Redacted LSJ.pdf

Limited Sources Justification United States Department of Agriculture

FAR 8.405 Federal Supply Schedules Multiple Award Schedule Program

1. Identification of the agency and the contracting activity.

United States Department of Agriculture (USDA) Food and Nutrition Service (FNS) Contracts Management Division (CMD)

2. The nature and/or description of the action being approved.

Pursuant to FAR 8.405-6, FNS requests approval by the Head of the Contracting Activity to award a sole source Federal Supply Schedule (FSS) Bridge Contract to Deloitte Consulting LLP from 31 August, 2020 through 30 November, 2021 (15 months) to continue support for the mission critical FNS financial management systems and operations until a new full and open competition contract can be awarded and the transition to a new vendor can be successfully completed.

This acquisition will provides Financial Management, Food and Nutrition Service, US Department of Agriculture with continuing expert functional and technical support services to maintain the mission critical financial systems and operations of the Food and Nutrition Service in support of over $100 Billion in annual federal appropriations – in excess of 70 percent of all budget authority in USDA.

These appropriations support the mission of FNS by working to end hunger and obesity through the administration of 15 federal nutrition assistance programs including the Women, Infants, and Children Program (WIC), the Supplemental Nutrition Assistance Program (SNAP), Food Distribution Programs, and Child Nutrition Programs (CNP). In partnership with State and Tribal governments, these programs serve one in four Americans during the course of a year.

FNS maintained its own financial management system, IPAS, prior to May 2015 when FNS went live in FMMI after the development of the USDA FMMI Grantor solution for FNS. However, critical functionality was missing in USDA FMMI Grantor for FNS to continue program financial management operations. Deloitte played a key role in the process by which this functionality was incorporated into the FMMI Grantor environment and continues to support FNS in its work with USDA OCFO to maintain and operate these essential capabilities. Additionally, to support the Budget, Accounting and Grants Management Divisions, FNS developed the Budget User Desktop Solution (BUDS) for budget execution, Grants Information Management System (GIMS) for grants management, Automated Entity Resolution and Optimization System (AEROS) for accounts receivable activity, and various financial reports in SAP Business Objects. These FNS financial management systems and reports are hosted in the Microsoft Azure cloud.

It is critical to the continued operations of the FNS feeding programs, and $100 Billion in annual federal appropriations, that contractor support by Deloitte be maintained until a new contract can be awarded, a vendor selected, and the transitions of all system and financial operational services have been completed.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The contractor shall provide technical systems and financial management operations support services that will include all activities necessary to support FNS accounting, budget and grant operations associated with FMMI and FMMI Grantor, develop and maintain specific FNS FMMI reports, support the BUDS, GIMS AEROS, Grant/Letter of Credit Amendment Processing, and Integrated Data Extract & Analysis, including O&M and enhancements, special projects, and provide general IT support services, Microsoft Azure cloud hosting support and enhancements, and disaster recovery support.

This includes all phases of a system operation including: project planning and management for the implementation, the identification of any software modification, the identification of any new processes or interfaces, the testing of the system implementation, the development of system and user documentation, end-user training, change management activities, and sustainment support. The total estimated value of the supplies and services is $18,026,683 for a period of performance of August 31, 2020 through November 30, 2021. A 15 month period of performance is critical to ensure ongoing support at the required level of expertise and provides the time necessary to re-compete the contract and allow for an 8 to 10 month transition period with a potentially new contractor. It is essential that the transition period include the end/beginning of fiscal years given the complexity of FNS appropriations.

4. The authority and supporting rationale.

Pursuant to FAR 8.405-6(a)(1)(i)(B), Deloitte is the only contractor capable of providing the service and support requirements of the bridge contract which includes a detailed transition plan deliverable.

This bridge contract is a critically needed to continue Deloitte contractor support until a new full and open contract can be awarded. It is envisioned, due to the complexity and scope of the ongoing FNS financial management support needed, that it will require a 15 month contract with a transition period of eight to ten months due to the date of award falling so close to the fiscal year-end, the start of the new fiscal year and the financial statements audit work all being done during this end of year period.

It is critical to the continued operations of the FNS feeding programs, and $100 Billion in annual federal appropriations, that contractor support by Deloitte be maintained until a new contract can be awarded, a vendor selected, and the transition of all system and financial operational services have been completed. Without this support FNS will not be able to continue to maintain control over the $100 billion and put in jeopardy the operation of the 15 feeding programs as well as the USDA financial statements audit.

