Limited-Sources Justification
Pursuant to the authority of Section 201 of the Multiple-Award Schedule Program 41 U.S.C. 251, this justification is prepared in accordance with the requirements of Federal Acquisition Regulation (FAR) 8.405-6(c) for the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3. The circumstance justifying restriction is FAR 8.405-6(a)(1)(i)(B) through the following facts and rationale:
(1) Agency and Contracting Activity. The Department of Homeland Security, United States Coast Guard (USCG), proposes to enter into an order on the basis of a limited-sources justification.
(2) Nature and/or description of the action being approved.
Nature of action: USCG intends to limit competition to one vendor and award a sole source contract as only one source is capable of providing the supplies or services required at the level of quality required because the services are unique or highly specialized. The services under this justification were previously provided under BPA Contract HSCG23-14-A-PRZ259, which was awarded on 09/18/2014 and ends on 03/31/2020 and a bridge award 70Z02320FPFC032 for two months from 04/01/2020 to 05/31/2020.
Name and address of the contractor:
JAVA PRODUCTIONS INCORPORATED
2270 KRAFT DR
SUITE 1850
BLACKSBURG VA 240605130
Contract type: Firm-Fixed-Price
Estimated total value (including options):
Base Period 6/1/20-12/31/20 $244,639.20
Option Period 1 01/01/21-6/30/21 $203,175.00
Option Period 2 07/01/21-12/31/21 $203,175.00
Grand Total $650,989.20
- Type of funding: Operations and support funds
- Year of funding: Fiscal Year 2020
- Solicitation number: 70Z02320QPFC04600
- Background information about the requirement: JPI, Inc. was awarded the aforementioned contract to support the Coast Guard's Marine Inspector Performance Support Architecture (MIPSA) project. However, additional services are required to complete the full implementation of the project, prior to transitioning this requirement from the implementation phase to the on-going sustainment phase.
(3) Description of Supplies/Services.
This requirement is Project Management through the implementation and assessment phases of the USCG MIPSA project.
To achieve the outcomes outlined in ALCOAST 214/18 ACCELERATING TOWARD OUR FUTURE and ALCOAST 174/19 COMDT EARLY ACTION ITEM (EAI) FOR MARINE INSPECTOR PERFORMANCE SUPPORT ARCHITECTURE (MIPSA), this acquisition is to support the Coast Guard Marine Inspector Performance Support Architecture (MIPSA). The Contractor shall provide services to assist USCG in planning, executing and closing out programs and projects focused on capturing the total body of work performed by the marine inspector workforce, aligning that body-of-work to a cogent structure supported through various performance support and training products; these efforts will achieve a sustainable and predictable development structure for the Marine Inspector workforce.
Services required shall include: support during the entire project lifecycle; (planning, initiation, execution, integration, close-out); project management, planning and scheduling; coordination of communications; facilitation; reporting and documentation support; supporting policy and business process development; providing administrative executive support; supporting operational analysis, and collection and analysis of tasks, systems, and processes related to the Marine Inspector workforce performance support and training architecture. The contractor will take the information gathered as part of this project to manage the project, timelines, risks, and tasks. Most critical in the next phases of this project will be assistance with risk mitigation, communications, and plans for assessments.
GOVERNMENT FURNISHED INFORMATION AND PROPERTY.
The Government will provide sufficient workspace, equipment and supplies necessary to perform the on-site portion of Contractor services required under this contract. The Contractor shall be responsible for returning all Government furnished resources in good working condition, subject to normal wear and tear.
(4) Identification of the justification and the rationale.
FAR 8.405-6(a)(1)(i)(B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.
