LSJ_WebAgility_Ceiling_Increase.pdf
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Version 12/27/18
Department of Transportation Federal Highway Administration
IT Acquisition Center of Excellence (ACE)
LIMITED SOURCES JUSTIFICATION
JUSTIFICATION FOR CEILING INCREASE IN THE INTEREST OF ECOMOMY
AND EFFICIENCY
GS-35F-540GA/693JK418A600002 Accenture Federal Solutions under Blanket Purchase Agreement (BPA)
The Department of Transportation (DOT) makes this Limited Sources Justification (LSJ) for orders pursuant to Federal Acquisition Regulation (FAR) 8.405-6.
i.) Identification of Agency and Contracting Activity:
Program Office:
DOT, Office of the Secretary (OST) Office of the Chief Information Officer (OCIO)
Contracting Activity:
Federal Highway Administration (FHWA)
IT ACE
1200 New Jersey Avenue, SE Washington, D.C. 20590 ii.) Nature and/or Description of Action Being Approved:
The U.S. Department of Transportation (DOT) continues to have a need for information technology (IT) program support services further referred to as Web Agility 2 (WA2) that will enable sound IT management practices and consistently high-quality delivery of program contract support for DOT. The DOT OCIO develops cutting-edge, best-in-class websites and web infrastructure to support Department goals. Areas of focus for this BPA include operations and maintenance of the DOT web environments; development of new websites and microsites using web best practices and standards; information architecture, content strategy and management; graphics; accessibility compliance; website analytics and customer feedback tools;
data visualizations and integrations with external tools; and other requirements outlined within the Statement of Work (SOW). The Drupal content management system platform is the current OCIO shared web service of the Department.
The high-level list of task areas under the BPA include:
1. Web agility strategic planning and governance support
2. Administration, operations and maintenance of multi-site Drupal platforms
3. Website redesign and migration projects
4. Content management
5. Accessibility mitigation on the web
6. Agile web development
7. Quality assurance and project management support
8. New media development
In accordance with the approved Acquisition Plan, the solicitation was released on the General Services Administration (GSA) Schedule 70 for IT Services and awarded under GSA Contract No.: GS-35F-540GA to Accenture Federal Solutions as BPA No. 693JK418A600002 with a Period of Performance (POP) of 10/31/2017 through 10/30/2022.
The BPA was awarded with a ceiling of $12M for the entire five-year POP. This total was based on the Government’s assessment of history of work completed under the previous contract (DTOS59-10-D-00509) and potential new work to be supported under the BPA. Unfortunately, the Government’s assessment did not accurately anticipate the volume of future work. After just two years of the five-year POP, the BPA is already at its $12M ceiling. Therefore, based on current, actual expenditures a minimum ceiling increase of $12M is requested to continue work under the BPA for the remainder of the POP. This work anticipated over the next three years is outlined in detail below.
The requested ceiling increase will allow for Operating Administration (OA) specific new Drupal migration projects that will modernize, reduce cost and increase security as prioritized by the Department’s Chief Information Security Officer. Furthermore, the ceiling increase will allow for existing web customers to ensure critical enhancements can be made. Finally, the additional ceiling will ensure that necessary and routine annual operations and maintenance support can be maintained to ensure the upkeep of functionality, security, bug fixing as well as a variety of Drupal specific code updates made to the CORE code base. The Government did not anticipate the momentum with the Destinations Digital initiative. The success of the web team’s projects to migrate over to the open source, Drupal content management system along with the cost savings for hosting, O&M and security as a benefit for the shared service model contributed to the accelerated use of the BPA. Additionally, the capacity was expended quicker than anticipated due to several high-profile projects, larger than expected operating administration migrations, as well as the necessary architecture upgrade to Drupal 8.
iii.) A Complete Description of Supplies/Services Required to Meet Agency’s Need:
The DOT OCIO develops cutting-edge, best-in-class websites and web infrastructure to support Department goals. Areas of focus for this BPA include but are not limited to: operations and maintenance of the DOT web environments; development of new websites and microsites using web best practices and standards; information architecture, content strategy and management;
graphics; accessibility compliance; website analytics and customer feedback tools; and data visualizations and integrations with external tools.
