LSJ Exceeding SAT_082021_Redacted.pdf

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

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LSJ Number: PR Number:

Limited-Sources Justification

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), Office of Contracting (OCON), proposes to issue a modification on contract number GS00Q16AEA1001 order number 70SBUR19F00000243 expected modification number P00016, on behalf of the Office of Information Technology (OIT), Systems Delivery Division (SDD), pursuant to FAR 8.405-6, Limiting Sources.

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

USCIS OCON intends to limit the number of sources solicited pursuant to FAR 8.405-6(a) for the procurement of Salesforce development services from Acumen Solutions Inc., 8280 Greensboro Drive, Suite 400, McLean, Virginia 22102, under their General Services Administration’s (GSA) IT Schedule 70, contract number GS00Q16AEA1001 order number

70SBUR19F00000243.

3. Description of Supplies/Services.

Salesforce Phase 2 completion and the final Phase 3 development services for the STARS OCON Procurement application. This application is replacing OCON’s access database. The new application allows OCON to track procurement actions more efficiently. In addition to the Phase 3 development services, Salesforce dashboard and analytics training services will be provided to OCON’s customers as part of Phase 3.

The following requirements have been completed during Phase 2:

• Complete user stories after those stories have been groomed, delivery commitments from other groups on dependencies have been identified and coordinated, and the product owner has prioritized the stories based on available development capacity. (Completed)

• Provide technical support to OCON MVP and any additional new features and functionality. (Completed)

• Provide ongoing update of user/training guides of new features and changes to the application. (Completed)

• Provide an enhancements notification (showing print screens and necessary info).

(Completed)

• Assist with set-up of new user accounts as needed for the OCON MVP. (Completed)

• Assist with user account maintenance as needed for the OCON MVP. (Completed)

• Assist with system updates pertaining to employee changes (i.e. promotions, changing positions, Program Office reassignments) as needed. (Completed)

• Assist with updates to user profiles and permissions as needed for the OCON MVP.

(Completed)

• Assist with updates to Salesforce standards reports as needed. (Completed)

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• Assist with basic App changes (i.e. adding/removing a field, changing list views) as needed. (Completed)

• Support Salesforce system upgrades and release updates by active monitoring and user support, testing, and work prioritization. (Completed)

• Engage with other OIT teams to troubleshoot and resolve broader service disruption issues that affect multiple applications (e.g., ICAM, DHS OneNet, Network, Office of Chief Procurement Officer (OCPO), etc). (Completed)

• Provide application and platform problem investigation, diagnosis, and resolution.

(Completed)

The following Phase 2 requirements have not yet been completed and are required before advancing to Phase 3:

• Provide system integration enhancements for FFMS based on prioritization and capacity.

(Not Completed)

• Support integration with FFMS pending dependencies on commitment from other groups.

(Not Completed)

• Support OCPO PRISM integration enhancements on any existing extract updates to the archiving process and data delta processes. (Partially completed. Data Delta processes have not been completed.)

Upon completion of the remaining processes within Phase 2, the contractor can now move on to Phase 3 and completion of the application requirement. The following Phase 3 processes are essential to completion of the project and fulfilling the need of the requirement:

• Finish Phase 2 stories in the backlog after DHS OCPO resolves outstanding tickets.

• Provide user experience upgrades/changes. These potential upgrades can be substantive.

Once users have hands on experience with the application there can be major User Interface (UI) or User Experience (UX) changes which will not be considered standard Operations and Maintenance (O&M) but rather an enhancement.

• Ensure Automation and integration with the following:

o Contractor Performance Assessment Reporting System (CPARS) o Federal Financial Management System (FFMS) o ServiceNow (SNOW)

• Additional Operational Status Reports and Tableau CRM, formerly Einstein Analytics, reporting.

• Develop forward facing customer dashboards and analytics reporting

• Add pre-PALT calculator and procurement package tracking and CLIN level data

• Training:

o Provide dashboard and analytics training to OCON’s customer users.

o Provide end user training and new-hire training to OCON trainers.

o Provide additional administrator training for Salesforce and Tableau CRM, specifically on the OCON App (not general Salesforce training).

