PSaMS_Consolidation Memo.pdf

DEFENSE HEALTH AGENCY

DETERMINATION AND FINDINGS FOR

CONSOLIDATION PROCUREMENT

I have reviewed this requirement for the Defense Health Agency (DHA), Solution Delivery Division (SDD) variety of highly technical Services including Tier I/ Tier II/ Tier III consultation and customer support for implementation, troubleshooting, and management of Healthcare Applications Support requirements. The Contract Operations Branch - Professional Services Contracting Division, (PS-CD) proposes to solicit this requirement as a consolidated procurement action under 15 U.S.C. § 657q(c)(2)(B) and 7.107-2(e)(2)(i). The review resulted in the following findings:

FINDINGS

1. Agency/Requiring Activity/Contracting Activity: DHA/SDD/PS-SA

2. Nature and/or Description of Action being approved: This contract consolidates contract support for 7 products within Health Services Support (HSS), Clinical Support (CS), and Electronic Health Record (EHR Core) Project Management Offices (PMOs) of Solution Delivery Division (SDD): Aeromedical Information Management System (ASIMS), Clinical Information Systems (CIS), Department of Defense Cancer Registry (DoD CR), Patient Queuing and Notification Service (PQNS), Surgical Scheduling System (S3), Spectacle Request and Transmission System (SRTS), and Veterinary Service Information Management System (VSIMS) encompassed in the contracts shown in the following table.

Requirement Existing Contract Period of Performance Ends HSS ASIMS, PQNS, DoD CR, S3 (APCS) HT0011-21-F-0032 28 February 2022

HSS APCS (bridge) HT0011-22-F-0021 30 June 2022 SA/DBA Inpatient Support Svcs for Clinical Information Systems (CIS) HT0011-21-F-0048 28 February 2022

SA/DBA Inpatient Support Svcs for CIS (extension) HT0011-21-F-0048 30 June 2022

Surgery Scheduling System (S3) Support HT0015-16-C-0005 28 February 2022

S3 Support (bridge) HT0011-22-C-0011 30 June 2022 Veterinary Service Information Management System (VSIMS) Support Services (extension)

HT0015-17-C-0009

28 February 2022

VSIMS Support Services HT0015-17-C-0009 30 June 2022 Spectacle Request and Transmission System (SRTS) Programming Support HT0011-21-F-0095 28 February 2022

SRTS Programming Support (extension) HT0011-21-F-0095 30 June 2022

The 5 contracts supporting these 7 products will combine into one single award contract with a base period of 8 months and 4 option periods that are 12 months each. The shortened base period is due to the need to extend/bridge the previous support contracts within the same FY22 in order to allow sufficient time to compete and process this consolidation. Inclusion of the FAR 52.217- 8 extension of services clause enables extension up 6 months, if needed. This is a firm fixed price / labor hour mixed contract due to the variance included with at least two products de-scoping and decommissioning as they transition to MHS Genesis during the term of this contract.

Workload, duty site, and travel affected by anticipated de-scope schedules are provided to the vendor in the PWS. This gives transparency well as increased flexibility for schedule adaptations during de-scope and decommission activities, and prevents unnecessary expenditures due to contract obligations.

The products supported and services provided within this contract are:

a. The DHA SDD supports the US Air Force Medical Service, AF Commanders and service members through the Aeromedical Services Information Management System (ASIMS). ASIMS is the web-based USAF system of record for AF Individual Medical Readiness and 16 other mandatory medical programs, including immunizations for AF uniformed and non-unformed beneficiaries, preventive/mental/deployment health assessments, deployment medical clearances, medical employee and industrial occupational health, duty/deployment/fitness limiting profiles, pre and post-deployment medical processing, flyer grounding management, quarters and Personnel Reliability Program medical recommendations, medical clearances and separation health physical exams. ASIMS is used by over 500,000 Active Duty AF, Air National Guard, AF Reserves and MTF staff at over 300 locations in garrison and deployed settings. In addition to management of MTF level programs, ASIMS includes information processing services which support the collection and analysis of data for medical readiness, population health, preventive medicine, clinical decision support and operational/decision making for the AF Medical Service. Data quality assurance services aid in improvement of data quality and help meet standards of completion for congressionally mandated assessments and Department of Defense (DoD) requirements.

The contractor shall provide qualified service personnel with expertise to support the worldwide sustainment of the ASIMS to include design, develop, modify, upgrade, test, troubleshoot, implement, support, sustain, and train all modules within the ASIMS application. Contractor personnel will serve as the subject matter expert for the design of all ASIMS modules. Contractor personnel will also assist in accessing, analyzing, and disseminating information about specific populations by developing, validating and linking various medical, safety, environmental, occupational, and personnel databases. Contractor personnel will provide application development expertise to refine ASIMS prototypes for optimal implementation by the SDD.

b. The Clinical Information Systems (CIS) is a commercial off-the-shelf (COTS) suite of components comprising the mission-critical inpatient documentation system at Military Treatment Facilities (MTFs) around the world. The CIS inpatient documentation system provides point-of-care electronic documentation and integrated physiologic monitoring capabilities for clinical decision support.

CIS exchanges data with external systems using Logical Observation Identifiers Names and Codes or Health Level Seven International (HL-7) standards. Key interfaces include:

• Composite Healthcare System (CHCS)

• Joint Legacy Viewer (JLV) - provides select information from CIS to the Department of Veteran’s Affairs (VA) via the Data Exchange Service (DES)

• Computrition

• eCareManager

• Interface from CHCS to CIS (ICE)

As a deployed system, CIS requires operational support for software and hardware maintenance, technical and customer support, system monitoring and trouble notification, repair services, replacement parts, software updates, training, and configuration assistance. Also, as with all IT systems in operation on DoD networks, CIS is required to maintain cybersecurity compliance in accordance with DoD policy.

CIS is transitioning, and sustainment requirements are expected to de-scope as that transition progresses during the term of this contract. Active sites (data input, data storage, reporting) will transition to archive sites (data storage, reporting) as those sites transition into MHS Genesis. Archive sites will consolidate into the MHS Information Platform (MIP) once it is prepared to receive data and reporting functions. Current schedules are fluid, but both transition actions and the decommission of CIS are anticipated to complete during the term of this contract.

The Contractor shall provide all necessary personnel, management, administrative support, travel, and sustainment in support of CIS. Support services include the overall program and project management, change management and business process re-engineering, system and database administration for the CIS electronic health record application, and administrative assistance in support of CIS at MTFs worldwide.

During the term of this contract, it is anticipated that the CIS product will de-scope as they transition into the MHS Genesis and MIP programs, and decommission.

c. The DoD Cancer Registry (DoD CR is a repository that serves all DoD military treatment facilities and Cancer on Commission accredited DoD cancer centers around the world. This registry ensures that the MHS is compliant with federal regulations in tracking tumors and cancers on MHS beneficiaries for their lifetime. DoD CR provides Oncology Clinical Community (OCC) personnel the ability to document (a.k.a. abstract) tumor and cancer findings in a central database repository. DoD CR also provides Researchers the ability to view and access data for investigations and research purposes.

The contractor shall provide qualified service personnel with expertise to provide database support for the DoD CR that includes create, manage, modify, upgrade, troubleshoot, support and sustain the DoD CR application. Contractor personnel will serve as the subject matter expert for the DoD CR database. Contractor personnel will also assist in project requirements, developing and editing application technical documentation. Contractor personnel will assist in developing and maintaining all cyber-related activities (Patches, Scans, Security Technical Implementation Guides (STIGs), and documentation).

d. The Patient Queuing and Notification System (PQNS) is the system DHA SDD uses to support patient queuing throughout the MHS Enterprise. PQNS is a commercial off the shelf (COTS) software system by the trade name “Q-Flow” (vendor ACF).

PQNS is used at over 100 CONUS and OCONUS MTFs and associated satellite clinics. PQNS collects data on patient and staff throughput to facilitate a patient-centered workflow transformation. Real-time data helps MTFs make active management decisions to optimize processes and staffing to enhance the patient experience and improve efficiency by reducing waste in the system. Historical data allows predictive analytics to make data-driven decisions for future staffing and workflow optimization. Queuing data allows for sharing of best practices based on quantitative data and moves the MHS to a High 3 Reliable Organization through an Operating Company Model by reducing unwarranted variation.

