to the incumbent saves the Government time and significantly reduces the risk of collecting or losing data. It also assists with our ability to track compliance with statutory program requirements. In addition, the incumbent’s employees are already fully integrated into the ONDCP organization. The time required to in-process a new employee (if awarded to a new vendor) may take as long as 30 days for required EOP background checks and onboarding. There are 19 contractors, who have received EOP clearance on this project. The cost of investment that has been made towards EOP background investigations can range from $1,500 to $3,000 on a case by case basis.

Additionally, the incumbent’s employees already successfully meet the performance objectives and expectations associated with the contract and the DFC Me Grant Oversight System. The vendor also comprehends the operational landscape of ONDCP and has a complete understanding of mission needs and requirements. The employees know the technology and the functionality of the existing IT systems, which will minimize the transition time between the contract that is ending and the new award. This time savings is significant because once onboarding is complete, ONDCP estimates approximately 180 days may be required for new employees to become proficient at performing certain complex tasks described within the PWS.

This varies due to the skill level and complexity of tasks performed.

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

The contracting officer will make a separate determination as to the fairness and reasonableness of the price through price analysis. Historical data from the existing task order D15PD00159 will be utilized, published rates listed on the NITAAC CIO-SP3 Government-wide Acquisition Contract (GWAC), and ONDCP/DFC’s cost estimate will be used during the price analysis.

6. Any other facts supporting the justification.

This contract represents the most advantageous method of fulfilling the client’s need given price and other factors. Disruption in service would significantly impact the DFC program.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

The sole source contract will include a transition plan to assist with on-ramping a potential new vendor which mitigates programmatic impacts associated with transitioning contractors. Upon completion of this contract the intent is to compete this requirement with full and open competition.

8. The contacting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

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

L. Christine Quintana, Contracting Officer

9. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for an exception to fair opportunity) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify that the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

Helen Hernandez, COR

Date

10. A written determination by the approving official that one of the circumstances in FAR 16.505(b)(2)(i)(A) through (E) applies to the order.

FAR 16.505(b)(2)(i)(C) The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

Hernandez, COR

5.8.2020

05/11/2020

LYDIA

QUINTANA

Digitally signed by LYDIA

QUINTANA

Date: 2020.05.11 17:24:51 -04'00'

11. Reviews and Approvals

Concur

Date

Concur

Chief, Division 2

Approve

Michael Whalen

Competition Advocate

ROBERT BROWN Digitally signed by ROBERT BROWN Date: 2020.04.16 11:08:44 -04'00'

HEIDI HERRON Digitally signed by HEIDI HERRON Date: 2020.05.20 09:19:18 -04'00'

MICHAEL

WHALEN

Digitally signed by

MICHAEL WHALEN

Date: 2020.06.01 12:22:03 -04'00'