JUSTIFICATION AND APPROVAL FOR OTHER-THAN FuLL-AND-0PEN COMPETITION JUSTIFICATION. 1.0 Agency and Office Name: Consumer Financial Protection Bureau 2.0 Nature and/or description of the action being approved. Procurement of software as a service to enable CFPB to efficiently and effectively analyze its demographic data and MD-715 tables for triggers and potential EEO barriers based on sex, race, national origin, and disability. 3.0 Description of Requirement (including the estimated value). The Office of Civil Rights (OCR) within the Bureau�s Office of Equal Opportunity and Fairness (OEOF) is seeking to engage a vendor to provide software as a service to enable CFPB to efficiently and effectively analyze its demographic data and MD-715 tables for triggers and potential EEO barriers based on sex, race, national origin, and disability. Firm Fixed Price - $301,995 4.0 Statutory authority permitting other-than full and-open competition. FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services will Satisfy Agency Requirements 5.0 Demonstration that the proposed contractor 's unique qualifications or the nature of the acquisition requires use of the authority cited. CFPB EEO officials conducted benchmarking among similar federal agencies to determine if respective EEO professionals were aware of, had created, or had used similar software for identifying these �triggers.� Various larger federal agencies have developed such software in-house to their agency�s specific use. These agencies typically have statistical and data experts capable of creating sophisticated solutions which integrate data from HR systems and include statistical analyses and models. CFPB has no one with the skills to devise a customized solution for Bureau use. Further, no other EEO official at any other federal agency was able to identify any other software on the market that could be procured to accomplish this task currently. Similarly, CFPB EEO officials did internet research to see if they could independently identify such software. The only solution identified was Econosys software. Conducted a search on UNICOR, Ability One, Government-wide database of contracts and the Federal Supply Schedule. Keywords used included - Workforce Analyses, EEOC Management Directive 715, and Barrier Analyses. The results did not yield a product that was similar o the MD-715 Reporter tool. 6.0 A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2. A notice was publicized to Federal Business Opportunities (FBO) on 15 June 2020. No responses were received. 7.0 Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable. The contracting officer will ensure that pricing is fair and reasonable prior to award through use of 'other than cost and pricing data', and price analysis. 8.0 A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted. The CFPB's EEO Office conducted research among similar federal agencies to determine if respective EEO professionals were aware of, had created, or had used similar software for identifying these �triggers.� Various larger federal agencies have developed such software in-house to their agency�s specific use however, these agencies typically have statistical and data experts capable of creating sophisticated solutions which integrate data from HR systems and include statistical analyses and models. Further, no other EEO official at the federal agencies contacted was able to identify any other software on the market that could be procured to accomplish this task currently. Additionally, CFPB EEO officials did internet research, including required sources, and GSA schedules. 9.0 Any other facts supporting the use of other than full and open competition. None 10.0 A listing of the sources, if any, that expressed, in writing, an interest in the acquisition. None 11.0 A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required. The Program Office will continue to monitor available sources of data and will change strategy if warranted.
