LSJ_OEMS FMT Inv_PI_Budget Execution Support Final signed.pdf

General Services Administration Federal Supply Schedule Limited Source Justification

1. Identification of the agency and contracting activity:

a. Federal agency and contracting activity.

Health and Human Services (HHS) / Food and Drug Administration (FDA) / Office of Acquisition and Grant Services (OAGS)

b. Sponsoring organization.

FDA / Office of Enterprise Management (OEMS) & Office of Global Policy and Strategy (OGPS)

c. Contracting Officer’s Representative (COR)/Requiring Activity Point of Contact (POC) information.

i. Name: Elijah Jackson

ii. Mailing address: 10903 New Hampshire Avenue, Building 31 Room 3551

iii. E-mail address: Elijah.Jackson@fda.hhs.gov

iv. Telephone number: (240) 402-0352

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

a. Acquisition purpose and objectives.

This is a Limited Source Justification in accordance with FAR 8.405-6(a)(1) to provide required support for the remediation of the Invoice Reconciliation Process, process improvement documentation and budget execution support services for the FDA’s Office Enterprise Management Services. The services provided will help meet the requirements of OGPS’s ongoing mission critical initiatives.

b. Project background.

The Office of Enterprise Management Services (OEMS) Division of Resource Management (DRM) Financial Management Team (FMT), is responsible for managing all aspects of the OGPS budget, which includes the formulation of OGPS’s portion of the FDA’s President’s Budget Requests (OMB budget justifications), response to Congressional budget justifications, the development of annual and multi-year spend plans for OGPS headquarters and foreign offices, providing fund cables to foreign posts and payments to required Department of State financial systems for foreign offices, reconciliation of operating and payroll expenditures, preparation of monthly, quarterly and annual reports, oversight of government purchase cards use, and data collection and analysis of data associated with the formulation of responses to data calls from the Department of Health mailto:Elijah.Jackson@fda.hhs.gov and Human Services, the Office of Management and Budget and Congress. OEMS DRM Acquisitions Team serves as OGPS’s liaison to FDA’s Office of Acquisition and Grants Services for all contracts, inter-agency agreements and cooperative agreements. The Acquisitions Team interfaces with the FMT and OGPS as part of OGPS financial management activities. Current services are being provided under an IAA HSP23320150017I with HHS Program Support Center (PSC). Through this IAA with PSC, Deloitte’s support and knowledge of OGPS’s budgetary needs helped the organization improve its ability to efficiently plan and close-out each fiscal. Deloitte established and developed Budget Planning and Close-out guidance, strategy, and timelines that have immensely improved the organization’s ability to respond timely and meet agency deadlines.

Deloitte helped the organization strengthen its relationships with organizations such as the Division of Budget Execution and Control (DBEC) through its Deloitte networks in OFM. Deloitte supported the development of the Annual Financial analysis for the organization post close-out.

This analysis has been integral in equipping leadership with imperial data to help evaluate its progress and improve future planning, execution, and reporting efforts for the past four years.

The IAA is set to expire on June 28, 2020.

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

a. Project title. FMT Remediation of Invoice Reconciliation Process, Process Improvement Documentation & Budget Execution Support

b. Project Description.

The purpose of this task is to assist OEMS/FMT and OEMS/Acquisitions Team in carrying out activities such as remediation of invoice reconciliation process, process improvement documentation & budget execution support including updates on status of resource expenditure, and projections of available operating funds. In addition, the contractor will work with OGPS and OPLIA management & identified stakeholders in their financial management processes to perform improvements. The services required are non-personal and do not include any inherently governmental functions as defined in FAR 7.5 and OFPP Policy Letter 11-01.

Requirement type.

☒ Support services (non-R&D)

☐ Supplies/equipment

☐ Information Technology (IT)

☐ Other:

Type of action.

☒ New requirement

☐ Follow-on

☐ Other:

Proposed contract/order type.

☒ Firm-fixed-price

☐ Time and materials

☐ Indefinite delivery:

☐ Other:

☐ Completion Form

☐ Term Form

Acquisition identification number.

Requisition 1229966

c. Total estimated dollar value and performance/delivery period.

The total estimated value of this acquisition is $2,000,000.00 for a period of performance of 12-months from June 29, 2020 through June 28, 2021.

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

a. Acquisition authority.

☒ This acquisition is conducted under the authority of the Multiple Award Schedule Program. In accordance with Federal Acquisition Regulation (FAR) 8.405-6(a), consideration of schedule contractors will be restricted to fewer than the number required at FAR 8.405-1, FAR 8.405-2, FAR 8.405-3 (i.e., fewer than three FSS contractors). FAR 8.405-6 (a)(1)(i), for a proposed order or BPA with an estimated value exceeding the micro-purchase threshold not placed or established in accordance with the procedures in FAR 8.405-1, FAR 8.405-2, or FAR 8.405-3, the only circumstances that may justify the actions are-

☒ (A) An urgent and compelling need exists, and following the procedures would result in unacceptable delays;

☐ (B) 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;

☐ (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. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

https://www.acquisition.gov/?q=/browse/far/8 https://www.acquisition.gov/?q=/browse/far/8 https://www.acquisition.gov/?q=/browse/far/8 https://www.acquisition.gov/?q=/browse/far/8 https://www.acquisition.gov/?q=/browse/far/8 https://www.acquisition.gov/?q=/browse/far/8 https://www.acquisition.gov/?q=/browse/far/8 https://www.acquisition.gov/?q=/browse/far/8

☐ This acquisition is conducted under the authority of the Multiple Award Schedule Program. In accordance with FAR 8.405-6(b), consideration of schedule contractors will be restricted only to the item peculiar to one manufacturer. An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer.

b. Demonstration of the proposed contractor(s) unique qualifications to provide the required supply or service.

• Name and address of the proposed contractor(s).

Deloitte & Touche L.L.P 1725 Duke St Alexandria, VA 223143456

• Nature of the acquisition and proposed contractor(s) unique qualifications.

Since 2016, Deloitte has served as a trusted financial advisor to FDA’s Office of Global Policy and Strategy (OGPS), formerly the Office of International Programs (OIP), by consulting and supporting their Financial Management Team (OGPS FMT). Their historical knowledge of FDA’s financial management processes and systems have led to tremendous gains and maturity in OGPS’s financial management processes. Deloitte continues to leverage their system of networks across the federal government to support OGPS’s unique position of maintaining financial transparency and accuracy in 2 budget systems. OEMS/OGPS requires a contractor to assist with developing a solution for reconciling the Consolidated Overseas Accountability Support Toolbox (COAST) transactions with FDA’s Unified Financial Management System (UFMS). Deloitte’s unique qualifications makes them the only vendor capable of doing the work for the following reasons:

Reconciliation Systems - Deloitte has documented the process to use, provision access, and manage systems crucial to the reconciliation process used by FMT, OGPS, and Foreign Offices. The FDA and DoS financial management systems are used to reconcile foreign office transactions.

Deloitte has a deep knowledge of both systems and has worked to improve the use of both systems as well as their reporting capabilities. The systems and reporting tools include: UFMS, RFMS, Secure HTTP Internet File Transfer System (SHIFTS), Consolidate Overseas Accountability Support Toolbox (COAST), and Financial Business Intelligence System (FBIS).

ACRS/UFMS - Deloitte has documented the use of the Automated Clearing Record System (ACRS) module within UFMS, which allows for Foreign Office transactions to be reconciled within UFMS.

The knowledge is vital to the continuity of our reconciliation program.

