LSJ FY24-00343_Final_09.19.2024.pdf

OPOAM 3008.405-6(a)(2) Limited-Sources Justification (LSJ)

For orders or BPAs exceeding the Simplified Acquisition Threshold

LSJ No: FY24-00343 Page 1 of 6

LSJ No.: FY24-00343

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 Procurement Operations (OPO), Departmental Operations Acquisition Division II (DOAD II) proposes to award an order pursuant to FAR 8.405-6(a), Limiting Sources.

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

DHS/OPO intends to limit the number of sources solicited pursuant to FAR Part 8.405- 6(a) for the procurement of bridge services related to the assessment of internal control support services to Proposed Contractor: Guidehouse, Inc., 1676 International Drive, Suite 800, McLean, Virginia 22102-3600.

3. Description of Supplies/Services.

The requirement is to provide a bridge/continuation of professional services related to internal control support services to ensure: 1) complete and accurate delivery of year end deliverables critical to DHS and United States legislative reporting requirements; 2) sustained implementation of the Office of Management and Budget (OMB) Circular A- 123, including all appendices, internal control program across the DHS enterprise so as to maintain status on the GAO identified high-risk area: Strengthening Department of Homeland Security IT and Financial Management Functions, 3) support of other critical efforts related to risk management for Financial System Modernization, external audit oversight and maintenance specifically related to the planned decommissioning of current platforms and tight schedule for migration and modernization; impact on FY 2025 reporting requirements and legislative compliance; and 4) adequate coverage for a sufficient transition period, as applicable.

Period Timeframe Unit Price Total Price Base 50 Days

(Est. 09/27/2024 – 11/15/2024) N/A $368,008.45

Option 1 30 Days (Est. 11/16/2024 – 12/15/2024)

N/A $256,801.12

Total $624,809.57

4. Authority and supporting rationale.

8.405-6(a)(1)(i)(B) Only one source is capable of providing the supplies or services http://uscode.house.gov/

LSJ No: FY24-00343 Page 2 of 6 required at the level of quality required because the supplies or services are unique or highly specialized.

This acquisition is being 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, in accordance with FAR 8.405-6(a), Limiting Sources. An award will be made pursuant to FAR 8.405-6(a)(1)(i)(B) as 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. The original award was competitively solicited and awarded using the ordering procedures at FAR 8.405. It is necessary to limit competition for new work described herein as services are needed after expiration of the incumbent contract and pending resolution of a protest on the newly awarded task order. The incumbent’s knowledge gained through performance of the original contract could not be transferred to another contractor without a substantial duplication of time and costs.

Rationale:

Due to the nature of the acquisition, the use of the same contractor is required because this order will serve to bridge services of a recently expired order (70RDAD21FC0000105) and a newly awarded order (70RDA224FC0000023) that is currently under protest and a stop work order. An agency’s decision to enter into a voluntary stay of performance during the pendency of a bid protest is not, however, an agreement to entirely forego those services. It is necessary for the agency to enter into a bridge contract to avoid a gap in service. By ensuring a minimal level of critical support by the incumbent contractor, DHS will be able to ensure coverage of critical mission support during the protest period.

The incumbent contractor has extensive knowledge of the complexity of the work and is uniquely positioned to complete the work related to end of year reporting requirements and sustaining progress on high-risk areas and is also uniquely able to complete required work products in a timely manner to satisfy legislative reporting requirements and deadlines. The incumbent’s institutional knowledge and intellectual capital gained through performance of the original contract cannot be transferred to another contractor without a substantial duplication of time and costs.

Bringing in a new contractor would create substantial delays, require considerable lead time to become productive due to the learning curve, require a significant duplication of costs, and would significantly impact the program’s ability to support mandatory internal control support services. The current service provider has over 90 personnel already cleared and supporting DHS as well as over 6 years of specialized experience in supporting the http://uscode.house.gov/

LSJ No: FY24-00343 Page 3 of 6 assessment of internal control support services at DHS Headquarters to specifically include end of year reporting requirements as mandated by legislation and sustained system modernization internal control services. Under the current time constraints, it is not beneficial/cost effective to the Government or DHS to pursue alternate providers, as it would take at least approximately 120 days to sufficiently onboard adequate staff (estimated at 20+ personnel) depending substantially on the ability to leverage pre-existing DHS resources or the requirement to newly clear resources through the DHS background check and clearance process as well as to provision equipment, accesses, licenses, etc., to enable sufficient performance.

Given the limited timeframe of this bridge order, DHS has determined that the estimated duplication of time and costs thus could not be substantially recovered through competition and will result in unacceptable delays in fulfilling the agency’s requirements.

