19-0718_-_JEFO_(003).pdf

U.S. Customs and Border Protection

Justification for Exception to Fair Opportunity (JEFO) – FAR 16.505(a)(4)

Exceeding the SAT

Version 1.0 September 2016

Date: 4/17/19__________ PR Number: 20108725______________

1. Agency and Contracting Activity. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for an Exception to Fair

Opportunity.”

U.S. Customs and Border Protection (CBP), Information and Technology Contracting Division

(ITCD) proposes to enter into a contract on a basis other than full and open competition.

2. Nature and/or description of the action being approved.

CBP, Office of Information and Technology (OIT), Targeting and Analysis Systems Program

Directorate (TASPD) requires the purchase of Rosette Name Indexer (RNI) license renewal and annual operations and maintenance. Pursuant to FAR 16.505(a)(4), this requirement is peculiar to one manufacturer, Basis Technology. While multiple vendors on DHS FirstSource II can provide this software, RNI licensing is proprietary to one manufacturer, Basis Technology.

3. A description of the supplies or services required to meet the agency’s need (including the estimated value).

RNI provides an augmentation of the Global Name Recognition (GNR) product and custom processes TASPD uses in supporting CBP’s mission of securing our nation’s borders. The RNI provides CBP with additional mission capability to identify personnel we were not finding with the aggregate algorithm approach. RNI is a necessary product to continue increasing true positives while limiting false positives and improving mission capability with limited resources.

The estimated total value of this requirement is $1,084,578.85. This includes a twelve (12) month period of performance.

4. Identify the exception to fair opportunity and supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited.

____X____FAR 16.505(a)(4). Consideration is restricted to one item peculiar to one manufacturer for the reasons set forth below.

Rationale:

RNI improves name matching capabilities by limiting false positives (entities that are identified as one in the same, but are not) and increasing the production of true positives (entities that are recognized as the same and are indeed the same). The software allows CBP analysts to extract name and date of birth from APIS or PNR data and look at derogatory records to see if there is a name match so that operational personnel can be notified prior to making vetting, screening, and enforcement decisions.

Rosette Name Indexer is currently installed and being used by TASPD, allowing for additional mission capability than was found using the previous Global Name Recognition approach. This requirement is for the maintenance of an already existing software within TASPD. Market research previously found a scarcity of products that are mature in the entity resolution space because it is a difficult problem and few companies have adequate resources and algorithms to deal with global demographic data to meet CBP’s needs.

The research determined that RNI can provide CBP with additional mission capability to identify entities that are not currently available via other products on the market. RNI is able to provide

CBP with both high matching strength and high false positive rejection; this is a unique capability that has not been replicated in other products. In addition, the cost of this product is significantly less than the cost of additional personnel who would be required to manually review data in hopes of finding more true positives.

Without the RNI licensing, personnel’s work will be impeded to the detriment of the government. More time and effort would be put into determining these entity relationships, slowing down the decision making process, and leaving less time to identify and investigate true positive matches.

While the RNI software is proprietary to one manufacturer, multiple vendors can provide this software under the DHS FirstSource II contract.

5. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has determined that the anticipated price will be fair and reasonable based on the fact that the solicitation will be competed amongst Department of Homeland

Security FirstSource II contract holders.

The anticipated cost to the Government will be fair and reasonable as it is anticipated that there will be adequate competition. Furthermore, the final price will be analyzed against the

Government’s Independent Cost Estimate.

6. Any other facts supporting the justification.

None.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

The justification will be posted with the Request for Quote for the Department of Homeland

Security FirstSouce II IDIQ contract holders to see if additional sources have the capability sought by the agency.

TASPD is committed to performing additional market research as part of each periodic license renewal to ensure fair opportunity.

8. CBP intends to post this requirement on FedBizOpps pursuant to FAR 16.505(b)(2)(ii)(D).

No interest was received based on the Advanced Acquisition Plan # 2018043274. This will be posted to FedBizOpps by the Contract Specialist for any additional interest.

9. Technical/Requirements Personnel Certification:

Pursuant to FAR 16.505(b)(2)(ii)(B)(9), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the justification, are accurate and complete.

Technical Representative/COR Date

10. Contracting Officer Certification and Approval: *

Pursuant to FAR 16.505(b)(2)(ii)(B)(8), I certify that this justification is accurate and complete to the best of my knowledge and belief and hereby determine that the circumstances for an exception to fair opportunity exist:

Contracting Officer Date

5/6/19

*Note: In accordance with FAR 16.505(b)(2)(ii)(C)(1), proposed orders with an estimated value exceeding the simplified acquisition threshold, but not exceeding $700,000, the ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the ordering activity contracting officer’s knowledge and belief will serve as approval. For CBP, the contracting officer should sign each justification prior to approval by the next higher level (e.g., Competition Advocate, HCA, and/or CPO).

► JEFO Approvals:

12. COMPETITION ADVOCATE (Per FAR 16.505(b)(2)(ii)(C)(2) - Above $700,000)

Approved Disapproved

Name (Print): ________________________

Competition Advocate

Signature: ___________________________ Date: _____________

BBH13FM

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