1-3-2_Cybersecurity Program Support Services (CPSS) Consolidation DF Revised FINAL Signed 8.9.2024_Redacted.pdf

Period of Performance

02/16/2022 - 02/15/2025 03/16/2023 - 02/15/2025

Competitive/Non- Competitive

Non-Competitive, Direct Award Non-Competitive, Direct Award

Current Vehicle CIO-SP3 Small Business N/A-Open Market

Set-aside, type 8(a) 8(a)

P3CT I & P3CT II were awarded to assist in cross-divisional strategy and mission alignment, which has resulted in the forthcoming ISD reorganization. The vendor for P3CT I (Aretec, Inc.)

outgrew 8(a) status, and a direct award was issued to an 8(a) joint venture (Aretec SBD, LLC), of which Aretec, Inc. is a managing member. The second contract was of the same scope of work.

Work under both contracts is of the same scope and the second contract provided two additional Full Time Equivalent (FTE) resources. Combining both contracts will allow for oversight of similar workload by less program and project management. This will also allow the program to expand and assist in cross-division Program and Project Management and Strategy Operations.

Both P3CT I and P3CT II include the following tasks to help define program strategy, mission, organization readiness, and the programmatic and project management support that defined the need for the reorganization of ISD:

Task 1 - Program Strategy and Mission Alignment Task 2 - Organizational Readiness Task 3 - Program Management and Operational Excellence Task 4 - Continuous Process Improvement

ISD will undergo reorganization, and after reviewing operations, ISD determined a more efficient and effective use of federal staff and funding would be to include all tasks with several more requirements, and new optional tasks, in one award.

Work under the consolidated award will combine both awards to include an inclusive, yet broader scope of work:

Task 1 - Program Management & Project Support Services Task 2 - Information Security Governance and Training Strategic Support Task 3 - OIT Research & Strategic Planning Support Task 4 - OIT Communications Services

The NAICS code and Acquisition Planning Forecast System (APFS) number of the expected award are 541519 and F2024066241, respectively. The 541519 NAICS code comprises establishments that are primarily engaged in providing computer related services with the exception of custom programming, systems integration design, and facilities management services. This NAICS code varies from the previous procurements as the anticipated award will not include any integration services. Since the 541512 NAICS code comprises establishments that are primarily engaged in planning and designing computer systems that integrate computer hardware, software, and communication technologies, the NAICS code needed to be changed since 541519 most accurately represents the requirement now.

2) Market Research

The CPSS task order is a recompete of the existing task order 70SBUR22F00000023 and contract 70SBUR23C00000005, which both expire on 02/15/2025. The contractor for the P3CT I task order 70SBUR22F00000023, Aretec Inc., has graduated from the 8(a) program and is no longer a viable candidate for 8(a) set-aside. The new consolidated task order will be competed using an 8(a) vehicle with 8(a) participants.

The consolidation of the 2 (two) actions will provide various benefits, as it will only require 1 (one) Federal Program Manager, 1 (one) Contractor Program Manager, the ability to scale resources, and it will streamline the required services.

The original contracts were used to help in the determination of necessary reorganization of ISD to align with DHS, USCIS, and OIT missions. Now that the need of reorganization has been identified, consolidation would be a more effective and efficient use of both federal staff and funding.

Prior task order awards for this requirement have been set-aside to 8(a) participants, so market research focused on vehicles in which 8(a) vendors would be capable to meet the government’s requirement. Based on the results of the market research, CPSS will be set-aside for 8(a) contractors under the mandatory for use Strategic Sourcing Contract vehicle 8(a) STARS III GWAC. It was determined that there are numerous capable vendors on 8(a) STARS III, and the CIO-SP3 Small Business 8(a) track. Although, the CIO-SP 3 Small Business 8(a) track has recently been extended through 04/29/2025; the 8(a) STARS III provides access to over 1097 vendors, while the CIO-SP3 Small Business 8(a) track includes only 124 vendors. Based on the above and to ensure a robust competition in addition to receiving cost savings by utilizing the mandatory for use 8(a) STARS III vehicle; 8(a) STARS III vehicle was selected. 8(a) STARS III vehicle has pre-vetted contractors with pre-established maximum labor hour ceiling rates that apply exclusively to time and materials (T&M) and labor hour (LH) orders.

3) Contracting Alternatives

Alternative contracting approaches would involve re-competing the two (2) efforts separately and awarding and administering two (2) separate task orders or contracts. This alternative would not support USCIS’s efforts to streamline management of two distinct task orders or contracts providing similar program support. A consolidated task order will allow USCIS the ability to manage, more efficiently, its contractor support for related services.

The previous contractor for P3CT I (Aretec, Inc.) outgrew 8(a) status, and a direct award was issued to an 8(a) joint venture (Aretec SBD, LLC), of which Aretec, Inc. is a managing member.

The second contract was of the same scope of work but could not be added under the previous contract in accordance with FAR 19.805-1(a)(2) as the total value of the contract, including options, would have exceeded $4.5 million. Work under both contracts is of the same scope; the only difference is that the second contract provided two additional FTE resources. Combining both contracts will allow for oversight of similar workload by less program and project management. This will also allow the program to expand and assist in cross-division Program and Project Management and Strategy Operations thereby meeting the acquisition objectives of the ISD. There is increased risk in having two separate contracts with separate program management, not only for response time, but also in implementation, transition, and expanding and streamlining services across the entire division post reorganization.

A direct award cannot be issued again to either of the incumbents, as Aretec, Inc. has graduated from the 8(a) program and is now considered other than small business. Additionally, the adaptation of the requirement to meet current ISD needs exceeds the sole-source dollar threshold cap for 8(a) directed task orders.

4) Coordination with Component Small Business Specialist and Office of Small and Disadvantaged Business Utilization (OSDBU)

The proposed consolidation of these requirements and this Determination and Findings has been coordinated with the USCIS Small Business Specialist (SBS) and the Office of Small and Disadvantaged Business Utilization (OSDBU).

5) Negative Impacts to Small Business Participation

There are no known negative impacts to small business concerns with the acquisition strategy. In fact, the consolidation will bring a positive impact and provide more opportunities for 8(a) small businesses. The consolidated requirement is being conducted in accordance with Management Directive 060-01, “Development and Use of Strategic Sourcing Contract Vehicles.” DHS strategic sourcing contract vehicles are mandatory for use by DHS and its components, with limited exceptions.

8(a) STARS III GWAC’s pool is comprised of 100% 8(a) Small Businesses. As both Aretec, Inc.

and Aretec SBD, LLC have exited the 8(a) program, this consolidated requirement, which also includes new work, would now be available for eligible 8(a) contractors under STARS III to compete for the requirement. This strategy maximizes small business participation and increases competition.

Government will not pay the same services twice since both P3CT contracts are ending in February 2025, and the anticipated award date for this new task order is December 2024. A transition period is needed for contractors to go through the suitability/EOD process. In addition, the COR will monitor the contractors to ensure there are no duplicative efforts during the phased transition. The period of performance of the proposed consolidated requirement is a twelve-month base period with two (2) consecutive twelve (12) month Option Periods.

6) Benefits

Consolidation of these efforts will result in both quantifiable and non-quantifiable benefits.

USCIS currently has two (2) related contractors who pose an absorbable but minimal risk to contract performance. A competition of each contract would yield much greater operational and

In addition, by streamlining the number of task orders, the time allotted for transition and the security clearance process will be greatly reduced due to only having one awardee and less time will be spent on transition, a potentially steep learning curve and the overall Entry on Duty (EOD) process due to efficiencies of onboarding one contractor awardee rather than multiple contractors under separate task order which means more time will be available to focus on the mission needs of USCIS.

Reduction in acquisition cycle times based on the ability of the program office and the contracting office to manage one task order rather than manage separate task orders.

Consolidation will help streamline the acquisition cycle by reducing coordination efforts in preparing separate procurement request packages, possibly reducing the need for multiple COs or the need for numerous CORs managing multiple task orders. This will allow for better coordination of time and managing of workloads that will help to accelerate the acquisition lifecycles of many contracting office and program office procurements.

Compare Anticipated Benefits Based on the tasks included in the two current actions, not the new optional CLINS on the new task order, the two current tasks were evaluated for quantifiable cost savings. In establishing a consolidated task order, USCIS will be able to leverage its buying power through competition.

Competition achieved in response to an order solicitation under FAR 16.505 is expected to yield a better task order price. Normally, effective price competition results in realistic pricing, and a firm-fixed price (FFP) contract is ordinarily in the Government’s best interest. This contract type was utilized for the previous procurements and will apply to the anticipated STARS III order. By consolidating, USCIS expects to achieve greater cost savings due to a smaller contractor overhead; these cost savings help to ensure the government is receiving the best price when meeting agency needs.

Additional benefits: Critical to Agency’s Mission Success:

The estimated order value is , this includes a significant portion of new work.

The Independent Government Cost Estimate reflects the delta between the scope proposed for consolidation and new work, inclusive of options. The combined value of the work under this consolidation of current contracts is , combining the contracts will allow for a savings of . Therefore, the anticipated quantifiable benefits are considered substantial because they are 10% or more of the value.

In addition to the quantifiable expected benefits under this consolidation meeting the threshold to be considered substantial benefits, these benefits and others identified herein are critical to USCIS/OIT/ISD mission success. ISD is undergoing reorganization, and after reviewing operations, ISD determined a more efficient and effective use of federal staff and funding would be to include all tasks with several more requirements, and new optional tasks, in one award.

Also, this procurement strategy provides for maximum practicable participation by small business and will contribute to USCIS and DHS small disadvantage business (SDB) goals since the consolidated requirement will be set-aside for 8(a) small business concerns.