1.5.1-SSJ Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

SOLE SOURCE JUSTIFICATION: SIMPLIFIED PROCEDURES FOR CERTAIN

COMMERCIAL ITEMS EXCEEDING SAT, INCLUDING BRAND NAME

J&A-25-0034

In accordance with the procedures of FAR Subpart 13.5, using the statutory authority of 41 USC 1901, and consistent with the content requirements of FAR 6.303-2, this justification is based on the following facts and rationale:

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Immigration and Customs Enforcement (ICE), Office of Acquisition Management (OAQ), on behalf of Office of the Chief Financial Officer (OCFO), Office of Financial Management (OFM), proposes to enter into a contract on a basis other than full and open competition. As authorized under 41 U.S.C. § 3304(a)(1), this Sole Source Justification (SSJ) justifies “One Responsible Source”, to meet the OCFO/OFM requirements from FileOnQ.

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

(a) Type of action: Firm-Fixed Price Contract

(b) Amount the current J&A is justifying: $5,767,258.00

Brief Description: ICE intends to procure, on a sole source basis, commercial software licenses, maintenance, technical support and enhancements services from the following company:

FileOnQ, INC 832 Industry Drive Tukwila WA 98188

PH: 206-575-3488/800-603-6802

Fax: 206-575-3927

3. Description of Supplies/Services. Describe the supplies or services to be acquired.

Provide the estimated total value (including options, if any).

The scope of this acquisition is to provide records management software application. These commercial services are required to facilitate the OFM in providing payment processing and other financial services to its DHS customer components. The total value of this Contract inclusive of options is $5,767,258.00

Period Time Total Base 12 mos. $1,086,290.00 Option Year 1 12 mos. $1,118,878.00 Option Year 2 12 mos. $1,152,444.00 Option Year 3 12 mos. $1,187,018.00 Option Year 4 12 mos. $1,222,628.00

Total Cost $5,767,258.00

SOLE SOURCE JUSTIFICATION: SIMPLIFIED PROCEDURES FOR CERTAIN

COMMERCIAL ITEMS EXCEEDING SAT, INCLUDING BRAND NAME

4. Identification of the authority.

This action is being taken under the authority of Simplified Procedures for Commercial Items, 41 U.S.C. 1901 as implemented by FAR 13.501 and exempted from the requirements in FAR Part 6.

5. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

FileOnQ is the sole authorized provider of its proprietary software, and no alternative sources are available to DHS for procurement. Acquiring a different software solution would minimize efficiency and economy and increase the burden and administrative costs significantly to the Government (higher cost and operational disruptions) for several reasons:

Substantial Upfront Investment - Transitioning to a new software or hardware platform would require a considerable initial financial outlay, including licensing fees, infrastructure upgrades, and potential customization to meet DHS’s needs.

Extensive Employee Training - With a workforce of over 2,400 employees, adopting a new system would necessitate comprehensive training programs. This would require additional expenditures for instructional resources, trainer facilitation, and dedicated time for staff to gain proficiency, thereby impacting normal business operations.

System Compatibility and Integration Challenges - A new software solution may not seamlessly integrate with DHS’s existing systems; Cost Management Module (CMM), Invoice Processing Platform (IPP), and Federal Financial Management System (FFMS), potentially requiring costly modifications, middleware solutions, or third-party services to achieve interoperability. These efforts would further extend the transition period and increase overall expenditures.

o FileOnQ facilitates invoice processing, updates, approvals and certifying prior to interfacing with FFMS: FFMS is the payment processing system of record for Intra-Governmental Payment and Collection (IPAC) and vendor invoices.

