Redacted_JEFO_0039.pdf
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- Solicitation number
- 11212025_NIH_NITAAC
About this file
This document is a Justification for an Exception to Fair Opportunity (JEFO) for a 6-month contract extension for the Information Technology Enterprise Support Services (ITESS) contract. The current contract with TCG, Inc. is set to expire on September 17, 2025, and the Administration for Children and Families (ACF) is requesting a 6-month extension through March 17, 2026, with a total funding requirement of approximately $5.3 million. The extension is necessary due to delays caused by the HHS Contract Departmental Efficiency Review, extended approval timelines involving Political Appointees, and staffing reductions at ACF Tech and NITAAC.
TCG, Inc. is proposed as the sole contractor for the extension based on its unique qualifications, including extensive institutional knowledge of ACF's systems, established relationships with stakeholders, and specialized expertise in the agency's IT environment. The extension will ensure continuity of critical IT support services, including solution delivery, systems architecture, budget management, Federal Information Technology Acquisition Reform Act (FITARA) compliance, and enterprise project management. The costs are based on existing contract rates for Option Year 4, with no increase in hourly labor rates, and the extension will allow ACF Tech sufficient time to complete the competitive procurement process for a follow-on contract.
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“Source Selection Information – see FAR 2.101 and 3.104”
1. Identification of the agency and contracting activity:
• Federal Agency and Contracting Activity
Agency: Administration for Children and Families (ACF) Office of the Chief Information Officer (OCIO) Department of Health and Human Services (HHS)
Contracting Activity:
Gregory D. Holliday, Contracting Officer National Institute of Health NIH Information Technology Acquisition and Assessment Center (NITAAC) 11545 Rockville Pike, Floor 10 Rockville, MD 20852 Cell – Greg Holliday: 301-339-3111 HollidaG@odepsm1.od.nih.gov
• Sponsoring Organization
Administration for Children and Families Office of the Chief Information Officer (OCIO)
• Contracting Officer’s Representative (COR) Information
Name: Tanzeena Shireena Aadam Organization: Administration for Children and Families, OCIO 330 C St SW, Room 3300, Washington DC 20201 Phone: 202-401-1312 Email: Tanzeena.Shireena@ACF.hhs.gov
2. Nature and/or Description of the Action Being Approved
• Acquisition Purpose and Objectives The current contract period of performance (POP) for HHSN316201200178W / 75N98120F00001 ends on September 17, 2025, requiring a recompete and solicitation for a new award. To allow sufficient time for completion of the new acquisition process, ACF Tech is requesting a 6-month extension of the existing contract. This extension will ensure uninterrupted delivery of critical IT support services from September 18, 2025, through March 17, 2026, with a total funding requirement of $ REDACTED
The need for this extension is driven by several factors, including the implementation of the HHS Contract Departmental Efficiency Review (DER), extended approval timelines involving ACF Political Appointees (PAA), and staffing reductions at both ACF Tech and NITAAC, which collectively delayed progress on the recompete effort.
Justification for an Exception to Fair Opportunity mailto:HollidaG@odepsm1.od.nih.gov mailto:Tanzeena.Shireena@ACF.hhs.gov
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Additionally, on January 21, 2025, the Acting Secretary of HHS issued a directive instructing all HHS Operating Divisions to pause most external correspondence and public communications. This applied agency-wide and included suspending the issuance of documents, notices, solicitations, and other external communications until reviewed and approved by a Presidential Appointee.
In response, Acquisition Alert 2025-02 (Acquisition Guidance on Acting Secretary Memo entitled, “Immediate Pause on Issuing Documents and Public Communications – ACTION”), issued by the Deputy Assistant Secretary for Acquisitions on January 24, 2025, provided acquisition-specific instructions. The alert required all acquisition workforce members to refrain from releasing solicitations, contract actions, GPC and OTA transactions, or engaging in any public vendor communications unless first cleared through the appropriate political channels. This policy remained in effect until rescinded and significantly impacted acquisition planning activities, including those related to this contract renewal.
Given these cumulative circumstances, the requested extension will provide the necessary time to complete the full acquisition lifecycle in accordance with policy and approval protocols while maintaining continuity of mission-critical IT services.
• Program Office Review & Affirmation
The costs for this extension are based on the existing contract rates for Option Year 4, which were previously determined to be fair and reasonable by the contracting office.
There is no increase in the hourly labor rates for this extension period. The total cost of $5,302,440.19 represents approximately half of the annual cost for Option Year 4 with the current FTEs, which is proportionate for a 6-month extension.
• Project Background
ACF Tech is responsible for the execution and governance of all computer and information resource management functions within ACF, advising the ACF Assistant Secretary and Deputy Assistant Secretary for Administration on IT resources and management necessary to support all IT systems and solutions. The ITESS contract provides essential IT support services across ACF Tech and ACF program offices, helping to maintain security standards and spanning functions such as solution delivery, systems architecture, budget, Federal Information Technology Acquisition Reform Act (FITARA), Capital Planning and Investment Control (CPIC) management, acquisition support, enterprise project management, and Agile methodology and tools support services. ITESS serves as the functional integrator necessary to successfully meet IT goals and execute them in support of ACF’s mission.
