W52P1J20C4000JandA.pdf

Control No: 20-023 Contractor: Boaz Allen Hamilton

Supply/Service: Cemetery Quality Assurance Services Est Dollar Value:

JUSTIFICATION REVIEW DOCUMENT

FOR JUSTIFICATION AND APPROVAL FOR OTHER THAN

FULL AND OPEN COMPETITION

Supply/Service: Cemetery Quality Assurance Services

Authority: 41 U.S.C. 1901

Prepared by:

Contracting Officer:

Technical:

Requirements:

Michelle E. Breitbach DSN: 793-6070 Contracting Officer Email: michelle.e.breitbach.civ@mail.mil

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager:

Legal Advisor:

Contractor: Booz Allen Hamilton

Supply/Service: Cemetery Quality Assurance Services Est Dollar Value:

Department of Army Justification and Approval for Other than

Full and Open Competition

1. Contracting Activity: U.S. Army Contracting Command - Rock Island (ACC-RI) Rock Island Arsenal, Rock Island, IL 61299-8000.

2. Description of Action: The Office of Army Cemeteries (OAC) and Arlington National Cemetery (ANC) requests a firm-fixed price contract with Booz Allen Hamilton (BAH).

ACC-RI projects award• for February 2020 and will obligate fiscal year 2020, Cemeterial Expenses, Army funds. An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement

207. 103( d)(i)(B).

3. Description of Supplies/Services: The OAC is defined by Public Law 111-339 as the statutory authority to manage and oversee operations at ANC, the U.S. and Airmen's Home National Cemetery (USSAHNC) and 38 other Army Post Cemeteries. The proposed contract will provide the Cemetery Data Quality Assurance Program Management Office (QA PMO) support for end-to-end processes for QA and accountability of cemetery burial records through resources provided by 12 full time equivalents. In accordance with (IAW) Public Law 111-339, the contractor's responsibility is to perform, define and establish business processes, develop, implement, and sustain plans to achieve and maintain the goals of 100% accountability of cemetery burial records. BAH will support the review and analysis of unassociated burial records to generate and complete case verification of burials, including the accuracy of gravesite records, headstone/niche/memorial markers (commemoration and photos), and their geospatial location. BAH will also perform an annual 10% QA review of historical cases, and will develop training content specific to cemetery burial operations. BAH will also support the Data QA PMO by identifying requirements for the development of a QA review module that will be part of the ANC enterprise business system and authoritative system of record, called Enterprise Interment Services System (EISS). Pragmatics is developing EISS under the direction of the Office of the Chief Information Officer Program Management Office (OCIO PMO) (Contract W15QKN-19-F- 1335), as further discussed in paragraph 3. Once the QA module is developed and implemented, the functions BAH supports will be automated and no longer required by

ANC.

The period of performance is 01 March 2020 to 28 February 2021 with two, one-year evaluated option periods and a six-month evaluated option IAW Federal Acquisition Regulation (FAR) 52.217-8. OCIO anticipates the development and delivery of the EISS QA module will be complete. in the third quarter of FY21. The option periods are included to ensure adequate time to facilitate the EISS team's ability to develop the QA Module requirements using Agile Software development techniques and to validate or correct any issues once implemented. The practice of Agile development requires collaborative cross functional team work to deliver a software solution that supports

Supply/Service: Cemetery Quality Assurance Services Est Dollar Value:

adaptive planning and flexible, iterative changes to software to support changes to business processes. This order must include option years to support the Agile development, testing, implementation, production, and if necessary corrections, for the finalization of the QA EISS module which, if delayed, would extend beyond FY21.

The OAC and ANC estimates a dollar value of including options, based on historical costs.

4. Authority Cited: 41. U.S.C. 1901, as implemented by FAR 13.501(a)(1)(ii), Sole source under the simplified procedures for certain commercial items.

