F03_JA_-_LSJ_ACF_OCS_LIHEAP-ADDENDUM__REDACTED_for_POSTING_Redacted_2.pdf

ADDENDUM

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C 501

CONTRACT / TASK ORDER # 47QRAA25D004K / 140D0425F0832

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This document serves as an Addendum to the Limited-Sources Justification for the Department of Health and Human Services (HHS), Administration for Children and Families (ACF), Office of Community Services’ (OCS) Low Income Home Energy Assistance Program (LIHEAP) Support Services requirement approved on August 14, 2025 (reference: Solicitation # 140D0425Q0574) resulting in a bridge task order award (reference: Task Order # 140D0425F0832). The contracting activity is the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division 1, Branch 3 on behalf of the HHS, ACF, OCS.

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

HHS, ACF, OCS requires continuation of mission critical LIHEAP support for up to six months beyond the expiration on March 2, 2026 of the six-month base period for the current bridge. This requires modification to the bridge to increase scope as well as the level of effort and add option periods to allow for extension of the order for up to six additional months to ensure continuation of critical LIHEAP operations until a follow-on task order can be awarded.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The scope of this effort is to provide the services to maintain and enhance the LIHEAP Clearinghouse and Performance Management Website; assist with the annual calculation of the LIHEAP 1984 funding formula allocation by using the most recent available data and methodology; manage the National Energy Assistance Referral (NEAR) Phone Hotline/call center, Interactive Voice Response (IVR) and email service; provide training and ad hoc LIHEAP related assistance to internal OCS federal staff and LIHEAP grant recipients; provide comprehensive Residential Energy Consumption Survey (RECS) Data Match activities to ensure finalization of reports for final Office of Management and Budget (OMB) approval to include analyses; extensive reporting and reconciliation; training and technical assistance;

webinars; data acquisition and storage preparation; coordinate, facilitate, and

CONTRACT / TASK ORDER # 47QRAA25D004K / 140D0425F0832

4. The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

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

AQD awarded a six-month bridge task order on September 3, 2025 with a PoP from September 3, 2025 through March 2, 2026. The bridge included FAR 52.217-8 for up to an additional six months of services. During the bridge award process, the scope and level of effort for the requirement was significantly reduced through negotiations due to unanticipated complexities including an Independent Government Estimate (IGE) that was substantially underestimated as well as funding approval timelines prior to award that would have resulted in a potentially lengthy break in service. A modification to the bridge was completed approximately three weeks after the award, to add required immediate-need critical support services due to degradation of services based on the reduced scope and level of effort for the bridge at award.

Throughout the period of performance, there has been a continuous reassessment of the Government’s needs to ensure continuity of services for critical LIHEAP support needs due to the decreased level of effort and scope at bridge award.

As referenced in the original Limited-Sources Justification approved on August 14, 2025, ACF and AQD’s intentions were to continue the procurement process for the follow-on requirement. However, the procurement process for the follow-on requirement has experienced ongoing delays due to the complexities during the bridge award process and administration after award. Additionally, substantial changes to the IGE and Performance Work Statement (PWS) were required based on lessons learned from the bridge award. It should also be noted that responsibility for the LIHEAP program was previously under National Institutes of Health (NIH), National Heart, Lung, and Blood Institute (NHLBI). Due to organizational changes at HHS, LIHEAP became the responsibility of ACF OCS. Subsequently, the federal workforce supporting LIHEAP decreased which significantly limited the subject matter expertise available from internal government resources. During December 2025, ACF OCS pivoted to updating the IGE and PWS to increase the level of effort and scope as well as extension of the bridge PoP because it was determined that award of a follow-on task order was not possible without a lengthy break in critical LIHEAP support services. Due to the decreased level of effort and scope for the bridge task order at award, the IGE and PWS required significant updates to address LIHEAP’s ongoing critical support needs for potentially an additional six months of services to allow time for a follow-on task order to be procured.

Since the PoP under the existing order ends on March 2, 2026, it is imperative that LIHEAP support services continue to meet the Government’s need to provide critical support to vulnerable populations and remain in compliance with LIHEAP requirements. Thus, a modification must be issued no later than March 2, 2026, to ensure continuity of critical services without interruption. Therefore, it has been determined that the best immediate course of action is to issue a modification to increase the level of effort and scope of the current bridge and extend the PoP by adding option periods. This will allow time for ACF OCS to update the PWS and IGE accurately and completely as well as time for thorough market research to ensure competition among capable vendors for the follow-on award which will not be in place by March 2, 2026. The follow-on task order is anticipated to be awarded during early-to-mid fourth quarter of Fiscal Year 2026 (FY 26) to allow for an adequate transition period for a potential new awardee due to the complexity and breadth of the work.

Per FAR 8.405-6(a)(1)(i)(A), the Contracting Officer (CO) may make an award on a limited sources basis when an urgent and compelling need exists and following procedures would result in unacceptable delays. AQD intends to issue this bridge modification to Apprise Inc, the incumbent contractor, in the interim to maintain ongoing critical support for ACF OCS until a new follow-on task order award is in place. Extension of the bridge task order is required to ensure LIHEAP receives continuous uninterrupted services at the level of effort and scope originally intended at the time of the bridge award (47QRAA25D004K / 140D0425F0832).