DoS - Deloitte supported the development of Department of State (DoS) systems and reporting tools (RFMS, SHIFTS, and COAST) to be accessed and used by OGPS FMT. Deloitte documented the process of how COAST is managed at a technical and functional level within the FDA across OIMT, OGPS, and OEMS. This includes the activities to provision access, update data, and upgrade the COAST software. This knowledge is essential to continuous improvement efforts.

Given their intimate knowledge of the systems, their continued support is needed for the next phase of this project to develop a process for UFMS reconciliation with the new Department of State (DoS) Business Intelligence System (BIS) that is replacing COAST in Calendar Year 2020, and ensure consistent reconciliation of FDA transactions throughout the system change, including through analysis of whether it is possible to leverage or replicate the Center for Disease Control’s “Robo FTP” process which automates the obligation interface with Department of State. The FDA Deloitte Team has already developed a relationship with the CDC Team in connection with past efforts and they would leverage these relationships to quickly determine the need and spend much of the contract period in development instead of exploration.

OGPS Budget Toolkit – After assessing OGPS’s financial management maturity, documenting best practices, and assisting with a complete overhaul of all OGPS financial management processes, Deloitte created the OGPS Budget Toolkit, a SharePoint tool with several complex modules to respond to the financial needs of FDA, OGPS Leadership, and other stakeholders. Deloitte is uniquely positioned to continue supporting this effort as OGPS’s financial management needs continue to evolve by providing updates, to include maintenance and troubleshooting to the modules, key to OGPS’s continued positive financial standing in FDA.

FDA has quickly began migrating from the existing SharePoint platform to SharePoint online, with total migration planned for October 2020. Leveraging Deloitte’s unique knowledge and expertise surrounding the OGPS Budget Toolkit will be critical to migration to ensure a seamless transition by completing quality and user acceptance testing, troubleshooting, and fixing, or re-creating all workflows and routing that do not transition properly.

Financial Management Support – Deloitte has a deep understanding of OGPS’s complex funding structures and has developed and managed automated tracking tools to support strategic financial decisions for OGPS leadership. Deloitte has played an integral role in strengthening the internal development and management of financial management processes. They’ve played a unique role in improving processes which led to more sound financial plans. Having spent 4 years with OGPS Leadership, the team has built relationships with key stakeholders across all OGPS Offices. Deloitte understands the financial needs of leadership and uses this knowledge to enhance processes.

During these unprecedented times when budget offices must respond to unique funding challenges resulting from the impact of COVOD-19, Deloitte has leveraged their deep understanding of the OGPS’s historical challenges and unique financial requirements to develop analysis used to guide OGPS leadership’s financial decision-making process. OGPS requires seamless support in this area to track, monitor, and report on budgeted and actual spending, performing analysis to forecast end of year funding levels based on obligation and expenditure activities

COAST is the Department of State financial management system of record reporting tool that is used at US Embassies to process Foreign Office financial management transactions. Health and Human Services (HHS) is working with FDA’s Office of Financial Management (OFM) to build an interface that will allow COAST daily obligations to import into UFMS. OGPS is the only FDA Office that utilizes the COAST system. Deloitte is needed to provide ongoing services to support FY 2020 & FY 2021 remediation of invoice reconciliation process, process improvement documentation & budget execution support, including updates on status of resource expenditure, and projections of available operating funds. Such services will include various activities for project administration to ensure that the task is on schedule and meeting deliverables as well as supporting OGPS and OPLIA management and key stakeholders. The services provided will help meet the requirements of OGPS’s ongoing mission critical initiatives. Deloitte is the subject matter expert for FDA’s reconciliation of foreign office transactions, this depth of understanding of the DoS’s and FDA’s financial systems and IT implications make them the only vendor that can properly provide this service. Deloitte is currently training the FDA on a budget toolkit, if this program is switched to a new contractor then the Government will have to learn a new tool which could take additional time and effort for the Government to effectively utilize.