5. Reason for Authority Cited: As described in FAR 13.501 (a)(1 )(i), the contracting officer may conduct sole source acquisitions only if the need to do so is justified in writing and approved at the levels specified in FAR 13.501 (a)(2).

ANC maintains more than 393,000 burial locations for the eligible military service members and their dependents. In June 2010, the Army Inspector General (IG) and subsequently the Government Accountability Office (GAO) identified deficiencies or lack of sufficient business processes to maintain accountability for those buried at ANC.

Public Law 111-339 required the Secretary of the Army to submit a report to Congress for an accounting of gravesites and implementation of remedial actions. GAO analyzed Army policy and guidance, records and plans, and developed corrective courses of action. The GAO recommended ANC implement actions relating to information technology planning, workforce planning, assessments of operations and coordination and develop written guidance for assisting families. In 2011, a QA Task Force (TF) was created to implement the recommendations from the GAO, Department of Defense (DOD), and Army IG. The TF evolved into the Data QA PMO and continues to review and update policy guidance and business processes in support of the ANC and Army Post Cemetery mission for 100% accountability of cemetery burial records.

In May 2011, BAH began working the QA PMO requirement through an additional Contract Line Item Number (CLIN) on an existing ANC contract. Then, in August of 2012, the Data QA PMO competed and awarded Task Order W911 S0-08-D-0001 0080 under the Information Technology Enterprise Solutions - 2 Services contract (ITES-2S) to BAH to provide support as it developed processes and procedures to address the recommendations from GAO, DoD and the Army IG. From 2011 to 2017, ANC awarded three additional task orders to BAH to continue to perform these critical tasks. Major objectives accomplished during this time frame included support to deliver a Report to Congress on Capacity at ANC (February 2017), and analysis of burial processes to identify entry level training requirements for the Cemetery Administration Specialists supporting Interment Services directorate.

During this same time, ANC was also working with the Army Analytics Group (AAG) to modernize its business system, the Interment Services System (ISS), following the results from the 2010 DAIG report. The 2010 version of ISS was not an identified system of record capable of accountability of cemetery burial records or able to support Army post cemeteries. In 2013, ANC worked with AAG to expand ISS as an enterprise system that would eventually include a module to automate the Quality Assurance

Supply/Service: Cemetery Quality Assurance Services Est Dollar Value:

functions being performed manually by the TF. Those efforts did not result in the development of an EISS. ANC also acquired another automated system called the Research Tool (RT) during this time to help with the QA processes, but, it was also not a complete solution. In 2019, the OCIO PMO competed and awarded task order W15QKN-19-F-1335 to Pragmatics under a General Services Administration contract for the development and implementation of EISS. The EISS application development is underway with several modules already implemented. The QA Module will be the final module.

At this time, QA review of records remains a fragmented manual process utilizing the ANC RT to validate the accurate information related to burial records and gravesite information according to the following components: (1) dispositive records support the individuals memorialized and interred or inurned, (2) grave marker inscription is consistent with available records, and (3) marker location is accurately recorded in the geospatial mapping system to include headstone or niche cover photographs.

ANC will migrate and consolidate the RT system into EISS under Pragmatic's contract, but requires engagement from the QA PMO and BAH's expertise to coordinate with the EISS development team to ensure burial records are imported accurately while automating the tasks required to perform QA review. The proposed EISS QA Module will migrate and improve upon already established QA/QC processes implemented by the QA PMO in ANC's RT. These processes will become automated functions in ANC's authoritative system of record for all burials, and will allow ANC to effect a 100% accountability process within a single, consolidated enterprise system which will close an outstanding finding in the 2016 DODIG report.

ANC's efforts to implement the EISS will also meet recommendations in more recent DOD IG reports. In May 2019, the DOD IG published DODIG 2019-84 Evaluation of Operations and Management of Military Cemeteries, and DODIG 2019-83 Operations and Management of Arlington and Soldiers' and Airmen's Home National Cemeteries, evaluating the current processes for gravesite accountability. One recommendation from 2019-83 included implementation and fielding of a QA Module in the EISS, the authoritative system for all Army cemeteries, to adjudicate the accuracy of all burial data.

Similarly, the 2019-84 recommendation included a direct conversion of digital records, and efforts to standardize and automate the method for adjudicating burial data errors of fact. In response to the May 2019 DOD IG report, ANC now requires the compilation of knowledge, business rules, protocols, policy, and processes to transition to an advanced, and consolidated system that includes a QA Module. This requires engagement from BAH to support the integration of their cemetery burial records management knowledge of business rules, protocols, policy and processes to develop, test, and implement the QA Module. The QA module is scheduled for implementation into EISS in FY 2021 and will be the cornerstone of QA, quality control, and accountability for ANC, USSAHNC and ultimately every Army Post Cemetery.

Supply/Service: Cemetery Quality Assurance Services Est Dollar Value:

BAH is the only vendor with the immediate capability to support the current requirements and fielding the QA Module. As the incumbent since 2011, BAH has made significant contributions to improving ANC's accountability program to date. BAH has been the only contractor employed to account for and remedy the burial errors of fact found at ANC.

BAH has been an integral part in modernizing the QA program IAW Public Law 111-339, while supporting the transition of fragmented manual QA to an automated compliance function within the enterprise authoritative system of record. Through the course of a decade, BAH has reviewed and understood over 150 years of historical and institutional cemetery knowledge. BAH has spent a significant effort manually reviewing and interpreting disparate data records that range from handwritten ledgers to digitally scanned burial index cards. These varying states of information capture the historical significance of the technological eras of cemetery administration and operations for ANC and the U.S. Army. BAH's unique qualifications and support helped develop QA processes, to facilitate the transition process to the automated EISS function, which ANC estimates to complete in Q3 FY21. No other vendor has experience with the complex processes and procedures required to manage Army cemetery records with 100% accountability, or to operate the RF system.

Should this requirement be competed, ANC estimates it would take another vendor minimally 6-9 months to transition and provide basic entry level Data QA PMO support and at least 12-15 months achieve full operational capability as the support contractor.

This estimate is based on legacy Data QA PMO focus areas that require extensive historical programmatic knowledge to provide course of actions to leadership as part of the 100% accountability goal. Moreover, the estimated timeline to onboard another vendor factors in the time required for staff to complete the processes to receive Common Access Cards, System Authorization for Accounts, and training for several applications. Therefore, to onboard another contractor would detrimentally affect the programmatic transition timeline and harm the OAC's and ANC's ability to meet the requirements set forth in the GAO, DOD, and Army IG Reports, and ultimately risk non compliance with Public Law 111-339. Onboarding a new vendor in lieu of the incumbent would create a gap in intellectual knowledge and technical support for cemetery burial record management, and the ability to provide a secondary review of data once the application is deployed to production environment as ANC is seeking to leverage BAH's understanding of burial record data to validate a successful transition.

BAH's knowledge and expertise is a crucial component to the creation of ANC's EISS QA Module; any deviation from QA PMO's current glide path will undoubtedly result in catastrophic delays to the creation and implementation of this module, and potentially increases the risk in the accountability of individuals interred, inurned, and memorialized at ANC, USSAHNC, and Army Post Cemeteries.

6. Efforts to Obtain Competition: A notice required by FAR 5.201 will be issued.

Because this is a sole source action, effective competition is not applicable. The Government will achieve subcontracting competition by ensuring the contract will contain FAR clause 52.244-5, Competition in Subcontracting, which states that the contractor shall select subcontractors on a competitive basis to the maximum practicable extent.

Supply/Service: Cemetery Quality Assurance Services Est Dollar Value:

7. Actions to Increase Competition: No actions are being taken to increase competition. ANC foresees a phasing out of contracted services once the automated QA Module is deployed into the EISS production environment. Additional support to the Data QA PMO, if required, shall be identified prior to Option Year 1, to ensure continuity of operational support to OAC and ANC.

8. Market Research: ANC and the Mission and Installation Contracting Command conducted market research in October 2019 by issuing an RFI on beta.sam.gov and received responses from 21 vendors. The RFI included specific requirements of the Data QA PMO to include cemetery burial records review, quality assurance of cemetery burial records management, and the ability to make recommendations to automate and improve business processes for cemetery burial records for 100% accountability within an enterprise business system of record. Theoretically, the key words (business process improvement, quality assurance, identify requirements for enterprise business system enhancements, and training) in the PWS that describe the specific requirements could be supported by the private sector. However, when applied to the management of data specific to cemetery burial records management and 100% accountability, none of the respondents' demonstrated experience with Army cemetery business processes for burial record accountability with exception to the response from BAH. An overwhelming number of the respondents did not specify a methodology to identify and maintain disposition of cemetery burial records or an understanding of the requirements for Data QA PMO support. The majority of respondents described their overall approach to implementing Enterprise Architecture beyond the business needs of the Data QA Program through IT governance, application development and IT Help Desk support.

Therefore it was determined by the QA PMO Contracting Officer Representative and Contracting Support Element, the offerers' demonstrated a lack of understanding of the specific requirements related to QA of Cemetery Burial Records and 100% accountability.

9. Interested Sources: To date, no other sources have expressed a written interest in this requirement.

10. Other Facts:

Procurement History:

Enterprise Interment Services System (EISS) Contract: GS-35F-0189U, W15QKN19F1335 Contractor: Pragmatics Award Date: 9/20/2019 Competitive Status: Competed on GSA FSS 70

Contract: W91 QUZ-06-D-0019-2M04 Contractor: Booz Allen Hamilton Award Date: 02/28/2017 Competitive Status: Competed on CHESS ITES-2S

Contract: W91 QUZ06D0019-2M02

Award Date: 07/30/2013

Control No: 20-023 Contractor: Booz Allen Hamilton

Supply/Service: Cemetery Quality Assurance Services Est Dollar Value:

Competitive Status: Competed on CHESS ITES-2S

Contract: W91 QUZ06D0019-2M01 (Surge- CLIN003) Contractor: Booz Allen Hamilton Award Date: 05/24/2013 Competitive Status: Competed on CHESS ITES-2S

Contract: W911 S0-08-D-0001-0080 Contractor: Booz Allen Hamilton Award Date: 08/15/2012 Competitive Status: Competed (Army IMCOM)

Supply/Service: Cemetery Quality Assurance Services Est Dollar \

11. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Date: 2/7/2020

12. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Date: 2/7/2020

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable based on comparison to the Independent Government Cost Estimate and historical costs.

Certified Cost and Price Data is not required for this commercial acquisition.

Date: 2/7/2020 BREITBACH. MICHE ~~~~~i:~~~il~HELLE.E.126979

LLE.E.1269792570 ~!:~: 2020.02.07 00:s3:10-oe·oo·

Michelle E. Breitbach Contracting Officer

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

BREITBACH.MICH Digitally signed by

ELLE.E.126979257 :f5~6sACH.MICHELLE.E.12697

Date: 2/7/2020 0 Date:2020.02.0708:52:59-06'00'

Michelle E. Breitbach Contracting Officer

Supply/Service: Cemetery Quality Assurance Services Est Dollar Value:

Approval

Based on the foregoing justification, I hereby approve the procurement of Cemetery Quality Assurance Services on an other than full and open competition basis pursuant to the authority of 41 U.S.C. 1901, subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.

Date: 07 February 2020 Signature:

TKATCH.ADELAI ~~;~~~~~~iDE.J.12287125

DE.J .1228712503 ~!te: 2020.02.0112:35:19 -oe·oo·

ADELAIDE J. TKATCH

Com petition Advocate