3. Description of the supplies or services required to meet the agency’s needs (including the estimated value).
• Project title
Information Technology Enterprise Support Services (ITESS)
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• Project description The task order under contract HHSN316201200178W 75N98120F00001 with TCG, Inc. has a base year, and four one-year option periods. Currently this task order is in the performance period of Option Period 4. The government requests a 6-month extension as it continues the process of developing a competitive follow-on procurement. Market research is being conducted to identify potential sources for the follow-on contract and actions will be taken to maximize competition for the follow-on contract.
• Provide the following information:
i. Requirement type:
Support services (non-research & development) Supplies/Services Information technology (IT) or Electronic and Information Technology
Construction Architect-engineer (A-E) Services Design-Build Research & Development (R&D) R&D Support Services Other (specify):
ii. Type of action:
New requirement Follow-on Other (specify): Extension of the existing contract
iii. Proposed contract/order type Firm-Fixed Price (FFP) Other Firm-Fixed-Price (Specify, e.g., fixed-price award-fee, fixed-price incentive-fee):
Cost-plus-fixed fee Other cost reimbursement (Specify, e.g., cost-plus-award-fee, cost-plus-incentive-fee Time and Materials (T&M) Labor Hours (LH) Indefinite Delivery (Specify whether indefinite quantity, definite quantity, or requirements)
iv. Acquisition identification number: HHSN316201200178W 75N98120F00001
• Total estimated dollar value
The total Independent Government Cost Estimate (IGCE), based on the increased level of effort for the Option Period 4 six-month extension, is $ REDACTED which represents approximately a REDACTED % increase from the current ultimate contract value of $ REDACTED. This increase brings the revised total estimated contract value to $ REDACTED, as shown in the table .
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The total funding required for the JEFO increase will ultimately depend on the new contract award date and any potential Transition-Out period. The government anticipates extending the current contract funding for one to three months, with the option to modify for an additional three months if necessary. An independent government cost estimate for a 6-month period due to this JEFO is attached.
CLIN Type 6-month Extension Funding Estimate
CLIN 4001 FFP REDACTED
CLIN 4013 T&M REDACTED
CLIN 4012 T&M REDACTED
4006/4007 ODC REDACTED
Total REDACTED
• Revised performance/delivery period
Performance Start Date - End Date Funded Value
Base Period 9/18/2020 - 9/17/2021 REDACTED Option Period 1 9/18/2021 - 9/17/2022 REDACTED Option Period 2 9/18/2022 - 9/17/2023 REDACTED Option Period 3 9/18/2023 - 9/17/2024 REDACTED Option Period 4 9/18/2024 - 9/17/2025 REDACTED Option Period 4 (6-month extension) 9/18/2025 - 03/17/2026 REDACTED Total REDACTED
4. Identification of the exception to fair opportunity (see 16.505(b)(2)). The supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited.
• Acquisition authority.
(A) The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.
(B) Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized [FAR Subpart 16.505(b)(2)(i)(B)].
(C) The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.
(D) It is necessary to place an order to satisfy a minimum guarantee.
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(E) For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.
• Demonstration of the proposed contractor(s) unique qualifications to provide the required supply or service.
i. Name of the proposed contractor(s).
TCG, Inc, 7348 Georgia Avenue NW Washington, DC 20012
ii. Nature of the acquisition and proposed contractor(s) unique qualifications.
TCG, Inc. is uniquely qualified to continue providing these services during the extension period for the following reasons:
1. Institutional Knowledge: TCG has been the incumbent contractor for the ITESS contract since September 2020. Their team possesses extensive institutional knowledge of ACF's systems, processes, and security requirements that would be impossible to replicate with a new contractor without significant disruption to operations.
2. Continuity of Operations: The extension will ensure uninterrupted support for critical IT services while ACF completes the competitive procurement process for the follow-on contract. Any gap in service or onboarding of a new vendor would severely impact ACF's ability to fulfill its mission and may cause a delay of 2 to 4 months, as a new vendor would require onboarding, system familiarization, and stakeholder alignment.
3. Specialized Expertise: TCG has developed specialized expertise in ACF's unique IT environment, including the various systems and applications used to deliver the services and support provided by the Program Offices. These include the suite of data tools (Tableau, Smartsheet, Qualtrics, Smarty, and NVivo) and Agile tools that are critical to the successful continuation of the agile transformation in progress within ACF.
Transitioning to a new vendor would likely result in duplicative training and knowledge transfer costs and introduce risk to ongoing efforts.
4. Established Relationships: TCG has established effective working relationships with ACF staff and stakeholders, which facilitates efficient communication and problem-solving. A new vendor would require months to build the same level of trust and collaboration, potentially slowing project execution and decision-making.
5. Proven Performance: TCG’s familiarity with ACF’s internal operations, systems, and program requirements positions them to provide a seamless and efficient continuation of services with minimal transition risk. This continuity is critical to maintaining operational stability during the extension period.
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6. Impact of Award to Another Vendor: Awarding this requirement to a new vendor at this time would result in significant operational delays and increased costs. The onboarding process for a new vendor, including security clearances, access provisioning, and system training, is estimated to take up to 120 business days. This would delay support for mission-critical initiatives and potentially duplicate costs associated with overlap, retraining, and re-establishing workflows. Additionally, the risk of misalignment or disruption during this transitional period could negatively affect service quality, operational continuity, and stakeholder satisfaction.
5. Determination by the ordering activity Contracting Officer that the anticipated cost to be fair and reasonable.
The costs for this extension are based on the existing contract rates for Option Year 4, which were previously determined to be fair and reasonable by the contracting office.
There is no increase in the hourly labor rates for this extension period. The total cost of $5,302,440.19 represents approximately half of the annual cost for Option Year 4 with the current FTEs. The estimated hours are based on historical data which has been used to forecast consistently over the course of the period of performance. Based on the information presented in this document there is no indication that the price will not be fair and reasonable to the Government. A final determination will be conducted prior to award of the modification to this task order. A modification will only be awarded if it is shown that the quoted price to the Government is fair and reasonable.
6. Any other facts supporting the justification.
A six-month extension is required to:
Prevent a gap in critical IT support services Allow sufficient time to complete the competitive procurement process Ensure a smooth transition to any new contractor Maintain support for ACF's mission-critical systems and applications Provided timely analysis, management, and CPIC reporting for the $233M OCIO
IT portfolio.
7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.
This request is for a one-time, 6-month extension to ensure continuity of services while ACF Tech completes the competitive procurement process. The extension period is sufficient and appropriate, as ACF Tech is on schedule to complete the key acquisition milestones required for award within this timeframe. Specifically, the additional time allows for:
Finalizing and issuing the solicitation Conducting a thorough evaluation of proposals Making a timely contract award Allowing for a transition period, if a new vendor is selected
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ACF Tech has already initiated key pre-solicitation activities, including acquisition planning and internal coordination. The 6-month extension ensures that the remaining phases—solicitation, evaluation, award, and transition—can be completed without disruption to services and in accordance with federal acquisition regulations and internal review procedures.
8. Program office certification.
This is to certify that the portions of this justification that have been developed by the undersigned program office personnel, including supporting information and/or data verifying the Government’s minimum needs, schedule requirements and other rationale for other than full and open competition, are accurate and complete.
Official Name & Title Signature Date Project Officer Tanzeena Aadam
Head of the Sponsoring Program Office
Robin R. Collins Chief Information Officer ACF Tech
9. Contracting Officer certification.
This is to certify that the justification for the proposed acquisition has been reviewed and that to the best of my knowledge and belief the information and/or data provided to support the rationale and recommendation for approval is accurate and complete.
Official Name & Title Signature Date
Contracting Officer
Gregory Holliday
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10. Chief of the Contracting Office and Head of the Contracting Activity signature(s).
Official Name & Title Signature Date Chief of the Contracting Office
Ricky Clark Director, NITAAC
Head of the Contracting Activity (HCA)
"for" Olga Acosta Director, Office of Acquisition and Logistics Management
TIFFANY D. Digitally sig
D. CHADW
CHADWICK -S Date: 2025 -04'00' ed by TIFFANY
CK -S
08.08 15:24:17
11. Competition Advocate signature.
Official Name & Title Signature Date Competition Advocate
Dr. Kathryn Partin, Director of Research Integrity, National Institutes of Health
Digitally Kathryn M. Kathryn
S Partin -S Date: 2
10:43:2 signed by M. Partin -
25.08.10 -04'00'
| 1. Identification of the agency and contracting activity: |
| Contracting Activity: |
| • Sponsoring Organization |
| 2. Nature and/or Description of the Action Being Approved |
| • Program Office Review & Affirmation |
| • Project Background |
| 3. Description of the supplies or services required to meet the agency’s needs (including the estimated value). |
| • Project description |
| • Provide the following information: |
| ii. Type of action: |
| iii. Proposed contract/order type |
| • Total estimated dollar value |
| • Demonstration of the proposed contractor(s) unique qualifications to provide the required supply or service. |
| ii. Nature of the acquisition and proposed contractor(s) unique qualifications. |
| 5. Determination by the ordering activity Contracting Officer that the anticipated cost to be fair and reasonable. |
| 6. Any other facts supporting the justification. |
| 7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made. |
| 8. Program office certification. |
| 9. Contracting Officer certification. |
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