FileOnQ is designed to facilitate the invoicing process and eliminate redundant manual functions.

o IPP: Is a Treasury-mandated vendor invoicing process system. The IPP project was initiated in 2022 and integrated into FileOnQ and FFMS in December 2024. The interface between FileOnQ and FFMS is required to reduce data entry errors and overall processing costs by eliminating redundant manual functions when entering invoice data from FileOnQ into

FFMS.

o The upcoming initiative scheduled for implementation in June 2025 is the CMM. CMM will replace the Office of Financial Management system, ICE Financial Analytics System (IFAS), currently in the development phase by FileOnQ. CMM will consist of four separate FileOnQ applications, each operating as a stand-alone database within the existing FileOnQ system. The databases are:

Transactional: Captures transactional records from the financial system to determine costs for specific types of work, such as invoice processing, bond processing, and card transactions.

SOLE SOURCE JUSTIFICATION: SIMPLIFIED PROCEDURES FOR CERTAIN

COMMERCIAL ITEMS EXCEEDING SAT, INCLUDING BRAND NAME

Payroll: Captures payroll-related data from the financial system to calculate costs for OFM employee activities.

Contracts: Captures contract-related costs incurred by OFM.

Reporting: Consolidates data from all other CMM applications for reporting and analysis purposes.

Operational Disruptions and Productivity Loss - The transition to a new system would lead to temporary declines in processing efficiency as employees adapt to the changes. This adjustment period could negatively impact critical financial operations, such as vendor invoice processing and IPAC bills, potentially delaying payments and affecting supply relationships and DHS Components critical operations, such as ICE, CISA, FPS, MGMT, USCIS, and S&T

Given these considerations, procuring FileOnQ software solution on a sole-source basis would maximize efficiency and economy and minimize the burden and administrative cost to the Government. It would also be the most cost-effective and operationally viable approach to maintaining continuity, efficiency, and financial stewardship within our organization.

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

☐ OAQ has made

☒ OAQ intends to make this justification publicly available pursuant to FAR 13.501(a)(iii) and FAR 6.305(a) on SAM.gov on June 20, 2025.

☐ OAQ intends to make publicly available brand name justifications with the solicitation pursuant to FAR 13.501(a)(1)(iv) and 5.102(a)(6)

7. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has determined that issuing the Contract to FileOnQ for the software licenses, maintenance, technical support, and enhancements, represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs. This determination was based on historical pricing data of the most recent previous Contract, 70CTD020C00000003. Additionally, prior to issuance of the Contract, the ordering activity will consider the level of effort, and the mix of labor proposed to perform the specific task, in order to determine that the total price is reasonable. FileOnQ’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate (IGCE), which was based on historical pricing data of the most recent previous Contract cited above.

SOLE SOURCE JUSTIFICATION: SIMPLIFIED PROCEDURES FOR CERTAIN

COMMERCIAL ITEMS EXCEEDING SAT, INCLUDING BRAND NAME

8. Description of market research.

In accordance with FAR 10.002 market research was conducted by DHS’s technical representative in December 2024, to determine the availability of sources capable of fulfilling the Government’s requirement. The technical representative consulted various sources, to include existence of other contracts on DHS Marketplace and SAM.gov.

As part of the market research, other sources consulted were USASpending, and the Acquisition Gateway Procurement Pilot Searches conducted on these websites had no positive results. Additionally, based on an e-mail from FileOnQ, dated December 12, 2024, the vendor does not maintain a pool of authorized resellers and is not on any GSA contracts.

9. Any other facts supporting the justification.

Not applicable.

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

FileOnQ software is proprietary and not available via any other authorized reseller. The vendor affirmed that although their product is commercially available, they do not have any resellers and are not on any GSA contracts.

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.

For subsequent acquisitions, ICE will continue to monitor for potential changes to the requirement made by DHS or if the vendor approves authorized resellers, in an attempt to leverage competition. In addition, ICE is currently working towards moving to a new financial system in the future which will increase competition for these services.

12. DHS intends to post the requirement on SAM.gov pursuant to FAR 13.501(a)(1)(iii) and 6.305(a).

DHS intends to make this justification publicly available pursuant to FAR 13.501(a)(iii) and FAR 6.305(a) on SAM.gov on June 20, 2025.