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

Prior to award of the proposed contract, cost or pricing information will be obtained from the contractor. Price analysis will be performed and documented to sufficiently determine that the cost to the Government of the proposed acquisition will be fair and reasonable. The total firm fixed-price of the BPA order will be evaluated to ensure consistency with the existing BTT BPA labor rates, which were determined fair and reasonable at the time of BPA award. In addition, the proposed level of effort will be evaluated to ensure the labor hours are commensurate with the technical effort required for the work.

6. Description of the market research conducted among schedule holders and the results, or a statement of the reasons market research was not conducted.

Market research was conducted checking the strategic sources and existing FDA contract vehicles to examine potential procurement options. A new IAA was not a feasible option since the current vehicle from PSC was no longer available and no other IAA was identified that can meet the services.

The services of this requirement were determined within the scope of the Business Transformation Team (BTT) BPA HHSF223201510010B. The labor categories in the requirement were examined and compared with the BPA to assure alignment with OGPS needs. Other existing FDA contract vehicles were researched, and based on the required services, no other vehicle was appropriate for the work required.

7. Any other facts supporting the justification.

The use of the authority cited for procuring these services is not a result of a lack of planning or the expiration of funds. OGPS was recently informed that the existing contract vehicle used for the previous 2 years with PSC could no longer support the current task. Due to the quick turnaround time needed to continue this work without a break in service, a contractor is required for completing key activities that are time-sensitive and requires coordination with multiple stakeholders across both the FDA and the Department of State. It is in the Government best interest for the incumbent continue the following work for 1 additional year to avoid a break in service. This will allow OEMS/OGPS to continue key activities and have time to do proper acquisition planning to compete the follow-on work. The time it will take to compete the work and transition to a new vendor will cause a 60-day lapse in services. In addition, time for the new vendor to get aquatinted with the key activities listed could take up to six (6) months for the vendor to properly support all key tasks listed and would be considered wasteful government spending.

This requirement is urgent and compelling for the following reasons:

OGPS Foreign Office Transaction (UFMS/COAST Reconciliation) – DoS will update their financial reporting system in calendar year 2020. This critical change impacts the way in which foreign office transaction errors are analyzed and resolved. As the creator of the current processes and financial system connections, Deloitte will be able to quickly assess the new requirements, provide the necessary steps to appropriately transition, and provide timely updates to existing documentation so that OGPS FMT members are able to resolve UFMS errors in a timely manner.

Every month, OGPS FMT reconciles transactions with obligations made in UFMS and the Treasury Government-Wide Account (GWA) amount to maintain compliance with the Department of Treasury.

The current variance must be cleared prior to the end of FY 2020 and Deloitte has played a crucial role in analyzing errors and providing timely resolutions. OGPS FMT and Deloitte are currently working closely with OFM to reduce this variance and given the looming deadline. OGPS FMT relies heavily on Deloitte’s knowledge in this unique area and they would be able to continue providing analysis and support to meet these critical deadlines without diverting critical OGPS FMT staff resources to train and develop new contract resources.

OGPS Budget Toolkit – The OGPS Budget Toolkit contains several modules that impact OGPS’s planning and budget execution processes. With FDA year-end and FY 2021 FOP deadlines on the horizon, its critical for the OGPS Budget Toolkit modules to be fully functioning, this requires continuous monitoring, troubleshooting, and updating. Assistance in this area is critical to ensuring that OGPS can meet all year-end and FY 2021 FOP and AAP requirements without having to divert staff to train and respond to questions from new vendors.

FDA OIMT has already reached out to OGPS to determine which SharePoint pages need to be transitioned and, having created and provided continuous updates to the OGPS Budget Toolkit, Deloitte is poised to quickly transition to the new platform and respond to SharePoint migration needs. Additionally, their team will be able to mitigate any issues related to migrating to the new platform and can ensure that the transition is seamless during critical year-end and planning times.

