LSJ for HUD GFAS 6-Month Bridge Transition Supp_ID11210033_AllSigs_20210608.pdf

Limited Sources Justification

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification”.

Customer Agency: U.S. Department of Housing Urban Development (HUD), Government National

Mortgage Association (Ginnie Mae), Office of Chief Financial Officer

Contracting Activity: General Services Administration, Federal Acquisition Service, National Capital

Region (NCR)

Document Identification: Limited-Sources Justification (LSJ)

2. Nature and Description of the Action Being Approved.

This LSJ is for the issuance of a firm-fixed-price (FFP) task order to provide for transition and minimal continuity services of Ginnie Mae’s Financial and Accounting Systems (GFAS) support. The preparation and approval of this LSJ, in accordance with FAR 8.405-6(a)(1)(i)(B), justifies the action based on

Deloitte & Touche LLP (Deloitte) being the only one source capable of continuing to perform the services provided by the previous task order and any transition services required at the level of quality required because Deloitte possesses the knowledge and experience from 5 years of related GFAS support. The task order requirement is vital to the success of Ginnie Mae and its systems. The task order will be used as a bridge for 6 months commencing June 26, 2021 through December 25, 2021.

3. Description of services required to meet the agency’s needs including estimated value).

GFAS maintains the general ledger (accounting and financial records) for Ginnie Mae which guarantees privately issued securities backed by pools of mortgages insured or guaranteed by the Federal Housing

Administration, the Department of Veterans Affairs, the Rural Housing Service of the Department of

Agriculture (RHS), or HUD's Native American Program. GFAS is currently running on the PeopleSoft version 9.2 applications that tracks, records, and reports on the agency's financial and accounting information. Ginnie Mae utilizes the GFAS PeopleSoft tool to process and track commitments, obligations, revenues, and payments. GFAS supports automation, financial reporting, and fiscal management of agency resources. The current systems facilitate reporting to external stakeholders, such as the Office of Management and Budget, U.S. Department of Treasury (Treasury), the Government

Accounting Office, as well as other regulatory bodies. Ginnie Mae requires uninterrupted, seamless support of its GFAS services in order to perform systems budget formulation, reporting, integration, triannual reporting, OMB circulars financial requirements, and other financial and accounting system related activities to ensure continued mortgage and housing services across the United States.

The critical capabilities of the GFAS services are multi-tiered and highly complex financial and accounting systems that require real-time reporting that is often measured by data across other systems and reporting tools. The incumbent Contractor, Deloitte, has been performing GFAS support for the past

5.5 years as commercial-off-the-shelf services under the legacy Financial and Business Solutions (FABS)

Schedule 520. Ginnie Mae's OCFO operates with a limited number of staff, in which full GFAS support is needed for the various financial and accounting systems. The incumbent is considered the only source capable of providing these services at the level required and, should transition services be necessary, transferring such institutional knowledge. Ginnie Mae requires a contractor with immediate systems access and experience to provide services within the timeframe needed, without any disruption to the current financial and accounting activities being performed. The 6-month task order for GFAS support will offer Ginne Mae a comprehensive approach in maintaining systems operations, transfer of systems support, and financial and accounting activities efficiently, without interruption that offers unparalleled quickness, effortlessness, and steadfastness in the familiarity and satisfactorily performance of Ginnie

DocuSign Envelope ID: CD2223FB-F981-4CF5-874D-B77F7071BA81

Mae’s current financial and accounting systems.

4. The authority and supporting rationale (see 8.405-6(a) (1)(i)) and (b)(1)) and if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the requirement supply and service.

This action is taken under the authority of FAR 8.405-6(a)(1)(i)(B) which permits an agency to limit sources when “[o]nly 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.” With consideration to both uniqueness and specialization, the multifaceted financial and accounting IT systems that are used by

Ginnie Mae require a distinctive, concentrated level of understanding, selective accessibility, and mission-critical knowledge to operate in the systems (GFAS) environment. Moreover, these services must encompass on-going and annual compliance requirements established by the Federal Information Systems

Management Act, as well as National Institute of Standards and Technology. The current PeopleSoft system (version 9.2) that was upgraded and routinely enhanced by the incumbent is considered a more sophisticated system having premium functions that will require institutional expertise to train and transition. Deloitte is the only Contractor that was responsible for the systems migration and upgrade, has the historical experience and familiarity with the systems, its functions and reporting cycles, and operational knowledge of the new Ginnie Mae financial and accounting systems environment. Moreover, Deloitte provides the most efficient manner for transitioning GFAS support to the Government and the new awardee, as applicable, in terms of cost and time, as a competitive requirement would not yield further cost-savings and may delay the agency’s mission of timely transitioning services without disruption in operations.

GSA is currently competing the successor task order and intends to make an award in the next month. The services covered by this task order will be necessary even if the incumbent Contractor is awarded the successor task order.

5. A determination by the ordering activity Contracting Officer that the order represents the best value consistent with 8.404(d).

Pursuant to FAR 8.404(d), the Contracting Officer finds that the order represents the best value to the government. GSA has already determined the prices of the supplies and services under Federal Supply

Schedule (FSS) contracts, including rates for services offered at fixed hourly rates, to be fair and reasonable at the master contract level. The proposed labor rates will be verified to confirm they do not exceed the Schedule rates. The level of effort and the mix of labor determines the total price as being reasonable for the effort. The Government seeks additional discounts off of the established fixed hourly rates under the Schedule prior to placing orders. The Government is confident a 6-month bridge (task order) to the incumbent will represent the overall best value based on timing, cost-savings, and highly specialized expertise acquired.

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.

In accordance with FAR 10.002(b)(2), the techniques used in conducting market research included, 1) contacting knowledgeable individuals in Government regarding market capabilities and available sources to meeting the requirements, 2) reviewing the results of recent market research undertaken to meet similar or identical requirements, and 3) querying Government and commercial databases that provided relevant information to this acquisition. Several of Ginnie Mae’s current GFAS integrated product team (IPT) members were contacted to obtain information in which the consensus was that only a large business that has been engrossed and intimately involved in the current GFAS environment would have the capability and resources to successfully support and transition the current systems support to the Government and new awardee, as applicable. A review of the current RFI (#1450901) released on October 13, 2020 yielded 9 interested sources, small (SBs) and other than small businesses (OTSBs), of which the evaluating team determined the only capable sources were OTSBs based on company resources, complexity, magnitude, and established experience. A review of the GSA contracting system (ASSIST) for similar acquisitions, it was noted that this work has been performed by the incumbent (satisfactorily or higher) or OTSBs previously, in which highly qualified, skilled laborers that have the working knowledge of what needs to be transferred/transitioned timely is imperative. Customarily, transition services are often obtained from the incumbent to the new awardee, and therefore, to compete the services for transitioning support only would be detrimental to Ginnie Mae in potentially failing to obtain vital information known by the incumbent to support the GFAS environments operations successfully. A review of the historical procurement yielded that the incumbent has been performing the services for a period more than 5 years, having embedded knowledge and experience in all aspects of the new GFAS environment.

7. Any other facts supporting the justification.

Should Ginnie Mae’s acquisition be performed through a competitive process, the delay in a full competition may result in disruption of Ginnie Mae’s mandated financial reporting, substantial duplication of costs to the Government not expected to be recovered through competition, and unacceptable delays in the transition of this service. A competitive acquisition would be quite labor intensive for a timely award by end of June, and significantly more costly with consideration to training another source for transitioning unfamiliar systems and operations, as well as the number of procurement man hours required for fully competing the effort; noting there would not be a guarantee of a timely award avoiding disruption of GFAS services. A task order award to potentially a new Contractor would require additional costs because of the need to invest significant resources to both a competitive award and ramp up of training on the new GFAS environment for transitioning. The viability of GFAS to continue being supported throughout the transition is critical to avoid disruption in Government operations, its personnel, and mission goals. It is reasonable to expect that an effort to compensate for the inefficiencies, potential delays, and risks described above are realized under this justification to warrant the need for limiting sources in an effort to ensure the Government’s needs are met in a manner of specialized support and timeliness.

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

The transition (phase-out) services conclude the final activities required for GFAS support. In future acquisitions where transition support is necessary, the Government will closely monitor the schedule of milestones established that may cross into timing needed to perform transition services and adjust the timeline accordingly. Planned transition timing will be aggressively pursued to avoid restricting competition.

9. Technical/Requirements Personnel Certification

I hereby certify that the supporting data which form the basis of this justification is accurate and complete.

Mignon Stephens

Project Manager

GSA/FAS/NCR/AAS

10. Contracting Activity Certification

I hereby certify that this justification for GFAS services is accurate and complete to the best of my knowledge and belief.

Prepared and Concurred By:

Anethra Facione

Contracting Officer

GSA/FAS/NCR/COD

Reviewed By:

Dennis Harrison

Deputy Director, Contracting Operations Division

GSA/FAS/ NCR/COD

Based on the foregoing justification, I hereby approve the limited source justification on behalf of the

General Service Administration in its pursuit of a 6-month bridge order to Deloitte & Touche for the

GFAS Transition services.

Approved By:

Stacy Williams

Competition Advocate

GSA/FAS/NCR/AOD