The Drupal content management system platform is the current OCIO shared web service of the Department. Since 2011, OCIO began migrating and consolidating OST and OA websites into a shared look and feel, open sourced, Drupal web platform for users to create, edit and publish content. Drupal is designed to empower the subject matter experts to manage their content with the same ease as creating an email.
iv.) The Authority and Supporting Rationale:
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. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.
As described in Section ii above, the issuance of the solicitation under Schedule 70 for IT Services for the original BPA, whose ceiling is now requested to be increased, was not issued under sole-source or limited-sources procedures. The solicitation resulted in three GSA schedule holders who submitted quotes; Accenture offered the highest technically rated proposal and was selected in accordance with the evaluation criteria in the solicitation.
Accenture, has continued to manage the platform as well as continue the migration of OA websites, system integration and enhancements of the shared service to offer a low cost, high quality web site for the public audience.
The web platform meets the Department’s need to communicate with the public, stakeholders, partners and states in a real-time manner by the content owners themselves without the need of a developer to create the content in the website.
Raising the ceiling is more efficient and economical than awarding a new contract now.
Accenture is actively working to migrate the remaining operating administrations over to the shared service web platform. To transition to a new contractor for the final group of websites would risk the standard by which the platform was built and maintained, and progress made on the previous dozen websites already on the platform. It is vital that the platform be managed and websites built to a standard of development whereby the team implementing the new sites also manage the operations and maintenance of the existing websites to benefit from the economies of scale. Moving to another contractor would significantly delay ongoing work and add cost because OCIO would need to transition knowledge of our platform architecture, approach to shared service model, multi-site code bases, security, cross agency partners, and custom functionality. Transition work would result in two contractors working simultaneously for a period of transition time which would be costly awards that OCIO did not anticipate funding. This delay does not take into consideration the time required for the actual re-compete process which would essentially stop work on the platform and risk the ability to implement work required to maintain a secure, communication tool for the consumers.
Lastly, the OCIO has worked with operating administrations and OST Offices for work to be awarded for this fiscal year. Should the ceiling not be increased, there is no option to award the funding for mission / programmatic work to be performed, some work is follow-on to existing, on-going task orders.
The additional new work totaling approximately $6,000,000 for FY20 and $6,000,000 for FY21 is a logical follow on to existing Orders on this BPA. The ceiling increase will allow for extensions to existing Task Orders as well as new work.
v.) Determination by the Ordering Activity Contracting Officer that the Order Represents the Best Value Consistent with FAR 8.404(d):
Pricing for this BPA has been established in accordance with the terms set forth in the applicable GSA Schedule 70 basic contract under which this BPA is being placed. In accordance with FAR 8.405-3(e)(1), an evaluation of the rates is completed annually (e.g. at option exercise) to ensure the rates are still fair and reasonable in accordance with the GSA schedule. The next option will be exercised by October 30, 2019. The Government will request a discount in accordance with 8.405-4. Once the quote under the BPA is received the Contracting Officer, will review the individual labor rates proposed to ensure they are at or below the GSA schedule rates and therefore fair and reasonable.
GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, 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). By placing an order against a schedule contract using the procedures in 8.405, the ordering activity has concluded that the order represents the best value (as defined in FAR 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government's needs.
http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/08.htm#P157_26742 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/08.htm#P126_22049 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/02.htm#P14_694 vi.) Description of the Market Research Conducted Among Schedule Holders and the Results of the Research:
Prior to awarding the BPA, there were two main approaches to market research:
1. The OCIO program office solicited market research from the Federal GSA web council for feedback as to the model of web support and vendors that other agencies found to be best value and highly skilled in web platform management, specifically Drupal.
