Understanding Financial Capability JOFOC 3.16.21.pdf

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

Understanding Financial Capability Interventions

GCS

Other - HHS

Administration for Children and Families, Office of Government Contracting Services

Acquisition Title:

Agency:

Divisions:

Other Divisions:

Acquisition Year (FY):

Author and Title: Lisa Zingman, Social Science Research Analyst

2. Description of Action:

Nature: New Requirement Follow-on Requirement

Modification to Existing Purchase Order/Contract Number:

Pricing: Firm-Fixed Price Time & Materials Cost

Other:

Funds: OMA Other Funds:

Name of Proposed Contractor(s): MEF Associates

Street Address: 1330 Braddock Place, Suite 220

City, State, Zip: Alexandria, VA 22314

3. Description of Services or Supplies:

Basis for Approval (FAR 6.303-1(d)): Individual Basis Class Basis

The total estimated value of the proposed action, including all options is $ $633,863.95

The Understanding Financial Literacy Interventions in Employment-Related Contexts for Low-Income Individuals study (Contract N.

HHSP233201500077I/75P00119F37008) is developing a better understanding of financial literacy interventions within employment-related contexts for low-income individuals. The study has conducted expert consultations and a literature review and is developing, administering, and analyzing findings from a survey of employment and training programs incorporating financial literacy training. The purpose of this proposed contract is to conduct and analyze qualitative data, in forms such as interviews and site visits, from survey respondents, write a final report on the findings from all data collected, and disseminate study findings. This contract includes three non-severable services components: Services Component 1 has a period of performance of 32 months (April 2021 to January 2024); Optional Services Component 2 has a period of performance of 12 months (January 2023 to January 2024).

This contract is a sole source to the contractor of Contract No. HHSP233201500077I/75P00119F37008.

4. Authority and Rationale: Identify the statutory authority, FAR title and FAR citation permitting other than full and open competition. It may be one of the following most commonly used citations by the operating divisions of the Department of Health and Human Services (HHS), but other exceptions may apply per FAR Subpart 6.3.

Actions other than simplified acquisition procedures (select only one and provide an explanation):

FAR 6.302-1: Only one responsible source and no other supplies or services will satisfy agency requirements, 41 U.S.C.

3304(a)(1)

This contract is a sole source because the work can only be done by MEF Associates due to this work being a complimentary study to Contract No. HHSP233201500077I/75P00119F37008. To date the contractor has conducted a literature synthesis, expert consultations, and survey design at a cost of over $340,000 to the government. The intended contractor will need to rely on several aspects of the existing contract for the proposed contract: (1) their existing knowledge of the field developed through the expert consultations and literature synthesis to inform qualitative data collection; (2) their knowledge of the survey so subsequent data collection directly builds on and can go in-depth on topics asked about in the survey; (3) their contacts and relationships with survey respondents to follow-up with them within a few months for subsequent data collection; and (4) their ability to use the survey data and subsequent qualitative data collected under the proposed contract to write deliverables that integrate all the findings and meet the government’s objectives. There is no other contractor that can adequately do the work because the vendor is the only organization that has the necessary information. The government has already spent substantial resources building knowledge and relationships for this project and it would take an alternative contractor over a year and a half to get to the same place. In addition, it may be inappropriate for the existing contractor to share the names and contact information of the survey respondents with another contractor. This would take a significant level of effort and resources for a different contractor to overcome.

The government proposes that the base services component (Services Component 1) be for 32 months. This period of performance is needed to complete all the activities involved in obtaining the government's designated end product of value: a final report of study findings. Steps involved in producing the end project of value include developing the qualitative instruments, obtaining OMB approval to field the instruments, administering the data collection, analyzing the results, and developing final reports (including the end product of value), accounting for time for the government's review and publication process for all published reports. An Optional Services Component is included in this contract for 12 months for ongoing project management, privacy and data security activities, dissemination, analysis and reporting.

FAR 6.302-2: Unusual and compelling urgency, 41 U.S.C. 3304(a)(2)

FAR 6.302-5: Authorized or Required by Statute, 41 U.S.C. 3304(a)(5)

Other (See FAR Subpart 6.3 for additional authority)

Provide a full explanation to justify use of the exception.

5. Agency Actions to Take or Remove Barriers That Led to Other Than Full and Open Competition (If applicable):

Describe the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration prior to any subsequent acquisition for the supplies of services is made. If no such actions have been taken, explain why.

No actions have been taken to remove barriers that led to fair opportunity exception. The current solicitation is a sole source because the work will be done in tandem with Contract No. HHSP233201500077I/75P00119F37008. The original contract was awarded on the Program Support Center IDIQ for small businesses, and all potential bidders were given a fair opportunity to be considered. The purpose of the current solicitation is fund qualitative data collection of a subset of survey respondents that directly builds on the survey responses and reporting of findings across data collections. This is a sole source to the current Contractor because they have collected knowledge and data integral to successfully completing the activities included in the proposed contract, such that fair opportunity would not provide a benefit to the government.

