Ombudsman Registry Limited-Sources Justification (LSJ) - FAR 8.405-6_signed.pdf

Limited-Sources Justification (FAR PART 8.406-6)

Ombudsman Registry

Pursuant to the Multiple Award Schedule Program (as authorized by 40 U.S.C. § 501), this justification is prepared in accordance with the requirements of Federal Acquisition Regulation

(FAR) 8.405-6(c) for the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3. The circumstance justifying restriction is FAR 8.405-

6(a)(1)(i)(C) through the following facts and rationale: in the interest of economy and efficiency/logical follow-on.

(1) Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Office of Contract

Operations (CG-9121), proposes to enter into a modification to extend services under an order on the basis of a limited-sources justification (LSJ).

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

(a) Nature of action:

USCG has a requirement on a limited source basis to obtain services for support and maintenance of the Coast Guard’s Ombudsman registry and HSWL Mobile

Application. The Ombudsman registry directly supports the Ombudsman program. The task order requires a six-month extension pursuant to this LSJ The estimated cost to extend the services for six months is $67,549.44. Extension of services increases the total value from $320,197.76 by $67,549.44 to $387,747.20.

(b) Name and address of the contractor:

Raven Multimedia LLC

11440 W Bernardo CT

Suite 300

San Diego, CA 92127-2015

(c) Contract type: Firm-Fixed-Price

(d) Estimated total value (including options):

The current contract was awarded for a Base plus one option year as follows

Period Term Unit Price Total

Base Period 12 Months $11,258.24 $185,098.88

Option 1 12 Months $11,258.24 $135,098.88

Total $320,197.76

This limited sources justification is only for the added service period and is under the simplified acquisition threshold as follows:

Extension 6 Months $11,258.24 $67,549.44

Note: Services under this justification were previously award under GSA Schedule Contract GS-

35F-220DA, task order # 70Z02320FP1D02400, period of performance from 6/4/2020 through

6/3/2022.

(e) Type of funding: Operations and Support funds

(f) Year of funding: Fiscal Year 2022

(g) Contract/Task Order number: Modification to GS-35F-220DA/

70Z02320FP1D02400

(h) Background information about the requirement: The Ombudsman Registry and the HSWL Mobile Application maintains consistent statistical data collection and flow of communication to CG members and their families.

(3) Description of Supplies/Services.

The ombudsman registry is a public facing Software as a Service (SaaS) database of information on command information, ombudsman contact information and ombudsman statistical data. The ombudsman registry provides (1) the ability for CG families to locate their ombudsman and send a secure email to their command/unit ombudsman (2) generate various statistical reports, (3) disseminate information quickly from the program manager to unit ombudsmen, and (4) sustain the CG HSWL Mobile Application for iOS and Android platforms. The Coast Guard required services in support of the Ombudsman Registry and Mobile App.

(4) Identification of the justification and the rationale.

. In accordance with FAR 8.405-6(a)(1)(i)(C) – 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 was not previously issued under sole-source or limited-sources procedures.

In 2020, the USCG awarded a new task order to Raven Multimedia LLC for the Ombudsman

Registry and Mobile Application Services which was solicited via GSA on a competitive basis, with 1 quote received for a POP from 6/4/2020 through 6/3/2022. FAR 52.217-8 (Option to

Extend Services – NOV 1999) was included in the task order terms and conditions. However, a six-month extension of services CLIN was not included in the solicitation nor was price of an extension evaluated. Due to this circumstance, this Limited Source Justification is required to execute FAR Clause 52.217-8.

It is necessary to continue the services of the Ombudsman Registry and the HSWL Mobile

Application in order to maintain consistent statistical data collection and flow of communication to CG members and their families. The current requirement is due for re-competition in FY-22;

however, the program office has combined this requirement with the new requirement for creation of the Personal Financial Management Program Registry. The program office has completed market research for the new requirement and is currently navigating updated cybersecurity cloud service requirements for securing Personally Identifiable Information (PII).

The government will not be able to solicit, evaluate, award, and execute the new requirement until FY-23 which is after the current requirement expires. There is an ongoing need to continue these services while soliciting and awarding the next iteration of this requirement.

The Coast Guard Ombudsman Program is a CG-wide program established to improve mission readiness through family readiness. It is a command-operated program, intended to improve communication between command/units and CG family members. CG ombudsmen are communication links, information and referral resources, and advocates for CG family members.

The ombudsman registry is a critical tool for the ombudsman program as it provides visibility into ombudsman assignments and provides an efficient mechanism to manage and communicate ombudsman program activities. Accurate and immediate dissemination of information to CG family members is a priority. CG ombudsmen maintain family contact information and are able to provide information to family members. Using the ombudsman registry, CG leadership is able to provide information and resources to CG families via the ombudsmen network in a timely manner. Further, the HSWL Mobile Application meets the requirements outlined by Office of

Management and Budget for a high value dataset useful to and useable by the public.

