TRP Bridge Sole Source.pdf

SOLE SOURCE JUSTIFICATION

SIMPLIFIED ACQUISITIONS OVER THE MICRO-PURCHASE THRESHOLD

AND UP TO THE SIMPLIFIED ACQUISITION THRESHOLD

Date: 6/16/22 Requisition Number: FHF-22-0324

This is a sole source justification in accordance with 41 U.S.C. 1901(e)(2), FAR 13.106- 1(b)(1).

1. NATURE AND/OR DESCRIPTION OF THE ITEM/SERVICE BEING

PROCURED AND ITS INTENDED USE (INCLUDE THE ANTICIPATED

COST):

The Federal Housing Finance Agency (FHFA)’s Office of Human Resource Management has a requirement for a qualified 401(k) Plan provider to provide services related to a 401(k) Plan benefit for eligible FHFA and FHFA-OIG employees and retirees.

The period of performance shall be for a base year, 7/1/22-6/30/23; with three 6-month option periods.

The anticipated cost is $150,000.00 for the entire period of performance ($55,555 for the base year plus allowance for increase/fluctuation in participant usage in the option periods).

2. SOLE SOURCE JUSTIFICATION AND RATIONALE (CHECK ONE AND

EXPLAIN BELOW):

__X__ Only one responsible source.

_____ Unusual and compelling circumstances exist.

_____ Other

Rationale:

The last option year under the existing contract with T. Rowe Price (FHF-17-P-0006) for providing 401(k) plan provider services to FHFA employees and beneficiaries ends June 30, 2022. During market research conducted in the Fall of 2021, FHFA learned there would be considerable time and effort associated with transitioning from the present 401K contractor to any replacement, if the incumbent is not awarded the recompete.

Upon award it is estimated that it will take at least 8-9 months, but likely almost a year, for FHFA’s payroll provider, Department of the Interior’s National Business Center to complete the transition process.

A number of reasons are causing a delay in issuing a solicitation, most importantly of which, is to meet IRS requirements for executing the Cycle 3 Plan documents. The voluminous Adoption Agreement Restatement and related documents, including a Trust Agreement, are required to be in place by July 31, 2022. FHFA has been working diligently to review and negotiate these new Plan documents and is still waiting for a governmental plan version of the Trust Agreement. Therefore, the earliest the solicitation may be issued is upon signature of both parties on the Restatement documents, which may not occur until July.

Since the 401(k) benefit is such a well-established benefit to FHFA employees and their beneficiaries, until such time as a solicitation may be issued, an award made, and the transition process is complete, FHFA would still need to provide uninterrupted 401(k) services to its employees and beneficiaries.

Therefore, T. Rowe Price is the only source that can continue providing these recordkeeping services, necessitating the need for this sole source bridge contract.

This bridge contract is not due to lack of advance planning; it is in fact being issued due to advanced planning in the Fall of 2021 when FHFA reached out to its payroll provider to discuss the impact of the recompete, and also the Restatement documents were not available to FHFA at that time.

Therefore, to account for the time needed to get the recompete RFQ issued, awarded, and possibly award to a non-incumbent; this bridge contract needs to be made on a sole source basis for a base year with three 6-month option periods. In the event the incumbent is the successful offeror, two of the three options will not be exercised, as the expected start date of the recompete is January 1, 2024.

3. MARKET SURVEY.

Per the circumstances provided above no additional market survey was completed, as the bridge contract can only be made to the incumbent. The work is being recompeted with an anticipated 1/1/24 start date. The incumbent is aware of the recompete, and the options are to allow for any unforeseen delays in either the recompete or transition process.

4. IF THIS IS A DETERMINATION FOR SOLE SOURCE, THE

CONTRACTING OFFICER CERTIFIES:

a. Only one source is available.

b. The anticipated price will be determined fair and reasonable using standard price analysis techniques described in FAR Part 13.

Joyce Wilson Natalie Wallace Technical Representative Contracting Officer