PN FSCS JOFOC 6 5 2023 signed_Redacted.pdf

UNITED STATES DEPARTMENT OF EDUCATION

Office of Acquisition and Grants Administration Contracts and Acquisitions Management

Justification and Approval for Other than Full and Open Competition (JOFOC)

Authority: FAR 6.302, 41 U.S.C.

(a) “Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by FAR

6.3 and in accordance with the requirements by FAR 6.303-1, the justification for the use of the statutory authority under FAR 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

(b) JUSTIFICATION

(1) IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY:

This justification was prepared by Contracts and Acquisitions Management (CAM) in the U.S.

Department of Education (Department).

(2) NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED:

The purpose of this action is to negotiate and award Modification P00009 to the Department’s Contract Number 919900-20-C-0001, Evaluation of Promise Neighborhoods and Full-Service Community Schools. Under Contract 919900-20-C-0001, Mathematica is conducting two separate and Congressionally mandated evaluations of related programs: Promise Neighborhoods and Full- Service Community Schools. Both programs are discretionary grant programs which provide support to grantees to implement comprehensive, coordinated services for children, their families, and community members in disadvantaged communities and schools.

The modification is necessary to extend the period of performance of the Base Period, Option Period 1, Option Period 4, and Option Period 5 and make some minor, adjustments to some of the tasks in Option Period 4 and Option Period 5.

Analyzing data and preparing the final Promise Neighborhoods study report under the Base Period and Option Period 1 has taken longer than anticipated for several reasons. The pandemic was substantially disruptive for the Government, Vendor, and the Grantee Organizations. Therefore, it took much longer for the contractor to complete the data collection from grantees with a high response rate, which was a required step to proceeding to analysis and reporting. At the same time, there was a perfect storm of turnover in the IES COR, IES leadership overseeing this evaluation, and leadership in the contractor team, which created transitional delays. Finally, given how complex a program Promise Neighborhoods is (i.e., cradle to career pipeline of comprehensive services to whole communities, and not just individual schools), there are substantial data analytic challenges that need to be grappled with in producing findings and reporting that will pass muster with IES’s required peer review process. This review process via IES’s Standards and Review Office (SRO) has increasingly become more difficult to pass, due to increased scrutiny over how to report certain types of data and how to present findings in a policy-relevant way. Therefore, more time is needed to be thoughtful about these stringent standards to ensure that IES’s findings report for this program can ultimately be approved for sharing with the public.

More time is also needed to finish planning and implementing the evaluation of Full-Service Community Schools under Option Period 4 and Option Period 5. Given how complex the program intervention is (i.e., providing a full suite of tailored services to students, coordinating with multiple external partners in the community), rigorously evaluating the program is a major challenge and requires careful deliberation and time-consuming consultations with the relevant research and stakeholder community. On top of that, the arrival of the pandemic in 2020 (not too long after the contract was awarded in November 2019), as well as the change in administration in 2021 slowed down the process for deliberating and finalizing the study plans. Finally, Congress approved major increases in the program budget starting in FY22 and FY23,1 and the administration is interested in ensuring the national evaluation appropriately includes all the new grantees funded in order to be more relevant to future grantees and to inform program expansion.

Thus, further delays were inevitable to ensure that the evaluation design include these additional grantees. Therefore, more time is needed to complete study planning and to plan for and conduct the evaluation, which will then pave the way to analysis and reporting of findings that are useful to policymakers and the broader public.

In addition, some minor, cost-neutral adjustments to the tasks under Option Period 4 and Option Period 5 are necessary to reflect a greater emphasis on the already-planned implementation study component. Originally, the plan was to evaluate Full-Service Community Schools using a randomized controlled trial (RCT) design and a study component focused on how grantees were implementing the program. However, less than a year ago, the Department decided to pivot their grant requirements such that a RCT design was no longer feasible at this time, and that then the emphasis of the study design would be on the implementation component. The goal was to put greater emphasis on the already-planned implementation study component and to then use some lessons learned from this aspect of the study to revisit planning for the RCT further down the line.

This slight shift in the emphasis of the original study design necessitates some commensurate adjustments to related tasks for implementing the evaluation in options 4 and 5. For example, the data collection will be shifted to focus on the increased number of grantee schools instead of the comparison schools under an RCT but will still focus on whether they are implementing the types of community school activities that the program emphasizes. The data collection will also shift to focus on collecting implementation data over multiple rounds instead of just focusing on outcomes data over multiple rounds under the RCT, given the greater emphasis on implementation findings and learning how implementation evolves over the grant period. However, it is important to emphasize that the core aspects of the evaluation remain the same as originally planned, and that is why there are no net changes to the cost of the contract. That is, the study team will be collecting data from grantees and schools using data collection instruments cleared by OMB to evaluate the Full-Service Community Schools program, analyzing that data, and publishing reports to share the findings.

