SF_1014_-_JEFO_-_BAH_Analytics_4.30.19_Signed_4-30-2019.pdf

DEPARTMENT OF THE TREASURY

SF 1014 - JUSTIFICATION FOR AN EXCEPTION

TO FAIR OPPORTUNITY

Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505 Tracking No.

1. Identification of the requiring activity and the contracting activity:

The requiring activity is the Internal Revenue Service’s PGLD, Identity Assurance (IA) team.

The contracting activity is Procurement’s Office of Business Operations (OBO) Division, Support Contracts Branch.

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

The purpose of this Justification for an Exception to Fair Opportunity is to obtain approval to award a Bridge/Interim contract for Identity Assurance Operation Analytics to the incumbent contractor, Booz Allen Hamilton, Inc., as described in section 3.a below. The need date for these services is June 10, 2019.

The anticipated period of performance will be from June 10, 2019 through May 9, 2020.

The period of performance is inclusive of one 9-Month Base Period, plus one (1) 2-Month Option Period for transition (if necessary).

2.b Name of the vendor. Booz Allen Hamilton, Inc.

2.c Requisition No: 5000066138 2.d Bridge contract: X Yes No 2.e Brand name: Yes X No 3.a A description of the supplies or services required to meet the agency’s needs:

This acquisition is for analytics, monitoring, and professional services required by the Identity Assurance (IA) team located within Privacy, Governmental Liaison, and Disclosure (PGLD).

Authentication is necessary for taxpayers who request services from the IRS whether through a phone call, an online web application request, a visit to a taxpayer assistance center, paper correspondence, or filing a tax return. The Service has implemented a two-fold strategy to strengthen authentication and authorization across these channels: 1) improve the tools, and authentication and authorization processes for using internal IRS data and systems, and 2) explore where external third-party data sources can be incorporated into the overall authentication model. Specifically, Identity Assurance (IA) is chartered to centralize business oversight and facilitate cross-functional and Business Operating Division (BOD) decision-making for the development and integration of authentication and authorization frameworks, policies, processes, and measures across IRS, focusing on data-driven analysis, and impact to taxpayers along with associated measures.

Effective authentication and authorization policies, processes, measures and capabilities are essential to the IRS’s customer-centric business model. Authentication is necessary to ensure the IRS is providing services and information to the correct taxpayer and is a front-line defense against fraud and identity theft. Typically, authentication of a taxpayer occurs at the outset of a customer interaction, authentication and authorization processes and requirements can have a profound impact on the taxpayer’s experience in interacting with the Service. IA is instrumental to ensuring that Service-wide authentication and authorization capabilities, which are often managed by service functions, meet the needs of the business so the right services can be delivered to the right taxpayers, while mitigating the risks of fraud and identity theft.

IA requires contractor support with expertise in analytics, monitoring and reporting for systems and business processes related to Identity Assurance as well as expertise in project management to develop action plans, strategies, and roadmaps related to identity verification. IA is tasked

TO FAIR OPPORTUNITY

Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505 Tracking No.

with a portfolio of high priority initiatives central to IRS’s efforts to combat identity theft and refund fraud while improving the taxpayer experience, including authorization.

3.b Includes IT: Yes X No 3.c IGCE/Estimated dollar value:

The IGCE is $1,255,470.32 inclusive of a 9-Month Base Period and One (1) 2-Month Option Period.

4.a Identification of the exception to fair opportunity being used:

FAR 16.505(b)(2)(i)(A) – The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

FAR 16.505(b)(2)(i)(B) – Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

X FAR 16.505(b)(2)(i)(C) – The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order

FAR 16.505(b)(2)(i)(D) – It is necessary to place an order to satisfy a minimum guarantee.

FAR 16.505(b)(2)(i)(E) – For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

FAR 16.505(a)(4) – The requirement is for an item peculiar to one manufacturer.

4.b Supporting rationale:

The proposed acquisition requires use of the authority cited as follows:

The Government currently uses the proposed contractor for the described services. This bridge/interim vehicle addresses the Government need for continuity of operations in support of Identity Assurance’s mission by providing support with analytics, monitoring and reporting for systems & business processes, as well as project management activities related to identity verification.

The incumbent contractor has successfully performed these exact same services to support Identity Assurance’s mission under Contract Number TIRNO-11-D-00011-0032, originally awarded June 10, 2016. This contract was competitively awarded under the TIPSS-4 ITS IDIQ Contract and was not awarded under sole-source or limited-sources procedures. The proposed work is a logical follow-on to the incumbent contractor’s current work in terms of scope and value to the Government by allowing continuity of services with the incumbent vendor.

