Limited Source Justification - Potomac Wave - 36C10X25F0034.pdf

DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

Limited Sources Justification

(1) Identification of the agency and the contracting activity, and specific identification of the document as a "Limited-Sources Justification."

This Limited-Sources Justification for Other Than Full and Open competition is executed by the Strategic Acquisition Center – Frederick (SAC-F), on behalf of the Department of Veterans Affairs (VA), Office of Acquisition and Logistics (OAL), Functional Acquisition Manager - Contracting Management Office (FAM-C/COR).

(2) Nature and/or description of the action being approved.

The acquisition will be conducted under the authority of the Multiple Award Schedule Program.

The proposed action is for a twelve (12) month firm-fixed price (FFP) task order with an option for an additional four (4) twelve (12) month option periods for FedDataCheck subscription services.

The proposed effort will be awarded under General Services Administration (GSA) contract, GS- 00F-0007X on a limited source basis under the authority of 8.405-6(a)(1)(i)(B) “Only one source is capable.” FedDataCheck services are proprietary to PotomacWave Consulting, LLC (PotomacWave), 1725 Duke St. #320, Alexandria VA 22314, an Other Than Small Business.

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

FedDataCheck is crucial for ensuring transparency, accountability, and efficiency in federal procurement. The service automatically scans publicly available Federal Procurement Data System- Next Generation (FPDS-NG) award information, detecting FAR compliance and other inconsistencies in real time. With over 130 data validations, this service provides timely feedback to the VA procurement staff promptly identifying and addressing data quality issues, by sending automated email notifications to U.S. Department of Veterans Affairs (VA) Contracting Officers (COs) which identify potential data discrepancies that need to be rectified.

Additionally, the service includes a dashboard that allows VA leadership to monitor overall data quality and track data improvements over time.

This service provides a robust data blending tool, which verifies VA FPDS-NG entries and benchmarks them against government-wide data and various other standards. This functionality aids in oversight of the Federal Information Technology Acquisition Reform Act (FITARA) implementation and ensures that data is accurate when used to meet requirements in the Digital Accountability and Transparency Act (DATA). Furthermore, the service supports comprehensive analysis for procurement oversight and strategic decision-making across the VA Enterprise.

Strategic Acquisition Center (SAC)

The integration of robotic process automation (RPA) provides a quality report with data for review when completing the Contractor Responsibility Assessment (CRA) report. The CRA report includes crucial information on vendors' qualifications, as reported in the System for Award Management (SAM), the Federal Awardee Performance and Integrity Information System (FAPIIS), and FPDS-NG. This assessment ensures informed decision-making on contractor responsibilities. This report, alongside the RPA-generated Contractor Responsibility Determination Memorandum, streamlines the contractor evaluation process thereby increasing VA’s efficiency and compliance with FAR 9.1 requirements.

Moreover, FedDataCheck simplifies the completion of the annual FPDS Verification & Validation (V&V) Agency Procurement Data Quality Report, reducing administrative burdens and enhancing efficiency for procurement staff. These services will be enhanced by the addition of a new FedDataCheck application called Auto V&V. Through a VA-developed Application Programming Interface (API), the contractor will be provided limited data found in the procuring activity’s SF-30 and SF-1449 cover pages to cross-reference with FPDS data fields to ensure compliance with VA-stipulated guidelines. Results will be provided via a dashboard and reports, with inconsistencies addressed with notifications and option of manual or auto-correction of FPDS-NG data as applicable. Auto V&V will not only improve the quality of public-facing data, but it will also mitigate the manual effort required for department-wide data reviews.

The total estimated value of the proposed action is (inclusive of options).

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

This Limited Sources Justification is pursuant to FAR 8.405-6(a)(1)(i)(B). The Government has determined that PotomacWave is the only source capable of providing the services required at the level of quality required because their proprietary FedDataCheck subscription service is unique and highly specialized. PotomacWave is the only source capable of providing FedDataCheck as it holds the proprietary rights over its development, maintenance, and use.

FedDataCheck is trusted and utilized by numerous Federal agencies due to the unique and specialized nature of the service. FedDataCheck improves the quality of FPDS-NG data through a variety of comprehensive functions and features that crosscheck information for validity.

These services support Department-wide efficiency by drastically reducing administrative burden. The primary features of FedDataCheck are:

Automated monitoring of FPDS data quality, identifying potential errors with Federal Acquisition Regulation (FAR)-based validation rules and notifying the appropriate contracting officials within two business days;

Strategic Acquisition Center (SAC)

Automated email alerts to contracting officials about potential reporting errors on contract actions, identifying the flagged transaction, the relevant data check, a description, reasoning, and suggested corrective action, along with hyperlinks to applicable references such as FAR regulations;

Optional auto-correction of identified FPDS reporting errors, determining the correct code for flagged fields;

Various standard and custom reporting and dashboards including:

o Vendor risk reports which highlight entities with elevated risks such as exclusions and terminations o Custom contractor responsibility assessment report which gathers data from

SAM.gov and FAPIIS and is processed via robotic process automation o Web-based dashboards that provide transaction-level details for all corrections and dedicated AutoCorrect dashboard enables users to monitor changes made by the application o Graphical Dashboard and web-based reports to track compliance with the DATA Act

Supports the Office of Management and Budget (OMB)-required FPDS Verification and Validation (V&V) process by providing access to the updated OMB Exhibit 2 results report online which is updated quarterly.

