LSJ Audit Infrastructure General Fund SPE Approved_Redacted.pdf

Reviews

I have reviewed this justification and find it adequate to support other than full and open competition.

Date:

roving Ground

Limited Sources Justification – FAR Part 8

1. Contracting Activity: Army Contracting Command - Aberdeen Proving Ground (ACC- APG), Aberdeen Division D, 6515 Integrity Court - Bldg. 4310, Aberdeen Proving Ground, Maryland 21005-3013

2. Description of Action: The Assistant Secretary of the Army Financial Management and Comptroller (ASA(FM&C)) requests a bridge modification to extend the period of performance (PoP) on the Army General Fund Audit Infrastructure Task Order (TO), W91CRB-18-F-0238, by 12 months. As a result, the TO will increase by

The TO was awarded under General Services Administration (GSA) Multiple Award Federal Supply Schedule GS00F290CA. The GSA schedule has sufficient ceiling for the modification increase. The TO provides support for audit infrastructure to support the Army’s annual General Fund Financial Statements audit. The awardee is ERNST & YOUNG LLP (EY), 1101 New York Avenue, NW, Washington, DC 20005-4213. The PoP will be extended from 1 July 2024 to 30 June 2025. This PoP is inclusive of an initial period of nine months (9) and one (1) three-month option period.

This bridge will provide continuity of audit support services and allow for award of a competitive Single Award (SA) Indefinite Delivery, Indefinite Quantity (IDIQ) contract to continue performance. The SA IDIQ contract will be followed by a large-scale Army Improvement (AFI) Multiple Award (MA) IDIQ contract. The SA IDIQ contract is projected to be awarded by December 2024 and the MA IDIQ contract is projected for award by July 2026.

This requirement will be incrementally funded using Fiscal Year (FY) 24-FY25 Operations and Maintenance Army (OMA) funding.

3. Description of Supplies/Services: This is a non-personal services TO providing audit infrastructure to support the Army’s annual General Fund Financial Statements audit for Treasury Index (TI) 21 and Army (TI-97), develop and implement solutions to control gaps in the Army’s business processes, monitor and validate corrective actions, and provide education and training to the Army financial management workforce on the Army’s audit requirements.

The TO provides all personnel, equipment, supplies, facilities, transportation, tools, materials and other items and non-personal services necessary to provide an audit infrastructure to interact with external financial statement auditors, improve the Army’s financial reporting processes, monitor financial reporting controls and validate the corrective actions, and communicate and coordinate change management with Army’s Senior Leadership, to comply with Section 1002, paragraph 204d(b) of the 2019 National Defense Authorization Act (NDAA), as well the Chief Financial Officer Act of 1990 (P.L. 101-576) and 10 U.S.C. §240a et seq. The TO also provides for preparation and presentation of executive level briefings for Army installation personnel, Headquarters Department of the Army and Department of Defense personnel concerning work performed on the TO. As currently structured, support required under this TO is connected and interrelated and cannot be broken into individually awarded actions available for competition to multiple sources. The work required is considered highly specialized and includes a myriad of complex audit functions as further specified and explained in Section 5.

The requested amount of the value increase was derived from the Government’s estimate based on the projected level of support needed for a twelve (12) month PoP extension, inclusive of a transition period for the new competitive acquisition.

Current Milestones Single Award

IDIQ

Draft PWS and Sections L&M posted to SAM.gov Industry Comments Received Acquisition Strategy Approved/Acquisition Plan Approved Source Selection Plan Approved Solicitation Review Board Complete Issue Solicitation Solicitation Closing Date Initial Evaluations Complete Initial SSEB Report Complete Possible Discussion and Evaluations Final SSEB Report Complete Brief SSAC on Final Evaluation Source Selection Decision Document Approved Price Negotiation Memorandum Approved Contract Review Board Complete Anticipated Award Date Full Performance Begins (after 90-day transition-in)

H.R. Bill 2961: H.R. Bill 2961 was referred to the House Armed Services Committee on Armed Services on 27 April 2023 entitled Audit the Pentagon Act of 2023. The bill states “If, during any fiscal year after fiscal year 2022, the Comptroller of the Department of Defense fails to certify to Congress that a department, agency, or other element of the Department of Defense has achieved an unqualified opinion on its full financial statements, the amount available for such department, agency, or element shall be reduced.” The bill further defines the reduction as “for the fiscal year during which such determination is made, by an amount equal to 0.5 percent; and for any subsequent fiscal year during which such determination is made, by an amount equal to

1.0 percent”. While this bill is currently still in committee, if passed, such a reduction would undoubtedly have a profound negative impact on the Army’s flexibility, funding of the warfighter and critical requirements; limiting the Army’s ability to fully meet its mission.

Further, a 20 March 2023 Memorandum from Secretary of the Army indicated the intention to achieve a favorable opinion for the General Fund in 2027. American taxpayers entrust Army as fiscal stewards of resources. While audit deadlines have slipped in the past, going forward, Undersecretary (USA) and Vice Chief of Staff of the Army (VCSA) will hold Army Commanders and leaders accountable to the Army’s audit plans submitted to the Office of the Secretary of Defense (OSD). Per the Campaign Plan FY24, “Achieving the Army’s audit goal is critical as Congress considers financial penalties if DoD/Army continue to miss audit deadlines.”

12. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. This determination will be based upon price analysis as described in FAR 15.404-1(b). As a part of this basis, certified cost or pricing data will not be required in accordance with the exception at FAR 15.403-1(b)(3). This action is a modification to TO W91CRB-18-F-0238.

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13. Contracting Officer Certification: I certify that this justification is accurate and complete

Approval

Based on the foregoing justification, I hereby approve the modification for the Army General Fund Audit Infrastructure Task Order W91CRB-18-F-0238 awarded to ERNST & YOUNG LLP. The total estimated cost is for an additional twelve (12) months for the procurement of Audit infrastructure to support the Army’s annual General Fund Financial Statements audit for Treasury Index (TI) 21 and Army (TI-97). Award is pursuant to Title 41 U.S.C. 4106(c) as implemented by Federal Acquisition Regulation 8.405-6(a)(1)(i)(C), in the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order. Approval is subject to availability of funds and provided that the services herein described have otherwise been authorized for this acquisition.

Senior Procurement Executive