SS just CARPOL posted 8-4-20.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.

Contracting Activity: USDA, APHIS, MRPBS, Acquisition and Asset Management Division (AAMD) 250 Marquette Ave., Suite 410 Minneapolis, MN 55401

Ordering Agency: USDA, MRPBS, IT, Digital Services Support Office (DSSO) 4700 River Road Riverdale, MD 20737

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

The USDA, APHIS, MRPBS, AAMD intends to award a Blanket Purchase Agreement (BPA) under GSA contract GS-35F-540GA to Accenture Federal Services, LLC for continued software development, implementation, and system operation of the APHIS eFile system for permit modules.

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

The current eFile system has been developed under the Certification, Accreditation, Registration, Permitting and Other Licenses (CARPOL) Information Technology (IT) contract (BPA). This BPA was originally awarded to Phase One Consulting under a competitive GSA Federal Supply Schedule procurement. The purpose of the procurement was to consolidate multiple IT systems, as well as a number of end-to-end manual processes, under one IT system utilizing the Salesforce platform. The BPA objective was to integrate and implement a secure, scalable, and consolidated solution to facilitate the online submission, routing, and decision making of the CARPOL processes. The current eFile services are being performed by Accenture Federal Services (AFS) who succeeded Phase One Consulting via a novation agreement in December 2017.

The current primary focus of the eFile BPA is to complete development and integration of modules to allow for the replacement of two legacy IT systems (the ePermits system and the Animal Care Information System (ACIS)). Both of these are aging systems which are becoming more inefficient to maintain and need to be replaced in the very near future to avoid excess operations and maintenance costs.

APHIS will issue AFS a series of fixed-price BPA calls to accomplish the tasks that will enable the retirement of the ePermits and ACIS IT systems. The work will encompass additional design, change management services, and Agile sprint delivery to provide the required deliverables in the following areas:

1. Design, integration and sprint deliverables and necessary enhancements for remaining Plant Protection and Quarantine (PPQ) permit application types.

2. Design, integration and sprint deliverables and necessary enhancements for remaining Veterinary Services (VS) permit application types.

3. Support services for VS business logic definition.

4. Implement external Animal Care (AC) Registrations and Licensing capabilities in addition to remaining legacy data migration to allow the retirement of ACIS system.

5. Migrate AC and Biotechnology and Regulatory Services (BRS) permitting application to

Salesforce Lightning platform.

6. Deliver ongoing Operations and Maintenance until ePermits and ACIS is retired.

Estimated value for this BPA is $23,000,000 for Development, Modernization, and Enhancements and Operations and Maintenance. The BPA will be issued for a not to exceed amount of $24,000,000 over a two-year period.

4. The authority and supporting rationale.

FAR 8.405-6(a)(1)(C) - In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed 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.

Phase One Consulting was awarded a BPA, AG-6395-B-14-0087, under GSA contract, GS-35F- 0130U on September 26, 2014 for the CARPOL BPA, now known as eFile. This BPA was awarded competitively under GSA Schedule 70.

AFS has been working with APHIS very closely for the past two and a half years (after assuming the contract duties from Phase One Consulting) and has established an exceptional level of understanding of the intracacies of the eFile requirement. This experience is crucial in the continued development and enhancement of the eFile system, which is based on the Salesforce platform. As a result, AFS is considered uniquely qualified to continue performance of these critical services with the timeframe required to retire the other IT systems. In addition the their understanding of eFile’s unique requirements, AFS is one of a small number of companies (five in all) who specialize in Salesforce implementations and integrations within complex, multi-organizational government cloud ecosystems who have been awarded a GSA Salesforce Implementation, Integration, and Support Services (SIISS) BPA. This knowledge and experience is critical in the continued success of the eFile system and is especially crucial for the continued development and integration to replace the aging ePermits and ACIS systems without undue delay that would be associated with finding a new vendor and provide necessary training to allow them to continue essential tasks.

Replacement of personnel woud result in duplication of costs and significant delays due to training and suitability requirements, as well as the time required for new hires to learn site-specific practices and protocols which would sustantially delay APHIS’ modernization efforts.

The nature of the work in progress, the agency’s IT and program environment institutional knowledge, and intellectual capital gained through performance of the original contract cannot be transferred to a new contractor without a substantial duplication of time, resulting in a duplication of costs, missed milestone deliveries, and delays in obtaining efficiencies and effectiveness for the agency’s globally dispersed workforce and stakeholders.

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

In accordance with FAR 8.404(d), GSA has already determined the rates for services offered at hourly rates under schedule contracts are fair and reasonable. The rates proposed by AFS reflects an average discount of XXX from the GSA rates. AFS’ rates for the new contract are very similar to the contract rates for the prior contract which was awarded based on price competition.

At this stage of the eFile development, if any vendor other than AFS would be awarded the contract there would be a substantial and unnecessary duplication of costs due to the interruption of the support services to the Government for knowledge transfer which is not expected to be recovered through competition. In addition, the delays that this transition and transfer would require are unacceptable as the aging IT systems (ACIS and ePermits) need to be retired.

Swift movement on this BPA is required to minimize delays and additional costs to the eFile Project. Currently, APHIS is required to fund contractor operations and maintenance costs to maintain both the ACIS and ePermits systems as well as provide internal personnel to manage these systems. If this award is delayed, current production systems could see interruptions to mission-essential processes and services. Delays caused by a prolonged acquisition and a potentially lengthy transition process would cause significant delays in development of required functionality.

Additionally, delays would result in a significant expenditures to the Agency in maintaining both current and legacy systems.

Based on this information, I have determined that the pricing offered by AFS represents best value.

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.

In 2014, an open, competitive solicitation was conducted among small business GSA IT-70 contract holders. Phase One Consulting was awarded the contract under a best value determination. While there are other vendors who have experience with Salesforce implementations and integrations, AFS has two and a half years invested in the development of the eFile system (after taking over contract performance under the terms of the novation agreement). They have the knowledge and expertise needed to complete the development of the system. The transition to another vendor at this point in the development could cause significant delays and increased costs.

Limited market research has been conducted and no significant changes to the professional labor market were found to have occurred since the initial contract formation. Market research indicates further competition would not likely realize significant cost savings that would be offset the anticipated costs of mission delay of the eFile requirement. New contractors often experience steep learning curves and, as a result, contract performance can be slow to start until the new contractor gains sufficient knowledge of the organization and the operating environment in which the applications are to function. This is especially true in this case because the contractor must continue in-process development work involving applications that have been significantly customized to support APHIS’ core mission. And, in this case, the contractor has unique knowledge not only of the legacy systems involved but also of numerous other IT systems in various agencies that eFile must interface with.

7. Any other facts supporting the justification.

At the conclusion of this sole source contract there will be a competitive procurement for eFile operations and maintenance services as well as future development requirements for additional pathways.

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

Barriers to competition is not the intention of APHIS. The current contract was competitively awarded to the predecessor company before AFS assumed the performance. The eFile system was envisioned to be an iterative and scalable effort in lieu of a waterfall procurement. Thus, future contracts for incorporation of additional workflows and systems into eFile will be procured competitively. However, the current eFile development work is at a critical point in the timeline which would make it prohibitive to re-compete the contract at this time without great loss in time and money. This is a critical long-term development requiring historical reference and technical program capability. The risks of unacceptable delays and the particularly specialized nature of the work required are major obstacles to competition.

Certifications & Approval

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

Laura Lewandowski Branch Chief USDA, APHIS, MRP-Information Technology Services, Digital Services Support Office

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

Larry Nelson Contracting Officer

Additional Reviews & Approvals

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.

Larry Nelson Mission Area Advocate for Competition

Howard Price Mission Area Senior Contracting Officer

The head of the procuring activity placing the order for a proposed order or BPA with an estimated value exceeding $13.5 million, but not exceeding $68 million

Tiffany Taylor USDA, Head of the Contracting Activity