FedDataCheck is essential to meet the Government’s requirements and market research indicates there is no other product or service available to meet the agency’s needs. This market research supporting this determination is discussed in detail below in Section (6).

PotomacWave was awarded the current task order on a sole source basis on 12/02/2019 under the authority of FAR 8.405-6(a)(1)(i)(B). PotomacWave was determined to be the only source capable as the proprietary owner of FedDataCheck which was found to be the only database and reporting services specific to FPDS data that could meet the level of quality and requirements of the VA.

PotomacWave has successfully performed services identical to the scope and complexity of the current requirements for OAL’s FPDS-NG Data Quality Improvement Support Services task order 36C10X20F0015, under GSA contract GS-35F-222DA. No other identified firm has the specialized knowledge, experience, or understanding of this work. The contractor has been rated “Exceptional” by OAL in all CPARS rating categories for every rating period to date on the current task order.

Strategic Acquisition Center (SAC)

(5) A determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d).

The services offered on PotomacWave’s FSS schedule are listed at fixed prices. 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, the contracting officer is not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d). By placing an order against a schedule contract using the procedures in 8.405, the contracting officer has concluded that the order represents the best value (as defined in FAR 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government ’s needs. Although GSA has already negotiated fair and reasonable pricing, additional discounts will be sought before placing an order (see 8.405-4).

(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.

The ordering activity will post justification to SAM.gov in accordance with FAR 8.405- 6(a)(2)).

Market Research was conducted to identify schedule holders that offer services like FedDataCheck. A review of the GSA e-Library was conducted for Category 54151S (IT Professional Services) and 54151ECOM (Electronic Commerce and Subscription Services).

Within these categories, specific key word searches were conducted for “Contractor Responsibility Assessment”, “FPDS Autocorrect”, and “Procurement Metric Reports.” These searches resulted in only PotomacWave providing related services with their FedDataCheck subscription.

In addition to the above, and as detailed below, a Request for Information was posted to SAM.gov and no schedule holders responded to this notice to indicate they have a compatible solution that will meet the VA’s needs. See Section 7 below for further details.

(7) Any other facts supporting the justification.

Market research was conducted in accordance with VAAR 810.001-70, to identify two or more verified service-disabled veteran-owned small businesses (SDVOSBs) and/or veteran-owned small businesses (VOSBs) (SD/VOSBs), with the appropriate NAICS code, listed as verified in the Small Business Administration (SBA) Certification Database (VetCert). The Government identified and determined there were potentially 1,944 SD/VOSBs providing services under North American Industry Classification System (NAICS) 518210. However, due to the inability to filter for key words, a determination of capability to perform the specific required services was not possible.

Strategic Acquisition Center (SAC)

Therefore, additional market research was conducted within the SBA Dynamic Small Business Search (DSBS) which resulted in no small businesses identified that could provide the comprehensive services specific to FPDS data validation & analysis or Contractor Responsibility assessments.

To further ensure the Government made every effort to seek out SD/VOSB vendor participation and to identify potential alternative solutions to FedDataCheck, a Request for Information (RFI) was published to SAM.gov on 01/10/2025. The RFI requested sources capable of providing products/services like that of FedDataCheck. The goal was to determine if two or more SD/VOSBs capable of meeting the requirements and to gather information from industry to understand if anything like FedDataCheck had been developed since the award of the current task order in 2019.

Seventeen (17) vendors responded by the deadline of 01/24/2025 at 10:00 AM (ET). Three (3) vendors were eliminated for failure to meet the minimum requirements to provide answers to the Government’s questions. Of the remaining fourteen (14) vendors evaluated, twelve (12) were small business and two (2) were Other than Small businesses (including PotomacWave). Seven

(7) of the small businesses represented themselves as SDVOSBs, six (6) of which were certified in the VetCert database.

Capability determinations of the RFI responses were conducted and finalized by the Program Office on 02/04/2025. The results confirmed that only PotomacWave offers comprehensive services that can meet the VA’s needs. Alternative solutions provided by vendors required customized solutions that would need to be developed, failing to meet the VA’s immediate needs. Even if the VA could accommodate a delayed execution for said solutions, none of the vendors approached a fully demonstrated capability to meet the all the requirements and/or did not have specific knowledge/familiarity with FPDS-NG data.

The results of the RFI effort confirmed that FedDataCheck is the only product/service available and that the incumbent, PotomacWave, is the only source capable of providing said service to meet the Government’s needs.

Based on the above market research, the Government did not identify any VetCert verified SD/VOSBs capable of meeting the requirements thus not supporting a SD/VOSB set-aside or sole source approach.

A Notice of Intent to Sole Source was posted to SAM.gov on 04/17/2025, with a closing date of 04/24/2025. The VA received only one response to this notice on 06/02/2025 which was after the response deadline. The vendor was not found on the VetCert database.