LSJ - IT Governance Bridge - Solicitation 1605DC-19-Q-00065_Redacted.pdf

LIMITED SOURCE JUSTIFICATION

FAR Part 8.405-6(a)(l) (B)

Sole Source

1. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY

Contracting Activity Department of Labor

OASAM/OPS

200 Constitution A venue, NW Washington, DC 20210

Customer Agency Department of Labor

OASAM/OCIO

200 Constitution A venue, NW Washington, DC 20210

2. NATURE AND DESRIPTION OF THE ACTION BEING APPROVED:

This Limited Source Justification and Approval authorizes and approves the issuance of an order to Oxford Government Consulting, LLC, 616 Walnut Avenue, North Beach, MD 20714 to procure support of the IT governance activities within the Department of Labor (DOL) Office of the Chief Information Officer (OCIO) and to maintain continuity of critical operations while a long-term solution is implemented.

3. A DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET THE

AGENCY'S NEEDS (Including the Estimated Value):

OCIO requires services in support ofDOL's IT governance initiatives. This service will continue to support by providing the following:

Program and Project Management Support including the development and tracking of all program support documentation as defined by the DOL IT governance framework and Office of Management and Budget (0MB), to include: System Development Life Cycle (SDLC) Methodology, Capital Planning, Enterprise Architecture (EA), and Information Security.

IT Strategic Business Management Support for DOL to deliver on its goals to enhance the alignment between agency strategic business goals and operating plans, and Department-wide goals and initiatives.

IT Strategic Planning Support to ensure the IT business mission needs of the agencies are well documented and drive IT planning efforts at DOL.

Business Analysis Support to assist programs with mapping their existing business processes, analyzing workflows, identifying alternative approaches to improve efficiencies, and implementing changes when required which would, when necessary, include the development of a systematic approach to handling organizational change, both from the perspective of an organization as a whole and on the individual level.

Life Cycle Management Support in the efficient and effective modernization of the SDLC Manual and framework for an overall Life Cycle Management approach.

IT Investment Management Support for CPIC (Capital Planning and Investment Control) services in the areas of IT portfolio management and 0MB Exhibit 53 and 300 submissions, IT investment analysis and control, Earned Value Management, IT investment management process improvement, and eCPIC system support and operations.

Governance Support assisting in the development, production, and execution management of DOL's IT investment management governance framework, to include the DOL SDLC Manual, Capital Planning guidelines and directives, IT Security guidelines and directives, and Enterprise Architecture guidelines and directives. This includes all necessary documentation, facilitation, and coordination of governance activities.

Information Compliance Management Support for DOL management of public information collections needing Office of Management and Budget approval under the Paperwork Reduction Act (PRA) and internal collections necessary to meet Departmental business requirements.

The Independent Government Cost Estimate for this requirement is . The period of performance (POP) shall be for one (1) 6-month base period and two (2) 3-month option periods.

4. IDENTIFICATION OF THE AUTHORITY AND RATIONALE:

This work is a logical follow-on to an original order placed under a Federal Supply Schedule BPA which was placed in accordance with the applicable Federal Supply Schedule ordering procedures, FAR 8.405-6(a)(l )(B). Only one source is capable ofresponding due to the unique or specialized nature of the work.

Currently, Oxford Government Consulting, LLC is supporting DOL by providing IT governance support to the Office of the Chieflnformation Officer (OCIO). Oxford current contract will end in February 2019. DOL has a continuing need for the IT governance services. The Assistant Secretary for Administration and Management (ASAM) is currently redesigning the overall DOL IT governance structure with a focus on Shared Services. The target completion date for the redesign is February 2019. OCIO had not anticipated the ASAM's Shared Services effort. The structure redesign, once completed, will result in a need for OCIO to reconfigure its IT governance approach to support the changing requirements.

While the Shared Services redesign is being completed, OCIO has a continued need for IT governance support and it is essential that the current contractor maintains continuity for the interim period. This contractor is responsible for supporting several key statutory responsibilities of the Department spanning the Investment Management, Budget Development, and Strategic Business Management functions. These responsibilities cannot easily be transitioned to a new contractor without significant cost, effort and delays that will negatively impact DOL.

