1.5.1_6.103_Other_Than_Full_and_Open_Competition_CHEVO.draft_Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

J&A-26-0186

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Overhaul in accordance with the requirements of FAR 6.103.

The justification is based on the following facts and rationale required under FAR Overhaul 6.103-2 as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security, U.S. Immigration and Customs Enforcement, Office of Acquisitions Management, proposes to enter a contract on behalf of the Office of Administration on a basis of other than full and open competition.

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

(a) Type of action: Labor Hour

(b) Amount of the current J&A:

(c) Brief Description: The government intends to award a contract on an other than full and open competition basis to obtain Business Processes Improvement and Program Management Support Services in support of the Homeland Security Investigation’s Office of the Executive Associate Director and the Office of Administrative Operations.

CHEVO Consulting LLC 2275 Research Blvd

Suite 100 Rockville, MD 20850

Note: If the products or services under the justification were previously awarded under another contract, also provide the period of performance end date for that contract(s).

Current contract (70CMSD20FR0000218) was extended 90 days extension ends on 6/27/26

(e) Type of funding : OB3 funding

(f) Year of funding: 2026.

Period POP Price Base Year 6/29/2026 -12/28/2026

CAF FEE

.015%

Per contract total $

TOTAL

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

(g) Solicitation Number: RFQ 2.3.1

(h) Background information about the requirement :

HSI requires continued services for administrative operations and management support.

3. Description of Supplies/Services.

The requirement provides mission-essential program management support, administrative communication services necessary to support operations nationwide, including but not limited to:

• Improve and maintain a communications plan for the program

• Develop program placemats and narrative for internal and external stakeholders

• Assist in drafting, compiling and facilitating completion of presentations, HSI Front briefing documents

• Critical follow-up with key stakeholders to ensure there is consistent communication, coordination, and cooperation between all senior level HSI employees

• Crucial development of tools that create, produce, and aggregate data from multiple financial systems using Microsoft Office Suite or other applicable software

• Continued development of financial models for cost estimates and “what if” analysis to support resource requirement decisions.

These services are required on a continuous, uninterrupted basis to prevent degradation of enforcement and investigative operations:

4. Identification of statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. §3304 as implemented by:

☒ 6.103-2: Unusual and compelling urgency.

This requirement does not facilitate response to a natural disaster; however, it directly supports urgent national immigration enforcement and homeland security operations.

The Government intends to limit the period of performance consistent with FAR 6.103-2(2) and applicable DHS limitations.

5. Demonstration that the nature of the acquisition requires use of the authority cited.

The Government’s need for the services described in the PWS is unusual and compelling that conducting full and open competition would result in unacceptable delays and serious injury to the Government’s mission.

Background and Events Creating Urgency

The government’s operational environment has experienced a significant and immediate increase in workload, complexity, and enforcement priorities driven by:

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

• Executive-level direction emphasizing heightened immigration enforcement o Executive Order 14159 – Protecting the American People Against Invasion o Executive Order 14160 – Protecting the Meaning and Value of American

Citizenship

• Increased Presidential oversight, taskings, reporting and briefings

• Expanded requirements for real-time intelligence, data analytics, and rapid operational response

These conditions require immediate continuity of advanced analytical services to avoid operational gaps.

Why the Urgency Is Not the Result of Poor Planning

The urgency driving this procurement is not the result of a lack of advance planning by ICE or the Contracting Office; rather, it is a direct consequence of uncontrollable events. The unforeseen DHS partial shutdown halted the acquisition process during a critical phase, creating an unavoidable and significant gap in the timeline. Following the shutdown, the sudden acceleration in immigration enforcement activity mandated by evolving policy decisions further strained the remaining time. The combined impact of the lost time due to the shutdown and the urgent, expanded scale of the mission has created an environment where the administrative lead time required for a full and open competition would cause unacceptable harm to the Government’s ability to execute its core mission

Impact if Approval Is Not Granted

Absent approval of this justification:

• The government would experience a disruption in screening, vetting, and analytical support

• Investigative leads and enforcement actions would be delayed or lost

• The government’s ability to identify and disrupt transnational criminal organizations exploiting immigration systems would be materially degraded

• The government would incur unacceptable risks to homeland security and public safety

Accordingly, limiting competition is essential to prevent this degradation. The immediate performance of these services is a prerequisite for mission continuity, and any delay inherent in a full and open competition would represent an unacceptable failure to protect the national interest.

6. Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

The government conducted market research in compliance with FAR Overhaul Part 10.

While multiple vendors may possess general analytical capabilities, conducting a full and open competition at this time would delay award beyond mission-acceptable timelines.

☒ Request that OAQ make this justification publicly available pursuant to FRO 6.301 on Sam.gov 14 days after the award.

7. 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 discount offered to ICE and in comparison to the price charged for the same services. In accordance with the FRO 15.404-1(a)(2) the provided quote was compared with historical prices and in accordance with RFO 15.404-1(b)(5), the government compared the proposed price to the IGCE.

8. Description of market research.

Market research confirms the availability of vendors capable of performing similar work;

however, time constraints associated with the current mission urgency preclude conducting competitive acquisition without unacceptable delay.

9. Any other facts supporting the use of other than full and open competition.

Recent Executive Orders addressing immigration enforcement, border security, interior enforcement, and screening and vetting priorities have directly increased ICE’s operational workload and urgency. These Executive Orders require Federal agencies to:

• Expand immigration enforcement efforts

• Increase identification, screening, and removal of individuals violating immigration laws

• Enhance data-driven decision-making and operational responsiveness

While Executive Orders do not independently justify limiting competition, they constitute external mission drivers that materially affect urgency, acceptable risk, and timelines. The Government cannot tolerate delays associated with a full competitive procurement without jeopardizing the government’s ability to execute these directives effectively.

10. A listing of the sources, if any that expressed, in writing, an interest in the acquisition.

The government intends to reassess acquisition strategies and pursue full and open competition when mission conditions stabilize, and sufficient time exists to conduct competitive procurement without adverse mission impact.

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for supplies or services required.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

This government intends to limit the use of other than full and open competition to the minimum period necessary to address the current unusual and compelling urgency. As mission conditions stabilize the government will conduct additional market research, reassess technical and performance requirements, and develop an acquisition strategy that provides sufficient time to pursue full and open competition for any subsequent acquisition of these services, without compromising continuity of critical immigration enforcement operations.

12. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Contracting Officer Date

13. Technical/Requirements Personnel Certification.

I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Technical Representative/COR Date