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Control Number: Knox-2024-43 JUN 2023 Justification Review Document for Limited Source Justification - FAR Part 8 Program/Equipment: ABC- C Call Center SaaS Solution Authority: FAR 8.405-6(a)(1)(i)(B)... Control Number: Knox-2024-43 JUN 2023 Justification Review Document for Limited Source Justification - FAR Part 8 Program/Equipment: ABC- C Call Center SaaS Solution Authority: 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. Amount: , including all options. Prepared by: Reviewed by: Technical Representative: Requirements Representative: Reviews I have reviewed this justification and find it adequate to support other than full and open competition. Legal Counsel: JUN 2023 Limited Source Justification – FAR Part 8 1. Contracting Activity: Civilian Human Resource Agency (CHRA) 2. Description of Action: The CHRA Army Benefits Center (ABC) requests a firm fixed priced task order under General Services Administration (GSA) with TTEC. This acquisition is conducted under the authority of the Multiple Award Schedules Program, for Federal Supply Schedule contract GS-35F-151GA with TTEC Government Solutions, LLC located at 9197 S. Peoria Street, Englewood, CO 80112. The Government projects an award for this requirement in Sept 2024 and fiscal year 2024, Operations and Maintenance (O&M) funds will be used. 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). This action is a follow-on to contract W52P1J-22-F-0472 which was not competed under authority (FAR) 8.405-6(a)(1)(i)(B). The requirement was not competed since no other source is capable of providing the services necessary for this transition requirement. Additionally, the cost for contractors to obtain the necessary accreditations and requirements are estimated to cost in excess of for contractors and take up to a year to meet all standards necessary for those accreditations. 3. Description of Supplies/Services: TTEC is currently providing a cloud-based Software as a Service (SaaS) contact center solution in support of U.S. Army CHRA’s ABC located both within the continental U.S. and outside the continental U.S. ABC is responsible for Retirement (Civil Service and Federal Employees Retirement Systems), Thrift Savings Plan, Federal Employees Health Benefits, Federal Employees’ Group Life Insurance, Survivor Benefits, Injury Compensation and Unemployment Compensation programs. TTEC provides a technical solution only and does not provide agent assistance. CHRA agents utilize the contact center solution to process client calls to the ABC system. The system provides support for approximately 100 CHRA call center agents located in the U.S. with ability to expand by 25% in the future to support more agents located both inside and outside the U.S. The system includes the ability to route/record all incoming/outgoing calls to CHRA call center agents’ existing phones (analog, Voice over Internet Protocol and cellular devices). The system supports the ability for the agents to receive incoming calls regardless of where they are working (at the office, teleworking or alternate locations) from across the globe. The system has a Web Chat option for customers, with an ability to initiate chat from the ABC-Civilian (ABC-C) website built on the ServiceNow platform and to integrate with an external case management system via Application Programing Interface integration (screen pops) so agents can see customer information when answering the call. Call board capability for agents/supervisors to see real-time call statistics overall and by group is also a function JUN 2023 of the current system. Statistics include real-time agent and call statistics as well as the ability to pull in historical performance data from an external database. Most importantly, the system is in compliance with all Department of Defense (DoD) security requirements in accordance with the current version of the of the DoD Cloud Computing Security Requirements Guide (CC SRG) for sensitive information, including Personally Identifiable Information (PII). These requirements include but are not limited to being Federal Risk and Authorization Management Program (FEDRAMP) authorized and having a minimum DoD Impact Level (IL) 4 Provisional Authorization, and an Army Authorization to Operate. This solution supports security and storage of all call recordings to be in Federal Information Processing Standards 140-2 compliant encryption and provides the ability to easily locate/identify stored call recordings by different criteria including at a minimum using either the Department of Defense Identification (DoD ID) of the customer or the agent’s name and date/time. The customer is requested to provide his/her DoD ID as they navigate through the call menu. The system has the ability to support multiple incoming phone numbers, routing callers through the appropriate menu based on the number called and provides the ability to route customer calls with both touch tone and voice input. 4. Authority Cited: FAR 8.405-6(a)(1)(i)(B): Only one source is capable of providing the services required. The previous requirement was also issued by Rock Island last year to TTEC, LLC. with the authority of only one source was available. 5. Reason for Authority Cited: A bridge contract with the current contractor, TTEC, LLC, is required in order to reach the capabilities that will be offered through Army Microsoft 365 (A365) and the Teams environment. This capability is projected to be vetted by the end of Q4 FY24. The A365 solution eliminates the need for a phase-in period, allows better integration with existing Army enterprise applications, is properly vetted and authorized through all cybersecurity requirements, and will be offered at little to no cost to the government- offering a savings of approximately . The contract is contemplated to accomplish a transition to A365/Teams and reduce risk is as follows: Base: 3 Months from 30SEP24 to 29DEC24 52.217-9, Option Period One: 3 Months from 30DEC24 to 29MAR25 52.217-8, Option to Extend Services: Maximum 6 Months from 30MAR25 to 29SEP25 6. Efforts to Obtain Competition: On May 2, 2024, CHRA G6 put out a request for quote (RFQ) through the Computer Hardware Enterprise Software and Solutions (CHESS) Information Technology Enterprise Solutions- 3 Services (ITES-3S) contract vehicle. CHRA received no quotes back and was issued a Statement of Non- Availability. CHRA then contacted ACC-MICC, Fort Knox. On June 28, 2024, MICC requested a Request for Information (RFI) through GSA. They received 12 responses back. CHRA G6 reached out to small business, Simple Technology Solutions, to verify they had a valid Army Authority to Connect. Through the vetting process, it was discovered that AWS (Amazon Web Services) had a government