N0018917CZ022_FMO_IA_JA_Redacted.pdf

Source Selection Information – FAR 2.101 and 3.104

DEPARTMENT OF THE NAVY

NAVSUP FLEET LOGISTICS CENTER NORFOLK

700 ROBBINS AVE, BLDG 2B

PHILADELPHIA, PA 19111-5083

IN REPLY REFER TO:

J&A 19-018

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. IDENTIFICATION OF AGENCY AND CONTRACTING ACTIVITY.

The requiring activity is the Assistant Secretary of the Navy, Financial Management & Comptroller ASN (FM&C), The Office of Financial Operations (FMO), Washington DC; the contracting activity is the Navy Supply Systems Command Fleet Logistics Center Norfolk, Philadelphia Office (NAVSUP FLCN).

2. Description of the Action Being Approved.

The use of other than full and open competition to award a firm-fixed price modification to contract N00189-17-C-Z022, with Iron Arch Technology, LLC, of McLean, VA. FMO requires additional support to the Commander Naval Forces Europe (CNE) Command for the Improper Payment Program (IPP).

3. Description of Supplies/Services.

The proposed acquisition is for the procurement of increased support under the Improper Payments Program (IPP) under contract N00189-17-C-Z022, in order to address pending issues with CNE and their increased risk of improper payments. The term for this additional work is expected to run 1 January 2019 through 14 March 2019.

The current contract supports FMO Operations Management Division (OMD), which includes Improper Payments Elimination and Recovery Act Program (IPERA). The IPERA Program is a DOD program with significant high-level scrutiny. A DOD IG finding found that there are many instances of non-compliance with IPERA within the military Departments. Incorrect payments are being made to DoD employees and vendors, many of them overpayments. The DON has made improper payments a material weakness on its Statement of Assurance, and FMO has the lead to correct this deficiency.

Improper payment material challenges were recently discovered at Command, Naval Forces Europe (CNE). The Under Secretary of the Navy has asked FMO to send resources to assist CNE in correcting these deficiencies. IronArch is the only vendor capable to immediately address and remediate the findings. The vendor will help CNE to identify process disconnects, draft sustainment policy and procedures to correct them, and eventually test sustainment efforts.

The total estimated amount for this action is

4. Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 USC 2304(c)(2), unusual and compelling urgency.

5. Rationale Justifying Use of Cited Statutory Authority.

Pending issues at the Commander Naval Forces Europe (CNE) command, specifically associated with the Host Nation Program are resulting in an unacceptable and increased level of risk for improper payments. The Host Nation Program is a US-managed agreement among NATO nations in the Mediterranean area to equitably share expenses for joint operations. Therefore, increased process controls and more robust standard operating procedures must be immediately put into place to preclude improper payments for this highly-visible program. Iron Arch is the only firm who can immediately commence performing the increased level of vigilance that is required by CNE as a result of their ongoing Navy-wide support to prevent improper payments, which has been evaluated by Naval Audit Service as being effective. Only Iron Arch, both as a result of its ongoing performance under this contract and its familiarity with Navy’s Commercial Bill Pay Office in Naples, can immediately commence providing the required support to CNE by integrating business processes with compliant statistical estimation methodology, root-cause analysis to drive corrective action, advanced predictive modeling to prevent future improper payments, and automated IT solutions to drive success. Improper payments in an international overseas program could harm international relations. Contractor support is urgently needed to identify potential risk for waste, fraud, and abuse and produce an effective set of internal controls. Iron Arch can provide the urgently-needed support with virtually no start-up time; so the proposed modification is in the best interests of the Navy. A firm other than Iron Arch would have an extensive learning curve, which would not be offset by competing this effort at this time.

Now the pressing need for immediate support necessitates adding this enhanced coverage for CNE to the above referenced (current) contract with Iron Arch which expires on 3/15/19.

Additionally, it is noted that the need for further support beyond 3/15/19 will be included in the competitive follow-on solicitation/contract to Iron Arch’s current contract.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

A competitive, long term follow-on is in process. However, as noted above, contractor support is urgently needed to identify potential risk. Failure to provide this support immediately could be detrimental to the Navy’s involvement with the Host Nation Program.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined the anticipated cost to the Government of the supplies/services covered by the J&A will be fair and reasonable.

8. Actions to Remove Barriers to Future Competition.

As stated in paragraph 6 above, a follow-on to this contract is in process. The current contract ends 14 March 2019. The follow-on to the requirement is being competed as a set aside for SDVOSB. It is anticipated that at least two quotes will be received.

9. CONTRACTING POINT OF CONTACT

The NAVSUP FLCN point of contact for this contract action is Stephanie Murphy, who can be reached by email at stephanie.m.murphy@navy.mil and by phone at (215) 697-9619.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION