Redacted Limited Source Justification for GSA COI ID09170016.pdf

1. Identification of the agency and contracting activity

CONTRACTING ACTIVITY:

U.S. General Services Administration Contracting Division Federal Acquisition Service Pacific Rim Region (R9) 50 United Nations Plaza 2nd Floor Suite 2426 San Francisco, CA 94102

REQUIRING AGENCY:

U.S. Army Central (USARCENT) G8 1 Gabreski Dr.

Shaw AFB, SC 29152

2. Nature and description of the action being approved

The U.S. General Services Administration (GSA), R-9 Contracting Division (CD), Pacific Rim Region intends to issue a seven (7) month, firm fixed price modification to extend the existing GFEBS Contract #GS-35F-0371N / Order# GSQ0917BH0027. The Order was awarded by GSA FAS R-9 against GSA Federal Supply Schedule 70 GS-35F-0371N, SIN 132- 51 and NAICS Code 541219 to Accenture Federal Services, LLC., on behalf of USARCENT for accounting services on Mar 23, 2017 at a total value of . The original period of performance was a 12-month base term with three 12-month option terms.

This fixed price modification is for 7-months of additional performance at the current levels and is estimated at . The period of performance for the modification is expected to be Mar 28 – Oct 27, 2021. This modification will also include the value of the FAR Clause 52.217-8, Option to Extend Services (Nov 1999) for 6-months that was incorporated into the base contract at time of award. The estimated value of the option to extend services if all 6-months were exercised is . If the 52.217-8 option to extend services is exercised for the full 6-months, the total potential duration of the 52.217-8 extension and the 7 months of additional performance will be 13 months.

USARCENT's area of responsibility (AOR) is a large and complex region. It stretches from the Central Asian States to North Africa (Egypt). The AOR encompasses an area of approximately 11.8 million square kilometers (1.5 times larger than the continental U.S.)

consisting of 20 countries populated by more than 540 million people with 49 ethnic groups speaking approximately 60 different languages, and representing 27 religions.

USARCENT conducts shaping operations in the U. S. Central Command area of responsibility to deter adversaries in order to reassure and enable partners, while sustaining ongoing U.S.

operations in established Combined Joint Operating Areas. Concurrently, USARCENT transitions forces and capabilities in the AOR for roles anticipated in the next decade of the 21st Century.

ID09170016-Limited Sources Justification

FOR OFFICIAL USE ONLY

USARCENT G8 is responsible for theater wide Financial Management (FM) in the CENTCOM Area of Responsibility (AOR). They provide Title X support to all United States Army Forces (USARFOR) personnel within theater. USARCENT G8 also supports selected enduring locations and a number of contingency sites. They execute approximately $25B annually and develop policies and standards for all USARFOR.

Mission failure would occur along the following items, if this extension is not completed:

● 46% reduction in capabilities would occur because contractor personnel are not available to fill mission critical skill gaps as required by PWS Sections 3.1, 4.0, and

5.0. Those mission critical skills include expert knowledge of all regulatory and contractual policies to prevent violation of financial laws and regulations and preparation of ad hoc financial reports to inform decision making of senior USARCENT leadership. Contractor also provides expert level trainers to bring newly assigned military personnel up to speed when they rotate in and out every 6-months. Government personnel were reduced based on projected troop drawdown dates – circumstances changed that delayed drawdown. This reduction created a heavy reliance on highly technical and specialized contractor skill sets to accomplish USARCENT’s mission that supports US national security objectives in a volatile region.

● Degraded GFEBS Help desk support – GFEBS end users would not get the first level support they get today and would have longer wait times to get help for their daily issues as their tickets would go in the bigger Tier 2 bucket of the full Army Tier 2 support. This delay would impair USARCENT’s ability to get mission essential supplies to troops in the field. Help desk support is required IAW PWS Section 4.4.4.

● No Daily System Error Monitoring – The team provides daily system error monitoring and assists with resolution, without the team in place errors would increase and would have a negative effect on the mission. System monitoring is required by PWS Section 4.4.

● Minimal guidance on current business rules and processes and applying to usage of the system (PWS Section 4.4.9) – As GFEBS rolls out system changes and as USARCENT starts to utilize GFEBS-SA, the team assist them making sure they can execute their business processes in the new system and suggest changes in those processes to make both systems work. Without SME support, USARCENT mission would struggle with any system changes and usage of GFEBS-SA to keep their current business processes moving.

● Severe degradation to USARCENT’s in-theatre capability to integrate and support their supply system, financial system, contract system and aircraft support system as required by PWS Section 1.4, 4.4, 4.41, 4.4.4 and 4.4.9. Because all of these systems are interdependent, a GFEBs failure would disrupt USARCENT’s ability to obtain critical services to the bases such as food services, building maintenance and janitorial services.

● Significantly delayed response times to complete accounting reports, data analysis and management, drafting operational plans, Army-wide standards training, meeting support, accounting support (systems and managerial), planning, programming, execution status, and system support for USARCENT G8 using the FM Battle Command Systems as prescribed in PWS Section 3.0. This shortfall would degrade USARCENT’s ability to conduct planning and program functions for future needs in support of forward deployed troops, placing them at high risk.

