LSJ CRI Security Services - Executed.pdf

CONTRACT NO.: 9531CB20F00XX

LIMITED SOURCES JUSTIFICATION

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

1.0 Agency and Office Name: Consumer Financial Protection Bureau, Office of Security

Programs (OSP).

2.0 Nature and/or description of the action being approved. Under Blanket Purchase Agreement (BPA)# CFP-14-Z-00012, CFPB has contracted with Communication Resources Incorporated (CRI) to provide Security Consulting and Physical Access Control System (PACS) and Integration/Installation Services. The present BPA has two active BPA Calls due to expire in August 2020. The BPA expired on September 29, 2019;

therefore, no new BPA Calls can be issued to complete the PACS installation. CFPB has a continued need for the services currently being provided. The CFPB intends to award a task order to Communication Resources Incorporated for access control installation and services based on a Limited Sources Justification in the interest of economy and efficiency as a logical follow-on to an original Federal Supply Schedule order.

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

While a few calls are still being utilized, the BPA has expired and therefore no new calls can be issued, and the last two current calls are unable to address several reprioritized and time sensitive initiatives resulting from various threats of nation states. The additional work being sought will serve to strengthen PIV utilization, validation, and accountability.

The services to be provided under this Limited Sources Justification include PACS enhancement for certification validation for physical access, the addition of electronic security systems at regional offices, and consultative support for the Office of Security Programs (OSP) to takeover of identification sponsorship/on-boarding including HSPD- 12 card issuance procedural documentation. The Bureau anticipates needing a task order of approximately twelve (12) months to complete the installation of the PACS for the regional offices and to allow transition of PACS support to a new contractor through a new contract competition.

The new systems required in the field offices have required reprioritization as result of resent network threats and the current Corona virus. The expanded field office capabilities, which are a Director priority, will facilitate capabilities to control and report access to facilities that will allow contact tracing and facility cleaning strategies to be applied based

2 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552 on actual facility occupancy should there be a resurgence of cases in the Corona virus pandemic. The total estimated value of these services is $631,442.25 for a twelve -month GSA Limited Sources Order.

4.0 (a) Authority and supporting rational. The CFPB intends to award a task order to CRI for access control services based on a Limited Sources Justification. FAR Part 8.405-6 (a)

(1) (i) (C) permits the placement of orders for new work using limited sources in the interest of economy and efficiency as a logical follow-on to an original Federal Supply Schedule order, provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures, and it makes sense to do so taking into consideration the relevant factors. The original order was competitively placed under the authority of the Multiple-Award Schedule Program, FAR Part 8.405. The original order was not previously issued under sole-source or limited-sources procedures, but competed amongst eight vendors, on the General Services Administration Schedule 70 and the GSA Schedule 84 SIN 246-60-1 Security Systems Integration and Design Services, who had passed the HSPD-12 certification approved by GSA for System Integration Services and Products.

In terms of economy and efficiency, further solicitation of this work would present a substantial increased cost and risk as a result of delays and rework of tasks that could be required by the Bureau selecting a new contractor with limited system and agency familiarity coupled with the critical and time sensitive work required at the commencement of this task order award. These costs would not be expected to be recovered through competition. CRI designed, piloted, and installed the current Physical Access Control System in CFPB facilities at HQ and San Francisco along with other integrated systems.

The field offices must be equipped with compatible systems that meet system Authority To Operate (ATO) to provide similar levels of security and integrate. CRI has an in-depth knowledge of not only the systems and its integrations but with the Bureau’s processes required for FISMA ATO. CRI’s knowledge will be critical in cost savings while efficiently installing security systems in the field offices that will allow them all to function cohesively under a singular nationwide PACS. The security system installation and integration in the field offices will be completed with less cost and time as there will be no learning curve for CRI. CRI is a Woman-Owned Small Business and has in-depth knowledge of the specifics of the Bureau’s system, and processes which provide efficiencies and economic advantages in order to complete time sensitive initiatives.

4.0 (b) Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited. Not Applicable.

5.0 A determination by the ordering activity contracting officer that the order represents the

3 CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552 best value consistent with 8.404(d). Per FAR 8.404(d), GSA has already determined the 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 also compare current labor hourly rates currently offered to the Bureau under BPA CFP-14-Z-00012 to further substantiate that the price proposed is fair and reasonable. The ordering activity will evaluate the quotation received by CRI to determine if the total price is reasonable. The cost of $631,442.25 is therefore determined to be fair and reasonable by the Contracting Officer.

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. Market research was not performed as this requirement is for additional work to be performed by CRI. Please see Section 4.0 above.

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 GSA under limited sources.

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 is preparing a recompete of the security services contract that will be awarded prior to the completion of the requested logical follow-on contract. Once this additional work is completed by CRI, any contractor will then be able to continue support of the PACS system on behalf of the Bureau. Further the Government will continue to conduct market research and use FedBizOpps, if applicable, to find and solicit other qualified venders 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.

http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/05.htm#P55_9276 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/05.htm#P66_10435

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

Name: John M. Starr Title: Physical Security Specialist

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 (all actions)

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

Joshua Galicki Competition Advocate