Justification for Exception to Fair Opportunity 47QTCB21D0018 72MC1022M00003.pdf

J&A for Exception to Fair Opportunity, Task Order No. GSA STARS III-

47QTCB21D0018/72MC1022M00003

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

TO: Nadeem Shah, M/OAA Activity Competition Advocate

FROM: Patterson Brown, Contracting Officer’s Representative

SUBJECT: Justification for an Exception to Fair Opportunity, Task Order No. GSA STARS III

47QTCB21D0018/72MC1022M00003 with Stealth Solutions Inc.

1. This document sets forth the facts and rationale justifying an exception to fair opportunity in accordance with FAR 16.505. The U.S. Agency for International Development’s

(USAID), Office of Acquisition and Assistance, Regional Management Division, A Team

(M/OAA/RM/A) within the Management Bureau (M) in coordination with the Africa Bureau’s

Prosper Africa Executive Secretariat (PAES) has prepared this exception to fair opportunity.

2. The nature and/or description of the action being approved:

This is a request to approve a justification for a fair opportunity process for a one-year period of performance extension and increase of Total Estimated Cost (TEC) in the amount of $943,000 for the Prosper Africa Track Task Order implemented by Stealth Solutions Inc. The modification is requested to be issued on a sole source basis in the interest of economy and efficiency because the proposed additional work is a logical follow-on to the current order already issued under the GSA

STARS III. This contract was originally awarded competitively under the GSA MAS (STARS III).

This is the first non-competitive request for this award.

The contract is a Firm Fixed Price (FFP) Hybrid Time & Materials Type Contract awarded to

Stealth Solutions Inc. through a small business competition under the GSA schedule for the original period of January 3, 2022 to January 2, 2025. This is a request for a one-year extension from January 3, 2025 to January 2, 2026 and a TEC increase from $3,570,003.20 to $4,513,003.20.

PAES has confirmed funds in the amount of $943,000.00 are available to cover the IT system mid-development activities to take place during the one-year extension period. This contract was originally awarded competitively under the GSA MAS (STARS III).

3. Description of the supplies or services required, including an estimated value:

Stealth Solutions was awarded the Prosper Africa Tracker TO supporting PAES in the continued development and maintenance of a Deal Tracker using FedRAMP-certified and cloud-based

Salesforce software-as-a-service (SaaS) platform to allow all Prosper Africa initiatives to share information on prospective investment and trade deals and to collaborate more effectively to facilitate trade and investment transactions. Under this contract, the contractor is required to:

1. Ensure the successful completion of effort by providing project management oversight in compliance with USAID Bureau for Management’s Chief Information

Officer’s (CIO) (M/CIO) standard Software Development Lifecycle (SDLC) milestones and processes including; external and internal communications management and technical change control management (e.g. Technical Review

Boards (TRB)/Change Control Boards (CCB) and Application O&M CCB).

2. Address findings and recommendations from user training and usability testing, and

Plan of Action and Milestones (POA&Ms) identified in the Authority to Operate

(ATO) process. The Contractor shall also update all documents and artifacts as needed (e.g., training and Operations &Maintenance (O&M) manuals).

3. Provide training and onboarding support (user account provisioning, etc.) and support up to four (4) system updates/releases per year (max one per quarter). In addition, the Contractor shall provide Tier 2 and Tier 3 help desk support and onboard new users and remove expired users as needed. The Contractor shall also manage Salesforce licenses as required and update all documents and artifacts as needed.

As it relates to this action and as noted in bullets 1 and 3 above, the contractor will continue to assist the PAES in IT project oversight of the planned system upgrades per USAID's SDLC processes, ensuring effective communication and technical change control through Technical

Review Boards, Change Control Boards, and O&M CCBs. The Contractor will also address feedback on the new system updates and releases from user training, usability testing, ATO-related actions and handles training, onboarding, and quarterly system updates after a release.

Further, the contractor is currently in mid-development of two of its planned system updates/releases previously approved by the COR. Specifically, PAES requires the contract extension for Stealth Solutions to continue IT system development activities on two critically important and highly visible upgrades to the system that are in mid-development; One to include a

Monitoring, Evaluation and Learning (MEL) component to track the project's performance measures and one to include integration of MEL data from an external system IPs use called

Airtable. However, due to internal (e.g. USAID SDLC gate reviews, M/CIO approvals) and external delays (coordination with external stakeholders), at no fault of the contractor, more time is needed for the contractor to complete and deploy the system upgrades that are in mid-development. The latter especially is taking a lot of time because it is connecting an external system to our internal USAID network. These upgrades necessitate meticulous security reviews and approvals by M/CIO to ensure compliance with USAID’s IT and security protocols. The one-year requested extension is based on USAID’s past experience with similar types of system integration upgrades where the ATO process alone can take up to six months.

In addition to these priorities, recent personnel turnover has resulted in temporary gaps in institutional knowledge and continuity. This has necessitated additional time to onboard new team members and ensure they are adequately prepared to contribute effectively to procurement planning activities. Furthermore, the complexity of the follow-on procurement has added layers to the planning process. Key tasks, such as refining the scope of work, aligning with updated programmatic priorities, and incorporating lessons learned from the current contract, require thorough consideration and deliberation.

The additional time will be used to continue the following in-scope tasks:

● Project management oversight in compliance with USAID’s standard processes including external and internal communications management and technical change control management;

● At the Activity Manager and COR’s discretion, address findings and recommendations from user training and usability testing;

● Training and onboarding support and support up to four system updates/releases per year;

● Finalize mid-development work related to the integration of PAES partner organization's external data systems with USAID’s data management infrastructure by aligning with M/CIO requirements.

