LimitedSourceJustifESF2.8.2021Redacted.pdf

United States Department of Education

Office of Finance and Operations

Contracts and Acquisitions Management

LIMITED SOURCE JUSTIFICATION

1) IDENTIFICATION:

Agency: U. S. Department of Education

Contracting Activity: Contracts and Acquisitions Management

2) NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED:

The Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136) of 2020 established the

Education Stabilization Fund (ESF). Task Order 91990019A0008/91990020F0358 supports the ESF

Public Transparency Portal, an information system for collecting information on how the over $30 billion in grants awarded from the ESF are used and disclosing this information to the public. This task order is implemented by the Office of the Chief Data Officer (OCDO). The current task order provides data collection capability and support (e.g. helpdesk support) for thousands of grantees that report data on grant implementation back to the Department. This reporting is required to comply with both legislative requirements and requirements mandated by the Department. Numerous grantees have indicated that they need more time and support to finalize the required reporting. To provide this additional time and support to grantees, the above referenced task order requires a modification.

This task order was issued under the Education Data Management and IT Services (EDMITS) Blanket

Purchasing Agreement (BPA). This BPA was awarded under a competitive GSA procurement. It was awarded under GSA contract 47QTCA18D00JV to Applied Engineering Management Corporation (AEM).

3) DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY'S NEEDS:

The current task order requires the contractor to build and operate a data collection portal for grantees to report their ESF-related data. In addition, the task order requires the contractor to support grantees in their reporting through operating a helpdesk. Since grantees need more time and support to report their data, required services to meet the agency’s needs include:

Continued maintenance and operation of the data collection portal for an extended period. This includes ensuring that the portal is operational and providing support for managing data reporting user accounts of individual grantees.

Continued operation of the helpdesk for an extended period including additional support to handle current call volume. The contractor currently operates a helpdesk with both phone and email support for thousands of grantees. Helpdesk support includes technical assistance on how to use the portal and how to properly report data. The helpdesk also provides communications through technical assistance broadcasts, reminders go deadlines, and other communications.

Based on an independent government cost estimate, this modification will likely require an additional

$75,000

4) STATUTORY AUTHORITY PERMITTING LIMITED SOURCES JUSTIFICATION:

The authority is 8.405-6 (a) (1) (C) In the interest of economy and efficiency, the new work is a logical follow-on to an original order.

5) THE NEW WORK IS A LOGICAL FOLLOW-ON TO AN ORIGINAL FEDERAL SUPPLY

ORDER AND REQUIRES THE USE OF THE AUTHORITY CITED:

This new work is a logical follow-on to an original award. The current contractor is already currently operating their custom-built ESF data collection portal and helpdesk and just needs to continue these activities for a longer period. The original award was a competitive procurement under GSA Schedule 70.

It is not efficient from a cost or a technical perspective to have a different vendor complete the work of this additional data collection. For example, helpdesk analysts require extensive training on specific ESF survey instructions and methodologies to provide accurate guidance to grantees. It is far more efficient to leverage their existing knowledge with the specific ESF survey rather than for the government to pay for training of new analysts. In addition, helpdesk analysts need to be in constant coordination to ensure that survey instructions and guidance are consistent across similar questions. It would be inefficient and ineffective to attempt coordinating across different organizations over two different time periods of the same data collection. This scenario would likely lead to inconsistencies in guidance and poor data quality. Lastly, the data collection portal was custom-built by the current contractor. It would be inefficient for a contractor to either build a new custom-built portal or go through an extensive training and technology transfer process to maintain and operate the existing portal.

Offerors were not solicited because this is a logical follow-on to an original task order. This requirement is simply to allow the current vendor to extend the existing data collection period so that grantees have more time and support to finish their data reporting. As mentioned previously it would be ineffective and inefficient to have a different vendor, without the ability to leverage existing knowledge, training, and technology to take over the data collection in the final phases of a custom-built data collection process that has already been in place for a while. Grantee data reporting has been influenced by a number of factors including managing issues related to COVID.

6) DETERMINATION BY CONTRACTING OFFICER THAT THE ORDER REPRESENTS THE BEST

VALUE:

It is anticipated that this modification will be firm fixed price. OCDO supplied the Contracting Officer

(CO) an Independent Government Cost Estimate (IGCE) to assist in determining whether the price is fair and reasonable. The CO and Contract Specialist will conduct a price analysis of the vendor’s proposal before award to determine whether the price is fair and reasonable and represents best value.

7) DESCRIPTION OF MARKET SURVEY AND RESULTS, OR STATEMENT WHY MARKET SURVEY

WAS NOT CONDUCTED:

The Department of Education has decided not to conduct a market survey since this is just an extension of currently contracted activities for similar (previously negotiated) costs per unit of service. As mentioned previously it would be ineffective and inefficient (see response to question 5) to have a different vendor, without the ability to leverage existing knowledge, training, technology, etc. to take over the data collection the final phases of a custom-built data collection process that has already been in place for a while.

8) ANY OTHER FACTS SUPPORTING THE JUSTIFICATION:

N/A

9) STATEMENT OF ACTIONS, IF ANY, TO REMOVE OR OVERCOME BARRIERS THAT LED TO

THE CONSIDERATION BEFORE ANY SUBSEQUENT ACQUISITION FOR THE SUPPLIES OR

SERVICES IS MADE:

OCDO understands the serious nature of modifications and will work to limit their occurrence.

10) CONTRACTING OFFICER (CO) CERTIFICATION THAT THE JUSTIFICATION IS ACCURATE

AND COMPLETE TO THE BEST OF THE CO'S KNOWLEDGE AND BELIEF, AND THIS

PROCUREMENT IS NOT A RESULT OF A LACK OF PLANNING OR EXPIRATION OF FUNDS:

The CO certifies that the justification is accurate and complete to the best of their knowledge and the procurement is not a result of planning or expiration of funds.

Program Office Certification:

This is to certify that the data supporting this justification is the responsibility of the program office personnel, including verifying the Government's minimum needs or schedule requirements or other rationale for limited sources (pursuant to 8.405-6) or for other than full and open competition justification (pursuant to 6.303-2(b)) which form a basis for this justification, and that such data and rationale are accurate and complete.

__ _______2/2/21_____________________

Brian Fu Date

Contract Officer Representative

Keith Tucker Date

Project Manager

Contracting Officer Certification:

This is to certify that the data supporting this justification is the responsibility of the undersigned program office personnel, including verifying the Government's minimum needs or schedule requirements or other rationale for limited sources (pursuant to 8.405-6) or for other than full and open competition justification (pursuant to 6.303-

2(b)) which form a basis for this justification, and that such data and rationale are accurate and complete.

Pamela W. Bone

Contracting Officer Date

Approved:

Christopher Rosier

Contracting Activity Competition Advocate Date