solution for cloud environments. It was determined that CHRA G6 would need to create a cloud JUN 2023 environment with AWS in order to access these services. CHRA’s current cloud environment is Microsoft Azure Cloud Computing (Azure). Both the Azure and AWS cloud options for government is managed by the Enterprise Cloud Management Agency (ECMA). Because CHRA already had an existing cloud infrastructure with ECMA, our technical team reached out to Azure to request information on a similar platform offered within the Azure environment. It was discovered through the market research conducted that Azure is working on a call center solution through Microsoft Teams that, when set up, would come at little to no cost to the government. This solution is not yet ready and Azure and ECMA would like CHRA G6 to pilot a program. Additionally, this solution would come at little to no cost to the government, allowing a cost savings of approximately . a. Effective competition. The discovery of the Azure cloud-based solution for a call center that would cost the government little to no funding, effectively cancelled any competition that would arise in the future. This contract requirement would no longer be required since it would be provided under existing systems - through Army Microsoft 365 (A365) and the Teams environment. b. Subcontracting competition. No subcontracting would be needed with the Azure SaaS call center solution. 7. Actions to Increase Competition: Market research was conducted to find a cloud SaaS solution for the ABC-C call center IT requirements. FedRAMP is mandatory for all executive agency cloud deployments and service models at the Low, Moderate, and High-risk impact levels. Additionally, DISA certifies DoD cloud environments for use by DoD agencies and is the authoritative source for DoD cloud authorizations. As such, the market research sought to identify vendors with these capabilities. Contractors were also required to indicate whether they could offer integrated telecommunications capabilities. 8. Current Market Research: Request for Quote was requested through CHESS on May 2, 2024, with no responses obtained. A SONA (Statement of Non-Availability) was issued. Furthermore, an RFI was also submitted on May 28, 2024, through GSA by the MICC with 12 responses provided, five of which could be considered for a small business set-aside. Four of the small businesses responded that the effort to transition could take more than 60-days which cannot meet to transition timeframe along with the estimated 150 day accreditation process. Based on the discovery that Army Microsoft 365 (A365) and the Teams environment could be utilized and therefore eliminate any future requirement, the question was how best to provide services for the period needed to transition from the contractor’s current system to A365 and Teams. A review of MICC Fort Knox’s initial Market Research conducted through GSA’s Market Research as a Service (MRAS) by way of issuing RFI’s on 28 June 2024, revealed that there was a high risk that the contractors did not understand the security requirements and would require more time to transition from the current contractor to their new cloud based solution. Four out of five contractors JUN 2023 responded that the transition could take as much as of 60 days and security accreditation could take up to 150 days. Given the high risk of failure to transition on time with the full suite of security and accreditation needed and the potential impact to the Army, a bridge to transition from the incumbent’s SaaS platform to A365 and Teams within 3 months is in the best interest of the Government. 9. Other Facts: a. Procurement history. (1) Contract: GS35F151GA Order Number: W52P1J-22-F-0472 Contractor: TTEC Government Solutions, LLC Award Date: 30SEP2022 (2) Competitive Status: Only One Source (After extensive vetting of companies) (3) Authority FAR 52.212-4. AR 52.212-5 (4) Paragraph 7 of prior J&A states that CHRA G6 will continue to monitor the market by internet research, communicating with vendors via telephone or in person and keep up with the latest information from CHESS to determine the existence of other potential sources/supplies that can meet their requirements. (5) Procurement was made prior to this was based on FAR 6.302-1(a)(2)(ii)(A), supplies may be deemed to be available only from the original source in the case of a follow-on contract for the continued development or production of a major system or highly specialized equipment, including major components thereof, when it is likely that award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition. Only one company out 29 respondents presented a viable solution to the requirements after extensive fact finding and capability research. 10. Conclusion: This bridge is necessary as it allows the requesting authority the ability to work with Azure and Microsoft A365 to transition to a solution that comes at a significant cost savings to the government by eliminating a costly annual requirement. The Azure/A365 transition (estimated at 90 days) will need slightly more than the current time needed for phase-in (60 days) to meet the requirements of this contract, but once implemented will eliminate the need for the current requirement in future years and will be utilizing the Army’s current A365 and Teams inherent capabilities. A recompete and costly phase-in of a new contractor’s system would still require a bridge contract with the incumbent for 60 days to 150 days beyond the current contract based on the process of phase-in and obtaining security accreditation for the new system. This approach is unreasonable on many counts but most importantly the technical risks increase greatly having two systems while transitioning to A365/Teams, the need to issue a bridge under any contract strategy, and the unnecessary additional costs that would result. For all of the above mentioned reasons it is in the best interest of the Government to implement a bridge with the JUN 2023 incumbent to accomplish the elimination of this requirement which will result in a significant annual cost savings going forward. 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. 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. 13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. 14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief. JUN 2023 Approval Based on the foregoing justification, I hereby approve limiting sources in the acquisition of ABC- C Call Center SaaS Solution estimated at pursuant to the authority of 41 United States Code 4106(c) as implemented in Federal Acquisition Regulation FAR 8.405-6(a)(1)(i)(B), subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition. Signature: Typed Name: Yonason Bloch Title: Contracting Officer