● Help desk support and onboard new users and remove expired users as needed;

● Management of Salesforce licenses as required and update all documents and artifacts as needed.

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.

Logical Follow-on - FAR 16.505(b)(2)(i)(C)

The decision to continue with the same contractor for the follow-on work is justified by the need for continuity of services and the contractor’s specialized knowledge and expertise. Stealth

Solution is already intimately familiar with the ongoing oversight and management of PAT, its objectives, and associated data systems. Switching contractors at this stage would cause unnecessary delays, as a new contractor would require significant time to familiarize themselves with the project’s scope, proprietary data, and the unique workflows that have been developed. The contractor’s experience ensures that the transition between phases remains seamless, avoiding disruptions in service delivery and keeping the project on schedule.

5. A demonstration by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable:

GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing. The contracting officer in coordination with PAES has determined the burn rate and relative funding required for the anticipated one-year extension to be fair and reasonable and in the best interest of the government.

6. Other facts supporting the use of exception to fair opportunity:

The requested 12-month extension is essential to address several critical initiatives required for the continued development, integration, and operational excellence of the Prosper Africa Tracker

(PAT). The PAT system is undergoing a significant evolution to serve as the central framework for the initiative’s Monitoring, Evaluation, and Learning (MEL) plan. As the single source of truth for performance measures and reporting to leadership and Congress, the system requires substantial updates to integrate enhanced MEL functionalities. These updates, driven by organizational changes and persistent data quality challenges, are anticipated to take approximately 10 months to fully implement. Additionally, integrating Africa Trade and Investment (ATI), Prosper Africa’s continent-wide trade and investment initiative’s data management system (AirTable) with

Salesforce to automate the generation of over 20 MEL metrics is pivotal for accurate and timely assessment of Prosper Africa’s economic impact. This process, which will eliminate delays and inaccuracies caused by manual processing, is expected to require close to a year to complete.

The integration of the Prosper Africa’s Virtual Data Room (VDR) portal, enabling end-users to view approved deals in near real-time, is another priority initiative. While the integration is underway, several months are still needed to operationalize and streamline workflows, which will significantly enhance efficiency and shorten deal cycles. Concurrently, efforts to address findings from recent M/CIO security reviews and achieve Authority to Operate (ATO) certification are ongoing. With another M/CIO security review scheduled for March 2025, the project team requires

3 to 6 months to resolve all current findings, ensure full security compliance to safeguard the systems integrity.

Once these critical initiatives are completed, at least three months will be necessary to execute a robust transition-out plan. This phase will ensure that the succeeding team is effectively onboarded, properly briefed and prepared to manage the system without disruptions. The requested one-year extension is therefore not a precautionary measure but an essential timeframe to ensure these complex, mission-critical activities are completed without compromising the system’s IT security, functionality, or experiencing any downtime. It is integral to achieving Prosper Africa’s strategic objectives while safeguarding the reliability and long-term sustainability of the PAT system.

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:

To avoid further delays in the development phases of the planned system upgrades, the design team has developed a clear project milestone plan to mitigate further project delays in the deployment of system releases. The milestone plan is as follows:

i. Support ISSO and SA&A Activities and Audits for ATO (March 15, 2025 – January 2, 2026):

● Conduct security assessments and authorization tasks.

● Support Information System Security Officer (ISSO) activities.

● Address audit requirements and ensure compliance with ATO protocols.

ii. Functionality Development and Integration of ATI’s Airtable (January 1 – July 30, 2025)

● Develop and integrate Airtable functionalities to align with ATI requirements.

● Conduct user testing and validation.

● Ensure seamless data exchange between Airtable and other systems.

iii. Development and Incorporation of Prosper MEL Indicators Functionalities (June 1 –

August 30, 2025)

● Design and implement features to track MEL indicators.

● Test and validate new functionalities for alignment with Prosper’s MEL plan.

● Provide training and resources for users to adopt MEL features.

iv. Finalize Development Work Related to Backlog of Deals for VDR (June 1 – November

30, 2025)

● Review and address outstanding development work for VDR.

● Clear backlogs and ensure data accuracy.

● Conduct final testing to verify deal integration

v. Website Integration and Campaign Management (June 1, 2025 – November 30, 2025

● Develop and integrate website functionalities in Salesforce to capture contact information.

● Build and manage opt-in/opt-out communication features.

● Develop Campaign Management tools in Salesforce

8. Technical or Requirement Personnel Certification

In accordance with FAR 16.505(b)(2)(ii)(B)(9), I hereby certify that the technical statements included above, which form a basis for the justification, are complete and accurate.

signed via email 12/23/24

Patterson Brown, COR Date

9. Contracting Officer Certification

Based on the exception to a full and open competition provided under FAR 16.505(b)(2) and the justification provided above, I hereby certify that the justification is accurate and complete to the best of my knowledge and belief.

12/20/24

Daniel Moore Date

Contracting Officer

10. Approving Official Determination

I have determined that FAR 16.505(b)(2)(i)(C), as described above, appropriately applies to this order. Digitally signed by Nadeem

Hussain Shah (affiliate)

Shah (affiliate) Date: 2024.12.30 10:12:50

-05'00'

Nadeem Shah, Date

M/OAA Activity Competition Advocate

Nadeem Hussain