J ARedacted.docx

Control No. JA-11-0254

JUSTIFICATION REVIEW DOCUMENT

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Army Contracting Command – National Capital Region (ACC-NCR)

2. Description of Action:

This is a six (6) month extension of services from 30 September 2011 to 29 March 2012 for task order 0006 against IDIQ contract W91WAW-10-D-0078 IAW FAR 52.217-8 Option to Extend Services to continue to provide services for Installation Management Command G-9 (IMCOM G-9), Family and Morale, Welfare and Recreation (FMWR) Programs, New Parent Support Program (NPSP). The current contractor Strategic Resources, Inc provides support services for the New Parent Support Program-Home Visitation and educational training by informing and instructing service members and Family members on family life issues critical to sustain well-being. The current PoP for this contract is 30 September 2010 to 29 September 2011. It is a FFP Contract using OMA funds. The estimated value of the proposed action is $7,239,334.40.

The proposed contractor for this extension is the incumbent:

Strategic Resources, Inc. (SRI) 7927 Jones Branch Dr Ste 600W McLean, VA 22102-3329 703-749-3040

3. Description of Supplies or Services:

This task order provides services to operate the New Parent Support Program (NPSP)-Home Visitation support services and educational training by informing and instructing service members and Family members on family life issues critical to sustain well-being. SRI has provided services to a special population on an as needed basis for selected installations. This is a non-personal service; non-medical requirement; however the contractor is able to hire either Licensed Registered Nurses or Licensed Clinical Social Workers for the Family Services Specialist/NSPS Home Visitor positions.

Army Community Service (ACS) provides essential support to sustain readiness and quality of life for Soldiers and their Families. The Family Advocacy Program (FAP), one of the programs managed through ACS, provides prevention, education, training and direct services to address the problems associated with Family violence in the military. NPSP-Home Visitation falls under the FAP Program within the Army Community Services. The FAP provides comprehensive services to assist and advocate for victims of domestic abuse by providing prevention services and community resources. The New NPSP-Home Visitation serves Soldiers and Army Families living on and off the installation in accordance with the program protocol.

The NPSP-Home Visitation ensures that advocacy services are available to at risk Families. These services are provided in home by FAP clinically licensed professionals. The NPSP-Home Visitation has established prevention protocols for Families that include parenting skills with an evidenced based curriculum and support services. Clients must be eligible beneficiaries of the Military Healthcare System and authorized by Army Regulation (AR) 40-3, Medical, Dental, and Veterinary care to receive crisis intervention and routine victim advocacy services. Services are completely voluntary.

A new Army Community Services (ACS) model is in the review and approval process. In addition to the standard ACS base functions, the model incorporates new requirements for the New Parent Support (NSPS), Victim Advocates (VA), Survivor Outreach Services (SOS) and Army OneSource Community Support Coordinators (AOS CSCs), Army-wide. The Fort Knox Mission Installation Contracting Center (MICC) intends to proceed with the award of a new task order under the new HR Solutions suite during the six month extension, if necessary, to mitigate the risk of a break in services following of the expiration of this task order and the -8 extension. If the ACS model is approved in a timely manner, and if funding is available, it is expected that garrisons may be tasked to hire against new Department of the Army Civilian (DAC) authorizations, which would preclude the need for the MICC to award a new task order.

4. Authority Cited:

10 U.S.C. 2304c(b)(3) as implemented in FAR 16.505(b)(2)(i)(C) and DFARS 216.505-70(b)(2): The order must be issued on a sole-source basis in the interest of economy and efficiency as 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 for Authority Cited:

IMCOM G-9 has an ongoing requirement for Personnel Support Services (PSS) at CONUS and OCONUS installations. The new PSS suite IDIQ contracts were competed full and open and awarded by NCRCC (now ACC-NCR) in November 2010. This suite and the majority of the follow-on requirements have been transferred to the Fort Knox Mission Installation Contracting Center (MICC). The task order for this requirement, NPSP, was competitively awarded to Strategic Resources, Inc. (SRI) in September 2010 by ACC-NCR as a 12 month bridge from the previous 2004 PSS IDIQ suite. In the interest of economy and efficiency, these services are recommended to be provided by the original contactor as a logical follow-on to the Task Order currently in place, as all requirements fall within the scope of the current task order. If the new Army Community Services (ACS) model, discussed above, is approved in a timely manner, and if funding is available, it is the Government’s intention to convert the NPSP positions to Department of the Army Civilian (DAC) positions. HR Solutions and the MICC are monitoring the situation to determine if a new task order will need to be awarded as the ACS plan goes through the approval process. Accordingly, the Government has chosen to exercise FAR 52.217-8 Option to Extend Services. The 6 month extension of services as a logical follow-on to the existing task order, IAW FAR 16.505(b)(2)(i)(C) until such time as the outcome of the ACS model approval process is established. It allows the Government this critical period to assess whether it will be most advantageous to convert the current positions to DAC positions, with the concurrent draw-down of contracted requirements, or whether a new task order should be awarded to continue services under the new IDIQ vehicle.

A break in contract services will result in a loss of valuable expertise of the incumbent employees and the cessation of critical services provided to Soldiers and their Family members. The termination of NPSP-Home Visitation services provided under this task order will result in a significant disruption of services and will be absolutely detrimental to Soldiers/Family members and the Army. The Army will not have sufficient New Parent Support-Home Visitation staff to provide services for Families to mitigate child abuse, neglect and possible fatalities. The NPSP is the only FAP prevention program that provides services in the home. To disrupt services, particularly to isolated households, OCONUS and CONUS, will go against the provisions of the Army Family Covenant, which institutionalizes the Army’s commitment to provide Soldiers and Families — Active, Guard, and Reserve — a quality of life commensurate with their level of service and sacrifice to the Nation. There is no other like Army agency that can provide equitable services to clients. As a result, the critical client-advocate relationship which has been established would be jeopardized and the effective, coordinated transfer of personnel-sensitive records would be severely impacted, creating tremendous turmoil for these at-risk individuals. This would have an adverse affect on the Army’s goal in meeting/sustaining readiness.

The Human Resource Solutions (HRS) Program Office conducts monthly quality assurance evaluations. To date, SRI has consistently received satisfactory performance assessments under the current Task Order as documented by the program office. In terms of mission effectiveness, the contractor must be fully cognizant of the origination process. In order for another contractor to perform satisfactorily, a substantial amount of time would be required to overcome the necessary learning curve, provide experienced personnel, transfer accountability of Government furnished equipment and obtain approval of adequate management plans. Given the amount of staff involved and the need to recruit, hire, and train new staff, it is estimated that a minimum 90-day transition period would be required, with a minimum of 60 days with both the incumbent and new contractor onsite to ensure that the new contractor is familiar enough with the requirements to successfully accomplish the transition.

The incumbent contractor has been in place for four years. As a result, their personnel have gained expert-level understanding of the mission and are able to use this knowledge to anticipate customer’s needs and mission effectiveness. The ability of the Army to provide comprehensive and timely personnel support services to Soldiers and their Family members worldwide is critical in sustaining/maintaining the overall readiness of the force. An award to any other contractor at this point will force the Government to lose valuable expertise that the current contractor has gained and the continuity of established processes developed by the contractor that will immediately affect Soldiers. Such risk is attributed to the effort and time it would take a new contractor to obtain sufficient expertise and knowledge to provide 100% of the required mission support. Furthermore, the work processes in place and quality of efficiencies will suffer. The impact of a service break would be very significant.

SRI is performing the services under the current task order. Any contractor other than SRI would lack the detailed familiarity and expertise with the Army’s on-going efforts on this task order in support of New Parent Support Program-Home Visitation. In order to award this action to another contractor, a minimum of 45-60 days would be necessary for the processing of a new task order under the IDIQ contract vehicle. Additionally, it is estimated that at least 60 days would elapse before a new contractor is familiar enough with the requirements to successfully accomplish the required support and services, and likely more if there is not a phase-in/phase-out process to transition the current contractor to the new one. Furthermore, the work processes in place and quality and efficiencies will suffer, thereby severely limiting continuity and adversely affecting client services.

The Resource Manager estimates that the non-recoverable duplicated cost of a transition is approximately $4,756,889.60 (4 months, including solicitation and award of a new task order and a 2 month transition). This amount is based on the current labor CLIN at a FFP rate of $1,189,222.40 per month.

6. Efforts to Obtain Competition:

The task order for this requirement, New Parent Support Program (NPSP), was competed among all awardees and awarded to SRI in September 2010 by ACC-NCR as a 12 month bridge from the previous 2004 PSS IDIQ suite. Based on the information in paragraph 5, above, competition for this action is not feasible.

7. Actions to Increase Competition:

The new PSS suite IDIQ contracts were competed full and open and 16 contracts were awarded by NCRCC (now ACC-NCR) in November 2010. This suite and the majority of the follow-on requirements have been transferred to the Fort Knox Mission Installation Contracting Center (MICC). As discussed in previous sections, a new Army Community Services (ACS) model is in the review and approval process. If the ACS model is approved as indicated in sections 2, 3 and 5 above, it is expected that garrisons may be tasked to hire against new Department of the Army Civilian (DAC) authorizations, which would preclude the need for the MICC to award a new task order competitively. HR Solutions and the MICC are monitoring the situation to determine if a new task order will need to be awarded as the ACS plan goes through the approval process.

8. Market Research:

Competition of task orders competed for HR Solutions customers is obtained through the multiple award IDIQ contract holders. The award of those basic IDIQ contracts results after significant market research including synopsis of draft and final solicitation DASW01-03-R-0033, and sources sought synopses. No further market research was done.

9. Interested Sources

In accordance with FAR 5.202(a)(6) the proposed contract action is an order placed under FAR Subpart 16.5 and complies with the Exceptions to the requirement to post a synopsis required by FAR 5.201. To date, no other sources have expressed interest. However, any bids or proposals received shall be considered.

10. Other Facts

Procurement History:

Previous Contract Numbers: W74V8H-04-D-0065-0021 Awarded 2007; W919WAW-10-D-0078-0006 Awarded 2010.

These task orders were awarded as a result of Fair Opportunity.

There was no previous authority for less than Fair Opportunity.

No justifications were necessary for previous procurements.

The previous HR Solutions IDIQ contracts were awarded on the basis of full and open competition with over 40 offers received and evaluated. Task Order 0021 was competed among the three prime contractors under contract W74V8H-04-D-0065. The evaluation of their technical proposal revealed their technical approach was feasible in accordance with Section M of the solicitation; and their price proposal was determined to be fair and reasonable by the Contracting Officer. Also the best value trade off analysis conducted by the Government deemed SRI’s proposal as offering the best value to the Government among all the proposals submitted. . The current task order was similarly awarded to SRI under bridge IDIQ contract W91WAW-10-D-0078. The current -8 extension comes as a result of the transition of contract administration between ACC-NCR and the Mission Installation Contracting Center (MICC) Fort Knox. The 6 month extension of services as a logical follow-on to the existing task order, IAW FAR 16.505(b)(2)(i)(C), offers the most economical and efficient method of continuing the services until such time as the outcome of the ACS model approval process is established. It allows the Government this critical period to assess whether it will be most advantageous to convert the current positions to DAC positions, with the concurrent draw-down of the contracted requirements, or whether a new task order should be awarded to continue services under the new IDIQ vehicle with the MICC.

b. Acquisition Data Available:

All relevant technical data packages, specifications, performance work statements, etc., are in place as the result of the previous Full and Open Competition. This is a logical follow-on to the existing task order as the most advantageous method of continuing the critical services until the Government has determined the direction of the ongoing support of this program.

c. Unusual and Compelling Urgency: Not Applicable

d. Subcontracting Competition: Not Applicable

14. Approval: Based on the foregoing, I approve the procurement of the personnel services support for the IMCOM G-9 Family Programs, New Parent Support Program (NPSP) being described above using an exception to fair opportunity pursuant to the authority of 10 U.S.C. 2304c(b)(3); FAR 16.505(b)(2)(i)(C); and DFARS 216.505-70(b)(2), subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

Typed Name: Elizabeth Cloutier Date: 26 Sept 2011

Title: Special Competition Advocate Signature:

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