LSJ_FY22 ERMS fully Signed.pdf

LIMITED-SOURCES JUSTIFICATION FOR RESTRICTING CONSIDERATION OF

GSA FEDERAL SUPPLY SCHEDULE VENDORS

in Accordance with FAR 8.405-6 & CAM 1306.70 Electronic Records Management System (ERMS)

1. Identification of the agency and the contracting activity

The Department of Commerce, U.S. Census Bureau (USCB), Acquisition Division on the behalf of the Office of the Director, Policy Coordination Office(PCO), Records Management Branch(RMB), proposes using a Limited Source Justification (LSJ), pursuant to Federal Acquisition Regulation (FAR) 8.405-6(a)(1)(i)(C), Limiting Sources.

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

This is a logical follow-on for an originally competed task order under GSA MAS. The purpose of this procurement is to maintain the current ERMS, and provide optional enhancements, in order to ensure the USCB is compliant with OMB-19-21, Transition to Electronic Environment.

The ERMS is utilized by the USCB, Office of the Director, PCO, RMB and all the record producers throughout the USCB.

3. Description of the Supplies/Services Required

The ERMS serves as an integrated electronic records system and a record management platform where all electronic records repositories share an integrated common interface, or portal, to manage the entire records lifecycle from creation to disposition – including the electronic transfer of the RMB’s records to National Archive and Records Administration (NARA). The United States Census Bureau (USCB), Policy Coordination Office (PCO), Records Management Branch (RMB) is seeking contractor services to operate & maintain (O&M) the current ERMS, and optionally develop, modernize, or enhance (DME) the following functionalities/modules listed below.

• Ability to capture and track disapproved records outside of the BC-75 Form.

• Ability to interface the View360 Repository Module with SharePoint

• Ability to interface the View360 Repository Module with the Share Drives.

• Ability to interface the View360 Repository Module with Web/Social Media.

• Replace ERMS Capstone Email Records System with View360 Records Module.

• Ability to adapt to changes in requirements by National Archive and Records Administration (NARA), Office of Management and Budget (OMB) and the Federal Records Center (FRC).

The Contractor shall support and enhance the ERMS system, which is a COTS product, in the Census AWS Cloud, based on per seat and per record license models, which will require minimum customization to align with this ERMS requirement. RMB is requesting 5 concurrent users license subscriptions. The Contractor shall provide all CLIN’s needed to procure each Optional Records Module Email User License (Per Email Account) and Repository Record Licenses (50,000 Records) throughout all option years. In addition, Census will procure a Database Engineer and an Information Security Expert as Optional CLINs for Operations and https://www.acquisition.gov/content/8405-6-limiting-sources

Maintenance, and procure a System Application Administrator, Helpdesk and Project Manager as Optional CLINs for enhancement Professional Services.

The ERMS must integrate with existing USCB systems. The COTS Electronic Records Management System (ERMS) shall be able to store Capstone Email records and shall allow users to access the retain records from where they are located electronically by RMB’s staff and contractors. The ERMS will serve as a federated record managements environment, portal, where all electronic records repositories share an integrated common interface “platform” to manage the entire records lifecycle from creation to disposition – including the electronic transfer of the USCB’s records to NARA. The Contractor shall provide annual maintenance support, patches, and software upgrades to ensure system stability and security for the software.

Any necessary maintenance to the ERMS must be done at Headquarters or remotely outside of regular business hours 6 AM to 7:00 PM ET and coordinating with the COR and Technical Point of Contacts (TPoCs).

The ERMS resides in USCB Hybrid AWS Cloud environment, hosted on Windows and Linux servers, using PostgreSQL DBs. The Contractor shall ensure that the optional enhancements are installed correctly within the USCB IT environment based on the technical requirements.

The period of performance for this task order is one (1) base year and four (4) option periods and the FAR 52.217-8 Option to Extend Services. The effective date will be the date of Task Order award through September 27, 2023. The option periods will be as follows:

• Option Period 1- September 28, 2023, through September 27, 2024

• Option Period 2- September 28, 2024, through September 27, 2025

• Option Period 3- September 28, 2025, through September 27, 2026

• Option Period 4- September 28, 2026, through September 27, 2027

• FAR 52.217-8 Option to Extend Service: September 28, 2027-March 27, 2028

The total estimated value of this task order is $5,591,604.60.

4. Authority and Supporting Rationale -

The USCB will conduct this acquisition under the authority of the Multiple Award Schedule (MAS) Program. The statutory authority permitting other than full and open competition is 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 Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures.”

