LSJ for FAR 8.4 - 70Z02320FMMZ40100 - READACTED.pdf

Task Order # 70Z02320FMMZ40100

Limited-Sources Justification

Pursuant to the authority of § 201 of the Multiple-Award Schedule Program 41 U.S.C. § 251, this justification is prepared in accordance with the requirements of Federal Acquisition Regulation (FAR) 8.405-6(c) for the use of sources limited to fewer than those required in FAR §§ 8.405- 1;8.405-2; and 8.405-3. The circumstances justifying restriction satisfy the requirements of FAR § 8.405-6(a)(1)(i)(C) as set forth in the following facts and rationale:

(1) Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), proposes to extend performance of an already established GSA Schedule Task Order through utilization of FAR Clause 52.217-8 (Option to Extend Services), on the basis of a limited-sources justification.

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

(a) Nature of action: USCG intends to limit competition through extension of the already established Bridge Task Order # 70Z02320FMMZ40100 via FAR Clause 52.217-8.

(b) Name and address of the contractor: Exceed Corporation; 8100 Professional

Place; Hyattsville, MD 20785

(c) Contract type: Firm-Fixed-Price

(d) Estimated total value:

Period Unit Price Total

Option Period extension under

FAR 52.217-8

Note: The services under this justification were recently awarded under another Task Order:

(e) Type of funding: Operations and support funds

(f) Year of funding: Fiscal Year 2020

(g) Solicitation number: 70Z02320QMMZ11100

(h) Background information about the requirement:

This procurement was solicited as a Total Small Business Set-aside under GSA Schedule 874-7/Multiple Award Schedule(MAS). The result was a competitive procurement the award of which has been subject to a GAO Protest.

(3) Description of Supplies/Services.

This proposed action is a short-term Firm-Fixed Price (FFP) Task Order for on-site technical and administrative support services for the USCG’s National Maritime Center (NMC) Contact Center located in Martinsburg, WV. The Contractor shall support Mariner credential evaluation/issuance application status, clarification on medical waiver, safety and suitability determinations, provide answers about mariner application processes, mariner training and assessments, and schedule exam appointments.

(4) Identification of the justification and the rationale.

In accordance with FAR Part 8.405-6(a)(1)(i)(C), in the interest of economy and efficiency, this effort is a logical follow-on to an original FSS order that was placed in accordance with applicable FSS ordering procedures under full and open competition. The incumbent Task Order # HSCG23-15-F-MMZ022 expired on 6/19/2020. Sufficient time was needed to accommodate the re-compete solicitation that was issued. Accordingly, a follow-on 2-month Task Order was issued to bridge performance during the evaluation and award of the re-compete solicitation. As a result of the award on the re-compete solicitation, further extension of the 2-month Task Order is required to allow for sufficient time to resolve a GAO Protest. Therefore, in the interest of economy and efficiency and to provide sufficient time to resolve the GAO Protest, extension of this Bridge Task Order under FAR Clause 52.217-8 (Option to Extend Services) is warranted.

The mission of the USCG NMC is to issue Merchant Mariner Credentials (MMCs) to fully qualified mariners. The Incumbent has provided the requisite subject Contact Center technical and administrative support services since June 2015. This effort is not conducive to service or scripts for an automated voice response system, relying significantly on Contractor knowledge of underlying Mission Management System (MMS) Documentation, and applicable business processes associated with the Mariner Credentialing Program (MCP) to address a wide-array of customer inquiries. Knowledgeable Contractor/service providers are difficult to recruit due to the specialized nature of the MCP.

While there are other companies available that can perform the type of support services needed here, no other sources would be able to operate with the same type of efficiency and effectiveness as is needed under this extension time period, as they would have to acquire a significant amount of institutional knowledge and gain a thorough understanding of the MMS Documentation and MCP in a short period of time to provide the quality of service required.

Furthermore, a gap in service would be extremely detrimental. The MCP provides MMCs to fully qualified mariners, who rely heavily on the assistance of the Contact Center to navigate the process: the Contact Center responds to up to 34,000 contact per month, ranging from calls, voicemails, chats/tickets, e-mails, and mailed mariner applications. Failure to provide MMCs to mariners would compromise USCG missions and International Conventions as the MMC is documentation required for all crew members of U.S. ships weighing over 100 tons, including commercial shipping container vessels.

(5) Determination by the ordering activity Contracting Officer that the anticipated extension represents the best value consistent with 8.404(d).

The Contracting Officer has determined that issuing the proposed extension to the subject task order to Exceed Corporation to continue this effort represents the best value and will result in the lowest overall cost alternative, considering price and administrative costs, to meet the Government’s needs. This extension will be placed in accordance with FAR Clause 52.217-8 and under an already existent FAR Part 8.4 Task Order. General Services Administration has already negotiated fair and reasonable pricing. The contracting officer has considered the level of effort and the mix of skills available for the tasks needed that the proposed extension represents a reasonable total price and will be the best value for the department.

(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.

Extensive market research was conducted among GSA Schedule holders prior to issuance of the re-compete Task Order solicitation. Following the market research, a new, long-term re-compete Task Order was competed as a Total Small Business set-aside solicitation under GSA Schedule SIN 874-7 – garnering responses from many interested schedule holders. However, the result of the award for that re-compete solicitation was subject to a GAO Protest. To allow for sufficient time for resolution of said GAO Protest, and in the interest of economy and efficiency, the extension of the Bridge Task Order with the incumbent Contractor is needed to prevent a gap in mission-critical service.

(7) Any other facts supporting the justification.

The Contracting Officer has determined that issuing an extension to this Task Order will be the lowest risk to the Government. Extending Exceed’s established GSA Schedule Bridge Task Order eliminates duplicative costs that would not be recouped through issuance of another Task Order, while also providing for sufficient time to resolve the GAO Protest and maintain mission-critical performance.

(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that preclude the agency from meeting the requirements of 8.405-1 and 8.405-2 before any subsequent acquisition for the supplies or services is made.

A re-compete effort has already been issued and awarded, removing barriers to and allowing for competition for the acquisition of this service. The award of the re-compete that follows this extension was competed as a Total Small Business set-aside under GSA Schedule 874-7.

(9) Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Name Date Contracting Officer

(10) Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Name Date Technical Representative/COR

APPROVAL:

Final approver if not exceeding $700K Date Name Contracting Officer

STURMAN.SHERRY.L.150286

Digitally signed by

STURMAN.SHERRY.L.1502864781

Date: 2020.08.17 19:34:28 -04'00'

PAULO.WENDY.LY

NNE.1369635448

Digitally signed by

PAULO.WENDY.LYNNE.1369635448

Date: 2020.08.18 08:38:34 -04'00'

PAULO.WENDY.LYNN

E.1369635448

Digitally signed by

PAULO.WENDY.LYNNE.1369635448

Date: 2020.08.20 11:15:54 -04'00'