1_5_1_FSS Sole Source and Brand Name JA Exceeding SAT_20260910_Redacted.pdf

www.uscis.gov

Rev: 06/10/2026

Federal Supply Schedule (FSS) Sole Source Justification, Exceeding the Simplified Acquisition Threshold, Automated Purchase Card Tool

REFERENCE: Justification Log Number: FY26-0145 and PR Number: CFO260022

1. Agency and Contracting Activity.

The Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to award an Order, on behalf of Office of the Chief Financial Officer, pursuant to RFO 8.401(b), General and RFO GSAM/R 538.7104-3, Sole source justifications and RFO GSAM/R 538.7104-4(b)(2)(ii), Items Peculiar to one manufacturer.1

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

The DHS, USCIS Office of Contracting intends to award a GSA Multiple Award Schedule task order pursuant to RFO GSAM/R 538.7104-3, Sole source justifications– for a Purchase Card (PCARD) management Commercial of the Shelf (COTS) system – Actus.

Pursuant to RFO GSAM/R 538.7104-3, restricting consideration to an item peculiar to one manufacturer (in this case Actus), even if available from more than one reseller, must be justified.

3. Description of Supplies/Services.

The Office of the Chief Financial Officer (OCFO) ensures sound stewardship of USCIS fiscal resources, delivers accurate and timely financial reporting, improves financial management processes, and strengthens enterprise risk management and internal control. The OCFO mission is to secure and protect our resources for DHS.

Over 300 government credit cards have been issued to authorized personnel within USCIS business units and program offices to procure goods for USCIS. OCFO is in charge of ensuring proper management of the government PCARDs on behalf of USCIS.

OCFO seeks to continue using Actus software, the FedRAMP-certified purchase card system on a Software as a Service (SaaS) basis that incorporates all necessary federal financial management policies that regulate PCARD transactions, safeguards for specific audit attributes that DHS and USCIS include in the monthly audits, and provides for the automated management of processes associated with PCARD purchases.

Essential features include:

1 In this document, citations to RFO Part 8, RFO Part 2, and RFO GSAM/R 538.71 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-20 for FAR Part 8 and RFO-2025-FSS-GSAR for FAR Part 8, which were issued as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

Federal Supply Schedule Sole Source Justification, Exceeding the SAT, Auto Purchase Card Tool Justification Log Number: FY26-0145

The system must be a COTS product that is provided to USCIS on a SaaS basis and is certified by the government-wide FedRAMP program.

The system shall provide USCIS/OCFO with automation of the agency’s Purchase Card program approvals process flow. In Addition to automated and paperless PCARD approval processing workflow, the system shall also possess customizable options that meet USCIS’s unique PCARD program needs.

The system shall efficiently manage costs, streamline audit requirements, and provide stakeholders with additional oversight over the program. The system will be used to assist with mitigating risks associated with the PCARD program, with the ultimate goal of increasing program oversight, increasing audit compliance rates, and providing a user-friendly forum.

During the execution of this task order, USCIS plans to transition to a new financial management system, SAP S4/HANA. When SAP is established, this system shall connect to SAP via the Application Programming Interface (API) to record PCARD purchase approvals and financial transactions. The timeline for SAP S4/HANA migration has not been solidified;

therefore, this requirement will be represented as an optional contract line item and will be exercised when the two systems are ready to interface. The system shall, however, interface and exchange data as frequently as required for uninterrupted business operations with the agency servicing bank (currently CitiManager) for transaction and user data.

4. Authority and supporting rationale.

This acquisition is conducted under the authority of Multiple-Award Schedule Program, 41 U.S.C.

152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies. Pursuant to RFO 8.401(b), General, RFO GSAM/R 538.7104-3(b), Sole source justifications and RFO GSAM/R 538.7104-4(b)(2)(ii), Items peculiar to one manufacturer, the circumstance that justifies limiting sources to fewer than those required by RFO GSAM/R 538-7103-3 is:

RFO GSAM/R 538.7104-3(b)(1)(i) The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need.

RFO GSAM/R 538.7104-3(b)(1)(ii) Only one source is capable of providing the products, services, or solutions required at the level of quality required because the products, services or solutions are unique or highly specialized.

RFO GSAM/R 538.7140-3(b)(1)(iii) The order should be issued on a sole source basis in the interest of economy and efficiency because it’s a logical follow-on to an FSS already issued on a competitive basis.

Rationale:

On April 26th, 2019, the Office of Management and Budget (OMB) issued memorandum M-19-16 titled Centralized Mission Support Capabilities for Federal Agencies establishing Quality Services Management Office (QSMO) under the Department of Treasury. The QSMO was authorized to establish inter-agency standards and priorities for shared services and create a marketplace for agencies to acquire tools and services for financial management (FM).

As a result, federal agency customers must acquire FM solutions and services from commercial vendors through GSA MAS vehicles using the FM QSMO Special Item Number (SIN) 518210FM and catalog.

A solicitation will be issued to the prequalified vendors on the GSA Advantage SIN 518210FM for the acquisition of licenses for a government PCARD management COTS system Actus. USCIS currently does not have a system for PCARD management and administers the program “manually”.

Actus is the only COTS product currently recommended by the Treasury QSMO marketplace as a pre-vetted, standard product for government PCARD management. In addition, market research conducted by the program office confirmed that Actus meets all USCIS business requirements. Other products, while largely available on the market, do not fully meet USCIS requirements or comply with government policies, specifically, auditability.

Furthermore, Actus is the only PCARD management COTS system available from a SaaS FedRAMP-certified cloud. USCIS OIT will not authorize the acquisition of a COTS product from a cloud provider unless it is FedRAMP-certified. Currently, Actus is the only product available from a FedRAMP-certified cloud and is offered by one small business vendor: Paperless Innovations Inc.

CarahSoft Technologies Corp (large business) was an authorized reseller in FY23 and FY24;

however, it is no longer listed as an authorized reseller for Actus in 2026.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with RFO GSAM/R 538.7102-2(b)(4) and as defined by

RFO 2.101.

Based on the market research updated in April 2026, the Contracting Officer anticipates at least one offer from GSA MAS SIN 518210FM vendors. GSA has established the prices for Actus software licenses. The price will be assessed for reasonableness by comparing the offered prices to the IGCE and published price lists. The contracting officer will request additional discounts/price reductions before award consistent with RFO GSAM/R 538.7102-2 (b)(4) and RFO GSAM/R538.7102-2 (c)(2).)

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.

USCIS conducted market research in accordance with RFO Part 10 and HSAM 3010 to determine whether schedule holders could meet the requirement for continued licenses and support for the OCFO Purchase Card Management System. The research included reviewing GSA Multiple Award Schedule offerings, including the Financial Management Quality Service Management Office Special Item Number 518210FM, available Government contract vehicles, acquisition history, input from knowledgeable Government personnel, and consultation with the Small Business Specialist.

The market research found that Actus is the only identified commercial product that meets USCIS requirements and that Paperless Innovations, Inc., contract number 47QTCA24D002X, is the only currently authorized schedule holder offering Actus through the applicable marketplace.

Although another reseller had previously offered Actus, it is no longer listed as an authorized reseller for this software, and no other schedule holder was identified that can provide the required FedRAMP-certified software-as-a-service solution while satisfying the applicable Financial Management Quality Service Management Office requirements. Based on these findings, USCIS determined that a sole source award to Paperless Innovations, Inc. is the appropriate acquisition approach for continued use, licensing, and support of the existing purchase card management system.

7. Any other facts supporting the sole source justification.

USCIS intends to comply with the OMB memorandum, select a product/software from the Department of Treasury's recommended standardized, pre-vetted, interoperable products list, and procure the product from pre-qualified vendors through the GSA MAS Program. This way, USCIS OCFO ensures compliance and interoperability. If USCIS were to choose a different product and acquisition path, per OMB directive, it would have to build a business case and seek approval from QSMO and OMB for a product not yet available on the QSMO marketplace.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for the supplies or services is made.

USCIS intends to comply with the OMB directive for financial management tools and services standardization and will not seek to purchase a different product. However, if QSMO approves additional products in the future, USCIS may evaluate other products available on the marketplace.

9. USCIS intends to post this requirement on the Government Point of Entry (GPE) pursuant to GSAM/R 538.7104-3(b)(3).

10. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Sole Source Justification, are accurate and complete.

Date

11. Contracting Officer Certification and Approval

Pursuant to RFO GSAM/R 538.7104-3, I certify that the Sole Source Justification is accurate and complete to the best of my knowledge and belief, and I determine that the circumstance identified in Section 4 applies.