MCC Evidence Platform JOFOC.pdf

UNCLASSIFIED

intrinsically linked to the broader platform that ICPSR provides as a service for its customers. As such, in the interest of economy and efficiency, MCC seeks to award a follow-on contract to the incumbent contractor for the continuation of the MCC Evidence

Platform. A non-competitive award is in the best interest of the Government due to the substantial duplication of effort and cost that would result from issuing a competitive solicitation and potentially awarding to an alternative vendor; duplicated costs would include labor charges, ODCs, and Federal staff hours spent on the original effort to design, configure, and ultimately launch the Evidence Platform website. The duplication of such costs is not expected to be recovered through competition.

Further, award to any other source would result in unacceptable delays in fulfilling the agency’s requirements for the uninterrupted use and support of the Evidence Platform.

The estimated timeframes and financial costs of re-competition are outlined below and are based on MCC’s experience with the incumbent contractor to design and launch the

Evidence Platform website. ICPSR’s costs are considered competitive based on the original solicitation in which ICPSR proposed the lowest of the four offers received.3

Public website design, development, testing, and data migration

In order to transition the Evidence Platform to an alternative vendor, the new contractor would have to spend several months designing, developing, testing, and migrating data to a comparable version of the existing platform website. This would require conducting a full review of MCC’s repository of knowledge products as well as associated datasets, and defining and building an underlying data model for the various MCC programs and data object types, including metadata to allow for tagging, citation, and effective search

& filtering functions. In addition, this would include preliminary work to design the platform website, as well as the review of MCC’s TREDD Guidelines and other tools and templates used by MCC for data management to ensure site design incorporates required functionality and workflows to align with MCC practices for data documentation and dissemination. The contractor would also need to incorporate MCC branding guidelines into the site design, providing for a platform-specific logo, images, fonts, and color

3 A price analysis was performed at the time of award, and ICPSR’s price was determined to be fair and reasonable. Likewise, any follow-on contract will be reviewed closely to ensure fair and reasonable pricing, using the incumbent contract price as a benchmark (among others) for making that determination.

palettes, as well as providing for a domain name. Finally, the new contractor would need to develop a plan for migration of all platform data to the new version of the Evidence

Platform, which would cover all current knowledge products including studies and related documentation, such as study designs, questionnaires, data collection instruments, analysis reports, as well as datasets and associated codebooks. This would also require collaborating with the incumbent contractor to implement re-directs from links and URLs on the existing platform and properly mapping them to the corresponding location within the new platform website. Following each of these steps, the contractor would have to conduct final testing of the platform website prior to it being launched. Collectively, each of these steps would require approximately 8-10 months, roughly equivalent to the actual timeline depicted above for designing the current EP website.

IT Security Assessment & Authorization to Operate

In conjunction with the site design and testing efforts described above, a new contractor would need to incorporate and demonstrate compliance with various security requirements as it builds the Evidence Platform. In particular, the contractor must demonstrate FISMA compliance4 to obtain an Authorization to Operate (ATO) from

MCC for the platform. This would involve developing a System Categorization, Privacy

Impact Assessment, System Security Plan, Security Assessment Plan, Security

Assessment Report, Plan of Action and Milestones Report, Contingency Plan, Incident

Response Plan, Configuration Management Plan, and Continuous Monitoring Strategy.

Further, the contractor would be required to adhere to CIPSEA and NIST requirements for confidentiality and security of Controlled Unclassified Information (CUI) in a Non-

Federal System.

While some aspects of this workstream can be performed in parallel with the site testing efforts, most of the IT security work could not start until the infrastructure, and all critical elements of the platform are established and stable. This would require a new contractor to dedicate at least 5 months towards IT security work after the platform is stable. These efforts and associated costs cannot be meaningfully condensed based on the system requirements without undermining platform security.

Legal Review & Supplementary Agreements

An additional requirement for establishing the Evidence Platform involved developing critical supplementary legal agreements related to the curation and dissemination of both restricted use and public use datasets. These supplemental agreements are necessary for aligning with MCC’s TREDD Guidelines for data management, and describe the technical and organizational measures ICPSR will undertake to secure these datasets, while also outlining appropriate protocols for cases of a breach of confidentiality, a scenario in which restricted use datasets may become compromised and accessible to unauthorized third parties. If the operation of the Evidence Platform were transitioned to an alternative vendor, the new contractor would have to review MCC’s requirements for data documentation, transfer, processing, archiving and distributing restricted use and

4 Federal Information Security Management Act. The System Security Plan must also be compliant with provisions of mandatory Federal Information Processing Standards (FIPS), and meet all IT, data, system, and physical security requirements of the National Institute of Standards and Technology (NIST).

public use datasets, and to document its own workflows, staffing, and technology used to ensure data security and appropriate data processing procedures. Based on these reviews, the contractor would have to collaborate with MCC to develop data deposit and dissemination agreements for both restricted and public use datasets. This would also require sufficient time for MCC to conduct a legal review of the agreements to assess their suitability in light of MCC TREDD Guidelines, and for the final agreements to be incorporated into the contract terms. Although these various steps may not constitute a substantial level of effort from the contractor, they would be duplicative with work already performed by the incumbent contractor, and would consume additional Federal staff hours that were already spent on the original effort. They would also add an incremental amount of time to the overall timeline for launching a new version of the

Evidence Platform, and would constitute an estimated five months of work (conducted in parallel with other efforts) to allow for appropriate reviews and quality control checks by

MCC staff to take place.

