Limites Source Justification_STAFF Recompete Bridge 2.0_redacted_.pdf

CUI//SP-SSEL

FEDSIM is a Client Support Center housed within GSA, FAS, AAS Page 1

Version 11/10/2020

General Services Administration

Federal Systems Integration and Management Center

LIMITED SOURCES JUSTIFICATION

DESCRIPTION OF ACTION URGENT AND COMPELLING NEED

SOLICITATION 47QFCA22Q0012

INTERAGENCY AGREEMENT NUMBER 47QFCA21S0149

The General Services Administration (GSA) makes this Limited Sources Justification

(LSJ) for orders pursuant to Federal Acquisition Regulation (FAR) 8.405-6.

i.) Identification of Agency and Contracting Activity:

Agency:

General Services Administration (GSA)

Federal Systems Integration and Management Center (FEDSIM)

Contracting Activity:

GSA FEDSIM Contracting Office (QF0B)

1800 F Street, NW

Washington, D.C. 20405 ii.) Nature and/or Description of Action Being Approved:

FEDSIM intends to award a sole source Task Order (TO) under the Multiple Award

Schedule Professional Services Category (MAS-PSC) contract vehicle to provide mission-critical internal financial tracking and reporting, Project Performance Management (PPM), training development, and managed technical evaluation services for GSA FEDSIM and

GSA AAS Regional Offices.

FEDSIM is currently receiving these mission critical professional services under the existing Support for Training, Acquisition, and Financial Reporting at FEDSIM (STAFF)

Recompete Bridge TO 47QFCA22F0006, which was originally scheduled to end on

December 14, 2022. GSA began obtaining requirements for a new competitive TO to provide FEDSIM and AAS Regional Offices with professional services similar to those required in previous STAFF TOs as the long-term replacement. This award is estimated to be made in at the end of Fiscal Year (FY) 2022 or early FY 2023. The 47QFCA22F0006

Prime contractor is E3 Federal Solutions LLC d/b/a Avantus Federal (Avantus). A unique aspect of this TO is the unmitigable Organizational Conflicts of Interest (OCI) declaration that was agreed upon without objection by Avantus. The COI declaration states, “The awardee (and any subcontractors, consultants, or teaming partners) shall be ineligible from proposing (to include as prime, subcontractor, or consultant) on any procurement issued by

FEDSIM, except for procurements issued on behalf of the FEDSIM PMO for the duration of the contract. There is no mitigation strategy to resolve this organizational conflict of interest.”

DocuSign Envelope ID: C878FD48-565B-4050-BED4-1C0F5C545BF4

FEDSIM is a Client Support Center housed within GSA, FAS, AAS Page 2

In late January/early February, Avantus teamed with Booze Allen Hamilton (BAH) as a subcontractor on a FEDSIM procurement; BAH was subsequently removed from the competition and Avantus was informed by the FEDSIM Contracting Officer (CO) on

February 17th, by letter that they were in noncompliance with the OCI contained within their order. Subsequent conversations were held between Avantus, the FEDSIM CO and

FEDSIM leadership on this issue, with FEDSIM continuing to reinforce the unmitigable nature of the OCI. In March 2022, Avantus informed FEDSIM that it intended to sell the

FEDSIM business, but not the underlying GSA schedule that the order was awarded against. On April 8, 2022, Avantus notified the FEDSIM Director, Deputy Director, and

FEDSIM CO that it had entered into a letter of intent to sell the business to the Hive Group, LLC (Hive), a certified Historically Underutilized Business Zone (HUBZone) business and

GSA Schedule contract holder on the MAS-PSC contract vehicle. The estimated close date for the sale to Hive is May 2, 2022. Because Avantus is not selling the underlying GSA schedule, FEDSIM cannot novate the existing order and, therefore, must enter into a sole source agreement with Hive to continue these mission-critical services as Avantus will no longer have the ability to satisfy FEDSIM’s requirement upon completion of the sale. A lapse in these services would be detrimental to FEDSIMs ability to support its existing client base, putting $7 Billion (B) of client funds at risk, along with internal training, business analytics, and would severely hamper awarding of new orders due to the loss of the managed evaluation services.

On average, it takes GSA FEDSIM approximately nine months to competitively award a performance-based TO, depending on the project’s size, scope, and complexity, and number of offerors. Therefore, due to the urgency and criticality of providing uninterrupted mission-critical fiduciary contract and project management services, training development and delivery, and managed technical evaluation services required after May 2, 2022, FEDSIM reviewed contractual options and decided to award a six-month sole source contract to Hive under its MAS-PSC (i.e., 47QRAA21D000W) contract vehicle to allow uninterrupted mission-critical services to FEDSIM Integrated Project Teams (IPTs). The

Government’s competitive future strategy is to conduct market research and prepare proper acquisition documentation to conduct a best value, performance-based procurement using a

GSA contract to obtain long-term professional services and allow sufficient time for transition activities. Award for this contract is anticipated in late FY 2022 or early FY

2023.

