LSJ Acumen Salesforce Services_Redacted.pdf

CONTRACT NO.: 9531CB25F0055

LIMITED SOURCES JUSTIFICATION

1 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552

A. FACTS.

1.0 Agency and Office Name: Consumer Financial Protection Bureau, Enterprise Platforms Solutions.

2.0 Nature and/or description of the action being approved. The Consumer Financial Protection Bureau’s (CFPB) intends to limit the number of sources solicited pursuant to FAR 8.405-6(a)(1)(i)(A), an “urgent and compelling need exists, and following the procedures would result in unacceptable delays”, for the procurement of Salesforce implementation and development services from Acumen Solutions Inc. (Large Business), 8280 Greensboro Drive, Suite 400, McLean, Virginia 22102, under their General Services Administration’s (GSA) Schedule Contract # 47QTCA19D00BB.

This GSA Task Order will enable the Bureau to continue current projects under development without a break in service, transition, or loss of expertise as incumbent Salesforce staff currently conducts multiple development projects and O&M for the Enterprise Platforms Team (EPT).

3.0 Description of the supplies or services required (including the estimated value).

The CFPB Enterprise Platforms Team’s (EPT) Salesforce Program within CFPB’s Technology & Innovation (T&I) Division has a need to obtain expert Salesforce support services. Salesforce is a key strategic platform of the Bureau that is leveraged to deliver comprehensive solutions for Bureau staff, Partners, and Consumers. The EPT utilizes Agile development process to implement and maintain a portfolio of Salesforce applications and services in support of multiple CFPB divisions in achieving their missions. These systems enable focus on prioritized, essential work that directly supports the Bureau’s statutory responsibilities. The services procured under this contract will support the applications that reside on the Salesforce platform including, but not limited to Mosaic (Consumer Complaint Tracking System), Supervision and Examination System (SES), Non-Bank Registration (NBR), CFPB Collect, Enforcement Matter Management system, Informal Guidance Inquiry Management System (IG IMS), Legal Division Matter Management (LDMM) and more. These systems enable the Bureau to deliver on its statutorily mandated requirements. The Salesforce support staff focuses on prioritized, 3 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552 support would incur significant mission-critical disruptions resulting in reputational risks as well as additional costs. Seeking new competition for the completion of the ongoing implementations is impractical. With the acquisition timeline, start-up, phase in, and learning curve associated with this requirement, the current program efforts would be postponed for months to obtain new sourcing for services that are satisfactory. The work currently performed under this extension was to be transitioned to a new contract, however, the work cannot be transitioned at this time because the procurement actions to replace this task order are still ongoing.

Maintaining continuity ensures ongoing operations are not materially impacted, avoiding setbacks and potential delays that could impact the efficiency and reliability of the overall implementations. Having worked extensively with the Bureau's stakeholder community, the current vendor is well-versed in the specific nuances of the applications' architecture and unique requirements. Acquiring a new vendor at this critical time for the Bureau would necessitate extensive knowledge transfer and may lead to compatibility issues, potentially compromising the quality and reliability of the product and could lead to a potentially prolonged adjustment period that could impede productivity. Furthermore, the Bureau is experiencing turnover of its government staff resulting in a loss of institutional knowledge.

Retaining the incumbent contractor will help to mitigate the risk of that institutional knowledge loss. Finally, with the change in administration, the Bureau anticipates that updates will be required to many of the applications on the Salesforce platform. This approach gives us the flexibility needed to be responsive to support high-impact special projects aligned with the ongoing transition efforts and evolving priorities while continuing to deliver on core responsibilities. Continuing with the incumbent contractor will retain the knowledge and expertise enabling the Salesforce team to quickly adapt the solutions to changing focus and priorities.

At this juncture, a task order with the incumbent, Acumen Solutions Inc, therefore, serves as the only option to safeguard against operational delays, maintaining a smooth production cycle while minimizing unnecessary expenses and disruption to ongoing implementations associated with a vendor transition. This action mitigates this risk by allowing the current vendor to continue their implementation of the application, ensuring a smooth and efficient operation without the disruptions that would accompany a shift to a new service provider.

