P42 LOCCS_LSJ Justification REDACTED.pdf

J&A Log Number: 23-13

ATTACHMENT 1

LIMITED SOURCE JUSTIFICATION

Federal Supply Schedule Orders Exceeding the Simplified Acquisition Threshold

For Line of Credit Control System (LOCCS)

i. IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY, AND SPECIFIC IDENTIFICATION OF THE DOCUMENT AS A “LIMITED-

SOURCES JUSTIFICATION”.

Agency: U.S. Department of Housing and Urban Development (HUD), 451 7th Street SW, Rm 3106, Washington, D.CC 20410 Contracting Activity: Office of Chief Procurement Officer, Headquarters Program Office: Office of the Chief Financial Officer (OCFO)

ii. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED.

Approval is being sought to enter into a sole source bridge contract/task order with Lamb Informatics Ltd to procure Operations and Maintenance (O&M) and continuing support for the Line of Credit Control System (LOCCS).

Method of Contracting: New Contract (Bridge contract) Type of contract: Firm Fixed Price Type of Funds: This contract action will be funded with Office of the Chief Information Officer (OCIO) IT funds as well as separate funding for the Green and Resilient Retrofit Program

(GRRP).

iii. A DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET

THE AGENCY’S NEEDS (INCLUDING THE ESTIMATED VALUE).

The Office of the Chief Financial Officer (OCFO) requires O&M Services ensuring LOCCS remains fully operational. Service include Software maintenance efforts such as Corrective Maintenance, Troubleshooting User Support, Technical Support, Steady State Maintenance Level 2, Operational Support, Routine System Checks/COOP; Database Administration, OCFO Security, Year End Close, Project Management and Transition Out tasking.

Period of Performance: 04/01/2023 – 03/31/2024 Estimated Total Dollar Value:

iv. THE AUTHORITY AND SUPPORTING RATIONALE (SEE 8.405-6 (a)(1)(i) AND (b)(1)) AND, IF APPLICABLE, A DEMONSTRATION OF THE PROPOSED

CONTRACTOR’S UNIQUE QUALIFICATIONS TO PROVIDE THE

REQUIRED SUPPLY OR SERVICE.

Authority: FAR 8.405-6 (a)(1)(i)(A) An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

The incumbent contractor, Lamb Informatics Ltd, located at 4000 Legato Road, Suite 600 Fairfax, VA 22033, is the only capable source that can satisfy the Department’s requirement within the established timeframe and with the required specialized knowledge.

Lamb Informatics Ltd is uniquely qualified to provide the O&M support services required for this acquisition. They have successfully provided LOCCS O&M support services for the past six (6) years under contract DU100I-17-T-00001 and task order 86615322F00001, from December 2017- March 31, 2023. The vendor currently has staff in place to provide the continued technical, functional and management support required to ensure the successful O&M of LOCCS and is the only company that can provide the continued O&M Services required considering the time constraints to award and transition of a new contract. Lamb Informatics Ltd is currently providing the services and is capable of continuing support without interruption for this mission critical financial system.

Delay in providing these services creates unacceptable risk to the operations and mission of HUD and could negatively impact the stability of the Housing and Financial markets. The technical and subject matter expertise possessed by the Lamb Informatics Ltd staff will ensure the continued successful O&M support of LOCCS until the award of solicitation #86615322Q00028 to either the incumbent or follow-on vendor. The LOCCS system has congressional overview and connects HUD's program management information systems to HUD's program accounting data. With fifty million records in its database, LOCCS serves 158 HUD programs and 62,000 grantees, controlling payments for over 600,000 grants. Annual disbursements from LOCCS exceed $30 billion. Should the program fail, grantees such as Public and Indian Housing and Section 8 programs would not receive the funding necessary to continue.

v. A DETERMINATION BY THE ORDERING ACTIVITY CONTRACTING

OFFICER THAT THE ORDER REPRESENT THE BEST VALUE CONSIST

WITH 8.404(d).