The delayed execution of a modification to increase the level of effort, scope, and add option periods to extend the LIHEAP Support Services bridge would cause a significant disruption in the continuity of critical operations supporting the LIHEAP.

This bridge encompasses a wide range of complex and essential services, including maintenance of the LIHEAP Clearinghouse and Performance Management websites, operation of the NEAR hotline, execution of required federal data reporting functions (including calculation of the LIHEAP funding formula, RECS Data Match and Annual Report to Congress), technical assistance to grant recipients, and performance measure analysis.

Additionally, the nature of a delay would impede OCS's ability to provide uninterrupted support to LIHEAP grant recipients, to maintain 24/7 public access to energy assistance information, and to execute timely updates to federal systems that require compliance with cybersecurity, accessibility, and cloud-hosting standards.

Key deliverables—including weekly call center reports, training activities, and updates to eligibility tools, calculation of the LIHEAP funding formula allocation, required reporting to OMB and Congress, and performance dashboards — would either stall or be at risk of noncompliance with Federal statute and requirements.

The impact of this delay would undermine both federal program accountability and public access to critical information as well as cause operational disruption of the LIHEAP. As such, it would:

hinder the ability of low-income households to locate local intake agencies for energy assistance potentially causing life-safety risks to vulnerable populations due to delays with obtaining resources during harsh weather conditions, delay technical guidance to states and tribes which could significantly damage confidence and undermine trust in the Government’s ability to fulfill its statutory mission under 42 U.S.C. § 8621-8630, and interrupt progress on performance data analytics vital to congressional reporting and program oversight potentially resulting in data loss, inability to inform policy decisions and respond to emerging needs. This lapse would also introduce risks to federal information technology (IT) security and jeopardize compliance with established governance frameworks, including FedRAMP and Section 508 accessibility requirements.

As the incumbent, Apprise Inc is intimately familiar with the support required and is qualified to support ACF OCS while the procurement process for a follow-on task order continues. Apprise Inc’s performance under the bridge has been satisfactory.

Apprise Inc has the capability and expertise to continue to support this requirement with no interruption or schedule impact. Awarding a task order to a different contractor for the continued bridge support is not in the Government’s best interest as a new contractor would need time to familiarize themselves with the requirement and perform against compressed timelines. Apprise Inc can avoid the unacceptable delays that bringing in a new contractor would require and is the only vendor with the capability and experience needed to meet the Government requirements on this time-limited schedule at this time.

Obtaining competition for this bridge modification is impracticable under the circumstances described herein as it would require considerable lead time to identify sources, receive quotes, conduct a source selection, and process appropriate award documentation. Selecting any other source would also require a significant transition-in/ramp up period to get a new contractor up to speed on the complex and essential services provided, including transfer of documentation, and obtaining access to controlled Government systems.

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

The CO will determine the anticipated price fair and reasonable through the use of the General Services Administration (GSA) Multiple Award Schedule (MAS) program and through the program’s Schedule pricing. The rates used by GSA MAS program schedule contract holders have been determined at the time of Schedule contract award to be fair and reasonable. To further ensure the price is reasonable, price evaluation will be conducted in accordance with FAR 8.405-2(d). In accordance with DOI-AAAP-0024, Enhancing Competition, and due to only one quote being received, the price analysis tools and techniques at FAR 15.404-1(b)(2) may be used to further determine the price 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.

The Government’s previous market research showed that there are potentially several capable vendors under GSA MAS Special Item Number (SIN) 541611.

However, due to the current bridge task order expiring on March 2, 2026, there is not adequate time to follow competitive procedures to ensure a timely award such that there will not be a lengthy break in services. Thus, the bridge task order will be extended for no more than six months to ensure that there is no break in services and to bridge the gap between the existing order and a competitive follow-on order.

7. Any other facts supporting the justification.

A Request for Quotation (RFQ) was not released on GSA eBuy as it was determined that there is only one source, Apprise Inc, capable of providing the extended services for the LIHEAP Support Services requirement due to an urgent and compelling need. After the modification to the bridge task order is issued, a notice will be posted on SAM.gov along with a redacted copy of the approved Limited- Sources Justification in accordance with the requirements at FAR 8.405-6(a)(2).

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

The need for a subsequent sole source task order will be mitigated in the future through the award of a competitive follow-on task order anticipated to be awarded by early-to-mid fourth quarter of FY 26 to allow for an adequate transition period.

9. The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

I certify this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer

10. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

Program Office/COR

11. For justifications under 8.405-6(a)(1), a written determination by the approving official identifying the circumstance that applies.

Under the authority of FAR 8.405-6(a)(1)(i)(A), only one source is capable of providing the services required due to the urgent and compelling nature of the Government’s needs to ensure continuity of services for the LIHEAP support services requirement;

therefore, the approving official hereby determines the circumstances of this action can only be provided by Apprise Inc.

12. Reviews and Approvals

Concur

Branch Chief

Concur

Division Chief

Approve

Bureau Competition Advocate