Financial Management Support – As the full financial impact of COVID-19 on OGPS’s global operations continues to unfold, it is critical that OGPS FMT leverage Deloitte’s knowledge of the foreign offices’ financial needs to quickly and accurately respond to FDA and Congressional inquiries, provide planning support to OGPS Foreign Office Directors, and assist in guiding OGPS Leadership’s financial decision making. The team’s continued support is needed to provide data and coordinate responses to data calls, or requests for financial information to those from the White House Office of Management and Budget, the Department of Health and Human Services, FDA Office of Congressional Appropriations, and FDA Office of Budget. Given the knowledge they’ve gained regarding OGPS’s needs, they’re the most equipped to quickly respond to those ongoing requests, many of which are already underway.

Deloitte has been on the forefront of creating tools and analysis to respond to OGPS’s financial needs and, given looming year-end and FY 2021 financial deadlines, their support and depth of knowledge in this area is critical to providing OPGS and DBEC with the necessary financial data to better inform decisions. Deloitte will be able to leverage their FDA network of partners to better understand requirements and ensure that OGPS is poised to respond.

The agency will be harmed if there is a lapse in service due to additional procurement time for the following reasons:

OGPS Foreign Office Transaction (UFMS/COAST Reconciliation) – FDA would not be able to quickly pivot and analyze changes related to the new Department of State (DoS) Business Intelligence System (BIS) that is replacing COAST in Calendar Year 2020, leaving the Agency vulnerable to A-123 violations as seen in previous fiscal years. Additionally, FDA is required to reconcile the Department of Treasury’s Government-Wide Account (GWA). This mandatory requirement would be significantly, negatively impacted given that Deloitte provides support and analysis on the best practices to implement for the reconciliation of the OGPS Foreign Office financial transactions in UFMS, which reduces FDA’s overall variance with Treasury.

OGPS Budget Toolkit – The toolkit contains modules that are critical to OGPS’s projection of remaining FY 2020 funding needs and crucial to the development of the OGPS Financial Operating Plan. This platform also contains modules that allow OGPS to communicate funding requirements to DoS.

Without Deloitte’s continued expertise with the Budget Toolkit, OGPS FMT will be unable to quickly update workflows, templates, and databases to provide FDA with the data needed to ensure funding can be properly allocated to the Office.

Financial Management Support – OGPS’s foreign offices have been greatly impacted by the COVID-19 pandemic, from not being able to travel, to repatriation efforts. Without Deloitte’s continued support, OGPS would not be able to accurately determine the true financial impact that this pandemic is having on its budget and staffing needs. Given the time constraints surrounding many of the data calls and year-end deliverables, the organization would be unable to quickly pivot and respond to those needs, resulting in inaccuracies in financial data which leads to A-123 violations.

8. 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.

a) Removal of barriers to competition.

The FDA OEMS/OGPS will continue to monitor the marketplace for new requirements for professional services. OEMS/OGPS will adjust the acquisition strategy for future procurements accordingly to allow competition for future requirements.

b) Listing of sources, if any, that expressed an interest, in writing, in the acquisition.

N/A

9. Program office certification.

Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

Signature:____________________________________

Elijah Jackson COR/Requiring Activity POC

June 24, 2020

Sheri Welsh COR/POC Immediate Supervisor

Bobby Enoch Head of the Sponsoring Program Office

10. Contracting Officer Certification.

This is to certify that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

Gary Klaff Contracting Officer

11. Division Director and Head of the Contracting Activity signatures.

Vidya Vish Division Director

Bobby G.

Enoch -S

Digitally signed by Bobby G. Enoch -S Date: 2020.06.24 09:34:07 -04'00'

Sheri L.

Welsh -S

Digitally signed by Sheri L. Welsh -S Date: 2020.06.24 09:40:28 -04'00'

Elijah Jackson -S

Digitally signed by Elijah Jackson -S Date: 2020.06.24 09:50:20 -04'00'

Leonard Grant Head of the Contracting Activity

12. Competition Advocate signature.

James Sigg Competition Advocate