DHS has proposed to maintain only these mission essential elements in the bridge action until the follow-on action, currently awarded under Task Order 70RDA224FC0000023, has been cleared through the GAO protest process and/or appropriate corrective actions have been substantially completed. DHS has determined that it is not necessary to extend the full suite of performance requirements in scope on the prior task order nor all requirements in scope on the new order to continue the immediate mission requirement. As such, only the mission-essential elements of the work statement that must be maintained without a gap in performance have been included in this proposed bridge order. Specifically, DHS will only be completing work associated with the following task areas:

• TASK ONE: Assessments and Corrective Action Planning Support

• TASK TWO: Project Management Support

• TASK THREE: Technical Support

Additionally, work within these three task areas will be limited to only address the critical mission requirements related to the following:

1) The complete, accurate, and timely delivery of fiscal year 2024 year-end deliverables critical to DHS and United States legislative reporting requirements;

2) Sustained implementation of the Office of Management and Budget (OMB) Circular A-123, including all appendices, internal control program across the DHS enterprise so as to maintain status on the GAO identified high-risk area, Strengthening Department of Homeland Security IT and Financial Management Functions;

LSJ No: FY24-00343 Page 4 of 6

3) Support of other critical efforts related to risk management for Financial System Modernization, external audit oversight and maintenance specifically related to the planned decommissioning of current platforms and tight schedule for migration and modernization; and impact on fiscal year 2025 reporting requirements and legislative compliance; and

4) Adequate coverage for a sufficient transition period, as applicable.

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 Task Order to Guidehouse, Inc. for assessment of internal control support 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 procurement will be conducted utilizing procedures found in FAR 8.405-3 Blanket Purchase Agreements (BPAs), to issue a single task order against the Assessment of Internal Control Support Services (AICSS) BPA for the Department of Homeland Security (DHS) Office of the Chief Financial Officer (OCFO) Risk Management and Assurance Division (RM&A). DHS/OPO has already determined that BPA rates are fair and reasonable. Discounts to these BPA rates will be requested. Additionally, prior to issuance of the task order, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific task being ordered in order 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 (IGCE).

6. A description of the market research conducted among schedule holders and the results.

Market research was extensively conducted in 2023 and 2024 as part of the AICSS BPA award competition and the subsequent task order competition. As part of that process, three

(3) primary methods were employed:

1) Acquisition History Review: The reviewer examined the different task orders awarded in the past six years providing the RM&A OCFO division with internal control support services. In addition, the reviewer examined the strategic sourcing vehicles listed under the DHS Strategic Solutions portal to identify/select the specific financial professional services offered.

2) Strategic Sourcing Vehicle Analysis (performed during BPA Market Research):

Under professional services listed under the current the Department’s full list of strategic sourcing vehicles (SSVs) by category, the reviewer evaluated the two possible options, (1) One Acquisition Solution for Integrated Services (OASIS) and (2) the Program Management, Administrative, Clerical and Technical Services II (PACTS II).

3) Review of the GSA Federal Supply Schedule/Multiple Award Schedule (performed during BPA Market Research): The reviewer examined the GSA Federal Supply Schedule/Multiple Award Schedule and GSA eLibrary to identify

LSJ No: FY24-00343 Page 5 of 6 business establishments by the type of economic activity (i.e., North American Industry Classification System (NAICS)) and respective alignment to GSA’s schedule (i.e., Special Item Number (SIN)) and inventory and examine available vendors able to support the work being solicited.

Based on the AICSS BPA Market Research, the review of the RFI responses indicated that there are at least four (4) vendors that could compete for the work as a prime awardee. A review of the GSA MAS indicated that there are six (6) additional other than small business GSA MAS contract holders that may be able to serve as a prime BPA holder. These firms not only provide local services, but they would be able to address the Department and the Component’s needs in accordance with the DHS Financial Accountability Act and OMB Circular A-123 by rapidly deploying a number of experienced personnel to support the requirements.

In June 2024, DHS awarded a Multiple-Award BPA to four (4) vendors. As part of the additional market research conducted for this order, each of the Department of Homeland Security’s AICSS BPAs was reviewed in September 2024 to determine the ability of each BPA holder to provide these required services. Guidehouse, Inc. is the incumbent on the existing order, and it is necessary to extend the services performed under the existing order to limit a break in service, thus allowing sufficient coverage with historical knowledge required to complete mission critical end of year and legislatively mandated external reporting requirements, and if applicable, transition historical knowledge as part of a vendor transition of service support.

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

There are no additional facts to include as part of this justification.

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. Include a statement of actions taken or that will be taken to increase competition for future acquisitions of the same item/service (e.g., the government intends to revise overly restrictive technical specifications, acquire data rights, or pursue some other means to increase future competition).

This requirement has been competitive in the past and most recently a task order was awarded that was competed as a follow-on to the expiring contract with the incumbent (70RDAD21FC0000105). This limited source justification is only required as a bridge while the GAO protest is resolved.

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

10. Technical/Requirements Personnel Certification.

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Limited-Sources Justification (LSJ)

For orders or BPAs exceeding the Simplified Acquisition Threshold

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.

Alyssa Smiley Program Technical Representative

11. Contracting Officer Certification and Approval

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:

Paula Nusbaum Contracting Officer