Supporting Rationale:

Epik Solutions is currently providing the software license and development of the ERMS under task order number 1333LB21F00000326. This original task order was competed under GSA https://www.acquisition.gov/content/8405-6-limiting-sources

MAS and awarded to Epik Solutions on September 29, 2021. Epik Solutions was the only respondent to the solicitation.

Epik Solutions has spent approximately ten months onboarding, developing, customizing, and seeking approvals for the ERMS solution within their View360 platform. The ERMS solution is planned to ‘go-live’ for USCB on approximately August 15, 2022. The original task order providing this development and deployment is scheduled to end on September 29, 2022. The View 360 solution is proprietary to Epik Solutions.

Market research was conducted to determine if other records management systems exist in the commercial market and can perform the same or similar functions to satisfy the Government’s need, and, if this requirement could be competed amongst small businesses. Market research determined there are multiple small business capable of providing a records management software solution but none that fulfilled all the Government’s requirements without requiring costly customization and add-ons. Awarding this requirement to another source would likely result in unnecessary delays and duplication of costs to the Government and place the Government at risk for not complying with OMB Memorandum M-19-21.

OMB-M-19-21 requires all Federal agencies to manage all records in an electronic format by December 31, 2022. Awarding this requirement to another source would require the Government to start over with the development and customization of a new software solution. This would likely present an unnecessary delay in the Government’s schedule of having a fully functional records management solution in place to comply with OMB M-19-21’s deadline of December 31, 2022.

Based on previous contract history, it is reasonable to expect a new vendor would need approximately one month to onboard staff for the contract and an additional minimum of six months to customize a software solution, test, receive approvals for deployment, provide training on the new solution and deploy said solution. This would result in a minimum of seven months where the Government would be without an electronic records management solution. Not having an electronic records management system places the Government at risk for not meeting implementation requirements of OMB M-19-21.

In addition to the potential schedule delay and risk of noncompliance, the Government would be required to pay for the duplication of efforts already performed by Epik Solutions in development and deployment of their View 360 ERMS solution. Based on market research, the Government would not recover costs already spent in the development and deployment of the current solution if it were to pursue a competition for these same services. It is more efficient for the Government to continue services with Epik Solutions to avoid costly delays in developing and deploying a new electronic records management solution.

For these reasons, it has been determined it is in the Government’s best interest to pursue a logical follow on with Epik Solutions.

5. Contracting Officer Determination of Fair and Reasonable Price

In accordance with FAR 8.404(d) Pricing, GSA has already determined the rates for services offered per semester under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d). Therefore, a comparison will be made to determine if the rates proposed by Epik Solutions align with the rates on their GSA Schedule.

Although GSA has already negotiated fair and reasonable pricing, the Contracting Officer will seek additional discounts before issuing the task order award. In accordance with FAR 8.405- 2(d), the Contracting Officer will determine that the final proposed value of the task order is fair and reasonable. A comparative analysis will be done between the Independent Government Cost Estimate (IGCE), Epik’s proposal to assist in the determination of fair and reasonableness.

6. Market Research

Market Research was conducted to obtain information used in developing requirements, formulating contract structure, identifying commerciality and all qualified concerns, and establishing the best acquisition approach for procuring an ERMS Solution. Market Research was conducted including the following:

• Historical acquisition information

• Personal knowledge in procuring supplies/services of this type

• Review of Government and/or commercial databases for relevant information

• Review of Internet searches.

The Market Research Team reviewed several internet resources for information on mandatory government sources and other sources such as the Federal Supply Schedules (FSSs) and Government-wide Acquisition Contracts (GWACs) available to meet the needs of this ERMS requirement. Although many sites were used in conducting Market Research, the Team found the following sites listed below provided the most relevant information.

• Vendor websites;

• General Services Administration (GSA) MAS IT 518210DC, 518210ERM, and/or 54151S;

• National Institutes of Health (NIH) NITAAC CIO SP3 Small Business Government-wide Acquisitions (GWAC), Chief Information Officer-Solutions and Partners 3 (CIO-SP3) Small Business, Task Area 8, Records/Document Management;

• The National Aeronautics and Space Administration (NASA), Solutions for Enterprise-Wide Procurement (SEWP), Groups B, C, D (small businesses);

• Query of the Governmentwide database of contracts and other procurement instruments intended for use by multiple agencies available at

[https://www.contractdirectory.gov/contractdirectory/] which included the Federal Procurement Data System (FPDS); and

• Beta.SAM.gov.

