LSJ_MCICOM_FIAR_Inventory_FINAL_Redacted.pdf

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USMC MCICOM 100% Real Property Audit
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MCICOM-JA-19-007
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Exception to Fair Opportunity LSJ&A

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UNITED STATES MARINE CORPS

MARINE CORPS INSTALLATIONS COMMAND

3000 MARINE CORPS PENTAGON

WASHINGTON, DC 20350-3000

IN REPLY REFER TO

Source Selection Information – See FAR 2.101 & 3.104 1

MCICOM-JA-19-007

05 July 2019 Limited Source Justification and Approval Exceptions to the Fair Opportunity Process

Under the Authority of FAR 16.505(b)(2)(ii)(B)

1. Identification of the Contracting Activity and the Requiring Agency.

The Contracting Activity is the Marine Corps Installation Command (MCICOM) HQ Contracting located in Arlington, VA. The Requiring Agency is DC, Installations and Logistics (I&L) and Marine Corps Installations Command (MCICOM) located in Washington, D.C.

2. Nature and/or Description of the Action Being Approved.

The action being approved is for the award of a modification to task orders N00189-18-F- Z424/Continued Contract M95494-19-F-0044 for Financial Statement Audit Remediation for Property Plant and Equipment Inventory of Related Property for Headquarters Marine Corps, Deputy Commandant for Installation and Logistics.

3. Description of the Supplies/Services Required to Meet the Agency’s Needs (including the estimated value).

This specific effort is a 100% physical Existence and Completeness Inventory directed to be completed by 30 September 2019 specifically addressing the identification of the following attributes utilizing the outlined business process:

Attributes

a) Asset Number

b) Facility Category Code

c) Preponderant User

d) Operational Status

e) Asset Size

General Business Process outline:

1) Obtain system documentation to support assets

2) Reconcile documentation to iNFADS

3) Obtain maps for asset locations

4) Complete asset review (attributes above)

5) Report interim status

6) Conduct quality control: Review any discrepancies

7) Conduct a Government internal quality assurance and control: Complete and endorse inventory packages

The goal is to formulate teams based on region size, asset quantities, and nuanced asset/location complexities as follows:

Source Selection Information – See FAR 2.101 & 3.104 2

- One (1) Real Property Accountable Officer per installation for training, oversight, and quality review

- One (1) Public Works personnel per installation for training, oversight and quality review

- Total estimated team size of 11 in addition to RPAOs and Public Works personnel

Installation and quantity of assets:

1) 1st District: 29 Assets

2) 8th & I: 122 Assets

3) MCGCC 29 Palms: 6,138 Assets

4) MCLB Albany: 942 As Assets sets

5) MCLB Barstow: 562

6) MCAS Beaufort: 4,296 Assets

7) MCSF Blount Island: 326 Assets

8) MCB Butler: 7,064 Assets

9) MCAS Cherry Point: 1,766 Assets

10) MCAS Iwakuni: 2,725 Assets

11) MCB Hawaii: 2,793 Assets

12) MCB Camp Lejeune / MCAS New River: 10,341 Assets

13) Marine Forces Reserve: 1,592 Assets

14) MCAS Miramar: 1,752 Assets

15) MCB Muchuk: 880 Assets

16) MCB Pendleton: 9,557 Assets

17) MCRD Parris Island: 895 Assets

18) MCB Quantico: 1,792 Assets

19) MCRD San Diego: 530 Assets

20) MCAS Yuma: 1,695 Assets

It is estimated that a total of support personnel (equivalent to hours) will be needed to complete these efforts by the established due date based on a completion of 6 assets per hour projection. The estimated cost to perform this accelerated inventory task for the installation is . Operations and Maintenance (O&M) funds will be used.

4. Identification of the Exception to Fair Opportunity and Supporting Rationale.

FAR 16.505(b)(2)(i)(C) The requirement is to be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract. All awardees were given a fair opportunity to be considered for the original order.

Considering the deliverables and efforts are performed as part of Task Order N00189-18-F- Z425/Continued Contract M95494-19-F-0045 (ref Section 2 paragraph 2.1.1.3 and CDRL A001 & A003) where the deliverables support the Governments audit activities related to inventory assessments of real property, the efforts are directly aligned to the work being performed. The Secretary of Defense (SECDEF) and the Secretary of the Navy (SECNAV) have both directed that the Department of Navy (DON) conduct a complete real property asset existence and completeness inventory and improve end-to-end processes by the end of FY19. This in turn resulted in MCICOM being directed to conduct a 100% inventory validation of real property assets which lead to all Commanders being required to establish a baseline for USMC real

Source Selection Information – See FAR 2.101 & 3.104 3 property assets through conducting a 100% Existence and Completeness (E&C) inventory of all real property assets at their respective Marine Corps base, station, installation and other associated specialty logistics area locations by 30 September 2019.

Under the current Marine Corps task order, KPMG has been providing audit advisory and remediation services which included the execution of an inventory validation process. Due to the accelerated timeframe directed by Navy FM&C and OUSD where this inventory has to be completed by the end of FY19, KPMG is the most economic and efficient option for the government to satisfy this need based on their experience within Marine Corps Installations Command and overall support provided for existing asset inventory efforts.

These efforts directly support Marine Corps Installations requirement to complete a full existence and completeness (E&C) baseline of all Real Property assets (100%) against the accountable property system of record within internet Naval Facilities Assets Database (iNFADS).

Based on the above, KPMG is the only source that can satisfy agency requirements within the timeframes and schedules provided.

5. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer conducted further price analysis to determine if the estimated level of effort to be added to this (time & materials) task order is reasonable. The anticipated cost to the Government for the increased level of services covered by this limited sources justification is in line with the current rates outlined in the Task Order. The level of effort is commensurate with the estimated amount of time needed to complete the inventory effort at the specified locations for the number of assets identified by the deadline date established. Based on complexity, level of effort and estimated labor categories multiplied by the applicable rates, the price is determined fair and reasonable. The applicable rates were determined fair and reasonable at award.

6. Other Facts Supporting the Justification

Market research was performed which included reviewing the scope and duration of this requirement against the contractors efforts and capabilities to meet its current requirements in addition to considering the increased and accelerated schedule for a real asset audit inventory.

The market research also found that historically, on-boarding periods for conducting an inventory of this scope are cumbersome and may significantly delay schedules and completion of the needed inventory by the established due date. The contractors direct past performance with similarly scoped inventory efforts under this same task order in support of Marine Corps Logistics Command will help to reduce the training and ramp-on time to conduct this inventory within the deadlines and timeframes established by the DON.

7. Actions to Remove or Overcome Barriers that led to the Exception to Fair Opportunity.

Upon completion of the Task Order Optional Period of Performance, the Marine Corps intends to compete the services initially awarded for audit inventory support by using fair opportunity procedures. The increased level of effort to be placed on this task order for the added task requirements and deliverables has the estimated completion date scheduled for 30 Sept 2019.

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