The OCIO program office discovered in this analysis that the OCIO platform was larger and more complex as far as the number of large sites on a shared code base that required one Contractor to own the governance – design, security, development, new requirements, enhancements and corporate ability to manage dozens of task orders simultaneously executed. It would be far too labor intensive to have, for example, many smaller companies bidding for work for every task order and work to be awarded in this manner. The OCIO program office determined that one larger firm with a staffing bench of high quality talent of project managers, business analysts and developers that would effectively “own” the platform from a service, operational, security and enhancements perspective was the better decision. This would save the government management time and increase efficiency overall.
2. Further, the Contracting Officer conducted sessions for three Alaskan Native Small Businesses, who presented to OCIO their past performance and qualifications in web project management and the Drupal technology as another form of market research. The OCIO program office determined that these Alaskan Native Small Businesses acted more so as staffing companies rather than high quality specialists with in-house talent that OCIO was requesting in the solicitation. These Alaskan Native Small Businesses did not demonstrate to the OCIO program office the ability to source talent in a timely manner while executing numerous simultaneous task orders.
Market research supports that it is most economical and efficient to stay with Accenture as other alternative options (e.g. ANC set-aside) would not meet the requirement. Additionally, the work is interrelated and therefore needs to remain on a single award BPA to be conducted by one vendor and not broken up into task orders to be competed individually on GSA.
vii.) Any Other Facts Supporting the Justification:
Examples of specific work that cannot be awarded without this BPA ceiling increase economically and efficiently before the end of the fiscal year, and without service interruption and without cause for security concerns, are as follows:
• An additional call order required to update all documentation for the purposes of knowledge transfer as well as overlap support of the ongoing activities pertaining to the operations and maintenance of the web platform that encompasses 12+ Operating Administration sites on our multi-site codebase, Portal, learning management and secure codebase. This additionally includes the in-progress work associated with our Drupal 7 migration to Drupal 8 as well as the hosting and content delivery network architecture. The magnitude of impact might be illustrated in that the current work load of the BPA holder is 26 ongoing task orders for work on our Drupal platform and other web-based applications and tools.
• An additional call order required to transfer the knowledge and overlap support of our permitting dashboard website, data platform and project management tool that was created for the OST Office of Policy, Office of Management and Budget (OMB) and GSA Federal Permitting and Infrastructure Steering Committee (FPISC). This highly visible website and tool integrates across the federal government as a key component to the White House’s Cross Agency Priority (CAP) Goal of streamlining the permitting process.
• An additional call order to transfer the knowledge and overlap support of our Federal Motor Carrier Safety Administration (FMCSA) Portals and Learning Management System that allows state partners to log in, report, sign up and numerous other functions with external partners.
• An additional call order required for knowledge transfer and overlap support to the highly visible, S10 correspondence management application on the Microsoft Dynamics Solution called the Electronic Document Management System (EDMS). This system interacts with every operating administration as well as OST office, inclusive of the Secretary’s office.
• For the continuation of service levels, there would need to be a lengthy overlap of teams to support the functions, development, security as well as customer change management for the success of the OCIO web and EDMS project services.
viii.) Statement of the Actions 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 current period of performance extends through FY22, however the current projections account for work through FY21. A new BPA is planned to accommodate FY22 work.
Specifically, prior to the acquisition of new web agility services, a follow on to this BPA, the OCIO federal web team would solicit market information from the Federal Web Council listserv to determine examples of how other government agencies model their web platform execution from a Contractor or team of Contractors. DOT OCIO would analyze the models for efficiency, security and governance. A Request for Information (RFI) will be issued on multiple venues (e.g.
GSA, FedBizOps) to assess capable vendors.
The market research would examine the capability of the Contractor to act as the “owner” of the platform and services as well as leverage a vast bench of resources that provide a highly sought-after skillset in the Washington, DC job market.
The OCIO federal web team would look to solicit to a subset of vendors that have proven to have managed a web platform of the magnitude in DOT’s OCIO.
ix.) Evidence that any Supporting Data that is the Responsibility of Technical or Requirements Personnel and Which Form a Basis for the Justification Have Been
Certified as Complete and Accurate by the Technical and Requirements Personnel (If Any):
The list of future work and associated dollar values outlined above under Section ii is certified by the OCIO as complete and accurate.
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