PEPS Sole Source Justification_draft2223V6AWFINAL.pdf

Version 1.2

January 19, 2023

SOLE SOURCE JUSTIFICATION

FOR AN ACTION EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

USING SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS

91003118C0010 – Creative Ideas Simple Solutions, Inc. (CISS)

1. Agency and contracting activity. Department of Education, Office of Federal Student Aid (FSA), Acquisition Directorate, and the Partner Participation and Oversight Division (PPO).

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

The Postsecondary Education Participants System (PEPS) is the Office of Federal Student Aid (FSA) management information system of all organizations that have a role in administering student financial aid and other Higher Education Act programs. PEPS maintains eligibility, certification, demographic, financial, review, audit and default rate data about schools, lenders, and guarantors participating in the Title IV programs.

The purpose of this Sole Source Justification is to extend the period of performance of contract number 91003118C0012 (Contract) with Creative Ideas Simple Solutions, (CISS) contractor for 3 months. The Contract is a firm-fixed price, sole source contract to provide work and the tasks required for continued and effective operations and maintenance (O&M) of the PEPS system.

The requested 3-month extension will allow PEPS to continue to meet its program needs. This new extension provides the Government the necessary time to work with Next Gen PPO and other program offices, as the implementation of the long-term solution is in the process of being completed with a go-live date expected within the next 3 months. This extension will include three 1-month options, which could allow up to a total of 9 months of service which ensures a continuity of operations and improved administration of Title IV services as FSA finalizes implementation and completes transitioning in the event of any delays.

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

FSA requires continued services, operations, maintenance, system security, disaster recovery, development, and program management for PEPS and the web-based eligibility application that feeds PEPS (eApp). The services include all operations, maintenance, system security, disaster recovery, development, and program management for PEPS and eApp. The services also include the exit transition of services. The stated scope of services facilitates FSA’s program integrity efforts and assists with the required oversight of institutions participating in FSA’s Title IV programs. The total estimated value of this contract for the 3-month base and three 1-month options is estimated to be $656,156.58.

4. Statutory authority permitting the sole source extension acquisition. This procurement action will be awarded in accordance with 41 USC 1901.

(EDFSA-18-C-0018 - PEPS)

5. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited. The contracting officer has determined the following circumstances justify the use of a sole source as supported below:

Only one source – Only one source can provide the services required at the level of quality required because the services are unique or highly specialized.

The use of this authority is supported by the contractor’s unique qualifications. The same contractor, CISS, has employees that have operated and maintained the PEPS system, for over 20 years. The current system and the platform it uses play a significant factor in FSA’s current data migration and testing support and the need to continue with the incumbent vendor until the Next Gen Partner Connect environment is available and deployed. FSA has determined a significant amount of risk and transition time would be incurred by having a new vendor assume operations and maintenance for the current configuration of the underlying system. The short, 3-month period of performance for this contract, does not allow time for a recompete and the necessary time needed to get another vendor onboarded.

In the event of a lapse in service, the legacy system will not supply critical data, via interface, to COD, NSLDS, DOD, EZ-Audit, FMS, EDWA, G5, and other FSA Title IV delivery systems that facilitate financial aid being administered accurately and timely to institutions and students. The school file that is used by DOD and other agencies to support Title IV eligibility determinations for DOD tuition assistance would also be disrupted. These impacts would affect the administration, monitoring, and oversight of institutions (i.e. Schools, Guaranteed Agencies, Lenders, and Servicers) participating in the Federal Student Aid programs. An interruption in service would cause the PEPS system to shut down and school eligibility and oversight work would come to a halt, thus negating the Department’s responsibility of ensuring that post-secondary institutions participating in the Federal Student Aid programs meet the requirements under Title IV Higher Education Act of 1965 as amended.

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

No other sources will be solicited due to the short-term nature of this follow-on need. To fulfil the posting requirements, set forth in the FAR, this J&A will be posted on SAM.gov.

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

The Contracting Officer will determine that the proposed price for the 3-month contract and three 1-month options is fair and reasonable based on a comparison to similar pricing in the market, and the past pricing under the current Contract (which was previously determined fair and reasonable at award).

8. Description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

Based on the very short-term nature of this contract, market research was not conducted.

9. Any other facts supporting the use of a sole source (including brand name), such as:

All other supporting facts have been documented herein.

10. List of the sources that expressed a written interest in the acquisition.

A total of 10 sources submitted capability statements in response to the Department’s forecast, however none of the offerors, other than the incumbent, can maintain the PEPS system without interruption of critical services.

• Liona Enterprises

• AMS Networks

• Greenbriar Gov Solutions Inc.

• Break Forth Solutions

• Advent Services LLC

• WIN Trio LLC

• AGovX

• Resolute Educational Solutions

• PTG International

• Strativia Technical Consulting Services

11. Actions to Promote Future Competition

The portion of FSA’s NextGen Partner Connect Services Environment that will eliminate the need for the PEPS O&M support is being conducted through a competitive acquisition.

12. Technical/Requirements Representative Certification

I certify that this requirement constitutes the Government’s minimum needs and the supporting data provided herein is accurate and complete to the best of my knowledge and belief.

______________________________________ __3/27/2023_________ Rhonda Kelly Date Contracting Officer Representative, COR

13. Contracting Officer’s Certification and Approval

I certify this justification is accurate and complete to the best of my knowledge and belief.

______________________________________ __3/27/2023_______ April West Date Contracting Officer