REDACTED_JOFOC to Increase Max Value of FAIMIS IDIQ Contract.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

This document is a justification for other than full and open competition on behalf of the U.S. Nuclear Regulatory Commission (NRC), Acquisition Management Division.

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

This is a justification to modify Indefinite-Delivery, Indefinite-Quantity (IDIQ) Contract No. 31310018D0004 (“the contract”) to increase the maximum value on a noncompetitive basis to accommodate work that is within the original scope of the contract.

The contract was awarded on January 31, 2018 to CGI Federal Inc. (CGI Federal), 12601 Fair Lakes Circle, GWAC Solutions Center, Fairfax VA, 22033, with a five-year period of performance from February 1, 2018 through January 31, 2023.

3. Description of the supplies or services required to meet the agency's needs (Including the estimated value).

The scope of the contract allows the NRC to acquire software licenses and support services for the NRC’s CGI Momentum®-based core financial system, known as its Financial Accounting and Integrated Management Information System (FAIMIS) and related systems. The ceiling increase is to continue ongoing support services for FAIMIS and related systems, since the original maximum value was inadequate for these purposes. These services include:

• ongoing operations and Maintenance (O&M) support of FAIMIS;

• a new task order to provide interface support with the NRC’s Unison PRISM®-based acquisition system;

• FAIMIS training for NRC employees and system documentation; and

• modifications and enhancements to maintain compliance with new Federal policies and procedures, and agency requirements.

The NRC anticipates that an increase of $15,000,000 to the contract maximum value is required to support those needs. That would increase the maximum value from $31,225,760 to $46,225,760.

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

The statutory authority for this action is 41 U.S.C. 3304(a)(1), as implemented in 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.

CGI Federal does not authorize any other commercial sources to provide CGI Momentum® software licenses and related support services that the NRC requires to operate and maintain FAIMIS. Therefore, the only way that the NRC can satisfy its requirements for this acquisition is to procure them directly from CGI Federal.

Additionally, the NRC has invested a considerable amount of resources (7 years and approximately $80 million) in FAIMIS, which has been customized to meet the NRC fee billing collection requirements that are outlined in the agency's annual Fee Policy rule.

Planning, procuring, and fully implementing a different Enterprise Resource Planning (ERP) solution would take years and would be duplicative in effort and costs particularly given the NRC’s considerable investment in FAIMIS, which includes a $2 million investment to upgrade FAIMIS in 2017. In order to realize the benefits of these investments and avoid significant duplication of costs, the NRC intends to acquire additional software licenses and support services for FAIMIS until such time as the NRC is prepared to conduct a competitive acquisition to replace FAIMIS.

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 Special Notice was posted on the beta.sam.gov website from November 23,2020 through December 8, 2020 under the title, “Notice of Intent to Increase Maximum Value of IDIQ Contract for CGI Momentum® Software Licenses and Related Support Services”, with Notice ID 31310018D0004_Modification_P0003. At the end of the response period on December 8, 2020, there were no comments from any interested party.

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

The Contracting Officer (CO) determined the prices for the contract years to be fair and reasonable at the time of award.

8. A description of the market research conducted (see FAR Part 10) and the results, or a statement of the reasons market research was not conducted.

The CO recently confirmed though market research that CGI Federal does not authorize any other sources to provide the CGI Momentum® software licenses and related services that the NRC requires. Therefore, the only way that the NRC can satisfy its requirements within the scope of the contract is to acquire them directly from CGI Federal.

9. Any other facts supporting the use of other than full and open competition.

None

10. List sources, if any, that have expressed, in writing, an interest in the acquisition.

None

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 required.

The Acquisition Management Division will closely scrutinize any subsequent requests for acquisition of similar services and will ensure that any restrictions to competition are adequately supported and documented.

12. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

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

Louis Gilden Date Contracting Officer

13. Requirements personnel certification.

I certify that the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

Nandini Sharma Date

OCFO/DOC/FSB

COR

Approve:

Eleni Jernell Date Competition Advocate