The MAS-PSC vehicle was selected for this action under the limited sources justification

(Federal Acquisition Regulation (FAR) 8.405-6(a)(1)(i)(A), Urgent and Compelling). The contract type determined to be most appropriate for this acquisition is Firm-Fixed-Price

(FFP), Time and Materials (T&M), and Labor Hour (LH) with Cost Reimbursable Contract

Line Item Numbers (CLINs) for Long-Distance Travel and Other Direct Costs (ODCs). A hybrid FFP, T&M, and LH TO will take advantage of known, stable historical data from previous STAFF TOs and account for FEDSIM growth and changes in acquisition policies that would result in new and revised training requirements, and the need for unforeseen surge in PPM support. The optional PPM Surge task will inherently vary in level of effort

FEDSIM is a Client Support Center housed within GSA, FAS, AAS Page 3 required due to the annual fluctuations in Government contracts, financial obligations, budget constraints, and FEDSIM’s anticipated portfolio growth.

The Government anticipates awarding a six-month TO, with an estimated value of

$7,210,611. Additionally, the TO will include the FAR 52.217-8 Option to Extend Services clause, which could potentially lead to a total contract value increase of . If executed, the TO would have a not-to-exceed value of which is within the threshold for the Competition Advocate’s signing authority.

iii.) A Complete Description of Supplies/Services Required to Meet Agency’s Need:

The scope of this requirement is to provide professional services that will incorporate best practices into the management and control of FEDSIM client projects throughout their lifecycle. This support includes pre-award and post-award acquisition services, financial management, and customized training development and assistance for continuous learning.

The STAFF Recompete Bridge 2.0 TO will provide standardized financial tracking and invoice review, monitor project performance, and streamline an approach to budget development and cost analysis. The sole source STAFF Recompete Bridge 2.0 TO will also provide FEDSIM with managed technical evaluation support services at the contractor site.

Primary services under the STAFF Recompete Bridge 2.0 TO will be provided to FEDSIM personnel; however, there may be requirements under the TO to provide similar services to

GSA AAS Regional Offices. The objective of this sole source TO will help GSA FEDSIM to achieve the following objectives:

a. Provide support to FEDSIM’s growing workforce to ensure acquisition, financial, and service quality to client projects.

b. Ensure that quality is consistently maintained across all FEDSIM projects.

c. Ensure activities among acquisitions are coordinated at the program level and that acquisitions have the logistical support necessary to meet scheduled milestones.

d. Support the growth of FEDSIM’s portfolio of large, complex IT and professional services projects.

e. Ensure support to FEDSIM University to maintain FEDSIM’s high standards for acquisition, financial, and service quality.

iv.) The Authority and Supporting Rationale:

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

Consideration of schedule contractors will be restricted in accordance with:

a. FAR 8.405-6(a)(1)(i)(A) - An urgent and compelling need exists and following the procedures would result in unacceptable delays.

GSA began obtaining requirements for a new competitive TO to provide FEDSIM and

AAS Regional Offices with professional services similar to those required in previous

STAFF TOs. However, due to the unforeseen violations of the existing contract’s OCI declaration, and the subsequent selling of the business unit by Avantus, award of a sole source order to Hive is warranted in order to provide the mission-critical services until the successor contract can be competed and awarded. The current STAFF Recompete Bridge

TO, while originally scheduled to end on December 14, 2022, will realize debilitating performance issues once the sale from Avantus to Hive is completed if no new order is

FEDSIM is a Client Support Center housed within GSA, FAS, AAS Page 4 established. FEDSIM was given short notice of the pending sale of the business unit required to fulfill its mission-critical services, leaving the only option to prevent a lapse in service and permit FEDSIM to receive mission-critical services is through the establishment of this STAFF Recompete Bridge 2.0 TO.

The sole source TO needs to be awarded no later than May 1, 2022, to avoid a lapse in mission-critical services provided by the STAFF Recompete 2.0 TO. As of March 2022, FEDSIM had approximately 309 employees supporting client projects across the following seven sectors: Civilian, Air Force, DoD, Army, Navy, Geographic Combatant Command

(GCC), and Innovation. FEDSIM had $69B active contract awards, with contract obligations in excess of $7.1B.

FEDSIM is actively growing its staff and project portfolio. In FY 2019, FEDSIM had 135 active projects with a contract ceiling of $32B. In FY 2019, FEDSIM Contracting awarded

43 contracts with a contract ceiling of $8B. In FY 2020, FEDSIM had 214 active projects with a contract ceiling of $51.5B. In FY 2020, FEDSIM Contracting awarded 51 contracts with an aggregate estimated value of $14.4B. The increase in active projects and contract obligations shows the demand for FEDSIM acquisition and post-award project management services are increasing. For example, in FY 2020 FEDSIM reviewed and processed approximately 2,885 invoices valued at $5.4B. Figure 1 illustrates the importance and relevance of the number of trained staff and projected net revenue projections for GSA FEDSIM.

