Redacted_ACL_JA_NASA_SEWP.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (J&A)

ACL Analytics Software Maintenance

NITYU17RC039

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for an Exception to Fair Opportunity.”

a. Requiring/Requesting Activity 555 E. 88th Street Bratenahl, OH 44108

(216) 204-3520 Joshua.s.lisowski.civ@mail.mil

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

Columbus, OH 43213-1152

2. Nature and/or description of the action being approved.

The purpose of this document is to obtain approval for Items Peculiar to One Manufacturer (Brand Name) acquisition in accordance with FAR 16.505(b)(2)(ii)(B). Competition is limited to the following brand name products: ACL.

The procurement strategy is to issue a request for quote (RFQ) on the NASA Solution for Enterprise-Wide Procurement (SEWP), and the fair opportunity procedures set up by the SEWP will be followed. According to those procedures, a RFQ with a brand name requirement must include a justification and approval and be submitted to NASA SEWP Contract Groups. The order at issue includes a brand name requirement. Therefore, the below justification and approval will be included with the RFQ, which will be submitted to two SEWP Contract Groups.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

DFAS I&T Shared Services Directorate requires the software of the software listed below for audit readiness.

Product Name Qty Renewal - AX - Admin Console (Non-Production) 2

Renewal - AX - Admin Console 2 AX Exception Server 1

AX Development 2 AX Admin 2

AX Analysis (Ad-HOC) 10 AX Web 20

AX Remediation 20

DFAS ACL Audit Exchange Premium Support will enable DFAS staff to utilize ACL in the most efficient methods and contact ACL Technical Support in the event assistance is needed. ACL has been used in DFAS for over 10 years.

ACL software provides security and access control to the network portion of Audit Exchange. ACL Analytics is controlled on each user’s computer. Software support will be provided to all DFAS users via telephone or electronic help desk. The software will be installed on servers and will be done at the responsibility of the government.

Standard commercial warranty in accordance with the existing License Agreement.

The estimated cost of this acquisition for a period of performance of nice (9) months is as follows:

Nine Month Period: $XX,XXX; January 17, 2017 through September 30, 2017

4. Identification of the exception to fair opportunity (see 16.505(b)(2)) and the supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited. If the contracting officer uses the logical follow-on exception, the rationale shall describe why the relationship between the initial order and the follow-on is logical.

The purpose of this Justification is to obtain approval to proceed with a e brand name acquisiton product, ACL Software Subscriptions.

With the increase in requirements to reach a state of audit readiness in DFAS, the need to perform data analysis on large data sets, to include analysis in assisting data verification and reconciliations is increasingly important. ACL has been used in DFAS for over 10 years with a cost of $X,XXX,XXX.XX

Consequently, the renewal of the existing software represents the most cost effective approach for DFAS, ensuring continuity of operations without interruption. Implementing a new solution would be costly to DFAS causing significant downtime transitioning between products. The reason for the lengthy transition between products would be due to multiple producted needing implemented as part of the new solution as ACL is the only software on the market that can complete all of the functions mentioned below:

• Risk Based Auditing

• Workpaper Management

• Audit Analytics

• Remote Offline Auditing

• Team-Based Analytics

• Data abd Results Workflow

• Reporting and Dashboarding

In addition ACL is the only software that can complete Audit Management, Compliance Management, IT Goverance, Fraud Management and Operation Risk Management all within the same tool.

This requirement is for the renewal of existing software maintenance already implemented and in place throughout DFAS and is essential to the Government’s requirement. It is in DFAS’ best interest to leverage the current investment in ACL and purchase maintenance, as opposed to competing for a new software product, which would result in substantial duplication of cost to DFAS. The cost of re-procuring licenses and implementing a new product would be costly and not in the best interest of the Government.

5. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

In determining a fair and reasonable price, the Contracting Officer will evaluate a more detailed breakdown from a formal Independent Government Cost Estimate (IGCE). Based on an RFQ issued against the SEWP IDIQ vehicle, it is anticipated the pricing will be fair and reasonable, as determined under the terms and conditions of the RFQ to be submitted to all small business SEWP contract holders. Additionally, price comparisons will also be accomplished from as many other sources as possible, including commercially as well as any Government-Wide Acquisition Contracts (GWAC) and the GSA Federal Supply Schedules.

These items are available from multiple Value Added Resellers on the NASA SEWP schedule. Based on market research, it is anticipated that SEWP pricing will be lower than open market pricing.

6. Any other facts supporting the justification.

Nothing to add to this section that has not already been articulated within this justification document. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

Although a sole manufacturer is needed, there are multiple resellers with the required maintenance package/services available on NASA SEWP. An RFQ will be posted for maximum competition. Competition will be sought among F5 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/16.htm#P464_78748 certified resellers for the best possible pricing. The DFAS Technology Services Organization will continue to research and monitor the market in order to explore alternative solutions in seeking competition and making technology decisions that are in the best interests of the Government.

All eligible sources were contacted for pricing and availability information via NASA SEWP RFI Tool.

The following sources were contacted for pricing and availability information:

XXXXXX

8. The contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

9. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for an exception to fair opportunity) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

Technical Certification

Printed Name

Title Organization Code

Signature Phone Date

Requiring Activity/Program Management Office Certification

Contracting Officer Certification I hereby determine that the anticipated cost for this contract action will be fair and reasonable. I certify that this J&A is accurate and complete to the best of my knowledge and belief.

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