SOLICITATION NOTICE
R -- Contractor Support for DHS, Civil Engineering Resource Management Division, CG-438
- Notice Date
- 8/26/2013
- Notice Type
- Justification and Approval (J&A)
- NAICS
- 541219
— Other Accounting Services
- Contracting Office
- Department of Homeland Security, United States Coast Guard (USCG), USCG Facilities Design & Construction Center, 5505 Robin Hood Road, Suite K, Norfolk, Virginia, 23513-2400, United States
- ZIP Code
- 23513-2400
- Archive Date
- 10/25/2013
- Point of Contact
- PAMELA J. ARGILAN, Phone: 7578523449
- E-Mail Address
-
pamela.j.argilan@uscg.mil
(pamela.j.argilan@uscg.mil)
- Small Business Set-Aside
- N/A
- Award Number
- HSCG47-13-F-3EFK16
- Award Date
- 8/26/2013
- Description
- JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION Authority, e.g., 10 U.S.C. 2304(c)(7)) Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 8.4 and in accordance with the requirements of FAR 8.405-6, orders placed under Federal Supply Schedules are exempt from the requirements in FAR Part 6. This sole source follow on procurement is justified by the following facts and rationale required under FAR 8.405-6(a)(1)(i)(C) as follows: 1. Agency and Contracting Activity. The Department of Homeland Security, U.S. Coast Guard, Civil Engineering's Resource Management Division, proposes to enter into a contract task order on a basis other than full and open competition. 2. Nature and/or Description of the Action being Approved. This acquisition is with the purpose of seeking services that continue prior efforts preparing asset Capitalization of packages for COMDT CG-438 and identifying, proposing alternatives and bridging gaps in field offices with the shore infrastructure project funding subaccounts. Specifically, this requirement is to provide subject matter expertise necessary to help DHS achieve and sustain an unqualified (or clean) audit opinion FY14-18 and enhancing and preserving the gains achieved to date. Coast Guard anticipates awarding a Firm Fixed-Price contract task order in the estimated amount of $649,756.00 using FY13 AFC-43. This is a follow-on action to contract HSCG23-09-J-VFG078 awarded in 2011 under a GSA FABS BPA. This action will be sole sourced to Kforce Government Solutions, Inc (KGS), 2750 Prosperity Ave, Suite 300, Fairfax, Va 22031. 3. Description of Supplies/Services. This requirement is to provide subject matter expertise necessary to help DHS achieve and sustain an unqualified (or clean) audit opinion and enhancing and preserving the gains achieved to date. For several years, the USCG has been engaged in an overall remediation effort specifically targeted at correcting weaknesses associated with asset valuation, audit supportable documentation, indirect cost allocation, etc. These efforts have helped Coast Guard make significant progress towards its goal of achieving and sustaining an unqualified audit opinion on their financial statements, which this contract seeks to continue and further the progress achieved so far. Since KGS' GSA contract expires on 27 August 2013, this action is for a one year period of performance in order to provide continuity while CG-43 awards a contract to cover the period of August 2014 through August 2018. The estimated number of hours and amount of this one year is GSA FABS Labor Category Base Year Hours Hourly Rate Senior Financial Manager 1920 $121.84 Financial Manager 1920 $106.99 Financial Manager 1920 $106.99 Total Hours 5760 Period Unit Price Other Direct Costs Total Base Year 12 mo $53,729.74 5,000.00 $649,756.93 4. Identification of Statutory Authority Permitting Other Than Full and Open Competition. The applicable statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c)(1)implemented by the FAR Subpart 8.405-6 entitled "Limiting Sources." The work is a logical follow on to the current ongoing task order issued under the GSA FABS BPA. This original BPA was placed using full and open competition among the contractors on the GSA FABS IDIQ contract. In the interest of economy and efficiency this authority applies because to award to any other source would result in substantial duplication of costs or unacceptable delays. 5. Demonstration that the Nature of the Acquisition Require Use of the Authority Cited. For several years, the USCG has been engaged in an overall remediation effort specifically targeted at correcting weaknesses associated with asset valuation, audit supportable documentation, indirect cost allocation, etc. These efforts have helped Coast Guard make significant progress towards its goal of achieving and sustaining an unqualified audit opinion on their financial statements, which this contract seeks to continue and further the progress achieved so far. Previously, though no longer the case, and a catalyst for the initiation and pursuit of these efforts, was the lack of proper valuation of Construction in Progress (CIP) programs, which in turn became one of the material weaknesses contributing to DHS' inability to receive a "clean" audit opinion in the past. The goal of this requirement is to provide assistance so process improvements identified and initiated by KGS can continue and an unqualified audit opinion can be achieved and sustained. Since 2011 when the Coast Guard competed and awarded a task order for subject matter experts among the contractors on the GSA FABS BPA, KGS has provided the subject matter expertise to help CG-43 develop and execute their internal efforts to remediate their multiple-year CIP backlog which impacted proper valuation of USCG and DHS Real Property assets. KGS was integral