P03_JA FAR 13.501 Sole Source over SAT_.pdf

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A)

For

Sole Source Acquisition (>SAT-$7.5M under FAR 13.5)

1. Contracting Activity:

Department of Veterans Affairs

Veterans Benefits Administration (VBA)

Office of Mission Support (OMS), Acquisition Division

Washington, DC 20006.

2. Nature and/or Description of the Action Being Processed:

This Sole Source Justification and Approval sets forth the facts and requests approval for the issuance of a short-term firm-fixed price contract action to the small business vendor Veros Real Estate

Solutions LLC (UEI: KLGSU472K6F1), pursuant to sole source procedures IAW FAR 13.501. This is an unusual and compelling urgent requirement which precludes full and open competition and delay in award of this proposed sole source contract would result in serious operational delays in the

Government’s ability to service Veteran home loan appraisals and approvals.

3. Description of Supplies/Services Required to Meet the Agency’s Needs:

The Loan Guaranty Service (LGY) requires Appraisal Management Service (AMS) contracted services to improve standardization, risk management, performance, as well as the credibility and quality of valuation functions for all loans administered under the VA-guaranteed home loan benefit program.

The proposed six (6)-month sole source contract is estimated at $1,979,000.00.

Failure to provide these services will prevent LGY from continuing enhanced Construction and

Valuation (C&V) oversight and may delay the Veterans ability to receive timely appraisal reports.

These services assist in the improvement of individual appraisal report quality and appraiser performance, while streamlining and standardizing the appraisal review process. These efforts contribute to protecting the interests of Veterans and the Government in the administration of the VA-guaranteed home loan benefit.

The current AMS contract is under the jurisdiction of the Strategic Acquisition Center – Frederick

(SAC-F). The AMS contract has already been extended utilizing FAR 52.217-8 and we have been advised additional extensions are not authorized. The current AMS contract will expire on 18-Jan-

2025.

The LGY team is expeditiously working to provide VBA Acquisitions with a complete and actionable procurement package to re-procure AMS contracted services before the current AMS contract expires. The service line is aware of the established Procurement Lead Time (PLT) for the follow-on estimated value and fully understands that time is not on the service lines side. This proposed short term contract action would greatly reduce the chance of AMS service disruption and reduce the chances of Veterans being unable to receive appraisals and potentially home loans, as well as allow for time needed for the service line to develop and submit a follow-on procurement package.

4. Statutory Authority Permitting Restricted Competition:

This acquisition is being conducted following Simplified Procedures for Commercial Items in FAR

13.5 in accordance with 41 USC 1901 or 41 USC 1903 and documented as required by FAR 13.501.

5. Demonstration of the Contractor’s Unique Qualifications:

The incumbent vendor Veros Real Estate Solutions LLC holds the current contract for LGY

Appraisal Management Service (AMS) for the VBA with a base year period of performance 18-July-

2019 to 17-July-2020, with 4 annual option years. Option Year 4 concluded on 17-July-2024, prior to that date a six (6)-month extension was processed, and the current expiration date is 18-Jan-2025.

The service line anticipates that a follow-on vendor would require up to six (6)-months to be fully approved, integrated and operational for use. Due to modernization efforts the follow-on procurement package is still being developed by the service line. Consequently, this proposed sole source short term contract is considered an urgent and compelling requirement due to time limitations, and because a delayed award will cause significant operational disruptions to VBA’s Loan Guaranty

Service (LGY), which will significantly hinder the VBA’s ability to provide home loan services in a timely and efficient manner to the nations Veterans.

The incumbent vendor Veros Real Estate Solutions LLC is currently using proprietary products and services and has significant knowledge of the VBA’s policies and procedures. If an alternate vendor were selected for a short-term bridge contract, all stakeholders participating in the VA’s appraisal review process would need to receive training on new product/services, to include but not limited to how to read and interpret scoring reports and basic nuances of a new system, this training would necessitate significant time and resources for the VA to accomplish. A new vendor would also need to be able to provide an Appraiser Assisted Automated Valuation Model and provide training to adequately process and service Reconsideration of Value (ROV) requests. In addition, a new vendor could also cause a disruption in data collection collected during approved scanning procedures. Lastly

VEROS currently has an establish connection with WebLGY, establishing a new connection for an alternate vendor would require a significant time commitment to complete, which would cause a deterioration in services.

By awarding this proposed sole source action to VEROS Real Estate Solutions LLC, the VBA will have pricing and operational consistency, and will avoid delays related to processing times needed to complete a follow-on requirement package, synopsize the requirement, search for sources, solicit and evaluate quotes. Thus, this proposed sole source action provides less risk and is more advantageous to the Government.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:

The proposed six (6)-month sole source contract action will not be synopsized per exception under

FAR subpart 5.202(a)(2). The proposed contract action is made under unusual and compelling urgency per FAR Subpart 13.501 for purchases conducted using simplified acquisition procedures.

This requirement is part of a recompete effort under a procurement that is ending on 18-Jan-2025.

The VBA service line is actively creating a procurement package that includes the incorporation of modernization requirements into the PWS. Thus, this proposed six (6)-month sole source contract action is to ensure there is no gap in services while the follow-on procurement package is drafted, submitted, and procured. No other sources will be sought due to time limitations.

7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be

Fair and Reasonable:

The vendors proposed pricing for the requested six (6)-month extension will be evaluated as compared to the current contract to determine fair and reasonable.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted:

IAW FAR Part 10.002(b)(1), market research was conducted for the initial award of expiring contract

36C10X19C0033, which corresponds with this requirement. Market research was conducted and potential sources were located, however due to the anticipated time to on-board a new vendor and due to the urgency of this requirement, it is in the best interest of the Government and Veterans to award a short term contract to the incumbent vendor Veros Real Estate Solutions LLC.

9. Any Other Facts Supporting the lack of competition:

Due to the service line pending modernization a follow-on procurement package is taking longer than anticipated to develop and as a result is still currently being developed. As a result, a follow-on contract is not anticipated being complete by the time the existing contract has concluded, a lapse in services would greatly impact Veterans ability to secure a VA home loan.

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:

None.

11. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required:

This requirement is part of a recompete effort under a procurement package being actively developed by the service line. This proposed six (6)-month sole source, short-term contract action is to ensure there is no gap in services while the follow-on procurement package is completed, submitted and procured. Using the speculated dollar value of a follow-on procurement and established PALT times once a complete and actionable procurement package is submitted and accepted it is anticipated that an award can be made in approximately 150 days.

12. Requirements Certification: I certify that the requirement outlined in this justification is a Bona

Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Name Date

Title

13. Approvals:

a. Contracting Officer’s Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer Date

b. Supervisory Contract Specialist (required for actions valued >SAT-$750K): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief and approve.

Jorge Martin Date

Supervisor Contract Specialist

HIGHER LEVEL APPROVAL (required for actions over $750K):

c. Designated Contracting Activity Advocate for Competition or Head of Contracting Activity

(HCA): (over $750K to $7.5M): I have reviewed the foregoing justification and find it to be complete and accurate to the best of my knowledge and belief and approve.

Alyssa M. Dark, Director Date

Acquisition Directorate

Advocate for Competition for the VBA