3. Description of the services required to meet the agency’s need (including the estimated value)

USARCENT G8 has four strategic FM objectives for the theater:

(1.) FM Battle Command Systems (eCommerce), (2.) Cost Culture, (3.) Cost of USARCENT and (4.) Implementing new FM Tactical Doctrine

This modification would provide Functional Resource Management support of the four objectives and the contractor would provide the following services:

● generate accounting reports

● data analysis and management

● drafting operational plans

● Army-wide standards training

● meeting support

● accounting support (systems and managerial)

● planning

● programming

● execution status, and

● system support for USARCENT G8 using the FM Battle Command Systems

The estimated value for the 7-month extension is

4. The authority and supporting rationale:

Pursuant to FAR 8.405-6(a)(1)(B), only one source is capable of providing the services required at the level of quality required because the services are unique and highly specialized.

The following rationale listed below demonstrates that it is not practicable to transition to a new contractor given all of the constraints in our current COVID operating environment.

Like the USA, Kuwait and Qatar (host countries under this contract) have been devastated by COVID-19, the deadliest pandemic since the Flu pandemic of 1918 that killed at least 50 million people worldwide. To date, approximately 2.24 million people worldwide have died from COVID-19.

This devastating virus has completely transformed how people live their everyday lives.

Previously simple and routine activities have become arduous, complex and more time consuming because of required safety measures to prevent transmission of COVID-19. The measures include social distancing, wearing masks, enhanced personal and facility hygiene, working remotely and in some cases, temporarily ceasing operations of Government and private sector functions. All of these circumstances have compromised the functioning of the services rendered under this contract.

As an example, the borders of both Kuwait and Qatar have been temporarily closed several times over the past 11 months. If any of the relevant borders associated with this effort were unexpectedly closed during the timeframe that was planned for mobilization of new contractor personnel, there would be no way to get deploying personnel into the country, which in-turn would seriously compromise - if not threaten entirely - the GFEBS mission. In addition, the visa offices in these countries have temporarily halted issuing visas on several occasions. When open and issuing visas, these offices are working restricted hours with minimum staffing, which results in extended processing time for visa applications. If the visa office was unexpectedly closed due to a COVID-19 office outbreak during the timeframe that was planned for incoming new contractor personnel to apply for new visas, there would be no way to get deploying personnel into the country, which in-turn would similarly compromise GFEBS contract operations. The current policy of Kuwait and Qatar is to automatically extend the visas of in-country personnel when new visas are not being processed, in order to preserve mission integrity. The incumbent contractor, Accenture, has the qualified personnel in place, with the requisite credentials, in order to provide mission continuity during which the effort may be competed over an elongated timeframe, allowing at the very least for the currently foreseen contingencies occasioned by the COVID pandemic.

Adding the complexities of COVID-19 to the already complex operational and logistical challenges of operating in the USARCENT theatre presents an unprecedented level of difficulty for mobilizing contractors into this theatre. The specific challenges associated with mobilization for this particular requirement include but are not limited to the following:

● A new contractor would have to secure a new formal agreement after finding an in-country sponsor company to facilitate approval of work visas for contractor employees. The timelines associated with this undertaking are elongated by COVID-related protocols, even in the absence of travel restrictions, border closings, etc.

The in-place contractor (Accenture) will only have to extend the current agreement which is less complex and would be completed in one-third the time;

● A new contractor must secure a new property lease for contractor employees’ living quarters; this is a complex and time-consuming process, as opposed to just extending the current lease. Employee living quarters must meet stringent safety and anti-terrorism parameters to safeguard contractor personnel, and as a result, are much harder to secure. The timeline for properly and successfully undertaking this effort is elongated by COVID-related restrictions on leasing activities.

● In-country sponsorship is also required for employees to obtain a driver’s license, which is taking longer than usual because of limited operating hours and longer waits in line due to constraints on how many people can be in office at any given time;

● Contractor must have a contract document with a period of performance that substantiates the time frame of the VISA request. Executing a contract modification would get the required contract document in the contractor’s possession several weeks faster than awarding a new contract;

● Contractor employees are required to obtain new CAC cards that coincide with dates of a new contract. These new CAC cards will only be issued after contractor presents a copy of the new contract document to the CAC card issuing office. Executing a contract modification would get the required contract document in the contractor’s possession several weeks faster than awarding a new contract;

● The new contract requires upload into SPOT. New LOAs will have to be processed in

SPOT to coincide with new POP. This step will be avoided when awarding a modification to the existing contract;

● ARCENT must finalize the new DD254 within the new and unfamiliar automated

Procurement Integrated Enterprise Environment (PIEE). This step will be avoided when awarding a modification to the existing contract;

Considering the above requirements that are impracticable to accomplish even without the current pandemic, when adding the COVID-19 difficulty factor into the equation, the entire acquisition team is in unanimous agreement that awarding a new contract, mobilizing a new contractor into this challenging USARCENT theatre and achieving full contractor operations by March 28, 2021 is not feasible or achievable. This pandemic took the entire world by surprise and there was no way the Government acquisition team could have foreseen this event, nor foreseen - even after several months of dealing with the pandemic and the world’s evolving responses - the particular impacts it would have on the competition and award of a follow-on contract for this requirement.

