Limited Source Justification.pdf

U.S. Customs and Border Protection Limited-Sources Justification (LSJ) - FAR 8.405-6

For orders or BPAs exceeding the Simplified Acquisition Threshold (SAT)

Date: September 16, 2020 PR Number: 20117934

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity. Identification of the agency, contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

The Department of Homeland Security (DHS), U.S. Customs and Border Protection (CBP), Office of Acquisition, proposes to award an order pursuant to FAR 8.405-6(a), Limiting Sources.

2. Nature and/or description of the action being approved. Describe the action being approved, and include the name and address of the proposed contractor(s).

CBP intends to limit the number of sources solicited pursuant to FAR Part 8.405-6(a) for the procurement of financial operations support services to Dextera Corporation, 870 Trinity Parkway Suite 120 Centreville, Virginia 20120.

3. Description of Supplies/Services. Describe the supplies or services to be acquired.

Provide the estimated total value (including options, if any).

The Financial Operations Support Services requirement is for various financial tasks and helpdesk services in different functional areas in support of CBP’s Office of Finance National Finance Center, Financial Operations Directorate and Financial Systems Division operations.

CBP’s Office of Finance is responsible for the financial integrity of CBP operations, and provides broad range of financial systems, capabilities, processes, controls and counsel. The Office of Finance National Finance Center, Financial Operations Directorate and the Financial Systems Division comprise sections and branches that perform important financial functions for CBP. The Payroll Branch oversees the processing of the CBP regular timecards by the United States Department of Agriculture (USDA). The Financial Reporting and Analysis Branch performs financial management functions for CBP, provides accounting services to other Federal Government entities and prepares trial balance reports, periodic regulatory reports and annual financial statements. The Travel Section processes manual and automated travel vouchers in addition to employee’s permanent change of station vouchers. The Travel Section is also responsible for the administration of the Travel Card Program. The Commercial Accounts Section is an Accounts Payable function with the primary responsibility for processing commercial vendor and Government Trading partner payments. The Financial Operations Office of the Executive Director completes defined work projects and special tasks assigned from the Office of Finance.

For orders or BPAs exceeding the Simplified Acquisition Threshold (SAT)

In order to support the above described workload, a contractor is needed to perform various assignments in different functional areas to accomplish the mission of ensuring financial integrity of CBP operations, and provide a broad range of financial systems, capabilities, processes, controls and counsel.

The estimated total value of the services is $3,571,097.60 with a period of performance up to twelve (12) months - 09/26/2020-09/25/2021.

4. Authority and supporting rationale. Select one of the circumstances justifying limiting sources pursuant to FAR 8.405-6(a)(1)(i) below and demonstrate the proposed contractor’s unique qualifications to provide the required supply or service.

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

This action is needed in order to avoid a potential lapse of critical services. The current contract expires on 09/25/2020. The sole source task order will serve as interim contract to prevent a void in services that otherwise will adversely impact the Office of Finance operations given the criticality of the services involved. The proposed award to Dextera Corporation will provide the Agency sufficient time to do a follow-on full and open competition acquisition in early FY21.

The Government intends to release a Request for Quote in October 2020 with an anticipated award by the end of March 2021. The period of performance for the interim action includes a potential six month transition period, as needed. CBP intends to transition off the interim contract as soon as feasible, so the entire 12 months may not be necessary.

Based on the above circumstances, Dextera is the only source capable of providing the required financial operations services during the interim period of performance. Only Dextera possesses the expertise and cleared personnel to provide the subject services at the level of quality required due to the security background investigations required for forty-three (43) contractor personnel that will be working on the task order. The average timeframe for the completion of a successful background investigation resulting in security clearance for one contractor personnel is six (6) months. Dextera is the incumbent contractor and has employees with security clearances currently performing on the contract. Given the number of required contractor personnel coupled with the average six (6) month timeframe for the completion of background investigations, it is highly unlikely another contractor would be able to meet the background investigations requirements in a timely manner prior to the task order award date and perform the services at the level of quality required. Given a new contractor may not have the full operational capacity to provide the required level of quality services due to the referenced background investigations, there is a high risk that awarding the twelve (12) month task order to a contractor other than Dextera would lead to a gap in critical services including, Payroll, Travel, Commercial Accounts and Systems, Applications and Products in Data Processing (SAP), as summarized below.

