Justification__Approval_Eagle_FBO.pdf

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION FOR OTHER THAN SIMPLIFIED ACQUISITIONS (FAR Part 6)

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Sole Source Justification”

a. Federal agency: Pension Benefit Guaranty Corporation (PBGC)

b. Contracting Activity: TAS Software and Hosting Services

c. Project Officer Information:

• Project Officer Name: Tracy Soforenko

• Department: OIT/IT & Business Modernization

• Office No.: 5549

• Phone: 202 326-4000 x3943

d. Type of Document Justification and Approval

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

a. Acquisition purpose and objectives.

The Trust Accounting System (TAS) is an investment portfolio and accounting solution managed by the Financial Operations Department (FOD) to support the accounting and financial reporting of investment assets, plan receivables, and liabilities related to terminated pension plans and the commingled investment portfolio through an application service provider model. The application is hosted by the Application Service Provider (ASP) Eagle Investment Systems LLC in Pittsburgh, PA. The hosting model provides PBGC with dedicated support for release management and upgrades of Eagle’s hardware and infrastructure. The TAS is based on the commercial off-the-shelf (COTS) product, Eagle Investment Systems LLC Accounting and Data Management Solution (ADMS). In addition, Eagle Professional Services may be requested on an as-needed basis.

b. Project background.

Alternatives Analysis: Between August 2009 and November 2009, PBGC conducted an alternatives analysis to determine the most appropriate approach for delivering the required Trust Accounting functionality. A Commercial Outsource model was selected from amongst available alternatives.

Full Service ASP Implementation Acquisition: In 2010, PBGC contracted with Booz Allen Hamilton (BAH) to perform an evaluation of available products/services and implement the selected products/services as a full service TAS solution.

COTS Product Selection Approach: The TAS team followed a structured and thorough approach in evaluating the available COTS products for implementation at

PBGC.

From September 2010 through May 2011, the Portfolio Investment Systems market was evaluated by conducting extensive market research using various research methods including reviews of Gartner studies, online profiles, trade publications, the team’s industry experience, and other industry sources. Twenty-four vendors in the market were evaluated based on the market research and a “long list” of 14 vendors were determined to have enough fit for further analysis.

Approximately 110 requirements were documented and prioritized during discussions with PBGC TAS user groups and those requirements were presented to the long list of vendors in a Request for Information (RFI). The requirements were functional and non-functional. Twelve product vendors highlighted their products in responses to the RFI. The twelve products were then filtered to a “short list” of three products using evaluation criteria that were established with the TAS stakeholders. The vendors in the short list were invited to demonstrate their solutions to PBGC based on PBGC-specific use cases. The products were evaluated hands-on from a functional and technical perspective. The TAS team also assessed risks to the PBGC for each short list solution.

In May 2011, PBGC chose the Eagle COTS product from among the commercially available options based on its best fit to PBGC’s requirements.

ASP Implementation: PBGC worked to configure the Eagle ADMS product to fully meet PBGC requirements and integrate the application with PBGC internal applications along with Interactive Data corporation’s (IDC) Securities Pricing Service and the Electra Information systems Bank Data Aggregation Service. In September 2011, BAH executed a sub-contract with Eagle Investment Systems for use of the ADMS product through June 30, 2013 along with supplemental Eagle Professional Services and support for FISMA compliance.

Production Operation: TAS began production operation in January 2013. TAS serves as PBGC’s system of record for the Trust Fund.

c. Project Value and Timeframe.

Based on market research conducted before and during the TAS Investment Package Evaluation, the Investment Industry provides the most favorable pricing if agreements are five years in duration. Understanding the limitations of federal contracts, this contract is defined as a base year and 4 one-year option periods beginning July 1, 2013.

Based on our draft Independent Government cost Estimate, we anticipate a contract across the five options valued at $5.8 Million.

d. Authority.

This contract action is being sought under the FAR 6.302-1, only one responsible source and no other supplies or services will satisfy agency requirements.

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

PBGC requires the following services from Eagle:

Eagle ADMS Usage including a Production environment, a disaster response (COOP) environment if required and a Test environment

Additional Environments to support PBGC’s development and user acceptance testing of PBGC specific configurations and integration

Information Technology Security Continuous Monitoring – Support from Eagle Access resources to continuously improve the security posture of the Eagle environment and application to meet the requirements under the Federal Information Security & Management Act.

Eagle Professional Services (Optional) - should PBGC require expert support from Eagle beyond the scope of those services already provided under the Usage agreement, PBGC will be able to tap Eagle’s Professional Services to obtain access to Eagle’s in-house product experts.

The table below outlines the anticipated dollar value of these services over the base and 4 option years.

Component of Service Base Year Option Year 1 Option Year 2 Option Year 3 Option Year 4 Contract

Total Eagle ADMS Usage $775,000 $775,000 $775,000 $775,000 $775,000 $3,875,000 Additional Environments for Development & System Testing $80,000 $80,000 $80,000 $80,000 $80,000 $400,000 Security Continuous Monitoring $150,000 $150,000 $150,000 $150,000 $150,000 $750,000 Eagle Professional Services (Optional) $150,000 $150,000 $150,000 $150,000 $150,000 $750,000 Other Direct Costs $5,000 $5,000 $5,000 $5,000 $5,000 $25,000 Total $1,160,000 $1,160,000 $1,160,000 $1,160,000 $1,160,000 $5,800,000

4. An identification of the statutory authority permitting other than full and open competition.

The specific authority allowing this action is FAR 6.302-1. Only one responsible source and no other supplies or services will satisfy agency requirements.

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The only company able to provide and host the Eagle ADMS application is Eagle Investment Systems. The Eagle ADMS application is a commercial off the shelf software product developed and supported exclusively by Eagle Investment Systems.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies.

A notice will be posted on FedBizOpps advising of the intent to award this as an Sole Source procurement.

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

The contracting officer will perform a price analysis to ensure the price to the Government will be fair and reasonable.

8. A description of the market research conducted and the results or a statement of the reason market research was not conducted.

Extensive market research was performed during FY 2010 and FY 2011 leading to the selection of Eagle ADMS as the PBGC TAS Application Service Provider.

In March 2013, PBGC confirmed that Eagle Investment Systems remains as the only application service provider of the Eagle ADMS application.

9. Any other facts supporting the use of other than full and open competition, such as:

(i) Explanation of why technical data packages, specifications, engineering descriptions, statements of work, or purchase descriptions suitable for full and open competition have not been developed or are not available.

(ii) When 6.302-1 is cited for follow-on acquisitions as described in 6.302-1(a)(2)(ii), an estimate of the cost to the Government that would be duplicated and how the estimate was derived.

(iii) When 6.302-2 is cited, data, estimated cost, or other rationale as to the extent and nature of the harm to the Government.

N/A

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

N/A

11. 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 acquisition for the supplies or services is made.

N/A

12. 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.

I, Mark Miller, hereby certify that this justification and all the data supporting this justification are accurate and complete to the best of my knowledge and belief.

Original Signed Mark Miller, Contracting Officer Date:

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.

In terms of the rationale for limited sources; I, Theodore J. Winter, Jr. hereby certify that this justification is complete and accurate.

Original Signed Theodore J. Winter, Jr.

Financial Operations Department Director

Date:

13. Reviews and Approvals.

Original Signed Steven Kvalevog, Competition Advocate Date: