SoleSourceJustification-73351020D0002.pdf

Sole Source Justification Memorandum – FAR 6.302-2, Unusual and Compelling Urgency Page 1 of 2

73351020D0002

Sole Source Justification- Supplement to Class JOFOC for COVID-19

Emergency Acquisition for Professional Support Services CAFS IT Systems

Presidential Declared Emergency – COVID-19 Virus and Response to Resulting Economic

Crisis

FAR 6.302-2, Unusual and Compelling Urgency – Exception to FAR Competition Requirements

1-The Office of Capital Access (OCA) operates and maintains the Capital Access Financial

Systems (CAFS) IT systems, through which all financial actions sponsored by the SBA are processed. This is a new contract for the emergency professional services to support the CAFS IT systems as it goes through large growth in terms of numbers of transactions and in designs that take on new financial programs, such as PPP (Paycheck Protection Program), and enhanced financial programs, such as increased loans by ODA (Office of Disaster Assistance) . This acquisition is necessary due to increased processing and reliability demand placed on the CAFS systems for COVID-19 loan approval and servicing as the Federal Government puts in place financial help for the nation’s small business community. This increased demand translates to many new IT workers on this system that require direction and coordination.

In April 2020, and in response the CARES Act legislation, the SBA processed 14 years’ worth of

SBA loans in prior years, in 14 days during the first round of PPP.

Acquisition of these professional services for the CAFS IT Systems are of an unusual and compelling urgency that precluded full and open competition. The SBA determined that a delay in the award of this contract would result in serious injury, financial or other, to the Government.

See FAR 6.302-2(b).

This IDIQ (Indefinite-Delivery Indefinite-Quantity) contract has a base of one year with two 6-month options to allow flexibility in meeting the emergency demand as it develops. The minimum total order amount is $5M and the maximum order amount is $13M – and may need to be increased to handle these urgent and compelling circumstances. The first task order is in the amount of $13M, and satisfies the IDIQ minimum and maximum.

Guidehouse, LLP (Guidehouse - DUNS no. 079529872) is the chosen contractor due to its understanding and familiarity with the CAFS IT systems, as it serves as both the CSA (Central

Servicing Agent) for the SBA Guaranty 504 Loan Program and as the FTA (Fiscal Transfer

Agent) for the SBA Guaranty 7(a) Loan Program.

2-Review was obtained. The CO considered all comments and made the best business decisions under the circumstances. The reviews and response are documented in the PRISM file.

Sole Source Justification Memorandum – FAR 6.302-2, Unusual and Compelling Urgency Page 2 of 2

3.Market research was performed to find a business ready and able to immediately begin to provide the required services. No written interest was expressed by the marketplace. Only the awardee, Guidehouse, was found to be able to perform quickly and effectively. Pricing was found fair and reasonable when compared to marketplace pricing.

Determination: I certify that this justification is accurate and complete to the best of my knowledge and belief. In addition, the President’s declaration of a formal COVID-19 national crisis adds credence to this sole source decision.

Cheryl T. Flanagan, Contracting Officer, SBA

The class J/A for urgent compelling actions signed by the SBA SPE (Senior Procurement

Executive) as Congress was passing the CARES Act, applies to this procurement because of the emergency contracting actions required to support the CAFS (Capital Access Financial System)

IT Systems operated by SBA, OCA (Office of Capital Access) OPSM (Office of Performance and Standards Management). All PPP (Payroll Protection Program) funding is processed by the

CAFS IT systems, along with all financial programs sponsored by the SBA, including all disaster loans and grants. The strain on the CAFS IT systems as it processed and continues to process more funding in a few weeks than the systems have processed in the last 14 years, and also the

CAFS IT system is adapted to new rules and regulations of new and old federal programs aimed at the national small business community has caused tremendous strain on the SBA, and qualifies as a contracting emergency requiring the adaption to streamlined procedures.

Kip A. Sheppard, Acting SPE for the SBAS