Oxford has been supporting OCIO's IT governance efforts since 2014. OCIO's IT governance team consists solely of contractor staff from Oxford Consulting. Oxford has specialized knowledge, skills and abilities needed for the continued implementation of the OCIO's current IT governance strategy. Given the limited time for transitioning knowledge between the outgoing and incoming contractor, a new contractor will have to independently familiarize themselves with DOL's environment, learn requirements and determine the best approach to providing support. It is expected that the incoming vendor will require at least 90 days to be able to provide useful governance support. This will result in schedule delays and minimal IT governance support. Meanwhile the following initiatives must continue:

Investment Management - The governance team is tasked with all Office of Management and Budget (0MB) reporting requirements and manages the Department's IT Portfolio Submission via the Electronic Capital Planning and Investment Control ( eCPIC) reporting tool. The statutorily required submission details all IT spend of the Department as categorized by the newly established Technology Business Management {TBM) categories. The team has initiated the Department's TBM compliance initiative collaboratively developing the categorization protocols and guidelines used in the Department's implementation. This team also performs the required monthly oversight and ITDashboard.gov reporting of all DOL Major IT investments.

Transitioning to a new contractor staff would result in delays in reporting to 0MB and ultimately cause DOL to be non-compliant with the statutorily required monthly public reporting of IT investment health. Further, 0MB requires that agencies conduct two yearly in-depth reviews (Control and Evaluate Reviews) of major IT initiatives in order to adequately monitor the risk, compliance, cost, and schedule for each. A change in contractors for this short interim period would require a steep learning curve for a set of reviews that requires in depth knowledge from a significant support team, and could increase the risk of Office of Inspector General (OIG) or General Service Administration (GSA) audit findings.

Budget Development - Primary functions of this team include development of all 0MB budget submission documents for OCIO; review, analysis, and recommendation of all IT budget submissions from across the Department; and development of all draft responses to 0MB, GAO, and OIG inquiries. A learning curve would occur during the initial transition of a new team would increase risks to the quality of budget submissions. Additionally, transition to a new contractor during the key mid-winter Congressional Budget Justification development, review, and submission may result in missed or diminished funding opportunities.

Strategic Business Management - The governance team maintains the relevant support required for the quarterly Integrated Data Collection (IDC) report required by 0MB. Congress utilizes the publicly posted IDC data to monitor DOL IT performance, as a basis for some Federal IT Acquisition Reform Act (FITARA) scoring, and to compare performance across the Federal landscape. The publicly reported IDC data is also a key deliverable of the statutorily mandated E-Gov initiatives. Transitioning to a new contractor will impact the data gathering and will result in posting twice in one year, which will put the DOL FITARA score at undue risk.

Their continued support services are critical to OCIO's Investment Management and Budget Development. Oxford is uniquely qualified to perform these services because they are familiar with DOL's IT governance process. No other vendor can meet DOL's requirement in providing uninterrupted support without DOL incurring a significant reinvestment ) on top of the excess has already invested. Using a different contractor to execute the work will significantly impact DOL's mission critical IT governance given their unfamiliarity with DOL's key statutory responsibilities.

Therefore DOL has detennined that it would be in DOL's best interest to allow Oxford to continue to provide support until the DOL IT governance structure redesign is complete, its impacts on the required governance support can be detennined and a replacement contract can be competed. The new IT governance requirements are expected to be finalized by February 2019.

5. DETERMINATION BY THE ORDERING ACTIVITY THAT THE ORDER

REPRESENTS THE BEST VALUE:

GSA has detennined the rates of service to be fair and reasonable for the purpose of establishing the overall Schedule 70 BP A. However, GSA's detennination does not relieve the ordering activity Contracting Officer from the responsibility of making a detennination of fair and reasonable pricing for individual orders, As such the Contracting Officer will request additional price discounts and conduct a price analysis to detennine if the proposed pricing is fair and reasonable.

6. A DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS

OR A STATEMENT OF THE REASON MARKET RESEARCH WAS NOT

CONDUCTED:

Market research was conducted in accordance with FAR Part 10 to see if other contractors could meet the government's needs. This research has identified vendors capable of providing the services described. However, due to OCIO's bona fide need to have continuous services, Oxford Government Consulting is the only vendor uniquely positioned to continue the provision of services in support of agency goals and mission accomplishments without a break in service and severely impacting DOL. The current contractor has the proven expertise and specific corporate knowledge necessary to immediately begin working on these requirements.

In accordance with FAR Part 5.2, the Contracting Officer will transmit a notice via Federal Business Opportunity (FBO) for this procurement to improve small business access to acquisition information and enhance competition by identifying contracting and subcontracting opportunities.

7. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION:

Not applicable.

8. A STATEMENT OF ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE

OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT

ACQUISITION FOR THE SUPPLIES OR SERVICES IS MADE:

OCIO is currently preparing to compete a larger contract vehicle that will support DOL's IT governance activities.