A17_JA_LSJ_linkage_REDACTED_1.pdf

LIMITED-SOURCES JUSTIFICATION

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

Ref: Request for Quote (RFQ) no. 140D0426Q0124

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 is a logical follow-on for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division 2, Branch 1 in support of Health and Human Services (HHS), National Institutes of Health (NIH), National Institute on Aging (NIA), Division of Behavioral and Social Research (BSR).

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

The action being approved is the issuance of a short-term (6-month Base + two (2) 3-month Options) for a total 12-month performance period) sole source logical follow-on to maintain the NIA Linkage program while a new, competitively awarded cloud-based contract is finalized via the NIH contracting office. The short-term contract is needed to preserve continuity of the NIA Linkage program, which provides NIA grantees access to Centers for Medicare & Medicaid Services data and supports more than 1,150 researchers on 137 Data Use Agreements (DUAs) by linking NIA-supported study data with Centers for Medicare & Medicaid Services (CMS) data for Alzheimer’s, multimorbid chronic conditions, clinical trials, and surveys.

The Base period of the contract will be used to finalize and award the new contract and the subsequent Option periods will provide an overlap/transition so the incoming contractor can obtain an Authorization to Operate (ATO), DUA with CMS, and establish required secure infrastructure.

The vendor is Acumen LLC (incumbent), 500 Airport Blvd, Suite 365, Burlingame, CA 94010.

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

The vendor will provide commercial Linkage, Review, and Cloud Support Services to support the NIA Linkage program.

Specific tasks that will be performed because of this action include the following:

• Obtain CMS files and link CMS and other datasets to NIA-funded studies (e.g., National Health and Aging Trends Study (NHATS), Prostate-Specific Antigen Density (PSAD), clinical trials).

• Review researcher data-use requests for Minimum Data Necessary (MDN) compliance and manage controlled access.

• Store sensitive data and operate a Federal Information Security Modernization Act (FISMA)-Moderate secure data enclave; provide secure researcher access via Desktop-as-a-Service (DaaS).

• Provide technical assistance to researchers and maintain program information and resource content for NIA’s public-facing website.

The estimated value for this action (6-month Base +two (2) 3-month Options) for a total 12-month performance period) is $XXXXXXXX to provide flexibility in addressing schedule uncertainties. This structure ensures adequate time to award the competitive follow-on contract and complete critical security requirements, including obtaining an Authority to Operate (ATO) and CMS data access. If these activities are completed earlier than anticipated, the Government will not exercise the remaining options, thereby minimizing costs and avoiding unnecessary overlap. This phased approach mitigates risk of service disruption while accommodating delays caused by the recent government shutdown and staffing shortages.

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)C – In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order was not previously issued under sole-source or limited-sources procedures.

The incumbent contractor, Acumen LLC, possesses specific, documented capabilities and existing authorities that are essential to maintain continuity of the NIA Linkage program and that are not readily transferable to another vendor in the short term.

Awarding a short-term contract to Acumen is necessary to avoid unacceptable delays, substantial duplication of cost, and interruption of researcher access to CMS‑linked data.

Acumen, LLC is uniquely positioned to continue providing Linkage, Review, and Cloud Support Services due to its existing operational infrastructure and institutional knowledge. XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

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XXXXXXXXXXXXXXXXXXXXXXXXXX. Additionally, XXXXXXXXXXXXXXXXXXXXXX

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ensuring compliance with federal data security standards.

As the incumbent under General Services Administration (GSA) Multiple Award Schedule (MAS) contract GS10F0133S / 140D0421F0687, XXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Transitioning to a new vendor would introduce delays due to the time required to obtain a new DUA and ATO, potentially impacting active research. Continuity of service is critical, and Acumen’s established capabilities and authorizations mitigate risk and support uninterrupted program operations.

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

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XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX.

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

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XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX — creating unacceptable delays and greater cost, which NIA estimates at approximately $XXX for the new build out and operations for 1 year, plus an additional unknown amount for XXXXXXXXXXXXXXXXXXXXXXXXXX. The estimated cost of a new vendor is higher than the estimated cost of a Sole Source to the incumbent because a new vendor would need to establish new infrastructure and obtain data.

These attributes, the incumbent’s existing authorities, secure environment, and specialized operational experience make Acumen uniquely qualified to perform this short-term requirement with minimal risk to program continuity and research access.

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

The Contracting Officer (CO) will determine whether the anticipated prices are reasonable through the use of and comparison to GSA MAS schedule pricing which has already been determined fair and reasonable under FAR Part 8.404(d) and a thorough price analysis performed by the CO using comparable services and existing contracts.

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.

Market research was previously conducted for the original Linkage contract and is currently underway for the competitive recompete of that requirement. The sole‑source action is intended to preserve program continuity while the competitive solicitation is completed.

7. Any other facts supporting the justification.

The Linkage program supports ongoing NIH/NIA-funded research that relies on uninterrupted access to CMS-linked datasets. Disruption of services would delay researcher access to sensitive data and negatively impact active studies. Without a short-term action, the Government would face unacceptable delays in restoring full program functionality.

Although a competitive recompete is underway, staffing constraints and extended procurement timelines have pushed the earliest feasible award date to XXXXXXXXX.

While XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

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XXXXXXXXXXXXXXXXXXX. Transitioning to a new vendor at this stage would result in substantial duplication of cost and effort, introduce unacceptable delays, and risk loss of continuity in data governance and linkage quality.

In accordance with FAR 8.405-6(a)(2), the redacted LSJ will be posted on SAM.gov within 14 days of executing the award for a minimum of 30 days.

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 HHS contracting office is taking the main re-compete procurement (not the short-term contract) back in-house and has posted a notice on SAM.gov (HHS notice no. NIAID-SS-25-22653976, SAM notice ID 75N95026R00003) outlining key capabilities vendors must demonstrate, helping reduce uncertainty and encourage broader participation. The notice also announced the intent to issue RFP no.

XXXXXXXXXXXXXXX on or around XX/XX/2026, providing potential offerors sufficient time to prepare and ensuring transparency regarding the government’s requirements. The timeline shows HHS’s award is projected for XXXX XXXX, even under the revised schedule. Starting the short-term contract in March 2026 ensures coverage during the following HHS re-compete efforts:

• XXXXXXXXXXXXXXXXX

Any delays in acquisition planning or evaluation could push award further, making a shorter contract risky. An overall 12-month short-term (March 2026–March 2027) provides flexibility for unexpected delays and transition and ramp-up for the new contract. XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

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XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX.

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.

_//signed//__________________________________ Lydia Nuñez 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 meet the Government’s minimum needs.

_//signed//________________________________

XXXXXXXXXXXXX

Program Office/COR

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

FAR 8.405-6(a)(1)(i)C – In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited sources procedures.

12. Reviews and Approvals

Concur

__//signed//_______________________________

Branch Chief

Concur

__//signed//______________________________

Division Chief

Approve

__//signed//_________________________________

Bureau Competition Advocate