Figure 1 – FEDSIM Employees Onboard and Net Revenue Projections

The STAFF Recompete Bridge 2.0 TO will provide FEDSIM with the professional services needed to enable its staff to continue uninterrupted best value services to clients, maintain

FEDSIM is a Client Support Center housed within GSA, FAS, AAS Page 5 financial accountability and regulatory compliance, and enable FEDSIM to continue to grow to meet the increasing demand for FEDSIM services worldwide. Furthermore, as

FEDSIM’s organization grows, maintaining the quality of its services through rigorous training and development becomes increasingly important. The STAFF Recompete Bridge

2.0 TO will also provide training development support to FEDSIM and AAS personnel through FEDSIM University. The FEDSIM University Program provides AAS and

FEDSIM-specific Acquisition, Financial Management, Management/Leadership, Project

Management, and Technology education and tools to all FEDSIM personnel.

v.) Determination by the Ordering Activity Contracting Officer that the Order

Represents the Best Value Consistent with FAR 8.404(d):

The CO will perform a price analysis to ensure fair and reasonable pricing and the best value to the Government. The quote will be compared to Hive’s underlying GSA Schedule pricing, the Independent Government Cost Estimate (IGCE), technical approach, and to the historical costs in the current Task Order.

vi.) Description of the Market Research Conducted Among Schedule Holders and the

Results of the Research:

The Government examined if Hive, the firm acquiring the business unit currently providing services under the existing STAFF Recompete TO, has the requisite technical capabilities and experience with FEDSIM processes and procedures to perform STAFF Recompete

Bridge 2.0 services, and whether its services are available under a MAS Professional

Services Category vehicle.

Hive not only is acquiring the business unit currently performing the requirement, but has also performed similar services for GSA FEDSIM under previous TOs, and has received positive performance reviews. GSA FEDSIM reviewed GSA e-library and determined that the Hive is the legal entity that holds the MAS Professional Services Category (MAS-PSC) contract vehicle 47QRAA21D000W and it is currently in effect through November 19, 2025. Therefore, the Government can acquire professional services from Hive under its

MAS-PSC contract, and Hive personnel could perform the required STAFF Recompete

Bridge 2.0 services for GSA FEDSIM and its clients without interruption to mission-critical services.

This market research was conducted in September 2021 and April 2022.

vii.) Any Other Facts Supporting the Justification:

E3 Federal Solutions and its previous company names (e.g., E3/Sentinel) has been providing financial and management consulting to GSA FEDSIM since May 2008. E3

Federal Solutions personnel are highly familiar with GSA FEDSIM operations, its customized staff training requirements, and with the GSA AAS financial and contract management system (i.e., ASSIST). This six-month TO will enable GSA to prepare proper acquisition documentation and conduct a best value competitive procurement using a GSA contract vehicle to obtain FEDSIM financial management, training development, and managed technical evaluation professional services, and will also allow sufficient time for transition activities. Awarding a sole source TO to Hive would enable the same personnel who have a proven record of satisfactorily providing the required services and who have

FEDSIM is a Client Support Center housed within GSA, FAS, AAS Page 6 highly specialized technical expertise already in place to continuously execute the requirements of the STAFF Recompete Bridge 2.0 TO immediately upon award. Therefore, awarding a sole source TO to Hive is the only feasible and practical alternative for this six-month contract action. A contractor without the required knowledge and experience that is within the scope of the STAFF Recompete Bridge 2.0 TO requirement and required GSA security credentials would cause the Government to experience significant delays in quality service delivery to its clients and require additional GSA FEDSIM oversight if the

Government attempts to solicit this short-term requirement competitively.

viii.) Statement of the Actions the Agency May Take to Remove or Overcome any Barriers that Led to the Restricted Consideration Before Any Subsequent Acquisition for the

Supplies or Services is Made:

This sole source is anticipated to be awarded no later than May 1, 2022, to permit a May 2, 2022, Project Start date. A subsequent competitive acquisition will commence in calendar year 2022 and a TO award resulting from that competitive acquisition is targeted during the end of FY 2022 or early FY 2023.

ix.) Contracting Officer Certification that the Justification is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

I hereby certify that this Justification is accurate and complete to the best of my knowledge, and I determine on the basis of the findings above that the limited sources approach is in accordance with the requirements and is in the best interest of the Government.

Frank Bottalico Date

Contracting Officer

FEDSIM Acquisition, Navy x.) Evidence that any Supporting Data that is the Responsibility of Technical or

Requirements Personnel and Which Form a Basis for the Justification Have Been

Certified as Complete and Accurate by the Technical and Requirements Personnel (If

Any):

Supporting data provided by technical or requirements personnel has been certified as complete and accurate as demonstrated by the attached Technical and Requirements

Personnel assertion.

4/19/2022

FEDSIM is a Client Support Center housed within GSA, FAS, AAS Page 7 xi.) Written Determination by Approving Official Identifying the Circumstance that

Applies:

I hereby certify that this justification is accurate and complete to the best of my knowledge, and I determine on the basis of the findings above that the urgent and compelling need is in accordance with the requirements and is in the best interest of the Government.

Pete Burr Date

Competition Advocate, FEDSIM

4/19/2022