Accenture is the only company with GFEBS trained and certified personnel, who are in the required locations. Accenture was competitively awarded this current GFEBS contract on Mar 23, 2017. Accenture has GFEBS certified specialists already located in the required CONUS and OCONUS locations-Shaw AFB SC, Kingstown VA, Kuwait and Qatar.

USARCENT is responsible for the sustainment of the Army and DoD’s suite of financial and business management systems world-wide. The GFEBS system is a critical link between these business management systems because it integrates and supports DoD’s supply system, financial system, contract system and aircraft support system. Therefore, to meet its mission, USARCENT requires highly specialized expertise in the design, build, test, analysis, data input, error correction and maintenance of the GFEBS system.

GFEBS system went into production in 2009. The GFEBS system is critical because it affects supplies, credit cards, contracts and aircraft support. The GFEBS system is a fully automated system and results in efficient paper-less processes. Information input incorrectly results in multiple errors and requires extensive analysis and man hours to correct. GFEBS has experienced major problems resulting in the shutdown of the system due to input errors. Therefore, specialized user training and certification is critical.

GFEBS systems users are required to be certified for each role assigned within the system.

There are twenty-one (21) possible roles. The GFEBS specialist must be trained for an average of 138 hours for each assigned role. Training normally takes two (2) to three (3) months to complete course work and receive certification for access to one role. The specialist (contractor) is required to receive certification in all twenty-one (21) roles. The contractor will not perform roles that require movement of funds but must have the expertise to analyze and troubleshoot the system.

The Resource Manager (RM) is the final signature authority for input into the system. In general, military personnel are assigned as Resource Managers. Military personnel are assigned to a duty station for nine (9) months. The civilian GFEBS specialists (contractor) are responsible for inputting and correcting errors and providing critical support and training to the RMs.

Award to another contractor would create substantial disruption and unacceptable mission delays and an unacceptable degree of risk for mission compromise for USARCENT G8, due in large part to the necessity to respond in real time to ever-shifting COVID-19 circumstances.

The USARCENT mission has transitioned from primarily Counter Insurgency (COIN) to a Train, Assist and Advise (TAA) role as we move closer to the Resolute Support Mission (RSM). As a result of these changes, the large reduction of forces has caused considerable personnel constraints in being able to effectively manage the GFEBS program. In October 2017, USARCENT underwent another 46% reduction in forces. As a result, Government personnel are not available to fill contractor skill gaps, and selection of a new contractor, without proper transition-in time, and the significant risk of disruption due to delays occasioned by unforeseen and ever-evolving COVID-19 protocols (from both the host nations and DoD) would mean that quality of data services could drop so low, that the mission could not be accomplished.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d)

Prior to the issuance of the modification, Accenture’s proposed labor categories and labor rates will be reviewed and verified. A price analysis will be performed using the price analysis techniques outlined in FAR 15.404-1(b)(2) to determine that the proposed price is fair and reasonable. The IGCE, historical pricing, and a review of prices for similar contracts will be used as the benchmark for the price analysis. No award will be made until Accenture’s proposed price for the task order modification has been determined fair and reasonable.

6. A description of the market research conducted among schedule holders and the results

A formal market research report was not completed. Review of contractors on applicable contract vehicles, and experience with previous solicitations have indicated that there are other companies with the general skills necessary to perform this work. However, because of the highly specialized training requirement necessary to be certified in GFEBs operations, only one vendor, Accenture can meet the requirement in the timeframe needed. If other companies were selected to do the work, quality of GFEBs support would drop precipitously to unacceptable levels, and adversely affecting USARCENT’s mission while the incoming contractor received training and certification.

7. Any other facts supporting the justification

The prospective contractors did have a logistics capability to complete personnel security reviews, medical screening, vaccinations, 5-day CONUS Replacement Training Center course, CAC card issuance, military flight reservations, passports and visas in the compressed timeframe required for this acquisition.

The lead time required to complete personnel security reviews, medical screening, vaccinations, 5-day CONUS Replacement Training Center course, CAC card issuance, WRITTEN DETERMINATION IAW FAR 8.405-6(c)(2)(xi) AND FINAL APPROVAL:

Pursuant to 10 U.S.C. 2304c.(b)(2); DFAR 208.405-6 AND FAR 8.405-6(a)(1)(b), It is my determination that an urgent and compelling need exists and following the procedures would result in unacceptable delays. Accenture is the only source capable of providing the services required at the level of quality required because the services are unique and highly specialized.

Date Acquisition Oversight Executive Competition Advocate FAS, Region 9 U.S. General Services Administration