in the development of the policy, processes, and procedures which CG-43 has adopted and promulgated across its user base. KGS is the only firm with the experience, expertise, and level of understanding to provide these services to CG-43, and their key personnel have a unique understanding of the business processes, systems, and underlying accounting which are required to perform this function. As DHS is in the process of working rapidly and in real time towards achieving an unqualified audit opinion, the award of a contract to any other source would result in substantial duplication of costs and unacceptable delays for the continued provision of these highly specialized services. The learning curve for incoming personnel or contractors would have a direct effect that would present insurmountable challenges when attempting to mitigate the schedule impact leading into this upcoming audit. Alternative solutions will not work as, CG-43's CIP portfolio, capitalization requirements, business processes, and mission of providing infrastructure support to national security are unique, and similar capabilities or expertise could not be transferred from elsewhere in the Federal Government without significant delays, disruption to mission critical timelines, and an unsustainable gap in delivery. The applicable statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c)(1) implemented by the FAR Subpart 8.405-6 entitled "Limiting Sources." This authority applies because these services are a logical follow on action being provided by the current contractor, KGS, and award to any other source would result in substantial duplication of costs or unacceptable delays. The mission will be impacted if this JOTFOC is not approved because the CFO Act of 1990 requires all Federal Agencies to produce auditable financial statements, with oversight by the OMB and US Congress. The Homeland Security Financial Accountability Act of 2004 extended this requirement to the newly-created DHS. If this Justification-For-Other- Than-Full-And-Open-Competition (JOTFOC) were not approved, leading to the service no longer being provided, DHS would face an unacceptably high probability of not achieving an unqualified (clean) audit opinion. 6. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable. FAR 8.405-6(a) states that Orders placed under Federal Supply Schedules are exempt from the (competition) requirements in Part 6 therefore no effort was made to solicit for potential sources. 7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable. The contracting officer determines that the anticipated price(s) will be fair and reasonable based on KGS' Federal Supply Schedule (FSS). The incumbent effort is currently being acquired through a BPA task order issued under the GSA FABS schedule. The labor categories and rates proposed for this J&A have already been approved as fair and reasonable under KGS' FABS schedule and are consistent with the labor rates and costs currently being procured by USCG. 8. Description of Market Research. Once DHS achieves and sustains an unqualified (clean) audit opinion there will be a re-evaluation of the level of urgency to provide continuity of these highly specialized subject matter expertise services. At that time the USCG will be better able to manage a transition of these services either to government personnel or to a follow-on competitive contractor. 9. Any Other Facts Supporting the Use of Other Than Full and Open Competition. This requirement is to provide subject matter expertise necessary to help DHS achieve and sustain an unqualified (or clean) audit opinion FY14 and enhancing and preserving the gains achieved to date. In 2011, the Coast Guard competed a task order for subject matter experts among the contractors on the GSA FABS BPA. As a result of this competition KGS was selected as the Contractor with the subject matter expertise to help CG-43 develop and execute their internal efforts to remediate their multiple-year CIP backlog which impacted proper valuation of USCG and DHS Real Property assets. KGS was integral in development of the policy, processes, and procedures which CG-43 has adopted and promulgated across its user base. KGS is uniquely able to provide these services requested through their GSA FABS s BPA HSCG23-09-J-VFG078. KGS is able to complete this effort at an amount below any other provider as they will not incur the costs associated with the "learning curve" for this effort. To date the current contract action has cost the CG $4.2M for these services. It is anticipated the "learning curve" would equate to over a million dollars. 10. A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition. A synopsis has not posted on FedBizOps yet as FAR 8.405-6(a) states within 14 days of placing the order the ordering activity shall post the justification for a minimum of 30 days. 11. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required. This action is being put into place for a performance period of one year in order for the USCG to better be able to manage a transition of these services either to government personnel or to a follow-on competitive contractor.
- Web Link
-
FBO.gov Permalink
(https://www.fbo.gov/notices/0293a1808c2111f46225eeffef282152)
- Place of Performance
- Address: U.S. Coast Guard Headquarters, Washington, District of Columbia, 20593, United States
- Zip Code: 20593
- Zip Code: 20593
- Record
- SN03162665-W 20130828/130826235641-0293a1808c2111f46225eeffef282152 (fbodaily.com)
- Source
-
FedBizOpps Link to This Notice
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