Limited Source Justification redacted.pdf

LIMITED SOURCE

FOR AN ORDER/BPA EXCEEDING

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 8.405-6)

BPA #91003119A0012

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Agency and contracting activity. Department of Education, Federal Student Aid (FSA) Acquisition

Directorate

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

This is limited source justification for a follow-on order to order number 91003119F0363 under BPA

91003119A0012. The follow-on order will be awarded to Tai Pedro & Associates, PC.

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

Under the follow-on order, Tai Pedro will continue to perform contract examiner (CE) services. The CE services contribute to the quality control of contracting artifacts by providing peer reviews and pre-contract review panel reviews. These reviews focus on grammatical and compliance with FAR and local policies.

Tai Pedro will provide these services from 09/28/2020 to 09/27/2021. The total value of the order is $ for two (2) contract examiners.

4. Authority and supporting rationale. The following circumstance justifies limiting the source as supported below:

Logical Follow-on under the authority of FAR 8.405-6(a)(1)(i)(C) – In the interest of economy and efficiency, the new work is a logical follow-on to the original Federal Supply Schedule (FSS) order noted above. The original order or BPA was placed in accordance with the applicable FSS ordering procedures. The original order or BPA was not previously issued under sole-source or limited sources procedures.

Awarding the follow-on order will maintain continuity of service and avoid the costs associated with the learning of local policy and procedures. Awarding to a new vendor would result in a lack of services while the new vendor was on-boarded and would require time to acquire knowledge of FSA processes and policy. Additionally, the Government would have to step in and perform the CE functions until the vendor was ready to operate independently.

There is a lack of in-house Government resources to perform these functions and a disruption in services would have a negative impact on the Acquisition Directorate in meeting their customer needs and in turn increase the cost of re-establishing satisfactory service due to the cost of re-solicitation and the possible increase in cost of service. In addition, recompeting this contract would reduce the continuity in operation necessary in obtaining maximum performance.

(Insert PR/RFQ/BPA/Order number, as applicable)

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

Awarding a logical follow-on contract will save the Government approximately $65,011.20 in learning curve costs.

Rate (CE in FY20) Hrs. Amount comments

???? 480 $????? 3 months to learn & contribute without assistance

The Government would incur additional opportunity costs as it would have to perform the CE services for an interim period and also assist in bringing the vendor “up-to-speed.” With those costs considered, awarding a follow-on order to Tai Pedro provides the best value to the Government.

6. Market research conducted among schedule holders (or reason market research was not conducted).

Market Research was conducted at the establishment of this BPA (July 26, 2019) using GSA. Multiple-award BPAs, including BPA 91003119A0012, were competitively awarded under GSA 00CORP

Professional Service Schedule (PSS) SIN 874-6 Acquisition Management Support and Financial

Business Solutions (FABS) SIN 520-7. Additional Market Research can be found in the September 18, 2019 approved Acquisition Plan located in file folder labeled “Pre-Sol” on the APFP SharePoint site.

It has been determined that awarding the follow-on order directly under BPA 91003119A0012 is the most advantageous method of fulfilling the Government’s need, price, and other factors considered. A disruption of operations would result in significant cost impacts. Further sourcing options will be considered during the re-compete of this effort.

7. Any other facts supporting the justification.

None

8. Actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

When there are unavoidable learning curve costs, such as a complete personnel turnover, FSA will consider incorporating a transition plan as part of their evaluation criteria when re-completing this effort or overlap the new vendor with the old to minimize a decline in productivity due to knowledge loss.

9. Technical/Requirements Representative Certification. I certify that this requirement constitutes the Government’s minimum needs and the supporting data provided herein is accurate and complete to the best of my knowledge and belief.

Date

Contracting Officer Representative

(Insert PR/RFQ/BPA/Order number, as applicable)

10. Approving Official Determination of Circumstance Applicability.

In accordance with the requirement at FAR 8.405-6(c)(2)(xi), the undersigned approving official for this justification hereby determines the circumstance cited above at #4, Authority and supporting rationale, applies to this acquisition.

11. Contracting Officer’s Certification and Approval

I certify this justification is accurate and complete to the best of my knowledge and belief. For justifications >$250K up to $700K, my signature also serves as approval of the justification.

Date

Contracting Officer