These tasks will be supported via a Labor Hour CLIN with an estimated value of The period of performance is September 1, 2021 to August 31, 2022.

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4. Authority and supporting rationale.

This acquisition is conducted under the authority of Multiple-Award Schedule Program, 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), the circumstance that justifies limiting sources to fewer than those required by FAR 8.405-1 and 8.405-2 is:

☒ 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.

Rationale:

Only one source (Acumen) is capable of providing the services required at the level of quality required because the services are unique and highly specialized. It is necssary to continue the development for the next 12 months to complete phase 3 of these non-severable development services so that we can transition to the Operations and Maintenance (O&M) stage. Acumen has been satisfactorily performing the OCON development services since October 2019 and the development team is actively working on completing OCON’s Phase 2 of the procurement application. However, due to the data not being controlled by USCIS and owned by DHS OCPO and ICE (FFMS) has added additional complexity and numerous blockers outside of the vendors control and overall this project has been delayed. OCPO is currently in the process of adding resources to commit to USCIS. The ICE FFMS blocker has been removed as OIT DBIS team now has access to all the FFMS data required to complete the FFMS Integration. Based on the complexities involved with this project and the application development, it is not in the Governement’s best interest to work with another contractor at this time. The current contractor understands these complexities and has developed the processes and the user stories still unresolved, the time and effort to bring a new contractor on board to finish this final phase would outweigh the remaining time the contractor needs to get familiar with and complete this requirement. As these services are non-severable, continuation of Phase 2 and completion of Phase 3 are necessary for completion of the entire project and the Government’s benefit. Due to the delays and complexities identified above, the project is at a critical stage of completion and continuing with the knowledge and expertise of the current contractor will maintain the integrity of the project. Allowing another contractor to finish Phases 2 and 3 would introduce too many risks, including additional delays to the schedule and increased cost beyond what is currently needed to finish this project. Considerable time and effort would alse be necessary to introduce a new contractor and team to the complexities and progress thus far on this requirement which is in it is final stages.

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 modifying the proposed task order (70SBUR19F00000243) for the OCON development work represents the best value and will result in the lowest overall cost, considering price and administrative costs to meet the Government’s needs. This order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.” The General Services Administration (GSA) has already negotiated fair and

LSJ No: Page 4 of 5 reasonable pricing rates. We expect the proposed rates to be consistent with the existing rates of the task order and IAW FAR 8.405-4 discounts will be requested. Additionally, prior to issuance of the modification, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific task being ordered to determine that the total price is reasonable. The contractor’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate.

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 is required by FAR Part 10 and HSAM 3010, and the DHS Market Research Guide. Market Research was conducted, and the results show that Acumen is the only source that can meet the agency’ needs at this time at the level of quality required due to the necessary continuation of the services described in Sections 3 and 4. Additionally, the agency would need to spend funds to cover the transition costs if the new contractor was introduced to the requirement and potentially also incur costs related to the project delays. Therefore, it is expected that the agency will save a significant amount of money by going directly to Acumen. Market research shows that there are other capable vendors on the GSA Salesforce Implementation, Integration, and Support Services (SIISS) Blanket Purchase Agreement (BPA) but, in addition to the cost savings mentioned above, it is in our best interest to issue this modification to the current vendor due to the complexity of the development work, knowledge transfer, and cleared contractor staff already involved in the project.

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

There are no additional facts.

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

The government plans to end the STARS order, 70SBUR19F00000243 when Phases 2 and 3 are completed and award a new competitive task order in approximately one year (new effort is titled EPIC). This will be a natural stage for handoff from one contractor to another. To prevent delays and overburn from occurring on the Phase 3 development, the contracting officer will include a specific deliverable with a timeline for the completion of Phase 3.

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

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10. Technical/Requirements Personnel Certification.

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

11. Contracting Officer Certification

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

APPROVAL: Pursuant to FAR 8.405-6(c)(2)(xi), I hereby determine the circumstance identified in Section 4 applies.