M04 Redacted Limited Source Justification Signed_Redacted.pdf

CUI

PROCUREMENT SENSITIVE

SOURCE SELECTION SENSITIVE

LIMITED SOURCES JUSTIFICATION

Office of the Undersecretary of Defense, Comptroller (OUSD(C))

REFERENCES: FAR 8.405-6

DOCUMENTATION:

1. IDENTIFICATION OF THE REQUIRING AND CONTRACTING ACTIVITY:

Requesting Activity:

Office of the Undersecretary of Defense, Comptroller (OUSD(C)) 1100 Defense Pentagon Washington, DC 20301-1100

Contracting Activity:

DFAS Columbus Contract Services Directorate Building 21, Room 2B218 3990 E. Broad St.

Columbus, Oh 43213-1152

2. NATURE OR DESCRIPTION OF THE ACTION:

The Defense Finance and Accounting Service (DFAS) Contract Service Directorate (CSD) requires an extension of the duration of ordering period of five Blanket Purchase Agreements (BPAs) for audit services by two years, from June 2, 2026 to June 1, 2028. This extension is necessary for the five existing Independent Public Accounting (IPA) firm BPA holders to provide continued support to perform Statement on Standards for Attestation Engagements No. 18 (SSAE18), Audit Readiness / Remediation Validation, Agreed Upon Procedures Attestation Examinations and Audits of Component’s Federal Financial Statement(s).

Prior to this action, six BPAs were awarded on 2 June 2021with a period of performance expiring on 1 June 2026 to IPA firms that possess past performance rendering an opinion for audit and SOC1 engagements within DOD. Extending the BPA’s ordering period for an additional two years to 1 June 2028 would allow DFAS CSD to conduct a competitive process among the existing BPA holders to recompete the four existing OUSDC SSAE18 contracts prior to the expiration dates of 30 Sept 2026, and avoid the necessity for a competition of the BPA simultaneously with the four BPA orders for OUSDC. All current BPA holders have at least satisfactory past performance. In addition, extending the BPA ordering period by two years would also allow DFAS CSD to recompete six of the eight existing DFAS BPA order contracts prior to the period of performance end dates of 30 Sept 2027.

3. DESCRIPTION OF SUPPLIES/SERVICE:

DFAS requires a multiple award Blanket Purchase Agreement (BPA). Subsequent BPA orders could be issued in support of the OUSDC, DOD OIG and DFAS for Independent Public Accounting (IPA) firms to

CUI

PROCUREMENT SENSITIVE

SOURCE SELECTION SENSITIVE

perform Statement on Standards for Attestation Engagements No. 18 (SSAE18), Audit Readiness / Remediation Validation, Agreed Upon Procedures Attestation Examinations and Audits of Component’s Federal Financial Statement(s) that must be conducted in accordance with applicable examination/auditing standards generally accepted in the United States of America and the standards applicable to examinations / financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States. Examination and Audit work must be performed in accordance with Government Accountability Office/Council of the Inspectors General on Integrity and Efficiency Financial Audit Manual (GAO/CIGIEFAM). In addition, the contractor should follow audit guidance shown in OMB Bulletin 19- 03, as updated. The examinations must be performed in accordance with Generally Accepted Government Auditing Standards (GAGAS) and the AICPA SSAEs.

4. STATUTORY AUTHORITY AND SUPPORTING RATIONALE:

FAR 8.405-6 (a)(1)(C), which allows orders placed under FSS to limit competition if “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.” Therefore, extending the BPA ordering periods for HQ042321A50001-5003, 5005 and 5006 by two years to June 1, 2028 will ensure the ordering period coincides with the future BPA order competitions.

5. CONTRACTING OFFICER DETERMINATION THAT THE ORDER REPRESENTS

THE BEST VALUE AND ANTICIPATED COST IS FAIR AND REASONABLE:

This action will be for BPAs. As a matter of economy and efficiency, continuing to use the existing instrument allows the government the efficiency of working with the IPA firms on GSA with DOD past performance without having to duplicate the re-evaluation of past performance as well as the economy of knowing the rates on the BPA will remain fixed with the rates established on the BPA back in 2021.

The estimated price for potential orders which may be awarded during the extended BPA ordering period is approximately . The Contracting Officer determined that extending the previous competitively awarded BPAs for future competitions among the five existing BPA holders with recent, relevant, and positive past performance within DOD provides the best value to the government. Labor rates for this action will be reviewed in accordance with FAR 8.405-2(d) and DoD Class Deviation 2014 O0011 and the anticipated cost to the Government will be determined fair and reasonable. All contractors GSA contracts have been or will be extended to at least June 1, 2028.

6. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG

SCHEDULE HOLDERS AND THE RESULTS OR A STATEMENT OF THE

REASON MARKET RESEARCH WAS NOT CONDUCTED.

Market research included review of Multiple Award Schedule (MAS) (Category 541211), and reviewing existing DoD Financial Audit contract vehicles and Blanket Purchase Agreements (BPAs). There were 182 potential vendors available within General Services Administration (GSA) that possess a Multiple Award Schedule (Category 541211). Based on existing contract information, only the five BPA holders possess audit or SSAE18 experience as a prime contractor within DOD. DFAS had previously issued a