The contractor shall provide qualified service personnel to perform system administration (SA) and database administration (DBA) for the PQNS application hosted in a centralized environment. The PQNS project has over 100+ sites that will use the Q-Flow application hosted at 5 separate MHS Application Access Gateway (MAAG) sites. The application consists of web and application servers and SQL database servers. Contractor personnel shall work with the host agency, maintain both the production and the test environment and assist with Risk Management Framework continuous monitoring cyber compliance.

e. The DHA SDD provides the Tri-Services with a web-based, automated surgical scheduling system through the Surgery Scheduling System (S3). It provides standardization of Operating Room (OR) scheduling and reporting processes, and allows the tri-service to collect enterprise-wide metrics on OR efficiency. S3 is currently in use by US Army, US Navy and US Air Force Military Treatment Facilities (MTFs). The DHA provides full life cycle management support for information systems and services. IT support for S3 includes software interfaces, which are primarily data exchange with the S3DataCenter, the Anesthesia Recording and Monitoring Device (ARMD), Composite Health Care System (CHCS), and would include any new interface established.

The contractor shall provide qualified personnel to support the S3 application and interface software. The contractor shall provide personnel with skill sets necessary to produce platform upgrades, application version hot fixes and updates, interface version updates, support data pull requests/reports and sustain the software, as required.

S3 is transitioning and sustainment requirements are expected to de-scope as that transition progresses during the term of this contract. Current schedules are fluid, but transition actions and the decommission of S3 are anticipated to complete during the term of this contract.

f. The Spectacle Request and Transmission System (SRTS) application supports the need for a clinically integrated, secure Web-based application to support the Military

Health System Optical Fabrication Enterprise (OFE). SRTS supports the OFE’s objective to provide a significant contribution to military readiness worldwide by providing an automated means for clinics to submit and track spectacle orders. SRTS is a centrally managed application supporting the Clinic and Lab applications. SRTS encompasses several other components which include G-Eyes, Training, Web Services, and Reporting Services. SRTS receives technical and management life-cycle support which spans all phases of the acquisition lifecycle, from requirements assessment, programming and testing to operations and support.

The contractor shall provide qualified service personnel to perform application programming and provide the expertise to design, develop, modify, upgrade, test, troubleshoot, implement, and sustain as required. Contractor personnel will document and control all code changes using government-supplied software, comply with DHA change management processes, comply with DHA Information Assurance (IA), and prepare and conduct In-Process Reviews (IPRs).

g. The DHA SDD supports veterinary public health across the Department of Defense

(DoD) through the Veterinary Service Information Management System (VSIMS).

VSIMS is a tri-Service application supporting DoD food protection (food safety plus food defense), veterinary public health, and operational missions at over 700 locations around the world. It provides for collection and immediate delivery of targeted and relevant data to the entire chain of command and all appropriate customers, along with immediate availability of data required for mission performance to member personnel organized along diverse key capabilities. VSIMS maintains the Worldwide Directory of Sanitarily Approved Food Establishments for Armed Forces Procurement, and delivers modular management of workflow associated with audits of commercial food establishments, sanitation inspections of military food and animal housing facilities, status/condition of procured food, recalls of DoD-owned subsistence, lifecycle food protection for operational rations, food and water risk assessments across the DoD supporting short term missions or exercises, tracking of food analysis laboratory sample submission, equipment data, and animal bite-scratch report tracking.

The contractor shall provide qualified service personnel to with expertise to design, develop, modify, upgrade, test, troubleshoot, implement, support, sustain, and train all modules within the VSIMS application. Contractor personnel will serve as the subject matter expert for the design of all VSIMS modules. While frequent participation in project working groups is required by all personnel, application developers may expect only occasional contact with end users. These engagements, when necessary, will be only through coordination with the Government Lead. Contractor personnel performing Helpdesk duties are expected to have frequent contact with end users. All Contractor personnel can expect to participate in document preparation, including but not limited to project requirements documentation, design standards document, user manuals, etc.

3. Citation of the appropriate statute and/or regulation upon which the determination and findings (D&F) is based: Applicable Statutes/Regulations are 15 United States Code (U.S.C.) § 657q(c)(2)(B) and 7.107-2(e)(2)(i).