Affected Existing Tasks and Deliverables:

Task 9 – Promise Neighborhoods Data Analysis and Report Preparation | Draft Promise Neighborhoods report [Deliverable date extended from 35 months after contract award to 47 months after contract award] Task 10 – Promise Neighborhoods Restricted-Use Data File | Promise Neighborhoods risk disclosure analysis [Deliverable date needs to be extended from 42 months after contract award to 58 months after contract award] Task 12 – Promise Neighborhoods Comparison Group | No deliverables Task 20 – Full-Service Community Schools (FSCS) Technical Working Group | List of proposed Full-Service Community Schools TWG members [This task has been moved to Option Period 5] Task 21 – Selection of Intervention Provider(s) | List of proposed Full-Service Community Schools

1 The Full-Service Community Schools program doubled in size from FY2022 ($75M) to FY2023 ($150M), and the President’s FY2024 budget includes a request to more than double the size of the program again ($368M).

TWG members; RFP [This task is no longer relevant] Task 22 – Develop FSCS OMB Data Collection Forms and Prepare OMB Package | Full-Service Community Schools OMB clearance package, including data collection forms; Revised Full- Service Community Schools OMB clearance package, including data collection forms [This task has been revised to put a heavier emphasis on collecting data about implementation] Task 23 – FSCS Recruitment | Memoranda of understanding from schools [This task has been adjusted to focus on obtaining buy-in from stakeholders and recruiting grantees for data collection] Task 24 – FSCS Random Assignment | No deliverables [This task is no longer relevant] Task 25.1 – FSCS Initial Implementation Support | No deliverables [This task has been revised to provide early implementation information, which will aid in understanding and improving grantee implementation of full-service community schools] Task 26 – Option #4 Reporting Requirements | Monthly progress reports; Monthly security spreadsheets [This task has been revised to accommodate a longer period of performance] Task 25.2 – FSCS Ongoing Implementation Support | No deliverables [This task has been revised to provide implementation support related to grantee-reported outcomes measures and coordinate with the program office’s technical assistance provider] Task 27 – FSCS Data Collection | Data collection updates [This task has been revised to ensure that data are collected over the course the FSCS grant period] Task 28 – Option #5 Reporting Requirements | Monthly progress reports; Monthly security spreadsheets [This task has been revised to accommodate a longer period of performance]

Extend the period of performance of the Base Period, which includes Tasks 9 and 10, from 45 to 62 months due to the above changes:

o Current period of performance is November 7, 2019 through July 15, 2023 (45 months) o Modified period of performance is November 7, 2019 through January 15, 2025 (62 months) Extend the period of performance of the Option Period 1, which includes Task 12, from 30 to 48 months due to the above changes:

o Current period of performance is January 15, 2021 through July 15, 2023 (30 months) o Modified period of performance is January 15, 2021 through January 15, 2025 (48 months) Extend the period of performance of Option Period 4, which includes existing Tasks 21, 22, 23, 24, 25.1, and 26, from 36 to 60 months due to the above changes:

o Current period of performance is July 1, 2021 through June 30, 2024 (36 months) o Modified period of performance is July 1, 2021 through June 30, 2026 (60 months)

Extend the period of performance of Option Period 5, which includes existing Tasks 20, 25.2, 27, and 28, from 12 to 60 months due to the above changes:

o Current period of performance is July 1, 2022 through June 30, 2023 (12 months) o Modified period of performance is July 1, 2022 through June 30, 2027 (60 months)

(3) DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

Project Title: Evaluation of Promise Neighborhoods and Full-Service Community Schools

The primary goal of this project is to evaluate the Promise Neighborhoods program and evaluate the Full-Service Community Schools program. Both evaluations are Congressionally mandated.

(4) STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN COMPETITION:

The FAR authority permitting acquisition of these services is FAR 6.302-2 - Unusual and

Compelling Urgency (to make changes necessary due to the pandemic and shift in emphasis of the Full- Service Community Schools evaluation due to unanticipated policy actions by the administration and Department leadership).

(5) DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE

OF THE AUTHORITY CITED:

The current contractor is the only responsible source capable of meeting the Department’s needs.

The contractor collected and began analyzing data for the Promise Neighborhoods evaluation.

