VA118-16-D-1013 36C10B19N10130003 P00007_1.docx

Control Number VA-21-00031185 Contract Opportunity Justification and Approval Notice

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* = Required Field Contract Opportunity Justification and Approval Notice D399 Integrated Colmery Delivery - Logical Follow-On Modification

07724

36C10B19N10130003 P00007

N 541512 Department of Veterans Affairs Technology Acquisition Center

23 Christopher Way Eatontown NJ 07724 Amanda.Bleses@va.gov

VA118-16-D-1013

P00007 $3,653,279.13

02-12-2021

ACCENTURE FEDERAL SERVICES LLC

800 NORTH GLEBE RD #300

ARLINGTON

VA

22203

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, New Jersey 07724

2. Description of Action: The proposed modification to Transformation Twenty-One Technology Next Generation (T4NG) Contract VA118-16-D-1013 Task Order (TO) 36C10B19N10130003 is for an extension of up to six (6) months for the Integrated Colmery Delivery (ICD) effort in order to provide one (1) to two (2) additional development builds for the Chapter 33 Long Term Solution (LTS) system and LTS interfaces in preparation for the forthcoming Veterans Benefits Administration (VBA) Digital GI Bill effort. The Contractor shall provide project management support, software development, integration, testing, maintenance, training and communication services.

3. Description of the Supplies or Services: TO 36C10B19N10130003 was awarded to Accenture Federal Services, LLC (AFS) on February 15, 2020 for a fully functional and operational solution that fully implemented the Harry W. Colmery Veterans Education Assistance Act of 2017 requirements within VA’s education information technology (IT) systems, specifically LTS and its interfaces, to include all software and/or software development, integration, testing, maintenance and training. VBA is now in the process of transitioning its education systems from ongoing development and maintenance of its legacy systems to a managed services methodology through a Digital GI Bill initiative. This effort will extend the current TO for up to six (6) months to provide one (1) three (3) month development build, with an option for an additional three (3) month development build for the legacy LTS system and its interfaces. The period of performance for the proposed modification shall be from February 15, 2021 to May 14, 2021, with an option to extend to August 14, 2021. Funding has been identified and is available for this action.

4. Authority: The statutory authority permitting an exception to fair opportunity is Section 41 U.S.C. 4106(c)(3) as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(C), entitled “The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.”

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is Accenture Federal Services (AFS) LLC, 800 North Glebe Rd #300, Arlington, VA 222203. The Product Line priority is to improve business process flow for Veteran claims examiners, prevent a delay in delivery of legislatively mandated entitlements to Veterans, drastically reduce the risk of Veteran Personal Identifiable Information (PII) exposure, and minimize the use of resources specifically related to persons and paper. In support of these priorities, VBA received approval to proceed with its Digital GI Bill initiative at the end of December 2020 and a subsequent solicitation was released on T4NG for this effort on December 30, 2020. The release and subsequent award of the Digital GI Bill solicitation will effectively negate future requirements for continued development efforts for VBA’s legacy education IT systems as the Digital GI Bill requirements include digitizing the majority of work through Education Claim services, with rapid implementation and aggressive automation. Specifically, the Digital GI Bill contractor will be required to provide Claims Processing Services through its own contractor-provided solution and transition/migrate claims processing from VA IT systems to its own Education Claim services. The Digital GI Bill solicitation is currently estimated to be awarded in March 2021. Transition of Education services to the new Digital GI Bill TO will be significantly different than previous development and sustainment transitions. Historically, transitions between contracts/TOs providing development and sustainment support for the Education Systems has only involved the onboarding of resources and transfer of knowledge/learning curve associated with continuing to develop and keep VA’s legacy Education IT systems operational. The shift to the Digital GI Bill initiative represents a new paradigm where the processing of education claims will be transitioned/migrated from VA’s current IT systems to a contractor-provided solution. As such, and given the additional complexities of this transition and migration, it is estimated that it would take a minimum of three (3) months and as long as six (6) months until the new Digital GI Bill TO is fully operational and the services being provided under the current TOs providing development, sustainment, and ancillary support for VA’s Education IT systems, including the development services provided under the ICD TO, are either no longer required or can be transitioned to the new TO, which will depend on the capacity and capabilities associated with the Digital GI Bill vendor’s Education Claims processing solution.

Prior to VBA receiving approval to proceed with the Digital GI Bill initiative, VA was actively working on a recompete effort for the current Integrated Colmery Delivery (ICD) TO which expires on February 14, 2021. The ICD recompete, entitled Integrated Education Delivery (IED), would have included production and operational support as well as agile development services for enhancements for all IT systems within the Education Veterans Readiness and Employment Product Line (EVREPL), including the LTS system and its interfaces. The purpose of the IED procurement was to not only continue the agile development efforts performed under the ICD TO expiring in February 2021, but also consolidate the production and operational services for EVREPL that are currently performed under the Benefits Integration Platform (BIP) TO as well as the Benefits Sustainment Managed Services (BSMS) TO so that the full lifecycle of support for VBA’s education IT systems would be performed under a single TO to align with VA’s shift to a Product Line (PL) management methodology. The estimated value of the IED procurement was $80,547,868 for a 24-month effort, inclusive of all options. Request for Information (RFI) 36C10B21Q0066 was issued on beta.SAM.gov on December 10, 2020 and four (4) vendors responded (see Market Research paragraph for additional details). Due to VBA’s decision to move forward with the Digital GI Bill initiative, the IED procurement became obsolete and vendors were notified of its cancellation on January 6, 2021. Production and operational support services will continue to be provided under the BIP and BSMS TOs until these services transition to the Digital GI Bill TO. However, due to the expiration of the ICD TO on February 14, 2021, an extension to the current TO in order to continue providing the necessary LTS development work until these services can be migrated/transitioned to the Digital GI Bill TO is now required.

Based on economy and efficiency, a logical follow-on effort for the current ICD TO is the most reasonable course of action to ensure that the legacy LTS system and its interfaces continue to receive necessary development enhancements to meet current legislative requirements and user change requests in preparation for the transition to the Digital GI Bill effort. Specifically, the estimated time and costs associated with transitioning to a new vendor for this work is three (3) months and $392,000 based on historical transitions for development work on legacy IT systems as well as competitive prices for transition tasks on the ICS, BIP, and BSMS TOs. This transition would then have to be repeated once the Digital GI Bill TO was awarded and ready to take on these requirements, thereby incurring another three (3) month transition at the same additional expense. Therefore, it is not economically in the government’s interest to potentially transition LTS development services twice in the next six (6) months.

In addition, AFS currently has the needed resource familiarity, are readily available, technically competent, and have security-cleared staffing; and as such, provides the most efficient means to the Government for providing the required development services. No other vendor currently has resources in place with the technical knowledge, skillsets, and security clearances to provide these services during the short-term, three (3) to six (6) month, gap between the expiration of the ICD TO and when the Digital GI Bill TO is estimated to become fully operational. Based on the historical transition of these same development services, the first software development build is delivered five (5) to six (6) months after award, with subsequent builds delivered every three (3) months thereafter. The difference in build schedule between the first and subsequent deliveries is specifically due to resource onboarding and the technical transition required to be able to successfully develop software code for these legacy VA IT systems. Whereas under the previously contemplated IED effort, it was anticipated that the six (6) month base period would include the onboarding of resources, transition of knowledge/learning curve, and then subsequent performance and delivery of one (1) development build, by eliminating the need to transition the services, this ICD logical follow-on will enable the provisioning of one (1) development build by May 14, 2021 (three months after award) with an optional second development build by August 14, 2021, if exercised, prior to the transition/migration to the new Digital GI Bill TO once it is operational. As such, AFS is uniquely positioned as the only vendor who can provide immediate development support and provide the potential of multiple developmental builds within this performance period to fully support the transition to the Digital GI Bill solution. Finally, any other vendor would be unable to onboard its personnel, ramp-up, and become knowledgeable enough about the LTS requirements to successfully provide transition support to the successful Offeror of the Digital GI Bill solicitation. As the LTS system developer and integrator for the past two (2) years, AFS has implemented significant changes to the LTS system and its interfaces in order to meet the legislative requirements of the Colmery Act (Public Law 115-48) which included the most comprehensive changes to GI Bill benefits since enactment of the Post 9/11 Veterans’ Educational Assistance Act in 2008. AFS is the only vendor with the technical knowledge and expertise of the current code, rules, structure, system design, technical debts, and production defects that is necessary to perform the required LTS development work over the next three (3) to six (6) months and assist with the transition to the Digital GI Bill effort. Specifically, any other potential vendor will be required to review thousands of line of development code, perform an extensive review of technical documents and specifications, pinpoint within those thousands of lines of code exactly which items needed to be updated and gain an understanding of not only the LTS claims processing system but its numerous interfaces. Each identified interface, to include Web Enabled Approval Management System/ WEAMS Public (WEAMS), Flight, On-the-job training, Correspondence, Apprenticeship System (FOCAS), VA Online Certification of Enrollment (VA-ONCE), The Image Management System (TIMS), VA.Gov Education, Benefits Delivery Network (BDN), Corporate Winston-Salem Indianapolis Newark Roanoke Seattle (CWINRS), Veteran Readiness and Employment Case Management Solution (VRE_CMS), etc would need to be understood as making any update/modification in LTS will have an impact on the systems with which it interfaces. Additional development work for LTS and its interfaces is necessary during this timeframe due to the passage of the Veterans Health Care and Benefits Improvement Act of 2020 (Public Law 116-315) which provides additional/enhanced education benefits in response to the COVID-19 pandemic. To meet these legislative requirements, development efforts for the LTS system and its interfaces cannot be delayed until any other vendor is transitioned or until the Digital GI Bill TO is awarded and operational; the system changes are required to be implemented immediately. Transitioning the development services required to a new vendor would incur significant risk as any new Contractor’s staff would not fully understand the intent and context of the requirements included in this effort, what changes are required to the current version of LTS and its interfaces, and how to implement these system changes within the current development environment. AFS has a demonstrated effective and proven development and implementation processes in place for delivering LTS development builds and a strong working relationship with Education business customers, both of which will be necessary to meet the challenges of implementing these legislative requirements. Any lapse in development support and continuity would cause degradation of these critical services, which would result in VA’s systems potentially not meeting regulatory requirements as well as increasing security risks of exposure of personal information of Veteran and Employee data housed within the LTS system.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that can meet the Government’s requirements. There is no competition anticipated for this acquisition. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Federal Business Opportunities Page (FBO) and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: No barriers to future competition are anticipated. A competitive TO for the Digital GI Bill effort is anticipated to be awarded in March 2021 and future acquisitions will be awarded on a competitive basis.

8.Market Research: Prior to the release of the Digital GI Bill solicitation, an RFI was posted on December 10, 2020 RFI on the Contract opportunities site via beta.SAM.gov, for the IED effort which was the planned recompete of the current ICD TO. The RFI requested technical information necessary to determine capable vendors of providing the required services. In addition, prime contractors under T4NG were also notified of the RFI on beta.SAM.gov. On December 17, 2020, responses were received from four (4) vendors to include two (2) large businesses and two (2) service disabled Veteran-owned small businesses (SDVOSB). Although the IED procurement has now been cancelled, these responses are still an accurate representation of the interested vendors for the LTS development services which were originally included in the IED effort and which are now being extended under the current ICD TO. One of the respondents was AFS; the three remaining respondents were Booz Allen Hamilton Inc. (BAH), Sprezzatura-GovernmentCIO Joint Venture LLC (SCIO), and True Catalyst LLC.

True Catalyst LLC did not submit a capability statement. Instead, in response to the RFI, True Catalyst LLC submitted a letter which simply stated that its capabilities meet the requirements of the agency and that the company has an interest in bidding on the solicitation. VA Subject Matter Experts (SMEs) could not determine that this company would have the technical knowledge, skillsets, or experience to perform this requirement.

The remaining two respondents, BAH and SCIO, submitted relevant capability statements which were reviewed by the VA SMEs. BAH, as the current contractor for the BIP TO, has technical knowledge of the LTS system as it is the current provider of LTS production support. As stated above, LTS production support will continue to be provided under the BIP TO now that the IED effort has been cancelled until the migration to Digital GI Bill has been completed. However, LTS development has not been performed under the BIP TO in the past two years, and as such, BAH does not have the technical capability, including the expertise and resources, to meet the immediate development requirements for LTS over the next three (3) to six (6) months and would also be unable to provide the technical knowledge of the LTS development environment and its interfaces that will be necessary to transition these services to the Digital GI Bill TO. SCIO is a joint venture which includes GovernmentCIO LLC (GCIO). While GCIO, as the current contractor for the BSMS TO, has some technical knowledge of the LTS system, it has only provided peripheral sustainment support and does not have the necessary technical understanding, expertise or resources to provide the necessary near-term development services nor the technical support that will be required to transition these services to the Digital GI Bill TO.

Based on the above, there is competition for future efforts; however, only AFS can meet the Government’s current requirements within the needed time frame to provide additional developmental builds of LTS and its interfaces in preparation for, and to assist with, the forthcoming transition to the Digital GI Bill TO. Only AFS, as the current LTS developer has the technical knowledge of the current code, logic, requirements, and rules of LTS and its interfaces to immediately begin performance on the upcoming development build(s) and subsequent transition to the Digital GI Bill effort.

9. Other Facts: N/A