Limited_Sources_Justification_-_HWC_BPA_LSJ__19-004_July_23.pdf

U.S. Department of Homeland Security Federal Emergency management Agency 500 C Street, NW Washington, DC 20472

Limited-Sources Justification (LSJ) For Orders or Blank Purchase Agreements (BPAs) Exceeding the Simplified Acquisitions Threshold

LSJ No.: 19-004

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

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA) proposes to increase the ceiling of General Services Administration (GSA)/Blanket Purchase Agreement (BPA) number HSFE60-16-A-0201 for continued customer communication support on behalf of the Federal Insurance and Mitigation Administration (FIMA) pursuant to FAR 8.405-6(a)(1)(i)(C), logical follow-on. The Contracting Activity is the FEMA/Office of Chief Procurement Officer (OCPO).

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

DHS/FEMA intends to limit the number of sources solicited pursuant to FAR 8.405-6(a) for integrated customer communications, marketing, and public relations support services from Hassett and Willis Associates (HWA), 1100 New York Ave, NW, Washington, DC 20005. A BPA ceiling increase of $14,100,000 or 30% is needed to avoid a lapse in essential services until a competitive follow-on is awarded. This will increase the BPA ceiling from $47,000,000 to $61,100,000. The subject BPA was awarded 9/30/2016 with a base year and four one-year options for services through 9/29/2021. However, due to greater than expected usage the BPA’s ceiling is not sufficient for essential communication and public relations support needed for FY-19.

3. Description of Supplies/Services.

The work performed under the BPA includes providing expert support in all aspects of communications, marketing, advertising, and public relations to successfully meet FIMA’s strategic goals of: (1) advancing the insurance moonshot (to help meet the goal of building a culture of preparedness, FIMA has set a “moonshot” to double the number of flood insurance policies from 4 million to 8 million by 2022), (2) improving National Flood Insurance Program (NFIP) flood insurance policyholders’ customer experience, and (3) becoming a world-class insurance operation. This includes marketing the value of flood insurance, informing the public about the benefits of buying and maintaining flood insurance coverage, and promoting the purchase of flood insurance.

FIMA has engaged about 10 million people nationwide under the subject BPA by using digital display ads, outdoor advertisements, paid search, radio and print advertisements, earned media and infomediaries in areas where consumers are most likely to purchase flood insurance.

The BPA utilization rate has been greater than expected primarily due to: (1) the unprecedented series of major hurricanes and catastrophic flooding events experienced nationwide since the BPA was established and (2) the implementation of Rating Redesign-2 which is changing how flood insurance policies are rated and priced.

As a result of the dramatic increase in flooding events, NFIP has significantly increased its marketing efforts to target “at-risk” communities to entice individuals to purchase flood insurance policies. NFIP also had to provide extensive information to Congress, the media, and the public on the implementation and impact of Rating Redesign-2 with respect to how the new rating system will work and when it will be implemented.

The increased efforts to market flood insurance to “at-risk” communities and the need to communicate the impacts of the new risk rating system to a wide range of stakeholders has led to a dramatic increase in BPA utilization over the past three years.

As a result, the current BPA ceiling cannot cover essential work requirements for five high priority task orders needed this fiscal year which have a combined estimated value of $25,330,038 as summarized below. The BPA has a remaining ceiling balance of $11,230,038, therefore a ceiling increase of $14,100,000 or 30% is needed for placement of the following “high-stakes” task orders under the BPA.

Task Order Estimated Amount

Requirement

BPA TO 7 $ 2,000,000 Communication, marketing, and public relations support for Hazard Mitigation Assistance under the Disaster Recovery Reform Act (DRRA)

BPA TO 8 $ 750,000 Communication, marketing, and public relations support for Risk Rating 2.0 implementation

BPA TO 9 $ 250,000 Communication, marketing, and public relations support for Disaster Assistance Outreach

BPA TO 10 $16,000,000 Communication, marketing, and public relations support for NFIP Flood Insurance promotion

BPA TO 11 $ 6,330,038 Communication, marketing, and public relations support for Risk Rating External Stakeholders

Total Estimate $25,330,038

4. Identification of the exception to fair opportunity and the supporting rationale.

This acquisition is being 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, in accordance with FAR 8.405-6(a), Limiting Sources. The needed BPA ceiling increase will be made in the interest of economy and efficiency as a logical follow-on to original GSA/BPA HSFE60-16-A-0201 pursuant to FAR 8.405-6(a)(1)(i)(C).

The original BPA was solicited and awarded on a competitive basis using the ordering procedures at FAR 8.405.

It is necessary to limit competition for new work described herein as a logical follow-on because only the current BPA holder (HWA) is capable of providing the required services without any transition at the level of quality required since the services are unique and highly specialized. Only HWA has the needed institutional knowledge to continue services without any transition. In addition, HWA has the necessary staff already badged and cleared (adjudicated) by FEMA/Office of Chief Security Office. Any new contractor would need at least 30 to 60-days of transition to become familiar the complexities of NFIP customer communication requirements and to “onboard” the required staffing.

Any lapse in service would negatively impact NFIP’s ability to effectively provide customer communications, marketing and public relations for the five “high stakes” project described above. These projects are essential to FIMA meeting its goals of (1) advancing the insurance moonshot, (2) improving NFIP flood insurance policyholders’ customer experience, and (3) becoming a world-class insurance operation.

It will take up to 210-days to award a competitive GSA/BPA based on OCPO’s standard operating procedure “Timely Submission of Acquisition Packages and Budget Execution for Fiscal Year (FY) 2019” dated 12/10/2018. It critical that FIMA continues its customer engagement and marketing while the agency establishes a new BPA on a competitive basis.

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 has determined that increasing the ceiling of the current blanket purchase agreement with HWA for continued NFIP customer communication support represents the best value to the Government and will result in the lowest overall cost, considering price and administrative costs, to meet FIMA’s needs. The BPA modification increasing the ceiling will be conducted in accordance with FAR 8.404, “Use of Federal Supply Schedules.” The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates.

In addition the current BPA with HWA includes labor rate discounts ranging from 4 to 10%. Prior to issuance of the five new task orders referenced above, the ordering activity will consider the proposed level of effort and the mix of labor to perform the specific tasks being ordered to determine that pricing is fair and reasonable. The proposed labor mix and level of effort will be compared to the Independent Government Cost Estimate (IGCE) for each of the pending task orders.

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.

Market research results have demonstrated that the required services can be most effectively obtained under GSA/FSS Advertising & Integrated Marketing Solutions (AIMS). However, given the immediate need of FIMA requirements, only the current BPA holder HWA can provide these critical services in a timely and cost efficient manner without any transition.

7. Any other facts supporting the justification.

The five projects described herein reflect FIMA’s minimum communication, marketing, and public relations support requirements until a new competitive GSA/BPA can be established.

8. 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 supplies or services is made.

FEMA will be conducting a competitive recompete for a new GSA/BPA to be in-place on or before September 29, 2020 using the ordering procedures at FAR 8.405.

9. DHS intends to post this requirement on FBO pursuant to FAR 8.405-6(a)(2)(i).

10. Technical/Requirements Personnel Certification:

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Melis Mull Date Technical Representative

11. Contracting Officer’s Certification and Concurrence:

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and complete to the best of my knowledge and belief:

Michael D. Sutton Date Contracting Officer

12. Competition Advocate Concurrence:

Tyuana Bailey Date Component Competition Advocate

13. Approval:

Bobby McCane Date Chief Component Procurement Officer