A17_JA_LSJ_CWRP_REDACTED_1.pdf

LIMITED-SOURCES JUSTIFICATION

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

Solicitation no. 140D0426Q0177

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 /on behalf of U.S. Department of Health and Human Services (HHS)

Administration of Children and Families (ACF), Children’s Bureau (CB).

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

The action being approved is the for the issuance of a short-term six-month sole source logical follow on Fixed Price (FFP) task order with Time and Materials (T&M) type lines for

Travel and Order-Level Materials (OLMs) using a limited sources justification in accordance with FAR 8.405-6(a)(1)(c) procedures via General Services Administration (GSA) Multiple

Award Schedules (MAS) Category 541611 against JBS’ GSA contract #47QRAA18D00AE.

The issuance of this logical follow-on order will ensure the continuity of operations for the

Child Welfare Reviews Project (CWRP) from March 30, 2026, through September 29, 2026 while AQD completes the competitive acquisition for the new realigned requirement for

CWRP and Title IV-E Reviews that includes similar services.

The HHS CB has a continued need for child welfare expertise and information technology

(IT) support to administer the federally mandated Child and Family Services Reviews

(CFSRs). The primary goal of the CFSRs is to help states strengthen their child welfare services and improve outcomes for children and families by identifying program strengths, pinpointing areas of need, and highlighting where targeted technical assistance can support meaningful improvement.

The vendor is JBS International, Inc. (incumbent), 11200 Rockville Pike, Suite 320, Rockville, MD 20852.

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

HHS ACF CB requires continued programmatic, technical, logistical, and systems support to sustain ongoing CFSR activities and associated Program Improvement Plan (PIP) work. The

CB uses the PIP process as a corrective and improvement mechanism following CFSRs, ensuring states strengthen their systems and meet federal standards. Services include support for CB led reviews, state team training, stakeholder interview weeks, final results meetings, completion of final reports, ongoing PIP monitoring, and continuous operation and maintenance of the CFSR Data Management System (DMS), related portals and training platforms.

Period of Performance: The anticipated period of performance for this six-month follow on award is March 30, 2026, through September 29, 2026.

The Estimated Contract Value is as follows:

• Base Period: $XXXXXXXXX o Direct Labor: $ XXXXXXXXX o Order Level Materials (OLMs): XXXXXXXXX o Travel: XXXXXXXXX

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 or BPA must not have been previously issued under sole-source or limited-sources procedures.

The DOI, AQD, on behalf of HHS, ACF, and the Children’s Bureau (CB), awarded Contract

140D0420F0536 (CWRP) to JBS International, Inc. on September 21, 2020, following a competitive solicitation posted to GSA eBuy under MAS Categories 541611 and 54151S. The task order was issued under JBS’s GSA MAS Contract 47QRAA18D00AE.

Task Order 140D0420F0536 expires on March 29, 2026. The anticipated six-month bridge contract is a logical follow-on, XXXXXXXXXXXXXXXXXXXXX

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. Issuing this follow-on is in the

Government’s best interest because it prevents a lapse in federally mandated oversight services, mitigates staffing and compliance risks, supports Technical Bulletin (TB) #14 implementation and transition, and preserves the ability to conduct a full and open competition for the follow-on requirement.

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XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX. A follow-on contract is required to avoid disruption to statutorily mandated oversight functions

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This follow-on is strictly limited in duration and scope and is intended solely to ensure continuity of operations during the transition to a successor contract. It sustains ongoing work and supports reviews, training, and meetings already scheduled. It does not initiate new review cycles, expand scope, or introduce new systems or capabilities. XXXXXXXX

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XXXXXXXX. These preparations must begin well before the review dates and cannot be deferred until after a recompete without placing scheduled reviews at risk.

Any delay would result in postponed or cancelled reviews and training, disruption to stakeholder interview schedules, delays in final reports and PIP monitoring, and impairment of CB’s ability to meet statutory oversight responsibilities. Because the review calendar is fixed and interdependent, even a brief lapse in performance would significantly harm the

Government’s mission.

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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 XXXXXXXXXXXXXXXXXXXX.

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 CWRP contract and is currently underway for the competitive re-compete of that requirement. This sole‑source action is intended to preserve program continuity while the competitive solicitation is completed.

7. Any other facts supporting the justification.

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XXXXXX. These activities require extensive advance planning, including travel coordination, meeting space reservations, secure connectivity, preparation of materials, and coordination with state agencies, federal staff, and review team members. XXXXXXXXX

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If the incumbent contractor is not utilized, the Government would be unable to XXXX

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XX. Such delays would impede final report completion, delay PIP negotiations and monitoring, and compromise compliance with statutory oversight requirements.

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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.

Federal law requires the Department of Health and Human Services, through the Children’s

Bureau, to conduct ongoing monitoring and oversight of state child welfare programs.

Section 1123A of the Social Security Act, along with implementing regulations at 45 Code of

Federal Regulations (CFR) 1355.33 and 1355.35, mandates recurring Child and Family

Services Reviews and associated follow-up activities to assess state conformity with federal requirements. Additionally, 45 CFR 1356.71 and 45 CFR 1356.80–86 require Title IV-E

Foster Care Eligibility Reviews and National Youth in Transition Database (NYTD) Reviews to validate program compliance, data accuracy, and eligibility for federal reimbursement. In addition, the Payment Integrity Information Act of 2019 requires annual calculation and reporting of the foster care improper payment rate based on review data. These statutory and regulatory mandates impose continuous, time-bound monitoring and reporting obligations, making uninterrupted contractor support essential to maintain compliance.

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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//__________________________________

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//__________________________________

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