If the six month extended services were awarded to a new vendor, the cost would be much higher for such a short term undertaking primarily due to Assessment and Authorization Services Fees and Cloud Computing Network Implementation Fees that have already been absorbed in the current contract. The vendor would also need to design and develop a similar SaaS to meet the

USCG’s requirement. This would cause significant delays, as a new vendor would have to meet

DoD, DHS and USCG security requirements such as a new Authority to Operate (ATO) while the CG is still trying to compete the combined contract for SaaS. Issuing a logical follow on to

Raven Multimedia LLC is more time and cost effective when considering the potential gap in services time for competing a new requirement and the integration of a new system with a different vendor.

In addition, if a gap in services were experienced the USCG ombudsmen would lose the communication links and ability to effectively provide information and referral resources to CG family members. Therefore, that level of risk is unacceptable and it is in the best interest of the

USCG to award the logical follow on modification to the only vendor who is readily capable and available to provide these necessary services.

(5) Determination by the ordering activity Contracting Officer that the anticipated order represents the best value consistent with 8.404(d).

The Contracting Officer has determined that issuing the proposed task order to extension to

Raven Multimedia LLC represents the best value and will result in the lowest overall cost alternative, considering price and administrative costs, as well as the time and cost associated with a break in service.

This modification will be placed in accordance with FAR 8.404 – Use of Federal Supply

Schedules. General Services Administration, has already negotiated fair and reasonable pricing.

In addition, the Contracting Officer will ensure that the proposed prices for the extension period is fair and reasonable by comparing the proposed prices including level of effort to the previously firm fixed price previously determined fair and reasonable under Task Order

70Z02320FP1D02400 in accordance with FAR 15.404-1(b)(2)(ii), comparison of proposed prices to historical prices paid for the same or similar items. Additionally, the Contracting

Officer will pursue additional discounts to the established schedule pricing as necessary.

The ordering activity has considered the following historical GSA pricing in its assessment:

a) Level of effort and the mix of labor proposed to perform the tasks is reasonable. The level of effort and labor mix is unchanged from the current contract period.

b) The total price is reasonable. The Contracting Officer reviewed the historical pricing of the current requirement.

c) Duplicative cost if the government does not extend the services. A new award will require duplicative costs of at least $50,000.00 to provide assessment and authorization services as well as new cloud computing network implementation services.

d) Additional cost to the government: The government will experience ATO review costs for any new awardee.

Historical pricing is outlined below:

Cost Summary

CLIN Description Monthly Unit Price Extended Price

0001 Base Year

- Assessment and Authorization Services $35,000.00 $35,000.00

- Cloud Computing Network Implementation $15,000.00 $15,000.00

- Estimated Cloud Hosting Fees* $4,788.48 $57,461.76

- Operational Sustainment (Raven managed service) $6,469.76 $77,637.12

Total: $185,098.88

Cost Summary

CLIN Description Monthly Unit Price Extended Price

*Hosting Fees are based on industry best practices for compliance with NIST 800-53 requirements. Specific USCG requirements may result in additional cost.

(6) A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

The program office conducted market research of available vendors via GSA MAS and DHS

SSVs. Raven Multimedia has 17 years’ experience with the Navy Ombudsman program and over

11 years’ experience with the CG Ombudsman program. Past performance has been at least satisfactory, and they have developed significant corporate experience with the CG Ombudsman

Program.

Market Research was conducted in January 2022. Historical costs associated with similar registry requirements were compared with the expected costs for executing the six-month extension. The program office compared the extension price to the recently procured CG

AUXDATA registry. Initial AUXDATA pricing is $143,865 for licenses, $123,000 in transition costs, and $229,000 for sustainment costs.

(7) Any other facts supporting the justification.

The program office’s acquisition strategy is to combine the Ombudsman Registry with the recent congressionally mandated requirement for the CG to provide personal financial management support to its workforce (implemented via a Personal Financial Management Program Registry).

This combined requirement is planned for early FY23. The Contracting Officer has determined that investing in a new procurement for a current requirement that will be replaced later in early

FY23 is not economically or operationally prudent and is not an efficient stewardship of appropriated funds.

(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that preclude the agency from meeting the requirements of 8.405-1 and 8.405-2 before any subsequent acquisition for the supplies or services is made.

1001 Option Year

- Estimated Cloud Hosting Fees* $4,788.48 $57,461.76

- Operational Sustainment (Raven managed service) $6,469.76 $77,637.12

Total: $135,098.88

The government is currently executing pre-solicitation requirements for the acquisition strategy to replace the current Ombudsman Registry with the combined requirement described in paragraph seven (above). Market research indicates sufficient small businesses available via

GSA MAS and DHS SSVs to execute the future requirement. This six-month extension of services provides the most efficient method for maintaining these important services while the new combined requirement is competitively solicited, awarded, and executed.

(9) Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Jeanie Thorne Date

Contracting Officer

(10) Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

M.E. Sowers Date

Technical Representative/COR

APPROVAL:

Jeanie Thorne Date

Contracting Officer

16 May 2022