Justification Approval NFIRS Redacted 1.pdf

Control No.: 20-015

Justification for Exception to Fair Opportunity

Exceeding the SAT pursuant to FAR 8.405-6(a)(1)(B)

1. Identification of the Agency and the Contracting Activity:

Department of Homeland Security

Federal Emergency Management Agency (FEMA)

Office of Chief Procurement Officer (OCPO)

Acquisition Operations Division, IT and Support Services Branch

500 C Street SW

Washington, DC 20472

FEMA OCPO, on behalf of United States Fire Administration (USFA), National Fire Incident Reporting

System (NFIRS), proposes to award a Task Order pursuant to FAR 8.405-6, Limiting Sources to: 1. Continue uninterrupted systems operations and sustainment support for the National Fire Incident Reporting System

(NFIRS). 2. Provide transition plan/strategy including archiving system documentation and 3. Provide expert subject matter knowledge to support development and implementation of the NFIRS web-based tools and data interfaces that provide data submission, validation, and extraction processes required for the NFIRS. Intellect

Solutions LLC is the only HUBZone firm that can properly perform the work in the time available.

Awarding a bridge contract for the current NFIRS with Intellect Solutions LLC is essential to the

Agency’s mission of providing accurate, timely, and accessible information to the public before, during, and after disasters. This bridge contract is needed to avoid any break in service of NFIRS operation and availability for data collection, validation, and data extraction that critical to the USFA/FEMA and its mission, as well as to state level agencies and the Department of Defense (DoD), local fire departments, and U.S. Territories who participate in NFIRS. If a break in service occurs, the impact will be a drop in

NFIRS reporting participation and data collection; states and local fire and emergency medical services will not be able to obtain the data they need to make decisions affecting their departments’ operation; the

USFA National Fire Data Center (NFDC) will not be able to meet its assigned objectives outlined in

Public Law 93-498 which includes (but is not limited to) collecting and analyzing data to study the fire problem and reduce dollar and casualty losses from fire related incidents, and reduce risk to life and property relative to fire related incidents. USFA would not be able to support states, local, Tribal and DoD fire reporting agencies with their incident reporting systems if service is interrupted due to the inadequate experience level of an O&M contractor.

2. Nature and/or Description of the Action Being Approved.

a) Type of action: HUBZone Direct Award

b) Type of contract: FFP

c) Amount: $1,782,681.12 twelve (12) month base period

d) Type of Funding: Operations and Maintenance (O&M)

e) Year of funding: FY 2020 and FY 2021

f) Contract Performance Period: Twelve (12) months; 05/14/2020 - 5/13/2021

g) Other Information:

● A Direct Award contract to Intellect Solutions LLC (GSA IT 70 Schedule/GS-35F-144AA) is needed to ensure transition from IBM (EADIS contract) and operational continuity.

● Name and Address of Contractor: Intellect Solutions LLC (GSA IT 70 Schedule/GS-35F-144AA) located 85 S Bragg St. Suite 204B Alexandria VA, 22312-2793

● This action is required due to the immediate need of follow-on operation, maintenance and sustainment services to the current Task Order 24B NFIRS 70FA3018F00000627 under the EADIS

BPA HSFE30-17-A-002. The performance period expires May 13, 2020.

3. Description of Supplies/Services

NFIRS is a congressionally mandated system authorized to support USFA mission to study the fire problem in the U.S. on several aspects that result in reducing casualty and dollar losses; as well as support state and local fire departments in the same purpose. Reporting to NFIRS is required by Assistance to Fire Grants (AFG) applicants and other FEMA grants programs offered to first responders. NFIRS is a set of web-based tools that enable over 26,000 fire departments from all 50 states, the DoD, and U.S. Territories to access the NFIRS national database every day, 24/7. Critical interfaces include functions for over 200 third-party emergency software providers, and integration with the Enterprise Data Warehouse. The operation of these critical interfaces support FEMA’s and USFA’s mission to collect, store, and disseminate incident report data in real time, and therefore requires uninterrupted services. The NFIRS system is a custom-built legacy application that provides mission-critical information in support of DHS, FEMA, state and local level data access and availability goals. The proposed vendor will facilitate the continued operation of the production system and bridging of NFIRS modernization Release 10 to strengthen the system’s security and integration with the account management system FEIMS, and maintain a newer, more service-oriented architecture. Services will include ensuring the move from DC2 to the MW data center is cost efficient and successful.

The vendor will identify, analyze, document, trouble-shoot, test, and validate data and NFIRS system processes and interfacing points with other systems that have new technology and complex legacy custom-built code. The vendor will implement, and document the business process solutions, requirements and test cases used, including risk management registries. The vendor will also deliver a secure source code within a secure development environment, providing the industry standard, Capability Maturity Model Integration 3 (CMMI), within a Government Owned Contractor Operated (GOCO) maintenance and development environment. As a result, the vendor will need to validate secure source code solutions delivered to FEMA. The NFIRS system interfaces with FEIMS for user account management, and uses DHS’s Maestro for the storage and retrieval of document attachments, source code and other system related business process artifacts.

This effort encompasses the full range of NFIRS system application O&M, integration services and associated applications infrastructure services. Specifically, this effort includes, but is not limited to, use of various approaches for mission need determination; requirements analysis; and application testing, and implementation; support of non-production GOCO environments; independent validator, application related business process reengineering; configuration management and release management; and related project management as well as systems integration, performance and availability analysis and improvement, implementing contingency and risk planning.

The vendor will ensure operational continuity, provide technical support to USFA system users, ensure that all supporting documentation remains current in preparation for system transition, and to ensure compliance with

IT standards and guidelines, including Enterprise Architecture and Cyber Security.

4. The authority and supporting rational (see 8.405-6(a)(1)(i)(B), a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service

FAR 8.405-6(a)(1)(i)(B). Only one source can provide the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

This requirement is essential to provide uninterrupted operation, maintenance and sustainment services to support the continuity of the FEMA/USFA mission. Because of its historical knowledge with the NFIRS application, Intellect Solutions LLC has the experience required for the NFIRS custom built legacy system and its integration points with other FEMA systems. They also have historical knowledge and extensive experience with the FEMA enterprise environment, its change and deployment management processes that are unique and would require considerable ramp-up time for a new contractor to perform at an acceptable level of performance.

They are aware of transition activities affecting former EADIS TOs also involved in change and deployment management processes.

The NFIRS is a legacy system that relies heavily of the Enterprise Data Warehouse and the FEIMS account management system to fully access and operate the program. One of these systems, FEIMS, will continue with enhancements and security upgrades and as such, it is imperative that an experience vendor with the specialized knowledge and skillsets to be in place within the limited timeframe. The other system is in O&M and while the

NFIRS database is modernized, historical knowledge of its data format and integrity will be required. The current primary challenges with NFIRS are:

1. Modernization Release 10: The work involved to get this release to a deployment-ready state was interrupted and delayed by both agency issues (disaster response activities and furlough) and by enterprise contract issues. Setting up new architecture the TDL environment to test the Release 10 took longer and ran into conflicts with other systems and ongoing security upgrades. NFIRS has a massive data validation process that required extensive testing. The work for Release 10 is staged for deployment but was placed on hold due to COVID 19 activities. It is necessary for a team experienced with all facets of the work or trouble points deploy Release 10 to ensure successful handling.

2. Expired NFIRS ATO and POA&Ms: The cyber security requirement to fix all critical and high system vulnerabilities and reduce medium and low by 70% is imperative before ATO’s are renewed. The

Release 10 deployment (due to its code fixes for security) is essentially the remediation plan to meet this requirement. Unique knowledge of NFIRS legacy code is required to address remaining POA&Ms as well as mitigate high, medium and low vulnerabilities that might surface in new scans. The NFIRS

ATO has been expired since July 2019. Additionally, historical expertise and knowledge of the old

NFIRS code is necessary to assist with USFA’s approach to “sunset” one of the tools, the legacy java software (Data Entry Tool), in the next year.

3. Reduce Risk to other DHS major investments and to state and local fire service agencies: A vendor with specialized knowledge will have the unique technical expertise in the areas of system engineering, design, and legacy system integration. The NFIRS is one of FEMA’s high value assets (a major investment). The NFIRS data set is sought by DHS and FEMA data governance and initiatives, such as

EDAMI, FEMADex, and OpenFEMA, should remain stable during the proposed one-year contract period to transition from EADIS. Any type of system interruption would impact the overall USFA mission and congressional mandate to collect, store and disseminate fire related incident data, and support fire incident reporting agencies.

The NFIRS system has been operating since 1998, and much of the legacy system had no system documentation that could provide an understanding of the data elements and functions, which therefore make historical knowledge critical to uninterrupted services at such a pivotal time of data migration to the NFIRS system.

The experience required for the NFIRS custom built legacy system and the FEMA enterprise environment is unique and requires considerable ramp-up time for a new contractor to perform at an acceptable level of performance.

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

The Contracting Officer has determined that issuing the proposed Task Order to the proposed vendor for O&M support services represents the best value and will result in the lowest overall cost alternative, considering price and administrative costs, to meet the Government’s needs. This order will be placed in accordance with FAR

8.404 – Use of Federal Supply Schedules. The proposed vendor on the GSA IT 70 Schedule/GS-35F-144AA, has negotiated fair and reasonable pricing with GSA and is reflected in their schedule. Prior to issuance of the contract, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific task being ordered, and for determining that the total price is reasonable.

6. A description of the market research conducted.

A review of the results from GSA Advantage, GSA eLibrary, and DHS Strategic Sourcing Program, disclosed that various firms provide the type of services required: Operations and Maintenance Services. However, due to the complexity of the system and the critical need to avoid interruption, Intellect Solutions LLC is the is the only firm that can provide the required services without interruption. Although, various businesses had subcontracted with EADIS and are familiar with certain elements of the technical expertise, none had the current capacity to accomplish the overall coordination and execution of the level of work required.

7. Any other facts supporting the justification.

The requirements for this Task Order are unique because NFIRS was designed for a unique, detailed body of data and services to meet specific objectives outlined in Federal Fire Prevention and Control Act of 1974

(Public Law 93-498) and as such, USFA requires a contractor with expertise gained by working with the system over time.

If a break in service occurs due to a contractor with inadequate experience and the system is not maintained in its current state and availability, the impact will adversely affect the program in several ways. Increased risk or loss of NFIRS data integrity, availability, and its security would occur. There would be a drop in NFIRS reporting participation and data collection; states and local fire and emergency medical service departments would be unable to obtain the data and reports they need to make decisions affecting their departments’ operation. FEMA’s Assistance to Fire Grant applicants would not be able to validate the NFIRS reporting requirement; nor would FEMA/USFA be able to verify the department’s reporting status. The USFA National Fire Data Center (NFDC) would not be able to meet its assigned objectives outlined in Public Law 93-498 which includes (but are not limited to) collecting and analyzing data to study the fire problem to reduce dollar and casualty losses from fire related incidents and activity;

to reduce risk to life and property relative to fire related incidents; and to analyze the fire service needs.

The USFA NFDC would not be able to support FEMA’s initiatives to study the wildland fire problem;

would not be able to support states, local, Tribal and DoD fire reporting agencies with their incident reporting systems if service is interrupted due to inadequate experience level of an O&M contractor.

12. Approval.

Over $700,000 but not exceeding $13.5 million Date Component Competition Advocate