They are already familiar with the structure of the data and have already made progress with the data analysis. It is most efficient for the current contractor to continue analyzing these data and prepare the final report based on these data. It would be very inefficient and costly in terms of time and money for another contractor to have to obtain the data, become familiar with the data structure and the individual variables, and start from scratch in analyzing the data. Under this scenario, it would be impossible for another contractor to complete the required work within the desired timeframe. Similarly, the current contractor has already established relationships and engaged in numerous discussions with the relevant research and stakeholder community about the evaluation of Full-Service Community Schools, and they have already begun planning the complex evaluation. It would be equally problematic for another contractor to have to establish and foster relationships with the various stakeholders, come up to speed on the current plans, and continue planning and conducting the evaluation under Option Period 4 and Option Period 5 (which have already been exercised). In addition, Department leadership wants the evaluation to begin shortly after the FY23 cohort of grantees is awarded to understand their conditions at baseline and then track how implementation evolves over the grant period. There would not be sufficient time for another contractor to complete the planning for the evaluation and be ready to collect baseline data starting with the FY23 cohort. That would not allow the study objectives to be met because the evaluation would not be able to collect baseline data – which would not be very informative because the evaluation would not be able to assess where grantees start out and how implementation evolves over time – and the evaluation would be delayed by at least a year.

It is therefore imperative that the periods of performance for the Base Period, Option Period 1, Option Period 4, and Option Period 5 are extended per the program office’s request. The contract would then be revised as follows:

o Current Period of Performance for Base Period: November 7, 2019 through July 15, o Revised Period of Performance for Base Period: November 7, 2019 through January 15, 2025 o Current Period of Performance for Option Period 1: January 15, 2021 through July 15, 2023 o Revised Period of Performance for Option Period 1: January 15, 2021 through January 15, 2025 o Current Period of Performance for Option Period 4: July 1, 2021 through June 30, o Revised Period of Performance for Option Period 4: July 1, 2021 through June 30, o Current Period of Performance for Option Period 5: July 1, 2022 through June 30, o Revised Period of Performance for Option Period 5: July 1, 2022 through June 30, To summarize, competing and making a new award for completing the Promise Neighborhoods data analysis and report preparation under the Base Period and Option Period 1 and for continuing the planning and conducting of the evaluation of Full-Service Community Schools under Option Period 4 and Option Period 5 would require a wasteful duplication of efforts and result in substantially higher costs to the Government.

(6) DESCRIPTION OF EFFORTS MADE TO ENSURE OFFERS ARE SOLICITED FROM

AS MANY POTENTIAL SOURCES AS PRACTICABLE:

In accordance with FAR 6.305(a), the Justification and Approval for Other than Full and Open Competition (JOFOC) (a redacted version) will be published on the Business Opportunities (Sam.gov) within 14 calendar days after of the Modification’s execution. Interested parties may provide comment at that time.

This contract was awarded through a full and open competition under authority set forth in Federal Acquisition Regulation (FAR) Subpart 15 (Contracting by Negotiation) on behalf of the Department’s Institute of Education Sciences (IES), National Center for Education Evaluation and Regional Assistance (NCEE), as Cost Plus Fixed Fee contract.

(7) DETERMINATION BY CONTRACTING OFFICER THAT THE ANTICIPATED COST TO

THE GOVERNMENT WILL BE FAIR AND REASONABLE:

There are no added costs associated with this action.

(8) DESCRIPTION OF MARKET SURVEY AND RESULTS, OR STATEMENT WHY MARKET

SURVEY WAS NOT CONDUCTED:

The Department conducted extensive market research at time of award. This work is to be performed under Modification P00009 to the current contract. As stated previously, this modification builds on work already being conducted by the current contractor and procuring this work from a different contractor would create significant duplication of work, both in time as well as cost to the Government, and cannot be separated from that current work. The Base Period, Option Period 1, Option Period 4, and Option Period 5 have already been exercised and funded, and thus if the work were to be procured from a different contractor, the government would incur additional costs for the recompete of a new contract.

(9) OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND

OPEN COMPETITION:

Re-procurement of this contract also would unduly delay the work currently being performed, with the government incurring additional costs that would otherwise be avoided by continuing performance with the existing contractor. The government’s investment in this contract is substantial, and the government’s return on investment would be significantly diminished if the work required a recompete and if the current contractor is not allowed to complete the work.

(10) SOURCES, IF ANY, WHICH HAVE EXPRESSED, IN WRITING, AN INTEREST IN THE

ACQUISITION:

The Government plans to provide timely responses to inquiries from interested parties regarding this contract through email responses as appropriate. Please reference Section 6 above for additional information regarding this response.

(11) STATEMENT OF ACTIONS, IF ANY, TO REMOVE OR OVERCOME BARRIERS TO

COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION FOR THE SUPPLIES

OR SERVICES:

There are no current actions required at this time. The Department will continue to monitor the market to foster competition on future requirements.

Any future actions for similar contractual services will be advertised through appropriate mediums (e.g., Inclusion in the Department’s annual Forecast of Contracting Opportunities and through posting on the System for Award Management (SAM.gov) website), as appropriate.