The Government requires continued services from the incumbent contractor to provide interim/bridge support until a re-compete and transition to a new contract vehicle is completed.

The Government intends to issue a competitive solicitation for these services under GSA OASIS after the bridge contract is awarded, during the beginning months of Fiscal Year 2020.

5. A determination that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer has determined that the anticipated price will be fair and reasonable based on prior acquisition history for the same services.

TO FAIR OPPORTUNITY

Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505 Tracking No.

6.a Any other facts supporting this justification:

Procurement History These services are currently being provided by Booz, Allen, Hamilton under Contract Number TIRNO-11-D-00011-0032. This contract is set to expire on June 9, 2019.

The Total Value of the Identity Assurance Operation Analytics services provided by the incumbent vendor under Contract Number TIRNO-11-D-00011-0032 is estimated to be $6,000,000.00.

Because the work is highly specialized, mission critical, and the Government does not have the resources to perform the work in-house, the Government cannot allow a gap in services to occur.

6.b Attachments: X Yes No

7. A statement of the actions, if any, the Requiring Activity and Contracting Activity may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies and services is made:

The subsequent acquisition will be competed under a Best-in-Class vehicle (GSA OASIS) in FY2020 after this interim/bridge task order is awarded to continue services. At this time, the estimated release date of the competitive solicitation is sometime during the beginning months of FY2020. Identity Assurance plans to submit a package for a competitive acquisition later in

FY2019.

In the interim, IA needs interim support to bridge the gap between the expiration of the current contract and the award of the new contract. IA cannot have a break in service as the services provided by the incumbent vendor are crucial to the IRS mission. The vendor is also critically involved with the integration of a third-party vendor into Secure Access which is the gateway that all taxpayers go through when logging on to online applications. Without this service to monitor access, taxpayers will be negatively impacted.

A new, competitively awarded follow-on contract will be put in place after this interim contract to continue services expires. It is anticipated that the competitively awarded follow-on contract to TIRNO-11-D-00011-00032 will be in place by March 1, 2020.

8. Certifications and Approvals:

8.a Program Office Certification (Requiring Activity). I hereby certify that any supporting information and data provided (e.g., the Government’s minimum needs or requirements, or other rationale for the limited sources) and which form the basis for this justification for an exception to fair opportunity, are accurate and complete to the best of my knowledge and belief.

Name: Marsha Coleman Date: 4/30/19

Signature:

8.b Contracting Officer Certification and Approval. I certify this justification for an exception to fair opportunity is accurate and complete to the best of my knowledge and belief.

Therefore, unless additional approvals are required as prescribed below, as the authorized

TO FAIR OPPORTUNITY

Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505 Tracking No.

contracting officer for this acquisition, I hereby approve the processing of this requirement based on the authority specified in 4.a above.

Name: Mathew Nelker Date: 4/30/19

Signature:

6. Additional Reviews and Approvals (As applicable):

9.a Bureau Chief Information Officer or Authorized Designee (for IT requirements that are over $5 million, but not exceeding $68 million) (Contracting Activity). 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. (Note: The Bureau CIO may delegate their authority for proposed contracts over $5 million, but not exceeding $13.5 million to the Associate Bureau CIO(s).)

Name: Date:

Signature:

9.b Advocate for Competition (if over $700,000, but not exceeding $13.5 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity 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 the ordering activity’s Advocate for competition, I hereby approve this justification based on the authority specified in 4.a above.

Name: Date:

Signature:

9.c Head of the Procuring Activity or Authorized Designee (if over $13.5 million, but not exceeding $68 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity 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 the head of the procuring activity or authorized designee, I hereby approve this justification based on the authority specified in 4.a above.

Name: Date:

Signature:

9.d Treasury Chief Information Officer (for IT requirements that are over $68 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:

9.e Senior Procurement Executive (if over $68 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity and find it to be accurate and

1XYMB Digitally signed by 1XYMB Date: 2019.04.30 10:45:05 -04'00'

TO FAIR OPPORTUNITY

Treasury Standard Form – 1014 (Rev 5/18)

Prescribed by Treasury: DTAP 1016.505 Tracking No.

complete to the best of my knowledge and belief. Therefore, as the senior procurement executive, I hereby approve this justification based on the authority specified in 4.a above.

Name: Date:

Signature: