Program Management Support

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Justification for Other than Full and Open Competition United States Department of Agriculture
Federal Acquisition Regulation (FAR) Part 6.3
1. Identification of the agency and the contracting activity.

USDA, Rural Development (RD) Procurement Management Office (PMO), for services required by the
Rural Housing Service (RHS), Single Family Housing Guaranteed Loan Program.

2. The nature and/or description of the action being approved.

The USDA proposes to enter into a contract on a basis other than full and open competition,
negotiate a sole source, level of effort contract with RSM. This is an action for project and
program support services to assist with the implementation and completion of the required Uniform
Residential Loan Application (URLA) and the associated Uniform Loan Application Dataset (ULAD).

3. A description of the supplies or services required to meet the agency's needs (including the
estimated value).
The period of performance will be a base period of 9 Months commencing upon award with a one 3-
month option beyond the base period.

The purpose of this order is to assist RHS, Single Family Guaranteed Loan Program in implementing
the new critical requirements associated for URLA and the associated ULAD. On February 1, 2020, all
commercial and government lenders are mandated to implement a new industry standard for processing
of loan applications with the purpose of collecting additional information and enhancing language
requirements as required by the Home Mortgage Disclosure Act. The estimated contract amount is not
to exceed $850,000.00.

The contractor will support program management to ensure timely implementation of the new mandated
standards required for meeting the RD Mission of providing housing loans to rural America.
Contractor will support project implementation of essential program aspects which will provide:

Program control and administration; stakeholder management; value measurement; and coordination of
resources.

In addition, the contractor will provide subject matter experts to ensure Rural Development's
uniquely defined loan origination services meet relevant mortgage industry standards from the
Mortgage Industry Standards Maintenance Organization (MISMO) Version 3.4.

4. The statutory authority permitting other than full and open competition.

41 U.S.C. 3304(a)(1), as implemented by FAR 6.302-1, titled "Only one responsible source and no
other supplies or services will satisfy agency requirements."

This authority applies when the services required by the agency are available from only one
responsible source, and no other type of supplies or services will satisfy agency requirements.

RHS, Single Family Housing Guaranteed Loan Program has an urgent need to implement the URLA and
URLA dataset by the date established by industry regulation. URLA implementation date is a
non-negotiable deadline that RD and all commercial and federal lending entities are mandated to be
in compliance.

If system design, enhancement, compliance testing does not occur by the February 1, 2020 deadline,
the Guaranteed Loan Program will not be able to process and issue new loan applications to low- and
moderate-income constituents in the country.

This will subsequently jeopardize the availability of affordable housing for thousands in rural
areas. Development of necessary tools and applications for implementation of URLA was placed on
contract soon after the standard was announced, approximately two and a half years ago. The initial
contract was terminated within the last quarter. Due to the urgency of this effort, the IT
development needed to meet the implementation of the URLA standards was contracted to a new vendor,
with a very aggressive timeline. Due to the complexity and fast paced developmental environment, RD
requires program support assistance and subject matter expertise necessary to successfully deliver
the project.

5. A statement demonstrating the unique qualifications of the proposed contractor or the nature of
the action requiring the use of the authority.

RSM is the only contractor can meet Rural Development's needs, at this time. RSM has developed a
unique understanding of RD's loan processes and requirements. Recently, on an unrelated
requirement, RSM completed six months conducting an in-depth analysis of the rural development loan
application processes, RD's unique IT systems, and regulations through detailed documentary
analysis and nationwide interviews with RD personnel, becoming intimately familiar with the
program's requirements, processes and limitations.

Because of the urgent timeframes required for this effort, there is not a sufficient amount of time
for another vendor to develop the subject matter expertise of RD's unique loan processing
requirements necessary to successfully support this vital program through implementation (7
months).

RSM has demonstrated that they have the capability and expertise necessary to immediately, upon
award, to provide the needed program support.

In addition, RSM has project and program management services, as well as mortgage industry experts,
which will ensure that RD implements URLA in accordance with the Federal Housing Finance Agency's
requirements for the effective date of February 1, 2020.

6. A description of efforts made to ensure offers are solicited from as many potential sources as
is practicable.
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Because of the unique knowledge and experience of RSM, no other contractor would be able to meet
the timeline necessary for implementation and delivery.

7. A determination by the Contracting Officer that the anticipated cost to the Government will be
fair and reasonable.

An independent Government Cost Estimate has been developed (IGCE) based on the history of previous
contracts, current market conditions and program expectations. However, to ensure that the price
will be fair and reasonable, the data from the IGCE will be compared with the proposal received
from the offeror. An award will be made only if during negotiations it is shown that the
anticipated cost to the government will be fair and reasonable.

8. A description of the market research conducted and the results or a statement of the reason
Market Research was not conducted.

Various program support vendors were contacted and interviewed to assess the level of expertise and
knowledge of RD loan processing. RSM was the only vendor that currently demonstrated a sufficient
amount of subject matter expertise needed to successfully support the requirement.

9. Any other facts supporting the use of other than full and open competition.
N/A
10. A listing of the sources, if any, that expressed a written interest in the acquisition.
N/A
11. A statement of actions, if any, the agency may take to remove or overcome any barriers to
competition if subsequent acquisitions are anticipated.

In this instance, the failure of a previous contract which shortened the development timeframe of
the requirement created the barrier to competition. Competition is always the default acquisition
strategy and will be pursued according to timing of legislative mandates and notification
requirements.

Supporting data that form the basis for and included in this justification are certified accurate and complete.

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