Justification and Approval for GRB Procurement_Redacted.pdf

U.S. AGENCY FOR GLOBAL MEDIA

SOLE SOURCE (INCLUDING BRAND NAME) JUSTIFICATION AND APPROVAL FOR

FAR SUBPART 13.5 – SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS

Authority: 41 USC 3304– Use of Noncompetitive Procedures, FAR 6.302-1—Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Receiving Office: United States Agency for Global Media (USAGM), Office of Contracts (CON)

Requesting Office: United States Agency for Global Media (USAGM), Office of Human Resources (OHR)

1. Nature and/or Description of Action Being Approved:

a. This Justification and Approval document is prepared in accordance with the requirements of the Federal Acquisition Regulation (FAR) Part 6.302-1, "Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements" and 41 USC § 3304 – Use of noncompetitive procedures. The Agency intends to award a contract on a sole-source basis to Lentech, Inc. for the extension of software services for The Government Retirement and Benefits (GRB) proprietary software system. The GRB system is mission-critical to USAGM operations, serving as the sole portal for all health care, insurance, and Thrift Savings Plan (TSP) benefits for the entire USAGM federal workforce. The existing contract provides only six months for open competition (8/1/2024 – 1/31/2025), which is insufficient to conduct the necessary market research and thoroughly vet the technical capabilities of potentially qualified vendors and establish the necessary systematic interconnections and receive the Authority to Operate (ATO). Given the software's critical nature and limited timeframe, any deviation from the current contract framework jeopardizes mission-critical services due to its operational complexity and implementation timeline. This challenge is further compounded by the fact that Fall marks the federal open season enrollment period for insurance and other employment-related benefits, a time when all government employees make critical decisions regarding their benefits and other entitlements. If the system were to lose its operational status during the contract renewal or while a newly selected vendor attempts to operationalize the software—particularly if the vendor fails to meet contract expectations—the Agency would risk jeopardizing this crucial period and leave the Agency workforce unable to participate in open season as expected, and forced to go back toa paper-based process. The open season period is historically a high-demand timeframe for benefit modifications, placing significant pressure on the Office of Human Resources and the Agency alike. Any disruption during this period could expose USAGM to unnecessary legal risks and lead to unacceptable delays or interruptions in software service. This situation strongly supports the recommendation for a sole-source contract under 41 USC 3304, and FAR 6.302-1. The GRB system and the benefits it provides are central to USAGM’s mission, and any disruption to its operations would not only harm the Agency’s mission but also the well-being of its federal workforce. Lentech, Inc. is not just a reliable vendor; they are integral to the seamless operation of USAGM’s IT infrastructure supporting the GRB system. Their comprehensive understanding of this infrastructure, along with established and trusted relationships with USAGM benefit carrier groups and DoD Consortium partners, is crucial. These interconnections are the sole means that benefits data for the Federal workforce can enroll and manage their federal benefit entitlements. Lentech’s deep expertise in how GRB data integrates with USAGM’s DoD shared service human resources (HR) system and payroll providers is essential for ensuring that benefit enrollments are accurately calculated and properly withheld from employees’ paychecks. Any disruption or error in these processes could also lead to significant issues, not only for payroll and HR systems accuracy but for employee trust and satisfaction in the service provided. The complexity and sensitivity of these interconnections mean that the time required for another vendor to establish similar relationships, develop the necessary system interconnections, and secure the ATO far exceed the time remaining on the current contract. Transitioning to a new vendor under these time constraints risks severe disruptions, potentially compromising the integrity of the entire system and the accuracy of employee benefits processing. Given the critical interdependencies and Lentech's specialized expertise in the USAGM IT environments, any lapse in continuity would be highly detrimental. This underscores the necessity of retaining Lentech as the sole qualified vendor, as their unique position and deep understanding of USAGM's operations are vital to the Agency's continued success and operational stability. Furthermore, transitioning to another vendor would result in cost duplication, as a new vendor would need to replicate the IT environments and data interconnections that Lentech has already developed, managed, and secured.

2. Description of Services and Contract Details:

a. The requirement is for the continued use and support of the GRB software for a total of two (2) years, (one base period, and one (1) option year) the services will be identical for the two-year period as they are enumerated in the current contract: .

This software is used in enrollment, management, of all benefit related entitlement to each of the federal workforce population and is critical for ensuring uninterrupted operation of GRB and the continuity of the Office of Human Resources portfolio. The new contract would be effective from February 1, 2025 – February 1, 2026 (Base Period) and from February 1, 2026 – February 1, 2027 (one (1) option period). The estimated two-year value for this contract is .

3. Summarized Rationale Supporting Use of the Authority Cited Above:

a. Potential Harm to Agency Mission:

i. Any lapse in system operation could jeopardize the open season enrollment, exposing the agency to unacceptable legal risks and further disrupting the Agency’s mission. This element also supports the argument that there is an unusual and compelling urgency associated with this request.

b. Unacceptable Delays or Other Compromises:

i. Lentech’s is the only vendor that possesses the immediate ability to maintain

USAGM benefits systematic operations. This is essential to avoid any disruptions that could harm the agency’s mission and employee benefits processing.

ii. USAGM will experience duplicative costs for another vendor to recreate the exact same secure IT environments and interconnections. Work that has already been realized and is currently operational with Lentech.

c. Unique Expertise and Established Relationships:

i. Lentech’s specialized knowledge of USAGM’s IT infrastructure, established relationships with benefit carrier groups and DoD partners, and deep systematic integrations with the GRB system, HR system, and payroll providers demonstrate that they are the only vendor capable of meeting the agency’s needs without significant risk or deployment delays within the timeframe needed for services. The operational complexity and systematic integrations required to maintain these systems without interruption underscores Lentech as the vendor capable of meeting these requirements within the timeframe.

d. Time Constraints and Urgency:

i. The time required for another vendor to develop the necessary interconnections, relationships, and secure the ATO far exceeds the time remaining on the current contract. Additionally, the risk of disrupting the federal open season enrollment period adds to the importance.

4. Market Research:

a. Market research was conducted in calendar year 2021 and again in calendar year 2024 to identify potential sources capable of providing the required software services.

However, due to the proprietary nature of the GRB software and the preestablished knowledge of the Agency IT environments for HR systems, the time constraints involved, no other contractors were found to be capable of meeting the agency’s immediate needs within the required timeframe.

Certification and Approvals:

The information contained in this justification is certified accurate and complete to the best of my knowledge and belief.

Acquisition Initiator:

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

Print Name

Signature

09/11/2024 Date

Contracting Officer:

I hereby determine the circumstances of this acquisition support the justification to acquire these supplies or services on a sole source (including brand name) basis. I also certify that this justification is accurate and complete to the best of my knowledge and belief. (Add the following and delete the Review and Approval Section below if this certification is also serving as approval: “Since this effort exceeds Simplified Acquisition Threshold (SAT), but does not exceed $700K, this certification serves as APPROVAL.”) (Cross out sentence if over $700K)

The technical or requirements personnel are required to certify each justification as to its accuracy and completeness. By signing the justification the Contracting Officer certifies that the facts and statements made are accurate and complete

Reviews and Approvals

(See FAR 13.501 and BAM Part 9, Section 141.2 for review and approval requirements under specific circumstances)

Program Senior Official (Director of the Requesting Office):

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