MIPSA is a new project launched in late 2018 that is critical to the future of CG prevention and marine inspections mission (see attached foundational documents). It has high-level CG support from the Commandant, Vice Commandant, Atlantic and Pacific Area Commanders, Deputy Commandant for Operations, Deputy Commandant for Mission Support, programmatic, and the field. The knowledge gained by the current contractors is unique to the U.S. Coast Guard and to this project. While there may be other contractors who have some familiarity with the Coast Guard and/or with marine inspections, there are none who have the critical and unique knowledge specific to the workings of this project: for example, the political and programmatic concerns and constraints, personality, human performance technology, unique methodology, systems, or unique scope and details associated with this project. There are no other commercial or government agencies organizations in the world who are looking at this unique issue.
This project is currently at a critical juncture at which the incumbent JPI contractors are critical to keeping meetings and coordination with a team of over 80 Coast Guard accomplished performers, subject matter experts, and training developers on track. It would be impossible to bring new contractors on to provide the same level of support we receive or avoid delays in this project (see attached recent decision memos and draft ALCOAST outlining the current project timelines).
The contractor's unique qualification that is not prevalent elsewhere on the schedules is the knowledge and skills gained over the course of the past 15 months in the current contract. The knowledge and skills that are critical, are those related specifically to Coast Guard marine inspections and marine inspectors, the maritime industry, history, and viewpoints on this project are essential to maintain through final implementation and assessment of the MIPSA project.
The Contractors' Institutional knowledge and skills gained through meetings and USCG site visits is now mission-critical for the MIPSA project. Over the past 16 months, the Contractors have attended the following meetings (see attached Outlook calendar list of meetings; in addition, travel records were reviewed for both incumbent JPI contractors to compile this list)
- 90 twice-weekly USCG planning and update meetings
- 27 USCG Captain Update and Decision meetings
- 7 USCG Project board or admiral-level meetings
- 1 CG Advanced Distributed Learning (ADL) kick-off meeting for systems-based training development
- 15 project-specific ADL alignment meetings for systems-based training development
- 3 week-long MIPSA (USCG) stakeholder working group meetings with representatives from Training Center, Performance Technology Center, Performance Support Branch, CG-CVC, CG-5P-ti, CG-741, Marine Inspector Training Officers, and field subject matter expert representatives in Yorktown and Portsmouth, VA
- 2 week-long systems-based Task Validation Meetings with Performance Technology Center, CG-5P-ti and approximately 16-20 accomplished performers and subject matter experts, and a week-long Credentialing working group in Yorktown to build credentialing job aid with CG-5P-ti and Performance Technology Center representatives and Accomplished Performers.
- Week-long site visits to 8 USCG units:
- Sector New York,
- Sector Lake Michigan
- MSD Sturgeon Bay
- MSU Chicago
- Sector New Orleans
- MSU Houma, Sector Houston
- Sector Puget Sound
During these visits, the Contractors traveled with key stakeholder representatives from Performance Technology Center, Performance Support Branch, CG-CVC, CG-5P-ti, and CG-741 and recorded three to four interviews per day with marine inspectors, Marine Inspector Training Officers, Chiefs of Inspections Divisions, Prevention Department Heads, and Officers in Charge of Marine Inspections, gaining a unique and thorough perspective into the views and experiences of both the field units and also the stakeholder representatives.
The knowledge and experience gained through these unique and particular interactions and experiences has allowed the Contractors to fold seamlessly and effectively into the MIPSA project team. When tasked with drafting communications, correspondence, and other deliverables, the Contractors require only minimal direction due to their background knowledge of the MIPSA project. They consistently deliver high quality products that require little to no adjustment.
Having this consistency, efficiency, and thoroughness, due to their knowledge of the project and stakeholders, is mission-critical. If not present in a future contractor, it would delay and/or harm this Commandant-directed project due to the amount of time, approximately six months, and the active duty Coast Guard personnel availability necessary for new contractors to repeat the meetings with USCG and stakeholders. These events have already occurred, the representatives would not be available to travel to re-create these experiences, and these experiences would not have the same value if not accompanied by the representatives. Even if the representatives took the extra time to re-create these experiences for the contractors, the additional cost would be untenable: approximately $213,803: $153,802 in labor and $60,000 in travel, and the time required, would make it impossible to recreate these experiences. These cost estimates are based on an estimated delay of six months (940 hours each) for a new contractor to come up to speed and obtain the necessary knowledge and skills specific to this MIPSA project, and each of the 2 new contractor to conduct site visits and other travel, accompanied by approximately 2 key MIPSA personnel with knowledge of the project to guide them, totaling approximately $15,000 per person. This $15,000 per person is estimated based on reviewing the travel records for MIPSA site and other meetings.
The additional cost is $218,803 to recreate some semblance of the experiences needed to gain the knowledge and skills to be an asset to this project; in actuality, it is impossible to recreate the experience, and any change in contractors would result in these unacceptable additional costs, project delays, and decreased quality of deliverables. Without the knowledge gained from the last 15 months, the contractor's value to the project would greatly diminish. The loss of a productive Project Manager, along with the time, approximately six months, it would take to get a new contractor up-to-speed, would be harmful to the MIPSA project, by causing a delay and additional development time, duplicate costs for efforts already completed, and less thorough knowledge of the subject matter resulting in lower quality work. Lastly, the required period to complete the last phase is roughly 18 months to complete the project and afterwards the requirement can be competitive.
No other contractor has employees who have been privy to the conversations, discussions, and decisions that have occurred over the course of the 140+ meetings and 13 week-long site visits, team meetings, and task validation meetings. It is unacceptable to the government to delay this project to bring to new contractors up to speed.
(5) Determination by the ordering activity Contracting Officer that the anticipated order represents the best value consistent with 8.404(d).
The Contracting Officer has determined that issuing the proposed task order to JPI, Inc. to continue this effort represents the best value and will result in the lowest overall cost, considering price and time, to meet the Government's needs.
The estimated cost of a six month task order with two six month options is $650,989.20. The estimated additional cost to bring on a new contractor is $213,803: $153,802 in labor and $60,000 in travel. The additional cost to bring on a new contractor would be approximately 34% higher than using the incumbent contractor for this effort.
The contracting officer has considered the level of effort and the mix of skills available for the tasks needed to ascertain that the proposed order represents a reasonable total price and will be the best value for the Government in the terms of cost and time.
This order will be placed in accordance with FAR 8.404 Use of Federal Supply Schedules. General Services Administration (GSA) has already negotiated fair and reasonable pricing. The Contracting officer will inquire about additional discounts for this procurement.
(6) A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.
Market research was conducted over the past year. There are other small business schedule holders. However, the additional cost and time ($213,803 and six months) needed to bring on a new contractor would be detrimental to completing the MIPSA project on time and within budget. JPI, Inc. has the specialized knowledge and skills related to Coast Guard marine inspections and marine inspectors, the maritime industry, Coast Guard history, and viewpoints on this MIPSA project. Only JPI, Inc. is determined capable of completing the implementation work required under this procurement without duplicative effort and additional cost to the Government, as described above in Section 4 and below in Section 7.
(7) Any other facts supporting the justification.
The USCG estimates the duplicative time and cost required to bring new Contractors onboard and would be six (6) months and $213,803: $153,802 labor and $60,000 travel. A new vendor would need to repeat the meetings with USCG and stakeholders described in Section 4 before being capable to fully support the on-going planning, implementation and assessment efforts in the MIPSA project. Repeating those meetings would result in USCG personnel taken away from their current duties and a delay of six months and cost overrun of $213,803 in the MIPSA project. Lastly, the required period to complete the last phase is roughly 18 months to complete the project and afterwards the requirement can be competitive.
(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that preclude the agency from meeting the requirements of 8.405-1 and 8.405-2 before any subsequent acquisition for the supplies or services is made.
The previous contract was competed, there were no barriers to competition. This is a follow on order that will save $213,803 and six months of time because the current contractors have unique mission-critical knowledge and skills specific to the MIPSA project.
