USAID Pakistan _JA.pdf
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Islamabad, Pakistan
June 5, 2020
SENSITIVE BUT UNCLASSIFIED
DECISION MEMORANDUM
TO: Sean Hofmann, Deputy Director, Office of Executive Management (OEM)
FROM: Charline Eastin, Director, Office of Financial Management (OFM)
SUBJECT: Justification and approval (J&A) for other than full and open competition for
USAID/Pakistan’s Financial Management Specialist (Deputy Controller) U.S.
Personal Services Contract (USPSC) position
Issue:
This document sets forth the facts and rationale justifying the use of other than full and open competition for the Short Term, Offshore USPSC Financial Management Specialist position, in accordance with USAID’s Acquisition Regulation (AIDAR) Subpart 706.3.
Nature and description of action to be approved:
This is a request to approve the selection of the USPSC Financial Management Specialist on an other than full and open competition basis.
Description of supplies or services required (including the estimated value):
The Mission is seeking the services of a highly-experienced Financial Management Specialist (Deputy Controller) as the principal Certifying Officer and to serve as the focal point for all accounting functions including budgeting, accounting, payroll, payments, and support services to mission management and staff on funding issues and benefit and allowances. Additionally, the Specialist will be involved in the full range of Financial Management functions, including Phoenix accounting, financial analysis, and financial reporting. The contractor will provide mentoring and guidance to the Foreign Service Nationals (FSNs) in OFM and serve as an expert resource concerning matters relating to financial management. The contractor will serve as Acting Office Director/Mission Controller as needed for a period not to exceed six months.
The estimated cost of the contract is US $144,231.13
Identification of statutory authority permitting other than full and open competition:
The authority for this action is found in the Federal Acquisition Regulation (FAR) Subpart 6.3 and AIDAR Subpart 706.302-70, which allows USAID to use other than full and open competition when it would impair or otherwise have an adverse effect on programs conducted for the purposes of foreign aid, relief, and rehabilitation. AIDAR 706.302-70(b)(1) allows this authority to be applied to PSCs serving abroad.
Demonstration that the nature of the acquisition requires the use of the authority cited:
OFM supports a large and politically visible portfolio ($752 million program pipeline with reduced future annual obligating year budgets and $13.6 million per year in operating expense resources). The largest of the USG civilian assistance agencies in Pakistan, USAID takes a lead role in ensuring interagency coordination. Added to its internal coordination role are the necessary and daily engagements with USAID headquarters, the Office of the Inspector General, the Government of Pakistan (GOP), the Pakistani and American public, and other development partners and stakeholders. However, the Mission struggles with an extraordinarily high staff turnover rate, specifically among U.S. Direct Hire (USDH) personnel whose tours in Pakistan are typically between one and two years. The high turn-over, combined with the fast-paced operational tempo and number and complexity of programs, make it particularly challenging for Mission personnel to develop, manage, and evaluate its Foreign Aid programs.
This important position was not filled during the FY 2020 assignment cycle. Due to Pakistan's Service Recognition Package, which includes two R&Rs and completion of one year for homeleave, it is critical this position is filled as soon as possible with a highly qualified candidate that can provide coverage for the Office Director/Mission Controller in their absence, as this office requires one USDH employee at all times to certify vouchers and perform other duties.
Due to the highly specialized nature of the skills and experience required for this position, there are only a limited number of individuals capable of meeting the minimum qualifications and successfully providing the required services. However, market research has already identified several potentially highly-qualified individuals. Therefore, full and open competition would not likely yield additional highly qualified candidates, would be unnecessarily burdensome, and may delay the provisioning of services.
Description of efforts made to ensure offers are solicited from as many potential sources as is practicable, and whether or not a notice was or will be publicized as required by the Federal Acquisition Regulation (FAR) 5.202 (If not, which exception to FAR 5.202 applies):
Market research and knowledge indicate that only a limited number of individuals are capable of successfully providing the services, due to the highly specialized nature of the knowledge, skills, and abilities required. Market research has also identified several individuals who are known or believed to possess the required knowledge, skills, and abilities. Through limited competition, the Mission will solicit offers from at least three of these potentially highly-qualified individuals.
In accordance with FAR 5.202(b) and AIDAR 705.202, an advanced notice of the proposed contract action is not required and was not publicized.
A determination by the Contracting Officer that the anticipated cost is fair and reasonable:
The estimated cost of the six month contract is $144,231.13. This estimated cost is considered to be fair and reasonable, and is based on the position level and GS-15 (equivalent) market value established in accordance with Agency regulation.
Description of the market research conducted, and the results or a statement of the reasons market research was not conducted:
Market research was initiated by drawing upon professional networks to identify several individuals known, or believed to be, highly qualified and capable of successfully providing the required services. Further market research confirmed that at least three of these individuals are available and interested in providing the services during the required period of performance.
Other facts supporting the use of other than full and open competition:
N/A
Sources, if any, that expressed an interest, in writing, in the acquisition:
N/A
Statement of actions, if any, the Agency may take to overcome barriers to competition in the future:
Future requirements of this nature may again be solicited using limited competition. However, the high turnover of USDH staff will likely provide additional professional networks that can identify other potentially highly-qualified sources.
Contracting Officer certification and approval:
In accordance with FAR 6.303-2(c), I hereby certify that the technical statements included above, which form a basis for the justification, are complete and accurate.
Requesting Office Representative Charline Eastin, Director, Office of Financial Management - Cleared (6-5-2020)
In accordance with FAR 6.303-2(b), I hereby certify that this justification is accurate and complete to the best of my knowledge and belief. This justification is approved in accordance with FAR 6.304(a)(1).
Contracting Officer Sean Hofmann, Deputy Director, Office of Executive Management - Cleared (6-10-2020)
CLEARANCE PAGE FOR: JUSTIFICATION AND APPROVAL (J&A) FOR OTHER
THAN FULL AND OPEN COMPETITION FOR USAID/PAKISTAN’ FINANCIAL
MANAGEMENT SPECIALIST U.S. PERSONAL SERVICES CONTRACT (PSC)
POSITION
Drafter: Dean Walter, Deputy Controller, Office of Financial Management
Cleared: David Strine, Acting Director, Office of Executive Management (6-3-2020)
Bruce McPherson, Resident Legal Officer (6-9-2020)
Clay Epperson, Deputy Mission Director (6-10-2020)
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