In accordance with FAR 8.004 Use of Other Sources (as listed below), the Market Research Team reviewed Governmentwide acquisitions contracts (GWAC) and Indefinite Delivery/ Indefinite Quantity (IDIQ) (https://www.contractdirectory.gov/contractdirectory/) and found the supplies and services were available for this requirement under the General Services Administration (GSA)/Multiple Award Schedule (MAS), NASA SEWP V, and NITAAC CIO- SP3 Small Businesses.

The Market Research Team researched the commercial availability and small business capability to provide the ERMS services on GSA eLibrary. The Market Research Team identified the scope of the two GSA MASs that would provide a pool of qualified vendors:

• NAICS 54151S- “Information Technology Professional Services - IT Professional Services and/or labor categories for database planning and design; systems analysis, integration, and design; programming, conversion and implementation support; network services, data/records management, and testing. There are 3,534 small businesses under this category.

• NAICS 518210ERM – “Electronics Records Management Solutions - Electronic Records Management Solutions (ERM) provide a comprehensive capability to solve the complex challenges posed by the movement, manipulation, archiving, security, and management of electronic records. The vendor provides professional management and administrative support personnel with the necessary skills to perform effective record management services for both classified and/or unclassified records. The services are provided using either Government or vendor equipment and facilities or a combination of both. The objective of electronic records management services is to permit the access, maintenance, control, storage, disposition, and transfer of electronic records. Includes any ancillary supplies and/or services necessary to provide a total electronic records management solution.” There are 65 small businesses under this category. The Market research team reviewed the schedules and websites of multiple small businesses and identified three small businesses appearing capable of providing the required services.

One common theme among these three small businesses is the lack of an ‘out of the box’ solution. Each of these companies will have a solution that will require customization, or potential add-ons, and a separate approval from USCB’s IT office to satisfy the RMB requirements.

The current vendor, EPIK Solutions, developed the ERMS Solution under their proprietary software and platform. Also, EPIK included the RMB workflow processes using the Census Bureau Form BC-75, Records Transfer and Disposal Authorization. EPIK Solutions has been https://www.contractdirectory.gov/contractdirectory/ performing the services for the past year at or above the established performance requirements levels. Epik Solutions has spent the last 10 months developing and customizing the ERMS solution within their View360 platform. The ERMS solution is planned to ‘go-live’ for USCB on approximately August 15, 2022. The original task order providing this development and deployment is scheduled to end on September 29, 2022. The View 360 solution is proprietary to Epik Solutions.

Census market research indicates the services can be provided commercially, and, there are small businesses capable of performing the work. Census market research has reaffirmed the requirement and the basis of the IGCE. However, when considering the findings of the market research and determining the appropriate acquisition strategy, the Government must consider the significant risk of switching to a new solution. Awarding this requirement to another source would require the Government to start over with the development and customization of a new software solution. This would likely present an unnecessary delay in the Government’s schedule of having a fully functional records management solution in place to comply with OMB-19-21’s deadline of December 31, 2022, and the Government would not recover costs already spent in the development and deployment of the current solution if it were to pursue a competition for these same services. Based on the Market Research Team’s market research findings and the supporting rationale provided in Section 4 of this document, it has been determined it is in the Government’s best interest to pursue a logical follow on with Epik Solutions.

7. Other Facts Supporting the Justification

N/A

8. Actions to Remove or Overcome Barriers to Competition PCO/RMB is continuously evaluating new technologies and methodologies to support the Records Management Program, while also ensuring that current systems remain operational and accessible. PCO/RMB will include clauses in the task order to protect the Government’s right to own the data provided under performance of this task order to better align the Government for the opportunity to compete this requirement in the future. Prior to a subsequent acquisition, the USCB will seek additional focused market research such as the publication of formal Requests for Information (RFI) via Beta.SAM.gov website. In addition, utilizing the results of the market research the USCB will perform a detailed analysis to develop a detailed timeline, cost estimate and acquisition strategy to remove potential barriers to competition.

9. Technical Certification I certify that the data and information forming the basis for this justification are accurate and complete to the best of my knowledge and belief.

Milicent Alexander Date Program Office Representative Records Management Branch U.S. Census Bureau

10. Contracting Officer Certification I certify that this justification is accurate and complete to the best of my knowledge and belief.

I hereby approve award of the subject contract action due to (specify the circumstance for limiting sources, i.e., FAR 8.405-6(a)(1)(i)(C).

Lauren Withum Date Contracting Officer (CO)

11. Operating Unit Competition Advocate Approval

I have reviewed this justification and determined the rationale presented for issuing the task order as a Limited Sources-Logical Follow on is approved.

Leslie Andrecs Date Operating Unit Competition Advocate