For orders or BPAs exceeding the Simplified Acquisition Threshold (SAT)

Payroll

The Payroll section maintains employee pay records, ensures timely and accurate pay and generates actions impacting pay. Critical areas where the Payroll section will be negatively impacted if there is a gap in contractor services includes but not limited to onboarding payroll actions for new CBP employees, actions related to starting/stopping union dues, Voluntary Leave Transfer Program with potential impact on delaying donations, and account adjustments every pay period.

Travel The Travel section performs a wide variety of critical functions with travel vouchers expenses reviews and processing authorizations. Critical areas where the Travel section will be negatively impacted if there is a gap in contractor services includes but not limited to 75% work pertaining to Concur {Travel Application}, 100% work regarding vendor invoice processing for CBP Relocation Services in addition to safeguarding against erroneous billing and work involving Temporary Duty Travel (TDY) travel voucher auditing for CBP.

Commercial Accounts The Commercial Accounts section is a vendor payment function purposed to process commercial vendor and Government trading partner payments. Critical areas where the Commercial Accounts section will be negatively impacted if there is a gap in contractor services includes but not limited to processing of more than 100,000 invoices annually, support for the CBP Fleet Card Program, which has 30,000 credit cards used to provide fuel/repairs/ supplies, processing of an average of 60,000 monthly transactions under the CBP Fleet Card Program and checks processing for depositing incoming checks to the Treasury.

SAP

SAP provides CBP with an integrated, enterprise-wide software solution. SAP is used for Finance, Property and Procurement processes. Critical areas where SAP support will be negatively impacted if there is a gap in services includes but not limited to 100% of customer support services provided for SAP users inclusive of direct line support for lines supporting SAP customers with pressing issues.

Dextera Corporation is uniquely qualified to provide the required financial operation support services for the twelve (12) month period of performance under the proposed task order award.

Dextera has provided financial operations support to the Office of Finance for the past four (4) years and is, therefore, qualified to perform the requirements for twelve (12) months while the requirements is re-competed in FY21. The scope of work under the proposed bridge contract mirrors the original contract awarded to Dextera and is not materially different from the current requirements.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

The Contracting Officer will determine that issuing the sole source task order for financial operations support services to Dextera Corporation represents the best value and will result in

For orders or BPAs exceeding the Simplified Acquisition Threshold (SAT) lower cost, 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” using Dextera Corporation’s Multiple Award Schedule Professional Services, Financial Services, SIN/NAIC 541219 - Budget and Financial Management Service. The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates with regards to Dextera Corporation’s pricing. In addition, discounts to these GSA schedule rates will be requested from the contractor. Further, prior to the issuance of the task order, the Contracting Officer will ensure Dextera Corporation’s total price is reasonable when compared to the Independent Government Cost Estimate (IGCE).

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

While there are schedule holders under the MAS Professional Services, Financial Services, SIN/NAIC 541219 - Budget and Financial Management Service, using an alternate acquisition strategy for the procurement of the financial operation support services requirements on a twelve

(12) month basis other than a sole source award to Dextera Corporation poses a significant risk in terms of the ability of a new contractor to obtain the required number of cleared personnel to provide the financial operations support services. In a scenario in which there is no assurance that a new contractor would employ the current forty-three (43) contractor personnel, awarding the sole source task order to Dextera ensures full operational capacity with respect to contractor personnel needed to provide the required quality of services.

7. Any other facts supporting the limited-sources justification. Additional facts may be stated in this section. If there are no additional facts, you must state that here.

The acquisition documents for the full and open competition acquisition planned for FY21 are currently being finalized to ensure a timely FY21 award. As previously noted, the Government anticipates releasing a Request for Quote in October 2020.

A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made. Include a statement of actions taken or that will be taken to increase competition for future acquisitions of the same item/service (e.g., the government intends to revise overly restrictive technical specifications, acquire data rights, or pursue some other means to increase future competition). Posting requirements may also be addressed here or in #9 below.

In FY21, CBP intends to procure the financial operation support services requirements on a full and open competition basis for a five (5) year period of performance, and thus, eliminating the barriers to competition.

CBP intends to post a notice on Beta.Sam.Gov pursuant to FAR 8.405-6(a)(2)(i).