Limited-Sources_Justification_for_Federal_Supply_Schedule_Legal_Research_Redacted_1.pdf

LIMITED-SOURCES JUSTIFICATION

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

SOL# 140D0426Q0043

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.”

Department of the Interior, Interior Business Center, Acquisition Services Directorate, Health and Human Services (HHS), Office of Inspector General (OIG), Office of Counsel for the Inspector General (OCIG).

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

This is a new requirement for OCIG (under their recent reorganization) for legal research and public records search tools. This task order will be awarded under GS contract GS-02F-026DA to:

West Publishing Corporation (Thomson Reuters) 2900 Ames Crossing Rd, STE 100 Eagan, MN 55121-2498

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

The Contractor shall provide a secure, cloud-based, web-accessible investigative research and analysis software platform with the following capabilities:

Access Public Records to ensure that attorneys and investigative analysts sitting in a variety of U.S. locations (including government offices and remote telework locations via secure virtual private network) can access a wide array of public records to identify and notify individuals and entities under investigation for potential exclusion from Federal health care programs. Investigative analysts and attorneys require a tool that consolidates public and private record sources related to individual persons and business entities into a report with flexibility to customize the content. Provides searches based on the EIN / TIN, middle or last name, SSN, Street address, City, and/or State to enable investigators to verify the identification of individuals and business entities and provide a report that includes, but is not limited to, the following data:

SOL# 140D0426Q0043

o Individual SSN (include capability to search based only on the

SSN).

o Name and variations o DOB o Residential and Business Address history o Business entity EIN / TIN (include capability to search based only on the EIN or TIN).

o Professional health care licensure history o DMV records o Property records o Legal history o Family and other associates o Business associations o Business Entity history

Access to Legal Research tools for attorneys to further litigation and legal advice requirement for the OIG through access to relevant primary and secondary sources in the following areas:

o Cases o Regulations o Statutes o Legislative material o Administrative material o Treatises and related analytical material o Native American Law o AM Jur, ALR, CJS, CCH o Law Reviews & Journals

This procurement shall include either availability of a user licensed or subscription-based model, with scalable options to accommodate organizational needs and growth;

continuous system and data updates; training for agency personnel; maintenance; and ongoing technical support.

The Period of Performance will consist of a 12-month Base year, followed by four 12-month option years. In addition, a six-month option period may be exercised in accordance with FAR 52.217-8. The full Period of Performance is as follows:

Base Year: January 1, 2026 – December 31, 2026 Option Year One: January 1, 2027 – December 31, 2027 Option Year Two: January 1, 2028 – December 31, 2028 Option Year Three: January 1, 2029 – December 31, 2029 Option Year Four: January 1, 2030 – December 31, 2030 FAR 52.217-8: January 1, 2031 – May 31, 2031

The Independent Government Cost Estimated (IGCE) is The IGCE was developed using historical data and averaging pricing also includes a annual increase to allow for inflation.

IGCE Summary Base Year:

Option Year One:

Option Year Two:

Option Year Three:

Option Year Four:

Subtotal:

6-Month Extension

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)B - Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

The Contractor solutions required to meet HHS-OIG/OCIG’s for legal-research information and public record search tools (subscription access) that are unique and highly specialized. Market research documented in this file identified only one GSA Federal Supply Schedule holders capable of delivering the full scope of functionality, security, and nationwide remote access required. The selected vendor uniquely provides the required capabilities as a stand-alone solution, without being tied to additional bundled products or services. In contrast, prior procurements resulted in awards that included extensive bundled offerings, obligating the Government to pay for functionality and subscriptions that exceeded operational needs. By selecting a vendor that delivers only the specified public-records and legal-research tools, the Government avoids unnecessary scope creep, reduces subscription and licensing cost inefficiencies, and ensures a more targeted, scalable solution that aligns with OICIG’s requirements.

Under FAR 8.405-6(a)(1)(i)B, the circumstances of this acquisition therefore justify limiting sources.

Awarding a task order to the identified GSA schedule vendor is appropriate because GSA Schedule contracts provide pre-negotiated, commercially reasonable pricing and established contract terms, while reducing procurement and performance risk. Use of the GSA FSS leverages prior pricing and contract review processes, ensures access to vendors with demonstrated federal performance, and expedites award of a SaaS/licensed solution that includes continuous data updates, training, maintenance, and support essential to OIG operations.

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

The order will be issued under GSA Federal Supply Schedule contract GS-02F-026DA, whose established pricing schedule and past transactional history demonstrate that the rates and discounts available under this contract are fair and reasonable for the supplies/services being procured. Upon receipt of quotation, the contracting officer will seek additional price concessions to further reduce cost to the Government.

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 contracting team performed comprehensive market research to determine source availability for legal research and public records search platform to support HHS-OIG/OCIG investigative and legal work. Research activities included review of acquisition history, GSA Federal Supply Schedules (FSS), System for Award Management (SAM), CPARS/PPIRS, wage determinations, and prior market research.

The team conducted one-on-one vendor interviews, government and industry outreach, DOI small business vendor outreach, and reviews of commercial databases, catalogs, and product literature. AbilityOne and UNICOR schedules were reviewed and determined not to offer the required services.

The services sought are commercially available but only from a few specialized vendors. Market research identified one large businesses that currently hold GSA FSS awards and can meet the functional and technical requirements.

The prior procurement ( and current research indicate no broad vendor pool capable of delivering the consolidated investigative-public-records and legal-research database functionality specified.

Small business participation under NAICS 541199 appears in the market, however it is majority law firms offering legal services and not for this specialized legal research database requirement; the research concluded that two or more small businesses cannot meet the specific technical requirements.

Based on the documented outreach, government and industry interviews, and review of federal supply schedules and historical acquisitions, the market research supports the determination that only one source can meet the Government’s requirements, and therefore a limited-sources justification is appropriate.

7. Any other facts supporting the justification.

Request for Quotation will not be released on e-Buy, and will be submitted directly to the vendor, to ensure there is no lapse in service. The current contract expires December 31, 2025.

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 program office conducts continuous market research and will maintain proactive industry outreach to reduce barriers to competition. The office will systematically document all outreach activities, vendor engagements, and market developments, and will periodically reassess source justification in light of new information. This ongoing effort is intended to identify emerging commercial and small-business solutions that meet the program’s technical, security, and scalability requirements and to enable timely adjustments to acquisition strategy as appropriate.

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.

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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 eds.

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

The Contracting Officer certifies that the selected vendor is the only source capable of providing the required public-records and legal-research capabilities as a stand-alone solution; unlike prior procurements that forced the Government into broad bundled offerings and excess subscriptions, this vendor delivers only the tools OCIG needs, avoiding scope creep, reducing licensing and subscription inefficiencies, and ensuring a targeted, scalable solution—therefore, under FAR 8.405-6(a)(1)(i)(B), limiting sources is justified.

12. Reviews and Approvals

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