LimitedSourcesJustificationoverSAT - Financial Support Services BPA.pdf

Limiting Sources Justification

FAR 8.405

1. Identification of the agency and the contracting activity.

a. Contracting Activity: U.S. Agency for International Development

USAID/Uganda U.S. Mission Compound, South Wing

Plot 1577 Ggaba Rd PO Box 7856 Kampala, Uganda

c. Contracting Officer: Admir Serifovic

d. BPA Number: AID-617-E-15-00001/2/3 and AID-617-E-16-00001

e. Estimated Value of Action: $900,000

f. Reference: FAR Subpart 8.405-6(a)(1) (i) (C)

2. The nature and/or description of the action being approved.

This action is to modify the current Financial Support Services Blanket Purchase Agreement (FSS-BPA) for an additional 6-month period and moving the end date of period of performance from July 8, 2020, to January 8, 2021. This extension will allow adequate time to transition and implement various assessments which include: Pre-Award Surveys, Fiduciary Risk Assessments, Financial Reviews, Pre-Payment Verification, Host Country Contracting Capability Assessments, Audits, and Technical Assistance. To meet future needs for assessments and audits, USAID/Uganda is in the process of establishing a new multiple-award BPA. At this point, it will not be possible to issue the RFQ, evaluate responses, establish the new Financial Support Services BPA before the current BPA expires. The current BPA was meant to provide support under the new USAID/Uganda CDCS 2.0 activities; however, implementation of the various activities was significantly delayed. Therefore, a number of BPA Calls have been issued towards the tail end of its life span of the FSS BPA. Therefore, to avoid a break in service, USAID/Uganda needs to extend the services under this BPA until the new BPA is awarded.

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

Based on the purchases made under the current BPA, the projected calls under the BPA for the 6-month extension period will be seven (7) Assessments and three (3) Audits. The estimated cumulative cost for the ten (10) individual BPA Calls is $900,000. The BPA calls will conform to the approved pricing structure and under the FSS-BPA. The BPA Calls under this extension will be within the original BPA ceiling of $5,000,000, and each individual BPA call is under the Simplified Acquisition Threshold of $250,000.

4. The authority and supporting rationale.

If 8.405-6(a)(1)(i)(C) is the authority, explain why only the original source can provide the necessary supplies or services, such as substantial duplication of cost to the Government that is not expected to be recovered through competition, or unacceptable delays in fulfilling the Government's need. The original BPA was not previously issued under sole-source procedures.

Supporting Rationale

The intent of this 6-month extension is to continue the provision of services under the existing BPA. Activities in support of a re-solicitation of the BPA were started prior to December 2019, but challenges in staff availability led to delays in finalizing the Acquisition Plan, solicitation document, and supporting documents for the follow-on competition. As a result, USAID/Uganda has found itself in the situation where a customer requirement for continuing provision of essential financial services, combined with delays in award of a follow-on vehicle, created a need for bridge coverage.

USAID/Uganda plans to establish the new multiple-award FSS-BPA in November 2020 with up to six contractors. The 6 additional months will provide the implementers of the current Calls adequate time to complete the ongoing/planned Assessments and Audits. This extension authorizes the performance of BPA Calls competed prior to the end of the original BPA. No BPA Calls will be issued within the last three months of the current FSS-BPA. Once established, all future financial support services will be competed through the new FSS-BPA.

5. A determination by the ordering activity Contracting Officer (CO) that the order represents the best value consistent with FAR 8.404(d).

The Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable and in the Government’s best interest consistent with FAR 8.404(d). The current existing BPA was competed and fair and reasonable prices/discounts were determined since (a) USAID/Uganda has already determined the prices of the supplies and services under FSS-BPA contracts to be fair and reasonable; and (b) by placing the existing BPA against a schedule contract using the procedures in FAR 8.405, the Contracting Officer previously concluded that the BPA represented the best value (see FAR 2.101). This 6-month bridge is a continuation of that effort without any modifications to existing requirements. Further, USAID expects all the CPA firms in the existing BPA to submit quotations for the new FSS-BPA.

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 for this 6-month extension was not performed since changing contractors for this short term would be cost prohibitive and not generate any cost savings. A transition to another contractor would certainly entail spin up time (uploading the new contractor’s catalog, on-boarding the new contractor, staffing, establishing an initial schedule of required services, etc.), which would potentially delay essential Financial Support Services required by the USAID/Uganda Office Financial Management. The Market research conducted to establish the new BPA indicates that many of the current BPA holders will bid on the upcoming FSS-BPA as there are limited qualified CPA firms in Uganda.

7. Any facts supporting the justification.

See above.

8. A statement of actions the agency may take to remove or overcome any barriers to competition if subsequent acquisitions are anticipated.

A new multiple-award BPAs will be issued to six CPA firms in November 2020. The ongoing Calls under the existing BPA are expected to be completed during the new period of performance. USAID/Uganda anticipates all BPA Calls to be competed and closed before closing of the existing BPA.

9. Contracting Officer Certification.

The undersigned has determined that the pricing approach and discounts in effect for this modification will be unchanged from those previously established in the BPA, and thus are deemed fair and reasonable. Further, I certify that this justification is accurate and complete to the best of my knowledge and belief.