4. Findings that detail the particular circumstances: The objective of this contract is to provide technical support that includes expertise to design, develop, modify, upgrade, test, troubleshoot, implement, support, administer, sustain, maintain security, train, and/or conduct change management practices for all modules within each product as identified within the Performance Work Statement (PWS), and prepare and conduct product decommissioning activities, where applicable. During the contract period, two products are scheduled to de-scope and decommission as they transition to MHS Genesis. Anticipated de-scope schedules are included in the PWS. In consideration of inherent variances in the de-scope schedule, this contract will be labor hours rather than firm fixed price.

a. This contract has an 8 month base period and four 12 month options. The FAR 52.217-8 extension of services clause enables extension up 6 months, if needed. The shortened base period is due to the need to extend/bridge the previous support contracts in order to allow sufficient time to compete and process this consolidation.

b. Market research was conducted November 26, 2021, by researching the following databases: GSA eBuy, DSBS database, SBA Quick Market Research, and Ability One to determine if there were any significant market changes (i.e. technological advancements) or economic indicators that either affects price or the requirement itself, and there were none.

c. The below table reflects information on the 5 current contracts feeding into the consolidation. The current number of FTEs in the feeder contracts (57) decrease going into the consolidation contract (45) due to beginning de-scope of the CIS product.

Contract Set-Aside Contractor FTE Place of Performance

HT0011-21-F-0032

HSS APCS 8(a) ANC

SpecPro Management Services LLC 13

San Antonio & Remote Locations

HT0011-21-F-0048

SA/DBA Inpatient Support Svcs for CIS SB

LOUi Consulting Group, Inc. 31

Various CONUS and OCONUS Locations

HT0011-21-F-0095

SRTS Programming Support 8(a) Bestica, Inc. 2

San Antonio

HT0015-16-C-0005

S3 Support

8(a) Bestica, Inc. 4

San Antonio

HT0015-17-C-0009

VSIMS Support 8(a) Malama LLC 7

San Antonio & Remote Locations

New Contract SB TBD TBD

San Antonio & Various CONUS and OCONUS Locations

d. The following North American Industry Classification System (NAICS) codes were used for these efforts:

Contract NAICS NAICS Description HT0011-21-F-0032 541620 Environmental Consulting Services HT0011-21-F-0048 541519 Other Computer Related Services HT0011-21-F-0095 541519 Other Computer Related Services HT0015-16-C-0005 541512 Computer Systems Design Services HT0015-17-C-0009 541519 Other Computer Related Services

e. The DHA PS-CD Contracting activity intends to consolidate five contracts and compete it within Small Business. The primary place of performance with be the Joint Base San Antonio, although some FTEs are based at other CONUS and OCONUS locations. The contract is approximately $48,619,517.59 over a 4 year period, and allows for an optional clause 52.217-8, Extension of Services.

Base Period and Estimated Value:

5. Alternative Contracting Approaches Involving a Lesser Degree of Consolidation, and Rationale for Rejection: An analysis of alternatives was performed in support of the DHA decision to consolidate these five contracts within SDD to the PSaMS contract.

a. Alternative #1: Consolidate the requirements for seven products within five current contracts under a single contract. Consolidation of these requirements will save acquisition and contract administration costs, and provide maximum equitable flexibility for de-scoping actions that will occur within the contract period to include resultant cost savings. Competing this contract within Small Business allows all incumbent vendors to submit proposals, and allows for maximum participation from other vendors while still keeping the work within the Small Business Administration arena.

b. Alternative #2: Award five to seven separate smaller contracts. This approach would not allow realization of potential cost savings with acquisition and contract administration, and would increase risk and potential costs to the government by eliminating the flexibility benefits needed to accommodate de-scoping schedule variances.

c. Cost Savings: Consolidation provides the opportunity for the Contractor to support the DHA as a whole rather than many Contractors supporting separate actions. Consolidation provides potential cost savings and will permit dollars to be reprogrammed or budgeted

ASIMS Base Period 7/1/2022 - 2/28/2023 $691,430.46 CIS (Essentris) Base Period 7/1/2022 - 2/28/2023 $2,669,053.80 DoD CR Base Period 7/1/2022 - 2/28/2023 $138,030.48 PQNS Base Period 7/1/2022 - 2/28/2023 $414,091.44 S3 Base Period 7/1/2022 - 2/28/2023 $847,353.78 SRTS Base Period 7/1/2022 - 2/28/2023 $219,826.32 VSIMS Base Period 7/1/2022 - 2/28/2023 $866,524.68 S3-VHVS (optional) 7/1/2022 - 2/28/2023 $151,833.53

TOTAL $5,998,144.49

elsewhere. In an effort to implement efficiencies in acquisition, the DHA is taking action to identify and implement efficiencies in their contracts. The consolidation of these five efforts do not delay or reduce needed services, allows for the same level of support where needed, and allows for flexible de-scoping activities to account for schedule variances.