This acquisition will provide Financial Management with continuing expert functional and technical support services to maintain the mission critical financial systems and operations of the Food and Nutrition Service in support of over $100 Billion in annual federal appropriations, nearly 75% of the total USDA. These appropriations support the mission of FNS by working to end hunger and obesity through the administration of 15 federal nutrition assistance programs including the Women, Infants, and Children Program (WIC), the Supplemental Nutrition Assistance Program (SNAP), Food Distribution Programs, and Child Nutrition Programs (CNP).

The incumbent contractor developed and maintains the subject software systems, maintains all proprietary rights to IPAS, and transitioned FNS into the USDA FMMI and supports all FNS financial management operations. These systems are all hosted in the Microsoft Azure cloud. The systems include GIMS, BUDS, AEROS, and various FNS developed SAP Business Objects reports.

These systems are highly complex, were designed to increase FNS Financial Management productivity by eliminating manual processes, interface with FMMI and other external data sources, and require expertise in both IT system development and federal financial management including federal accounting, grants management and budget execution, to properly maintain and operate.

The transition of a new vendor would require they provide all the expert technical staff needed to assume the role now provided by Deloitte including operations & maintenance, enhancements, special projects, and provide general IT support services, patch management, and disaster recovery support. They would need expertise in the operations of the Federal version of the Microsoft Azure cloud and USDA’s FMMI financial management system. They would also need to provide support for all phases of any systems enhancement or new implementation including: project planning and management, the identification of any software modification, the identification of any new processes or interfaces, the testing of the system implementation, the development of system and user documentation, end-user training, change management activities, and sustainment support.

The current contract is due to expire on August 30 August, 2020. The services received under the contract are deemed critical to FNS’s Mission Area and must continue to be received until a competitive contract is awarded. If FNS does not have a contract in place by 31 August 2020, it would disrupt the continuity of services of the financial system and would be detrimental to FNS’ ability to account for and provide funding to its programs.

5. A determination by the ordering activity Contracting Officer (CO) that the order represents the best value consistent with FAR 8.404(d).

Although GSA-FSS has already determined prices under its Multiple Award Schedule (MAS) contracts to be fair and reasonable, the Contracting Officer will ensure the proposed cost to the Government for the supplies or services covered by this justification are evaluated for price reasonableness and the contemplated order represents the best value to the Government. A best value determination will be based on a Government technical evaluation and price analysis of the contractor’s quote, which will include a comparison of the contractor’s quote to the Independent Government Cost Estimate, other quotations, or by comparison to established GSA or other published price lists.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

The incumbent contractor developed the subject software system and maintains all proprietary rights.

There are no authorized resellers or service providers for the Performance Series (COTS) software product known as IPAS.

Vendors were researched using the GSA Advantage, Professional Services website. Categories were:

IT Professional Services, Financial Services (FABS) and Mission Oriented Business Integrated Services (MOBIS). Criteria for the search was: Large Business, listed on Schedule 70, MOBIS and FABS schedules. Expertise required in: IT Systems Operations & Maintenance, Information Security, Cybersecurity, Assessment and Authorization, cloud migration and optimization, Accounting operations, Budget execution, financial management operations, and federal financial software and systems integration.

25 Large Vendors were identified that met the above criteria. However, based on the background, need and constraints, the acquisition shall be completed pursuant to FAR 8.405-6 once the LSJ is approved.

7. Any facts supporting the justification.

The current contract was awarded on 08/31/2017 for a base and 4 option years, with a period of performance of 08/31/2017 to 08/30/2022. We are ending this contract early and will award the bridge contract to provide us the means to move into a competitively awarded contract in November 2021.

8. A statement of actions the agency may take to remove or overcome any barriers to competition if subsequent acquisitions are anticipated.

FNS is currently working to develop the full documentation needed to award a new contract to support its financial management operations under full and open competition. The PWS for this bridge contract includes a transition plan deliverable from the contractor which will reduce the risk to FNS and USDA. The need for the IPAS system will end at the end of FY 21 which is around October, 2021 when we start the new fiscal year.

Certifications & Approval

Supporting data which form the basis for and included in this justification are certified accurate and complete.

Hongmei Luo

COR

The information contained in this Limited Sources Justification is certified accurate and complete to the best of my knowledge and belief.

Ronnie Hall Contracting Officer

Additional Reviews & Approvals

Signatures are required at each threshold below up to the total estimated dollar value of the acquisition

Advocate for competition for the procuring activity (if over $700,000, but not exceeding $13.5 million).

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as advocate for competition for the procuring activity, I hereby approve this justification.

Richard Jiron Mission Area Advocate for Competition

Head of the Procuring Activity (if over $13.5 million, but not exceeding $68 million).

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as Head of the Procuring Activity, I hereby approve this justification.

Richard Jiron of the Head of the Contracting Activity Head of the Contracting Activity