LSJ_ARMY_ASACS_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C 501

Solicitation # 140D0424Q0418

General Services Administration (GSA) Solicitation No. 140D0424Q0418 solicited to Armed Forces Services Corporation/Magellan Federal under GSA Multiple Award Schedule (MAS) Contract No.

GS02F027BA (expiration date November 07, 2028)

This acquisition is conducted under the authority of the Multiple Award Schedule (MAS) Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This is a Limited-Source Justification executed by the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division II Branch IV, on behalf of The Department of Defense (DOD), Army - Army Resiliency Directorate (ARD).

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

The Government intends to issue an 24-month sole source task order by way of one 12-month base period and two six-month options, to Armed Forces Services Corporation (AFSC)/Magellan Federal to provide continuous severable support services for the Adolescent Support And Counseling Services (ASACS) program. The sole source task order will be awarded on a Time and Materials (T&M) basis that will include a not-to-exceed amount for other discretionary costs (ODCs) and travel. The current Task Order for these services, No. D16PD00864 was competitively awarded against GSA Contract No.

GS02F027BA, as a T&M type order that include a not-to-exceed amount for ODCs and travel. The period of performance for GSA Task Order No. D16PD00864, awarded on June 30, 2016, included one 12-month base year plus four 12-month option years. A logical follow-on utilizing the FAR authority FAR 8.405-6(a)(1)(i)C was awarded on June 29, 2021 via contract modification (P00014) to extend the performance period of existing GSA Task Order D16PD00864 by 36 months via the inclusion of three, 12-month option years. D16PD00864 is set to expire on June 29, 2024.

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

The purpose of this sole source task order is to continue the support of the U.S. Army - Army Resiliency Directorate (ARD) ASACS program for select U.S. military Outside the Continental United States (OCONUS) operations. The ASACS program includes a comprehensive program for prevention, education, identification, referral, and treatment. ASACS services are provided free of charge to all adolescent family members that hold a military ID card and are eligible for TriCare services.

The contractor is expected to provide Prevention/Education and Counseling services to eligible adolescent family members. This includes a comprehensive school and community based, resiliency, and other well-being prevention programs based on best practices as defined by recognized authorities on best practices for life skills and adolescent prevention services utilizing the Institute of Medicine - Universal, Selective, and Indicated- prevention model. The period of performance for this sole source task order is 24 months which will be comprised of a 12-month base period and two six-month option periods. The task order will also include FAR 52.217-8 Option to Extend Services. The total estimated value of the requested sole source task order is $14.9M.

4. The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

a. The following fair opportunity exception applies to this acquisition.

FAR 8.405-6(a)(1)(i)B - Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

b. Supporting Rationale.

A sole source task order is necessary at this time as it is anticipated that within the next 12-months the execution and administration of the ASACS program will be transitioning from the US Army Directorate of Prevention, Resilience & Readiness (DPRR) to the Defense Health Agency (DHA). It is unknown at this time if DHA will recompete this effort utilizing their inhouse contracting office or if the services will be provided by DHA directly. It is anticipated that DHA will dramatically change Statement of Work to include how the program will be managed and possibly the certification requirements necessary to perform the work.

Furthermore, it is expected that the ASACS program will experience a complete overhaul. The incumbent, AFSC/Magellan Federal, is uniquely qualified as it is currently providing these services and has the ability to continue providing service without requiring a transition-in period to establish the OCONUS personnel. AFSC/Magellan Federal has shown that it is uniquely qualified to manage the rigorous requirements of the OCONUS work such as managing Status of Force Agreement requirements, recruiting, on-boarding, and managing workers OCONUS with foreign and US government regulations.

Transition challenges are inevitable when changing program offices, which include but are not limited to delays caused by the entire program transition which could result in a break of service, additional time required to obtain clearance requirements with the Department of Defense Contractor Personnel Office in Europe, and other unknown clearance requirements required by DHA.

Additionally, there are costs associated when implementing a new program administration (additional requirements, new protocol, etc.) all which presents an unacceptable risk to the success of the ASACS program and overall mission needs. Continuity is critical to maintain safety and security of the vulnerable adolescent population in our military communities.

Under the current contract, AFSC/Magellan Federal has facilitated the ASACS program to adapt well to hiring challenges by mitigating financial impacts to the government and minimizing the time without services due to new hires by streamlining our processes and following host nation guidance.

Any disruption in services would have a strong negative impact to the mental health of military dependents and decrease the availability of mental health services provided to military dependents overseas. Additionally, the current vendor has established staff on site in 25/26 positions. In the event a new contractor is selected to take over the ASACS contract, there is significant risk of personnel movements and increased vacancies, both of which would result in additional delays and reimbursable monetary expenses based on host-nation regulations, travel restrictions, move related slowdowns, and difficulty filling many open positions.

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

The Contracting Officer (CO) will make a separate determination as to the fair and reasonableness of the price through price analysis based on historical data from the existing task order, D16PD00864, published rates listed in GSA MAS Contract No. GS02F027BA, the GSA Contract Awarded Labor Categories (CALC) tool and the independent government cost estimate (IGCE).

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.

The CO determined that the North American Industry Classification System (NAICS) code for this procurement is 621330, entitled “Offices of Mental Health Practitioners (except Physicians)”, with a size standard of $9 million and that the Product Service Code is R799 entitled “Other Management Support Services”. GSA Multiple Award Category 624SS with a description of “Social Services, Professional Counseling and Veterans' Readjustment and Behavioral Health Services” provides the necessary services for this effort. There are currently 51 contract holders under MAS Category 624SS, 16 of which are large businesses. Previous iterations of this contract have shown only two vendors have been able to successfully provide these OCONUS services, AFSC/Magellan Federal and Leidos, Inc. AFSC/Magellan Federal currently holds Contract No. GS02F027BA under GSA Multiple Award Category 624SS.

Historically, small businesses have not responded to Request for Information/Sources Sought notices due to the obstacles associated with OCONUS component of the requirement and the ability of small businesses to manage the rigorous requirements of the OCONUS work such as managing Status of Force Agreement requirements, recruiting, on-boarding, and managing workers OCONUS with foreign and US government regulations. This concern aligned with the Government’s already existing concerns of a small business being able to successfully complete the requirement.

7. Any other facts supporting the justification.

The proposed sole source GSA Task Order represents the most advantageous method of fulfilling the client’s need given price and other factors mentioned herein. The transition of the ASACS program to the DHA will require additional time and the disruption in service would significantly impact the critical mission requirements of the ASACS program.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

Upon completion of this sole source GSA Task Order it is unknown if this program will be executed by DHA employees or if a new contract will be sought. However, if these services are to be acquired via the award of a government contract, is anticipated that the government will competitively re-compete this effort. Market research will be conducted to determine the most advantageous procurement method for the re-compete of this effort.

9. The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

I certify this justification is accurate and complete to the best of my knowledge and belief.

L. Christine Schickler Contracting Officer Division 2 Branch 4

10. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify the technical data which forms a basis for this justification is complete and accurate and meet the Government’s minimum needs.

Dr. Terrence Elliott Contracting Officer Representative Army Resiliency Directorate (ARD)

11. For justifications under 8.405-6(a)(1), a written determination by the approving official identifying the circumstance that applies.

This sole source GSA Task Order represents the most advantageous method of fulfilling the client’s need given price and other factors in accordance with FAR 8.405-6(a)(1)(i)B - Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

12. Reviews and Approvals

Concur

Gregory Mazul Branch Chief Division 2 Branch 4

Concur

Rebecca Fentzke Division Chief Division 2

Approve

Michael Farrell Competition Advocate