LSJ EC America.pdf

Limited-Sources Justification (LSJ) For orders or BPAs exceeding the Simplified Acquisition Threshold

LSJ No: FY22-055

LSJ No.: FY22-055

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Office of the Chief Procurement Officer (OCPO), Oversight and Systems Support (OSS), Acquisition Systems Branch (ASB) and DHS Office of Procurement Operations (OPO), Information Technology Acquisition Center (ITAC) propose to award a limited sources Blanket Purchase Agreement (BPA) to EC America Inc. This document serves as a Limited Sources Justification pursuant to Federal Acquisition Regulation (FAR) 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 Multiple Award Schedule order provided that the original order was placed in accordance with the applicable Multiple Award Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

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

OPO intends to award a limited source BPA consisting of a one-year base period of performance and two one-year option periods to obtain cloud-based records storage solution and services required to operate and maintain the DHS Electronic Contract Filing System (ECFS) in an unclassified environment. The limited source BPA will be awarded to the incumbent contractor:

EC America 8444 West Park Drive, Suite 200 McLean, VA 22102

3. Description of Supplies/Services.

DHS seeks to continue to operate and maintain its current ECFS leveraging a cloud-based Software-as-a Service (SaaS) solution that is Federal Risk Authorization Management program (FedRAMP) authorized. DHS requires a DoD 5015.2 compliant electronic Commercial-Off-The-Shelf (COTS) solution to support electronic contract file storage, workflow, document management, and records management. This information technology (IT) requirement also includes services required to plan, develop, test, train, secure, implement, operate, and maintain the current ECFS. OCPO Acquisition Workforce Systems and Support (AWSS), ASB, is overseeing the ECFS effort.

The independent government cost estimate (IGCE) for this requirement is below.

http://uscode.house.gov/

Period of Performance Estimated Cost Base Period (1 year): $2.13 M Option Period 1 (1 year): $2.19 M Option Period 2 (1 year): $2.24 M

Total Estimated Contract Value: $6.56 M

4. Authority and supporting rationale.

DHS/OPO intends establish a BPA through the Multiple Award Schedule Program under the authority of 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies. Pursuant to FAR 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 Multiple Award Schedule order provided that the original order was placed in accordance with the applicable Multiple Award Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources.

The current ECFS BPA was competitively awarded in September 2017 and the work started immediately thereafter to prepare DHS for the implementation of the solution. DHS required that the solution have a current Federal Risk Authorization Management Program (FedRAMP) authorization. Although the ECFS solution held an agency FedRAMP authorization, a further detailed review of the authorization by the DHS Chief Information Security Officer (OCISO) determined that a complete IT Security Assessment would be required in order for ECFS to attain an Authority to Operate (ATO). The planning and preparation phases to implement the solution took approximately one year. During that timeframe, ASB worked with the contractor to attain the ATO, which took two years to complete. DHS began a rolling implementation starting in January 2020 with all components using ECFS by April 2020.

The current competitive awarded BPA’s ordering period ends in September 2022. Awarding a limited source logical follow-on BPA will allow DHS uninterrupted ECFS support and provide sufficient time for a new competition, an ATO in the event a new software solution is selected, and transition support. The new ECFS competition will be initiated in October 2022.

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

The Contracting Officer has determined that issuing the proposed BPA to EC America Inc for the ECFS solution and associated services represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs. This BPA will be placed in accordance with FAR 8.404, “Use of Multiple Award Schedules.” The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates. Discounts to these GSA schedule rates will be requested.

ANTOINETTE.CLAY

Sticky Note to

ANTOINETTE.CLAY

Sticky Note

HSHQDC-17-A-00026

Additionally, prior to issuance of orders under the BPA, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific tasks being requested in order to determine that the price is reasonable. The contractor’s labor mix and level of effort will also be compared to the 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.

Market research was conducted from November 2020 to May 2022. ASB had one-on-one meetings with schedule holders between November 2020 and May 2022. In April 2022, ASB reviewed electronic filing solutions that had attained both agency and Joint Authorization Board FedRAMP authorizations on the FedRAMP.gov website. Finally, ASB reviewed the most current Gartner Magic Quadrant Report for for Content Services Platforms (dated October 2021), and the Forrester Wave report for Content Platforms (dated June 14, 2021). A total of 27 solutions were reviewed. Of the 27 solutions, four had the core functionality required for ECFS, were DOD 5015.2 compliant, and had either an approved agency FedRAMP authorization or one that was “in progress.” Although an agency FedRAMP authorization may reduce the level of effort required for DHS to grant a solution an Authority to Operate, there is still a significant amount of work required. Solutions that are not compliant with DoD 5015.2 could meet the compliant requirement through the addition of a records management software solution. Licenses for the solutions are available on GSA Schedule.

Product Licenses

Available on

GSA

schedule

FedRAMP 5015.2 Compliant

Hyland Alfresco

Yes Agency in process Yes

Opentext Yes Agency in process Yes Laserfiche Yes Agency – part of

ECFS

Yes

AINS eCase Yes Agency – part of

ECFS

Yes, when integrated with Laserfiche

Software providers that don’t currently have a FedRAMP certification could work with DHS to get certified, but it would take a significant amount of DHS resources to complete the work. The Authority To Operate (ATO) that is currently in place for ECFS took two years to complete. The proposed limited source action allows the necessary time for a new competition, an ATO in the event a new software solution is selected, and transition support.

7. Any other facts supporting the limited-sources justification.

ANTOINETTE.CLAY

Cross-Out

There are no additional facts supporting the LSJ.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made.

At the end of the ordering period for this planned limited source logical follow-on BPA, DHS plans to have a new competitively awarded ECFS procurement. DHS will monitor system usage and data quality to help facilitate any future transition to a new solution. Throughout the course of the logical follow-on BPA’s ordering period, DHS will conduct further market research to identify other sources and software solutions capable of meeting the ECFS requirements. DHS will use the information learned from the market research and past experience to structure the subsequent competitive procurement. The new ECFS competition will be initiated in October 2022.

9. DHS intends to post this requirement on SAM.gov pursuant to FAR 8.405-6(a)(2)(i).

10. Technical/Requirements Personnel Certification.

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum needs and that the supporting data, which form a basis for the Limited-Source Justification, are accurate and complete.

Technical Representative/Contracting Officer Representative (COR)

11. Contracting Officer Certification

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Source Justification is accurate and complete to the best of my knowledge and belief:

Contracting Officer

12. Approval.

Pursuant to FAR 8.405-6(c)(2)(xi), I hereby determine that the circumstance in FAR 8.405- 6(a)(1)(i)(C) applies.

Procuring Activity Advocate for Competition, or designee