1_5_1 Limited Source Justificaiton FAR 8.405-6 PCard.pdf

Limited-Sources Justification, Exceeding the SAT, Automated Purchase Card Approval System Justification Log Number: -

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 FAR 8.405-6(a), the circumstance that justifies limiting sources to fewer than those required by FAR 8.405-1 and 8.405-2 is:

FAR 8.405-6 (a)(1)(i)(A) An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

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.

FAR 8.405-6 (a)(1)(i)(C) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

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 can acquire FM solutions and services from commercial vendors through GSA MAS vehicles using the FM QSMO Special Item Number (SIN) 518210FM.

Essential features include:

• 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

Limited-Sources Justification, Exceeding the SAT, Automated Purchase Card Approval System Justification Log Number: -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.

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 two resellers: Paperless Innovations Inc. (small business) and CarahSoft Technologies Corp (large business).

Paperless is the only vendor that is FedRAMP certified (as of February 2024) in addition to already being utilized by DHS- Immigrations and Customs Enforcement (ICE). As a result, this will allow USCIS to obtain Authority to Operate (ATO) more efficiently and utilizing fewer resources.

USCIS intends to comply with the OMB directive and QSMO requirements and acquire a product that is recommended on the Financial Management marketplace. USCIS has not identified any other product that can meet the requirements and is better than the one recommended on the QSMO marketplace.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

The contracting officer determines that the anticipated prices will be fair and reasonable based on the review of the GSA Advantage SIN 518210FM, contract number 47QTCA24D002X, as GSA has established the prices fair and reasonable.

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.

Federal Supply Schedules, existing IAA, and RFIs were researched during the market research process. Two RFIs were issued, the first on March 22, 2023 with seven (7) responses and the second August 28, 2023 which received five (5) responses. The only response that was capable of meeting the essential features listed above was Paperless Innovations.

The Department of Treasury Federal agency customers can acquire FM solutions and services from commercial vendors through the General Services Administration (GSA) Multiple Award Schedule (MAS) government-wide contract vehicle using the FM QSMO Special Item Number (SIN) 518210FM. The MAS was reviewed and Paperless was found to be on the schedule.