SF 1012_LS Justification_Clean Energy_final_Redacted.pdf

DEPARTMENT OF THE TREASURY

LIMITED-SOURCES JUSTIFICATION

IRA Clean Energy (CE) Special Handling Portfolio This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

Treasury Standard Form – 1012 (Rev 9/23)

Prescribed by Treasury: DTAP 1008.405-6

Tracking No.

1. Identification of the agency and the contracting activity:

The requiring activity is the Internal Revenue Service (IRS) Clean Energy (CE) Information

Technology (IT) Program Management Office (PMO).

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

The purpose of this sole-source justification is to obtain approval to award a Sole Source Firm

Fixed Price (FFP) contract to FedTec for the Clean Energy Support requirements described in section 3a below. This sole source award identified in the updated PWS.

The need-by date is November 22, 2024, for one ten (10) month Base Period (November

22,2024 – September 21 2025)

2.b Name of the vendor: FedTec LLC

2.c Requisition No.: 5000194178

2.d Bridge contract: ☐ Yes ☒ No 2.e Brand name: ☒ Yes ☐ No

3.a A description of the supplies or services required to meet the agency’s needs:

The required services are a continuation of the Clean Energy Program execution to acquire ongoing DME support for the Clean Energy continued development approach to IRA Energy

Security that aligns with the enacted H.R.5376 - Inflation Reduction Act of 2022 including additional provisions that were added by the Commissioner after the current task order was awarded.

The IRA PMO requires contractor support for IT Transformation for IRA, focusing on overarching Program. The CE contractor will continue to provide IT services management and implement individual case management functionalities into an IRS Enterprise Case

Management (ECM) platform using agile application development processes, methods, and standards.

The Project Management and oversight, portfolio management and prioritization, integration across the IT organization, organizational design and readiness, communications/outreach, planning and ensuring and technical expertise to support the development and implementation of the IRA Strategic Operating Plan efforts for multiple IRS solutions. The work to be performed which was added by the Commissioner after the current task order was awarded falls into four additional tasks: 1) Program Management, 2) Data Analytics, 3) Business

Reporting, and 4) Cybersecurity Support.

The contractor must ensure that newly introduced systems can seamlessly interact with existing platforms. This will require clear documentation and processes to facilitate smooth data flow and interoperability. The contractor should specify security requirements, including encryption, access controls, and compliance with IRS IT standards. Robust security protocols will not only protect IRS data but also bolster stakeholder confidence. The contractor should outline how data will be collected, analyzed, and reported, allowing IRS IT to derive actionable insights and improve operational efficiency. The contractor must ensure that all new systems and processes adhere to IRS IT regulations. Effective reporting serves multiple critical purposes that significantly enhance CE decision-making capabilities and overall project outcomes. The contractor must provide essential data and insights that enable CE IT

IRA Clean Energy (CE) Special Handling Portfolio This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

Treasury Standard Form – 1012 (Rev 9/23)

PMO to make informed decisions, by having access to accurate and timely reports, evaluate program performance, and adjust strategies as needed. The contract must provide structured reporting for the CE program of key performance indicators (KPIs) and metrics to evaluate both the contractor’s and the overall program’s performance.

3.b Includes IT: ☒ Yes ☐ No NAICS Code: DF01 NAICS Code: 541519

3.c IGCE/Estimated dollar value:

The Independent Government Cost Estimate (IGCE) for the Sole Source FFP is inclusive of one 10-month base period.

4.a Identification of the authority being used (Check the appropriate box that applies).

☐ FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

☐ FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

☒FAR 8.405-6(a)(1)(i)(C) – In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order or BPA provided that the original order or BPA was placed in accordance with FSS procedures in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

☐ FAR 8.405-6(b) – Items peculiar to one manufacturer. (i.e., Brand Name specifications)

4.b Supporting Rationale:

In effort to ensure all potential sources are aware of this effort, will be posted to Sam.gov.

FedTec is currently providing mission critical planning support and reporting for the IT related activities that will be communicated in the IRA Strategic Operating Plan under a contract vehicle. Integration and analyzing actions that the IRS IT IRA PMO requires to successfully communicate and report IT related activities in the IRA Strategic Operating Plan and immediately execute on its approval.

The successful execution of critical legislative mandates hinges on the immediate need to support the requirements elaboration, development, testing, and implementation of the essential

CE solutions. Specifically, the support provided through this task order is necessary to:

implement the required technological solutions timely. Without these resources, we will inevitably face unacceptable delays that will prevent us from meeting the established deadlines for these legislative mandates. Moreover, it is essential to implement robust security guardrails to prevent fraud associated with these mandates – failure to do so will further exacerbate delays, risking the integrity of our processes.

IRA Clean Energy (CE) Special Handling Portfolio This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

Treasury Standard Form – 1012 (Rev 9/23)

The risk of unacceptable delays can be comprehended in the context of critical legislative mandates that dictate the operations we perform. The impact of these delays includes non-compliance with deadlines, which may result in significant reputational harm to both the taxpayer and businesses; impaired access for taxpayers and businesses to the Clean Energy credits they are entitled to, negatively affecting their economic stability; an increased likelihood of fraudulent activities emerging from unregulated processes tied to the mandates.