This approach is both practical and cost-effective in maintaining the project's momentum.

It is in the Government’s best interest to continue this critical and statutorily required work with the current contractor.

5.0 A determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d). Per FAR 8.404(d), GSA has already determined the

4 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552 prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable and the ordering activity has concluded that the order represents the best value and results in the lowest overall cost alternative to meet the Government’s needs. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-1(c). The Contracting Officer will compare current labor hourly rates currently offered to the Bureau under CFPB’s GSA Order 9531CB24F0042 to further substantiate that the price proposed is fair and reasonable.

6.0 A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted. The CFPB requires support services for its Salesforce Platform. Specifically, it requires application development and Operations and Maintenance support. A Certified Technical Architect (CTA) is a key personnel position that is critical to the success of this support.

The market research team used GSA’s market research as a tool (MRAS) tool to publish an RFI including a draft PWS and questions. MRAS returned a 16-page executive summary. There were 79 interested sources including 64 small businesses. Although some of the small businesses indicated they had a CTA on staff, there was insufficient relevant experience in all of their capability statements. Some had experience with small scale Salesforce projects. Some did not reference any Salesforce projects in their capability statements. The market research team found that none of the small businesses that responded appeared capable of meeting the requirements.

The Bureau’s Salesforce applications implementations are often complex due to the use case which requires major development and highly customized coding. The CFPB’s Salesforce platform also serves a diverse external user base (consumers, entities, state and federal financial regulators, congressional, etc.) necessitating support for a wide variety of personas. Understanding and catering to this diverse user base adds an additional layer of complexity to the program that requires significant corporate experience and expertise.

None of the small businesses respondents to the sources sought demonstrated experience with a diverse pool of external users.

Architecturally, Salesforce’s complexity requires a unique skillset and expertise.

Salesforce often deals with mission-essential data, raising the stakes in terms of security risk. Ensuring the robust security of Salesforce requires specialized knowledge and resources. Additionally, integrations with various systems contributes to the intricacy of support requirements (MuleSoft, EZProtect, SharePoint Online, Provar, Qualtrics, etc.).

None of the small businesses provided evidence of extensive experience with these

5 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552 integrations tool.

The market research team found that there is insufficient corporate experience among small businesses to warrant a set aside. Market research determined that a logical follow-on with the current contractor was the only way to complete two mission critical implementations (Non-Bank Registration (NBR) and Supervision Version 3 (SV3) Regulator Portal) and ongoing operations and maintenance activities that are underway. Additional market research is being conducted to ensure adequate competition for the long-term effort.

7.0 A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies. No additional efforts were made to ensure that offers are solicited from as many potential sources as practicable because this order is being awarded under limited sources. A competitive solicitation is in the process of being finalized and will soon be released for the long-term effort which is expected to have periods of performance totaling 66 months.

8.0 A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required. The Government has been delayed in soliciting the Salesforce Services requirement due to numerous changes required in the procurement package identified in Section 4.0 (a) above and anticipates re-soliciting for competition in the next few weeks to support future CFPB Salesforce Services needs. This newly competed contract, which is anticipated to be awarded prior to the completion of the base period of this limited sources task order with Acumen Solutions Inc., will allow any contractor to provide continued Salesforce Services support to the Bureau. Further, the Government will continue to conduct market research and use SAM.gov, if applicable, to find and solicit other qualified vendors in the marketplace to fulfill future security service contract requirements.

B. APPROVAL.

1.0 TECHNICAL/REQUIREMENTS PERSONNEL. All 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 or requirements personnel.

6 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552

2.0 PROCUREMENT STAFF. To the best of my knowledge and belief, I certify that this justification is accurate and complete.

Laurent E. Pichet Contracting Officer

3.0 COMPETITION ADVOCATE. To the best of my knowledge and belief, I certify that this justification is accurate and complete.

Competition Advocate, Office of Finance and Procurement