In accordance with FAR 8.404(d), the ordering activity Contracting Officer will determine that the order represents the best value and results in the lowest overall cost to meet the Government’s needs. The price evaluation will be in accordance with FAR 8.405-2(d).

vi. A DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG

SCHEDULE HOLDERS AND THE RESULTS OR A STATEMENT OF THE

REASON MARKET RESEARCH WAS NOT CONDUCTED.

Market Research determined that there are three vendor, sans the current one, that appear to have the capabilities to support this requirement. They have been included in the Market Research for the re-compete solicitation #86615322Q00028. However for this bridge action, the only capable vendor that can do the work at this time is the incumbent, Lamb Informatics Ltd.

vii. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION.

This requirement is for the Operations and Maintenance (O&M) Services required to sustain LOCCS. Software maintenance efforts include Corrective Maintenance, Troubleshooting User Support, Technical Support, Steady State Maintenance Level 2 (SSML2), Operational Support, Routine System Checks/COOP; Database Administration, OCFO Security, Year End Close, Project Management and Transition Out tasking. Services include ensuring LOCCS remains fully operational. These services are currently provided by Lamb Informatics Ltd. under contract number GS-35F-347AA/86615322F00001. The current contract expires March 31, 2023.

In the event a sole source bridge contract is not executed for the required O&M services, LOCCS could fail or degrade to the point where the system would cease to serve as an effective “mission critical” Departmental Financial Management application (Please refer to final paragraph in section iv for impact of degradation).

LOCCS is an on-line, multi-user disbursement and cash management system used by HUD Accounting, Program staff and HUD’s business partners. The LOCCS system controls Departmental disbursements in accordance with directives from The Department of the Treasury (Treasury) and the Office of Management and Budget (OMB). It is both a payment system and a HUD post-award financial grants management system and is available six days a week to serve the funding needs of HUD's grant, loan, and subsidy clients. The LOCCS system authorizes disbursements to a broad range of recipients including Public Housing Agencies, State Governments, Municipalities, Independent companies, Non-profit Institutions, and individuals.

The LOCCS system accepts invoices from business partners and/or HUD staff on behalf of a business partner and makes decisions regarding approving or rejecting payment based on program rules. Approved payments are sent to Treasury for payment and the associated accounting transactions are posted.

viii. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS THAT LED TO THE

RESTRICTED CONSIDERATION BEFORE ANY SUBSEQUENT ACQUISTION

FOR THE SUPPLIES OR SERVICES IS MADE.

Re-acquisition of LOCCS O&M services is currently on-going through competitive actions by the Department through procurement services offered by General Services Administration (GSA), National Capital Region (NCR), Federal Acquisition Service (FAS) solicitation #86615322Q00028. At this time there is no estimated award date established, but it is anticipated within the period of performance of this sole source bridge contract.

ix. THE ORDERING ACTIVITY CONTRACTING OFFICER’S CERTIFICATION

THAT THE JUSTIFICATION IS ACCURATE AND COMPLETE TO THE BEST

OF THE CONTRACTING OFFICER’S KNOWLEDGE AND BELIEF.

The ordering activity Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief is evident by the Contracting Officer’s signature at Part 2, Contracting Officer’s Determination and Certification on the Form HUD-24013.

x. 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 LIMITED SOURCES) AND

WHICH FORM A BASIS FOR THE JUSTIFICATION HAVE BEEN CERTIFIED

AS COMPLETE AND ACCURATE BY THE TECHNICAL OR

REQUIREMENTS PERSONNEL.

Any supporting data that is the responsibility of technical or requirements personnel and which forms a basis for the justification have been certified as complete and accurate by the technical or requirements personnel as evident by the Assistant Chief Financial Officer for Systems signature at Part 1, Program Office Official’s Certification on the Form HUD-24013.

xi. FOR JUSTIFICATIONS UNDER 8.405-6(a)(1), A WRITTEN DETERMINATION

BY THE APPROVING OFFICIAL IDENTIFYING THE CIRCUMSTANCE

THAT APPLIES.

A written determination by the approving official identifying the circumstance that applies has been provided as evident by the Approving Official’s signature at Part 3, Approvals on the Form

HUD-24013.