The ramifications of such delays would not only disrupt our operations but would also jeopardize the mission of providing timely and accurate services to the public.

Failure to award this task order will directly threaten several mission-critical elements, including timely delivery of tax credits for taxpayers and businesses and operational integrity, which is critical for maintaining public trust and compliance with tax laws. Without these elements functioning effectively, we risk considerable backlash from the public and stakeholders who rely on these credits for financial support.

This task order is specifically designed to address the unacceptable delays that threaten our mission by: Implementing essential guardrails to ensure compliance with the legislation, prevent fraud, ensuring that the processes surrounding the legislative mandates are secure and trustworthy. Providing the necessary architectural and documentation support to deploy critical legislative mandates promptly, allowing us to meet deadlines without compromising the quality or security of our services. By securing these safeguards, we can protect taxpayers and ensure they have the access they need to credit and information.

FedTec is uniquely positioned to fulfill this role due to several key advantages: Established presence in the IRS environment.

Choosing a contractor unfamiliar with this scope would exacerbate delays. Personnel

Clearance: FedTec’s employees have already undergone background investigations required for this contract, allowing for immediate participation without

Experience and Continuity: Having been engaged for the past seven months, FedTec has the knowledge and experience necessary to contribute to the development of requirements and the roadmap needed for success. Implementing changes or new contractors mid-tax season would pose significant challenges. Introducing new resources at this juncture would not only disrupt established workflows but also hinder program effectiveness. The continuity provided by FedTec’s ongoing involvement in the project is essential for maintaining operational stability during this critical period.

The urgency of this acquisition is not due to lack of planning as the Inflation Reduction Act was enacted in August 2022 with accelerated milestones which include requiring the Agency to provide the IRA Strategic Operating Plan to the Secretary of the Treasury in February 2023.

The need for the stems from the initial market research which deemed the initial task order to go to a small business.

The IRS tax system and processes are highly complex, unique, and present multiple layers of abstraction thereby, requiring a support vendor who has specialized knowledge and understanding of the information pipeline. It takes approximately to fully

IRA Clean Energy (CE) Special Handling Portfolio This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

Treasury Standard Form – 1012 (Rev 9/23) understand the IRS environment, processes, and workflow. As a vendor that has some background in working within the IRS environment, FedTec has some understanding of the

IRS information pipeline, business, and technical workflows as well as organizational dependencies that will enable IRS to complete its planning for the implementation required by the IRA Strategic Operating Plan.

Upon immediate approval of the plan, the team will need to continue to rapidly move out on execution planning and dependencies of the Strategic Operating Plan across the Service to meet the FY24/25 committed goals such as expanding scanning services by filing season, allowing taxpayers to respond to notices online and expanding customer call back for taxpayers. In addition, this support is needed to help drive the Strategic Operating Plan over the next 12 months.

The award of this task order will provide additional resources to support a structured approach to . However, it is vital to recognize that the task order vastly reduces the risk of operational disruptions and service delivery failures to guarantee a smooth transition without compromising the progress and integrity of our current operations. Failure to secure a task order could result in a gap that would lead to delayed deliveries, and inability to meet client and tax obligations during the filing season. This could have far-reaching financial and tax repercussions for the organization.

Desired Outcome: All task order efforts are transitioned timely, seamlessly, and completely from the incumbent contractor to the successor contractor and/or Government personnel without a lapse in services provided or delays in scheduled performance.

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

The Contracting Officer will determine that the anticipated price(s) will be fair and reasonable based on comparing prices/costs with prior and similar task orders issued and GSA price list.

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

Market research was conducted in accordance with FAR Part 10. FAR Part 10 establishes the requirements for ensuring that agencies conduct market research to arrive at the most suitable approach to acquiring services. Specifically, FAR 10.001(a) requires that: Agencies shall (1)

Ensure that legitimate needs are identified, (2) Conduct market research appropriate to the circumstances, and (3) Use the results of market research to determine if sources capable of satisfying the agency’s requirements exist.

The Inflation Reduction Act (IRA) Clean Energy (CE) Security Program requires a continued development approach to IRA Energy Security that aligns with the enacted H.R.5376 -

Inflation Reduction Act of 2022 signed into law by President Biden on August 16, 2022.

H.R.5376 – 89, Subtitle D – Energy Security Parts 1 - 8, requires the creation of an Energy

Security Program that reflects direct support services in the following areas: program/project management, requirements elicitation, architecture, engineering, cybersecurity, development, testing, documentation, operational and maintenance, and enhancements.

Treasury Standard Form – 1012 (Rev 9/23)

10.d Treasury Chief Information Officer (for IT requirements that are over $75 million).

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification.

Name: Date:

Signature:

10.e Senior Procurement Executive (if over $75 million) (Contracting Activity). I have reviewed this limited-sources justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, I hereby approve this limited-sources justification.

Name: Date:

Signature: