1.5.1_LSJ_Cloud Services Bridge BPA_Redacted.pdf

U.S. Department of Homeland Security Sole Source Justification (SSJ) Federal Emergency Management Agency (FEMA) February 2026

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Sole Source Justification (SSJ) For orders or BPAs exceeding the Simplified Acquisition Threshold

SSJ No.: 26-058

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.1

Pursuant to the Federal Acquisition Regulations (FAR) 8.4, FAR Class Deviation 25-20 and in accordance with the requirements of RFO 8.4, the justification for the use of the authority under GSAM 538.7104-3 is justified by the following facts and rationale required under RFO 8.4 and

HSAM 3008.401-71.

1. Identification of the agency, contracting activity, and specific identification of the document as a “Sole Source Justification.”

The Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA), Office of the Chief Information Officer (OCIO) proposes to award a BPA pursuant to HSAM 3008.401-71, Sole source justifications, and GSAM 538.7104-3, Sole source justifications.

2. Nature of the action being approved (Contractor name, contract type, and total estimated value with options).

(a) Nature of action: FEMA intends to procure, on a sole source basis, a one-year continuation bridge Blanket Purchase Agreement (BPA) for cloud reseller (brokerage) services. This bridge BPA will support the ongoing migration and management of existing systems and data in a cloud environment, with the goal of enhancing cybersecurity, service scalability, service flexibility, data integration, and cost efficiency.

OCIO has previously migrated systems and data to Amazon Web Services (AWS) and Microsoft Azure, representing a significant government investment. Therefore, it is essential that this bridge BPA for cloud reseller services includes both AWS and Azure as minimum requirements. While the BPA may also include additional cloud service providers, AWS and Azure must be available as options to ensure continuity of operations during the bridge period.

1 In this document, citations to RFO Part 6, RFO Part 8, RFO Part 25, and HSAR Part 3006 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-20 for FAR Part 8, FAR Class Deviation 26-09, Revision 1, for FAR Part 25, and Homeland Security Acquisition Regulation (HSAR) Class Deviation 25-01 for HSAR Part 3006, 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.

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• Real or near-real time verification of every applicant’s identity, and an automatic referral mechanism for those applicants whose identity cannot be verified.

• Automated system-to-system updating or new/changed applicant information.

• The capability for a minimum of 500,000 simultaneous reviews by applicants to check the progress/status of their applications.

In the current configuration, DA.GOV is dependent on specific Service Oriented Architecture (SOA) services. The system cannot operate without these services without substantial code change. Amazon Web Services was the only Cloud Service Provider (CSP) that offered these services in-house as opposed to relying on potentially difficult to integrate or unreliable third-party add-ons. At this time, AWS is the only CSP that is compatible with DA.GOV.

Microsoft Azure FEMA requires provision of a variety of computing services-including servers, storage, databases, networking, software, analytics, and intelligence-for flexible resources and economies of scale. Most critically the use of Microsoft Azure will enable full integration with Office 365 and Active directory that is important for coordination and integration of data and information across the Agency. The Office 365 products are already broadly deployed across FEMA with significant amount of data in Microsoft SharePoint, Excel, and other products.

Therefore, it is critical that AWS and Azure be provided by the cloud reseller that is ultimately chosen for the BPA. Other options will exist on the BPA, but AWS and Azure must be a provided option.

4. The statutory exception and supporting rationale (see GSAM 538.7104-3(b)(1))) and if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

Select one of the circumstances justifying sole source pursuant to GSAM 538.7104-3(b)(1) below and provide supporting rationale.

GSAM 538.7104-3(b)(1)(iii) The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.

This acquisition is being conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies, in accordance with HSAM 3008.401-71, Sole source justifications, and GSAM 538.7104-3, Sole source justifications. An award will be made in the interest of economy and efficiency as a logical follow-on to an original Federal Supply Schedule

SSJ Template > SAT 2- 4 - SSJ No: XX-XXX order # 47QTCA18D002F pursuant to GSAM 538.7104-3(b)(1)(iii). The original award was competitively solicited and awarded using the ordering procedures at RFO 8.4. It is necessary to limit competition for the new work described herein as a logical follow-on because FEMA requires a one-year continuation bridge BPA to ensure there is no disruption in critical cloud reseller services. The current performance period ends on 03/29/2026, and there is not enough time to conduct a full and open competitive solicitation before this date. While FEMA had planned to transition to a DHS Cloud vehicle, it has been determined that the DHS Cloud vehicle will not be awarded in time to meet our operational needs. The bridge BPA will provide uninterrupted access to Amazon Web Services (AWS) and Microsoft Azure, which are essential for maintaining the agency’s cloud infrastructure and supporting ongoing operations. Any lapse or delay in service would risk significant operational impacts, including potential interruptions to cybersecurity protections, data integration, and service scalability. Therefore, this bridge BPA is essential to maintain continuity of services while FEMA completes the competitive acquisition process for a long-term solution. This approach is in the best interest of the government and supports FEMA’s mission by ensuring the reliability and stability of its cloud environment during the transition period.

5. FEMA intends to post this justification on SAM.gov pursuant to GSAM 538.7104-3(b)(3)(ii).

6. 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

7. 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

APPROVAL:

Contracting Officer

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Note: The Contracting Officer is the final approving official when the action does not exceed $900K.

Procuring Activity Advocate for Competition

Note: The Procuring Activity Advocate for Competition (PAAC) is the final approving official when the action exceeds $900K but is less than or equal to $20M.

Approval by the PAAC is not required if the J&A is reviewed and approved by an official designated by the Component who is a member of the armed services at the general or flag officer level or a civilian in a grade above the GS-15 (or equivalent) level. However, this exception does not apply to justifications citing that cite RFO 6.103-2 Unusual and Compelling Urgency as the authority.

Head of Contracting Activity

Note: The HCA is the approving official when the action exceeds $20M but is less than or equal to $90M (less than or equal to $150M for USCG). The HCA is not required to approve the justification if the Component PAAC is a member of the armed services at the general or flag officer level or is a civilian in a grade above the GS-15 (or equivalent) level. HCA may also delegate approval to a member of the armed services at the general or flag officer level or a civilian in a grade above the GS-15 or equivalent level. However, this exception does not apply to justifications that cite RFO 6.103-2 Unusual and Compelling Urgency as the authority per HSAR 3006.104-270 (HSAR Class Deviation 25-01).