MCC Manager Configuration

A critical component of the overall Evidence Platform is the private back-end administrative environment for MCC staff to access and upload new knowledge products, study documentation and add metadata for new content being disseminated on the public website. To design this environment (currently referred to as “MCC Manager”), a new contractor would have to collaborate closely with MCC staff to develop an understanding of the universe of MCC’s programs, studies, knowledge products, datasets, and subsequently to design appropriate workflows to enable MCC staff to create new knowledge products, upload documents, add metadata, and incorporate correct citation information as required, as well as enabling quality control checks before publicly posting. In addition, this would require the contractor to devise a process for account setup by MCC staff, as well as proper login and authentication. These steps would require significant effort in addition to the work directed towards designing the public component of the platform, and would constitute approximately five months of effort prior to launching the overall platform.

MCC Manager Training

In parallel with the steps required to design the back-end environment for MCC staff, a new contractor would also need to develop training materials including a guide for use by

MCC staff, as well as delivering at least 1-2 trainings on the use of the MCC Manager environment. The training guide would need to include detailed guidance and instructions for account setup and login, step-by-step directions for the creation of new knowledge products (including tagging with metadata and citation details specific to each knowledge product type), document uploads, and quality review workflows. The efforts to develop these training materials and deliver the training would be based on the agreed-on design of the MCC Manager interface, and would therefore require careful collaboration between the contractor and MCC staff as the users of the system. Once the MCC

Manager interface design and training materials are both finalized, the new contractor would be required to deliver training sessions to MCC staff to orient them to the new system and provide user support as they begin to use the system. The process to develop training materials and deliver the trainings would constitute approximately 3-5 months of price competition and other factors. For the follow-on contract, pricing will be reviewed closely to ensure its continued reasonableness, using the incumbent contract price as a benchmark (among others) for making that determination.

7. Description of the market research conducted or statement of the reason market research was not conducted

Market research was not conducted because the basis for the sole source award of the

Evidence Platform contract is not due to inadequate competition. Rather, in the interest of economy and efficiency, we assert that a sole-source award is in the best interest of the

Government. Nonetheless, ICPSR offered the lowest price at the time of contract award

(and scored the highest technically). MCC would not expect a significant shift in competition dynamics if this requirement were to be re-competed, especially considering the existing infrastructure ICPSR has in place to continue supporting the MCC Evidence

Platform.

8. Any other facts supporting the use of other than full and open competition for this acquisition

The Evidence Platform as currently designed and operated poses low risk to the

Government in terms of cost management and compliance with IT security requirements, providing high value for taxpayer dollars for such a strategic initiative for the agency. As the incumbent contractor, ICPSR is best suited to continue providing for the ongoing operation and maintenance of the Evidence Platform in the most cost-effective manner, as well as to avoid extended disruptions, delays, migration complexities, learning curves, and in-house expertise resource requirements due to transitioning the Evidence Platform content to a new vendor’s domain. ICPSR has also built a great deal of knowledge of

MCC’s internal processes related to data documentation and management, including the protocols associated with the MCC TREDD Guidelines. In addition, MCC’s Disclosure

Review Board (DRB), which oversees the documentation and dissemination of MCC’s public use and restricted use datasets, has aligned its procedures and workflows in relation to the transfer of data to ICPSR for curation on the platform website. ICPSR has observed meetings of the Disclosure Review Board and gained an understanding of its processes and expectations for data curation, and has designed protocols for data transfer, documentation and storage according to the DRB’s requirements. ICPSR has developed an understanding of the needs of key stakeholders at MCC and can appropriately tailor

Evidence Platform features and functionality to these needs. Given the strategic importance of the Evidence Platform, this understanding is important for supporting

MCC’s objective of encouraging utilization of its vast library of evidence and data by critical stakeholders including Congressional stakeholders, independent researchers, and the development community at large. This helps ensure that MCC is able to maximize learning by transparently publishing the results of its investments and underscores

MCC’s commitment to accountability of US taxpayer funds.

9. List of all sources, if any, who expressed in writing an interest in the acquisition

The identity of the unsuccessful offerors on the original solicitation is procurement sensitive information. With respect to the current action (sole source award to ICPSR), this justification will be posted on SAM.gov at least 15 days before the proposed action is taken; if expressions of interest are received, they will be considered accordingly.

10. Statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required

Prior to the expiration of the forthcoming sole source contract for the continuance of the

Evidence Platform, MCC intends to bring the public data sharing portion of the platform website in-house such that all relevant content, user environments, and data curation are managed internally and hosted on MCC.gov. This will require internal coordination and preparation to build the necessary IT infrastructure to design and host MCC knowledge products and datasets, and to plan for the migration of the externally managed platform content onto an MCC-managed one. In this scenario, MCC does not anticipate any future acquisitions for the operation and hosting of the public data sharing portion of the

Evidence Platform. However, MCC may not have the resources to support the restricted data sharing portion of the platform, and in this case, MCC will need to determine what it will do with the restricted data. If the restricted data will need to be housed on a third-party site (as it is now), MCC will explore all options available to remove any barriers to competition that may exist at that time.

11. Certification of the Managing Director of the Program Office:

I certify that the supporting technical data, which form the rationale for a sole source acquisition, is complete and accurate to the best of my knowledge and belief.

Certified by: ___________________________________ Date: _______________

12. Contracts & Grants Management Division Contracting Officer Certification:

Attached is a price determination that the anticipated cost to the Government is fair and reasonable. I certify that this justification is accurate and complete to the best of my knowledge and belief.

Certified by: ____________________________________ Date: _______________

13. Managing Director, Contracts & Grants Management Division:

Certified by: ____________________________________ Date: ________________

(Actions exceeding $1,000,000)

14. Office of General Counsel/Competition Advocate Approval:

Approved by: ___________________________________ Date: ________________

(All actions exceeding micropurchase threshold)