The Government would also realize reduced administrative cost associated with post award administration although it is understood that this reason by itself, does not authorize consolidation.

d. In an effort to quantify the potential cost savings for the proposed consolidation the following table is provided. It shows the cost of the current five contracts that each have one COR, one Contracting Officer (KO), one Contracting Specialist (KS), and one Product Manager (PM) processing and managing each contract. If awarded separately, 5 sets of these personnel would be required to process and manage these contracts, as opposed to only one set of these personnel when these contracts are consolidated. The following assumptions are made: CORs are on the GS-11 or GS-12 pay scale with an average annual salary in the San Antonio, Texas area of $84,564. KOs are on the GS13 pay scale with an average annual salary in the San Antonio, Texas area of $109,639. KS are on the GS-12 pay scale with an average annual salary in the San Antonio, Texas area of $92,205. PMs are on the GS-12 or GS-13 pay scale with an average annual salary in the San Antonio, Texas area of $100,922.

While there is no requirement for a these personnel to hold the assumed grades, this is the norm for the San Antonio Area and the DHA. If the proposed consolidation is approved only one of each personnel type would be assigned to process and manage the contract as well as provide quality assurance and surveillance of the effort.

Potential Contract Savings is computed by converting the annual potential savings to monthly, and multiplying by 56 months (8 mo base plus four 12 mo options).

Consolidation equals potential contract term savings of $7,230,160.

Table 1: Savings for CORs Personnel Annual Cost for 5 Annual Cost for 1 Annual Potential

Savings Potential Contract Savings

COR $422,820 $84,564 $338,256 $1,578,528

KO $548,195 $109,639 $438,556 $2,046,595

KS $461,025 $92,205 $368,820 $1,721,160

PM $504,610 $100,922 $403,688 $1,883,877

TOTALS $1,936,650 $387,330 $1,549,320 $7,230,160

*Information derived from the GS Pay Scale for the San Antonio-New Braunfels-Pearsall, TX on the opm.gov website. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2022/SO.pdf

6. Circumstances, Facts, Reasoning Supporting the Determination:

Key activities are described below.

a. Support the worldwide sustainment of the Aeromedical Services Information

Management System (ASIMS) application to include design, develop, modify, upgrade, test, troubleshoot, implement, support, sustain, and train all modules. Serve as the subject matter expert for the design of all ASIMS modules, and assist in accessing, analyzing, and disseminating information about specific populations by developing, validating and linking various medical, safety, environmental, occupational, and personnel databases. Provide application development expertise to refine ASIMS prototypes for optimal implementation.

b. Provide all necessary personnel, management, administrative support, travel, and sustainment in support of Clinical Information Systems (CIS). Support services include the overall program and project management, change management and business process re-engineering, system and database administration for the CIS electronic health record application, and administrative assistance in support of CIS at MTFs worldwide. During the term of this contract, it is anticipated that the CIS product will de-scope as they transition into the MHS Genesis and MIP programs, and decommission.

c. Provide database support for the DoD Cancer Registry (DoD CR) application to include create, manage, modify, upgrade, troubleshoot, support and sustainment.

Serve as the subject matter expert for the DoD CR database, and assist in project requirements, developing and editing application technical documentation. Develop and maintain all cyber-related activities (Patches, Scans, Security Technical Implementation Guides (STIGs), and documentation).

d. Perform system administration (SA) and database administration (DBA) for the Patient Queuing and Notification System (PQNS) application hosted in a centralized environment with over 100+ sites that using the Q-Flow application hosted at 5 separate MHS Application Access Gateway (MAAG) sites. Maintain both the production and the test environment which consists of web and application servers and SQL database servers. Work with the host agency, and assist with Risk Management Framework continuous monitoring cyber compliance.

e. Support the Surgery Scheduling System (S3) application and interface software.

Produce platform upgrades, application version hot fixes and updates, interface version updates, support data pull requests/reports and sustain the software, as required. During the period of this contract, it is anticipated that the S3 product will de-scope as they transition into the MHS Genesis program, and decommission.

f. Perform application programming and provide the expertise to design, develop, modify, upgrade, test, troubleshoot, implement, and sustain as required. Contractor personnel will document and control all code changes using government-supplied software, comply with DHA change management processes, comply with DHA Information Assurance (IA), and prepare and conduct In-Process Reviews (IPRs).

g. Design, develop, modify, upgrade, test, troubleshoot, implement, support, sustain, and train all modules within the VSIMS application. Contractor personnel will serve as the subject matter expert for the design of all VSIMS modules. While frequent participation in project working groups is required by all personnel, application developers may expect only occasional contact with end users. These engagements, when necessary, will be only through coordination with the Government Lead.

Contractor personnel performing Helpdesk duties are expected to have frequent contact with end users. All Contractor personnel can expect to participate in document preparation, including but not limited to project requirements documentation, design standards document, user manuals, etc.

7. Assertion of Measurably Substantial Benefits:

a. IAW with the Small Business Jobs Act of 2010, bundling means, “consolidating two or more procurement requirements for goods or services previously provided or performed under separate smaller contracts into a solicitation of offers for a single contract that is likely to be unsuitable for award to a small business concern.” The NAICS code 541519 – Other Computer Related Services will be used for this requirement and, therefore, will be suitable for small business concerns. This industry comprises establishments primarily engaged in Computer Related Services.

This requirement would not meet the definition of bundling as defined in FAR 2.101.

b. IAW the Small Business Jobs Act of 2010, consolidation means, “the use of a solicitation to obtain offers for a single contract or a multiple award to satisfy two or more requirements of an agency for services that have been provided to or performed for the agency under two or more separate contracts lower in cost than the total cost of the contract for which the offers are solicited.” The Act does not preclude agencies from consolidating requirements. However, the Act states an agency may use an acquisition strategy that consolidates contract requirements with a total value of more than $2 million, unless the agency’s senior procurement executive or chief acquisition officer takes the following steps: 1) conduct market research; 2) identify any alternative contracting approaches that would involve a lesser degree of consolidation of contract requirements; 3) make a written determination that the consolidation of contract requirements is necessary and justified; and 4) ensure that steps will be taken to include small business concerns in the acquisition strategy.

c. The cost of continuing the 5 separate contracts vice consolidating into a single contract is shown in the table below. Estimates for the awarding 5 separate contracts are based on the cost of the currently contracts at their end, and increased yearly at the same rate as the new contract. The same term of an 8 month base, 4 options of 12 months each, and a 6 month extension (total contract cost) is applied to all contract calculations. De-scoped workload is carried as unfunded in the consolidated contract, which is why the funded total is shown for the consolidation separately.

Total of the 5 separate contracts increased at the same rate used for the consolidation

$50,089,014.77

Consolidated contract, Funded total $26,966,580.56 Total Savings of consolidation over separate contracts

$23,283,516.50

De-scope Savings $21,652,937.03 Adjusted Savings of consolidation over separate contracts

$1,554,602.12

Potential contract savings of administrative burden

$7,230,160.00

Substantial benefit to the Government $8,784,762.12

d. Market research was conducted, alternative contracting approaches were addressed, and a written determination was made in the form of this determination and findings.

There are 4 companies that hold the 5 feeder contracts, all of which are Small Business and some, but not all, of which are 8(a). Additionally, some of the 8(a) companies either have recently or are soon graduating from the 8(a) program. All incumbent companies hold separate contracts in rough magnitude as the others, and any of them are expected to be capable of handling a contract of this size. No adverse impact to any of the incumbent companies is expected since they’ve held contracts for enough time to build an income base not dependent solely on this effort. In order to ensure that all incumbent companies are allowed the opportunity to compete for this contract, the DHA PS-CD Contracting activity intends to consolidate five contracts and negotiate a single contract after competition within Small Business as a Small Business set-aside. A DD Form 2579, Small Business Coordination Record, has been completed and approved by the Small Business Administration (SBA) on __02/05/2022__________________.

8. A Determination, based on the findings: Upon the basis of the findings above I hereby determine, pursuant to the authority of 15 U.S.C. § 657q(c)(2)(B) and 7.107-2(e)(2)(i), that the proposed consolidation of the requirements for Data Science is necessary and justified.

9. Expiration date of the D&F (refer to FAR 1.706): An expiration date is not applicable as this determination and finding is not for a class of contracts.

10. Signature of official authorized to sign the D&F:

1.