Limited Source JOFOC updated signed.pdf

ACQUISITIONS SECTION

LIMITED-SOURCE JUSTIFICATION

FEDERAL SUPPLY SCHEDULE CONTRACT

Identification of the agency and the contracting activity, and specific identification of the document as a “Limited-Source Justification”

Central Office:

Federal Bureau of Prisons (Bureau) National Acquisitions Section 320 First St. N.W., Room 200 Washington, DC 20534

Nature and/or description of the action, including a description of the supplies or services required to meet the agency’s needs and the estimated value:

This action will be a firm-fixed-price Blanket Purchase Agreement (BPA) for Foreign Language Translation Services of inmate communications. It will be issued pursuant to the terms and conditions of the GSA MAS 47QRAA18D001Y as a continuation award/follow-on of BPA

15BNAS20A00000068.

The Bureau has a requirement to continue verbatim foreign language translation of all inmate communications on the Bureau Required Monitoring—individuals who, based on criminal history, behavior, or law enforcement intelligence, pose a significant threat to staff, inmates, institutional security, or the surrounding community. For inmates under Required Monitoring, all social communications—telephone calls, electronic messages, and postal mail—must be reviewed by Counter Terrorism Unit (CTU) which includes:

Support services will consist of:

1) Written translation of inmate communications, staff correspondence, forms, legal materials, technical manuals, and other official Bureau documents.

2) Transcription and translation of audio and voice recordings, including inmate telephone calls, video translation, and other electronic communications.

3) Oral interpretation services, including consecutive, simultaneous, telephonic, video remote.

Continuity of Foreign Language Translation Service is essential to Bureau mission requirements. An interruption in service would create significant operational and security risks, including disruption of CTU’s ability to the secure and orderly running of institutions to include life and safety of inmates, staff and the public. In addition, disruption would negatively affect coordination with external law enforcement agencies that rely on monitoring of inmate communications for new and ongoing investigations.

Because these functions are integral to daily operations, uninterrupted Translation services from Piedmont Global Solutions, LLC (PGLS) are critical until a new multi-year acquisition vehicle is established

The estimated cost for PGLS support services for a base period of 3 months, plus three 1-month option periods, is not expected to exceed $9,900,000.00.

The authority and supporting rationale (see GSAR 538.7104-3(b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.:

• GSAR 538.7104-3(b)(1) Statutory exceptions. The statutory exceptions supporting the placement of an order or establishment of a FSS BPA that exceeds the SAT on a sole source basis are:

o (iii) The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis;

Rationale:

• PGLS is the current BPA holder with the equipment and sources to maintain the services in a timely manner to avoid interruption.

• Installation of Bureau systems for a new company would require 60-90 days.

• Contractor background checks and clearances with our system would take months to complete.

• Transitioning to another vendor at this time would require extended planning and redevelopment, creating unacceptable risk of service disruption.

• Service interruption would impact inmate communications, and interagency law enforcement data sharing, creating potential security and safety risks.

The contractor is the only source capable of and positioned to continue and complete the requirements that are currently underway for foreign language translation service.

Changing to a different vendor would be cost and time prohibitive to the Agency.

A determination by the ordering activity contracting officer that the order represents a fair and reasonable price consistent with GSAR 538.7102-2(d)(2) and 538.7104-2(a)(3).

• Ordering activities are not required to— o (1) Determine contractor responsibility at the order level or BPA level as contractor responsibility has been determined at the FSS contract level.

o (2) Make a fair and reasonable price determination for FSS products, services, or solutions at the order level or BPA level as FSS contract pricing has been determined fair and reasonable. Clearly identify the best value.

The Contracting Officer (CO) has reviewed the GSA FSS pricing catalog and the recent prices of similar purchases, as well as the Independent Government Estimate. Based on the information gathered, the CO anticipates the price will be fair and reasonable. In addition, a task order will be made in accordance with the terms and conditions of the GSA FSS. The CO will seek further price reductions for the required services.

Any other facts supporting the justification.

N/A

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

PGLS is the only source capable of and positioned to continue and complete the requirements that are already significantly underway. The Bureau will continue to conduct market research and make efforts to obtain competition for future acquisitions, when applicable. At the present time, no actions are available which could remove competition barriers for the required product.

The ordering activity contracting officer’s certification that the justification is accurate and complete the best of the contracting officer’s knowledge and belief.

I hereby certify this justification is made in good faith and the supporting data and information are accurate and complete to the best of knowledge and belief.

Brooke Wilson Date Contracting Officer