The Government will consider a competitive contract action in the future when procuring similar services in this topical area with a different group of programs and participants.

6. Bridge Contracts:

N/A

7. Actions to Increase Competition:

No actions have been taken to increase competition. The current solicitation is a sole source to an existing contract (Contract No.

HHSP233201500077I/75P00119F37008). The original contract was publicized to small businesses on the Program Support Center IDIQ, awarded competitively, and all potential bidders were given a fair opportunity to be considered. The purpose of the current solicitation is fund qualitative data collection of a subset of survey respondents that directly builds on the survey responses and reporting of findings across data collections. This is a sole source to the current Contractor because they have collected knowledge and data integral to successfully completing the activities included in the proposed contract, such that increased competition would not provide a benefit to the government.

The Government will consider a competitive contract action in the future when procuring similar services in this topical area with a different group of programs and participants.

8. Market Research:

The current solicitation is a sole source to an existing contract (Contract No. HHSP233201500077I/75P00119F37008). For the original contract, the Government issued a Sources Sought notice and five vendors submitted responses. Three out of the five vendors were found capable of successfully completing the requirements outline in the Sources Sought notice. The original contract was publicized to small businesses on the Program Support Center IDIQ, awarded competitively, and all potential bidders were given a fair opportunity to be considered. For the proposed contract, the government's market research included consulting with experts in the field on the need for qualitative data on this topic and the conclusion that a survey alone would not provide the level of detail the government needs to answer the research questions. Subsequent data collection will allow the contractor to conduct in-depth interviews and site visits with employment programs to obtain a level of detail a survey cannot provide. The market research led us to a sole source contract to enable us to conduct the necessary data collection to answer the questions of the government.

9. Procurement History:

Purchase order or contract number: HHSP233201500077I/75P00119F37008

Was action competed? Yes No

If action was not competed, state the cited authority, summarize rationale, and describe the actions that were supposed to be taken to increase competition and the results thereof:

The current contract is currently in progress and expected to continue until November 2023. The scope of this work is outside the original scope of the the project and therefore it has to be awarded as a sole source since no other vendor can successfully complete the work.

10. Additional Information to support the justification:

11. Technical / Requirements Certification: By my signature below, I certify that the supporting data included in this J&A is accurate and complete.

Program Manager

Name: Lisa Zingman

Position Title: Social Science Research Analyst

Email address: lisa.zingman@acf.hhs.gov

Phone: (202) 260-0323

Program Manager Supervisor (or one level above Program Manager)

Name: Hilary Bruck

Position Title: Deputy Division Director, Division of Economic Independence

Email address: Hilary.Bruck@acf.hhs.gov

Signature:

Date: 2/23/2021

12. Fair and Reasonable Price/Cost Determination: As Contracting Officer, by my signature below, I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable.

The Contracting Officer will conduct a price analysis to ensure the cost is fair and reasonable. The vendor has GSA rates established.

A detailed review of the contractor's proposal will be performed by technical and procurement personnel to also ensure the negotiated contract price is fair and reasonable.

Name: Jonathan Gonzalez Phone: 202-381-7248

Signature: Date:

13. Contracting Officer's Approval (Required for proposed contract not to exceed $700,000 (value calculated including all options)): I hereby certify that this justification is accurate and complete to the best of my knowledge. I approve this justification subject to availability of funds, and provided that the services and supplies herin describe have otherwise been authorized for acquisition.

Name: Jonathan Gonzalez Phone: 202-381-7248

Signature: Date:

14. Legal Review:

15. OPDIV Competition Advocate Approval (Required for proposed contract over $700,000 but not exceeding $13.5 million value calculated including all options)):

I have reviewed this justification and find that it adequately supports other than full and open competition.

Name: Phone:

Signature: Date:

16. Office of Small and Disadvantaged Business Utilization:

I have reviewed this justification and find that it adequately supports other than full and open competition.

Name: Phone:

Signature: Date:

17. OPDIV HCA Approval (Required for proposed contract over $13.5 million but not exceeding $68 million value calculated including all options)):

Name: Phone:

Signature: Date:

18. Department Competition Advocate:

Hilary C. Bruck -S Digitally signed by Hilary C. Bruck -S Date: 2021.02.23 16:13:28 -05'00'

Jonathan F.

Gonzalez -S

Digitally signed by Jonathan F.

Gonzalez -S Date: 2021.03.06 23:42:54 -05'00'

Jonathan F.

Gonzalez -S

Digitally signed by Jonathan F.

Gonzalez -S Date: 2021.03.06 23:43:10 -05'00'

Concur: Non-Concur:

Name: Phone:

Signature: Date:

(The below approval paragraph is required if the cumulative contract value, including all options, exceeds $68 million.)

19. HHS Senior Procurement Executive (SPE) Approval:

Based on the foregoing justification, I hereby approve other than full and open competition for the above stated procurement, subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

State supplies/services being procured:

State the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304:

Name: Phone:

Signature: Date: