R3117016 Justification for Other Than.doc

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

In Accordance with FAR6.303 1.

IDENTIFICATION AND DESCRIPTION OF ACTION BEING APPROVED:

The requiring activity is the Defense Contract Audit Agency (DCAA), 87 25 John J. Kingman Road, Suite 2135, Fort Belvoir, VA 22060 The contracting activity is the General Services Administration, Federal Acquisition Service, Mid-Atlantic Region, Philadelphia, PA 19107 2.

NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

The action being approved is a sole source purchase for Towers Watson Compensation Reports subscription renewal.

DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED

Towers Watson Compensation Reports are necessary to enable and facilitate the DCAA audits of contractor compensation systems and related claimed contractor compensation costs.

See attached Survey Compensation Reports Bill of material for a complete list of reports required Current period of performance is September 29, 2011 through September 28, 2012.

4.

IDENTIFICATION OF STATUTORY AUTHORITY:

6.302-1(a)(2)(ii) – Only one responsible source and no other supplies or services will satisfy agency requirements and will cause unacceptable delays in fulfilling the agency’s requirement.

5.

DEMONSTRATION THAT THE ACQUISITION REQUIRES THE USE OF THE AUTHORITY CITED:

One of the most important DCAA audit functions is to review contractor employee Compensation System Reviews (CSRs). It is imperative that DCAA has the appropriate salary and wage data as benchmarks to determine a contractor’s compensation level as reasonable in accordance with FAR part 31.205-6. This FAR site states that compensation can be determined reasonable by comparison to the compensation practices of other firms of the same size, in the same industry, in the same geographic area, and engaged in similar non-Government work under comparable circumstances.

The Towers Watson survey reports fully satisfy the FAR criteria. Towers Watson conducts more than 25 annual compensation benefits and policies and practices surveys on all aspects of pay encompassing more than 2,000 individual jobs. The survey reports consist of US surveys by job level, job family policies and practices and periodic reference.

5.

DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE AUTHORITY CITED.

DCAA has subscribed to the Towers Watson Survey Reports for over a 20 year period and has relied on their reputation for collecting accurate data, expertise in job evaluation and job analysis, and the reputable companies contributing data to their surveys.

Because Towers Watson fulfills the criteria set forth in FAR part 31.205-6, and together with their proven reliability, DCAA trusts Towers Watson’s survey information which is invaluable to DCAA in accomplishing its mission accurately and successfully.

6.

A DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED FROM AS MANY POTENTIAL SOURCES AS IS PRACTICABLE

DCAA will continue to conduct market research for any new publications that are being offered to determine if they could meet the agency’s need.

7.

DEMONSTRATION THAT THE ANTICIPATED COST WILL BE FAIR AND REASONABLE:

Fair and reasonable pricing determination will be based upon a detailed analysis using the following: the Towers Watson published price list, comparison to an independent Government estimate, and historical costs in accordance with FAR13.106-3 a.

8.

A DESCRIPTION OF THE MARKET RESEARCH CONDUCTED

Market research was conducted via the World Wide Web and GSA Advantage for comparable and reputable survey reporting companies. To DCAA knowledge, no other single source exists for the specifications and standards provided by Towers Watson.

9.

ANY FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN COMPETITION

N/A 10.

A LISTING OF SOURCES THAT EXPRESSED AN INTEREST IN THE ACQUISITION

N/A 11.

A STATEMENT OF ACTION THE AGENCY MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION

If future expenditures and allowances are granted for continued auditing support, all efforts will be made by the Government to monitor developments and changes in the marketplace and to aggressively seek alternate sources for comparable survey reports.

12.

CERTIFICATIONS

Contracting Officer’s Certification as required by FAR 6.303-2(a) (12) and FAR6.304 (a)(1) I certify that this justification is accurate and complete to the best of my knowledge and belief.

LaKeisha N. Hawkins

Date

Contracting Officer

Federal Acquisition Service