LSJ iPass Order.pdf

Attachment 4 U.S. Customs and Border Protection

Limited-Sources Justification (LSJ) - FAR 8.405-6 For orders or BPAs exceeding the Simplified Acquisition Threshold (SAT)

Version 2.0 November 2020

Date: March 18, 2024 PR Number: 2014-4033

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

The Department of Homeland Security (DHS), United States (U.S.) Customs and Border Protection (CBP), Office of Information and Technology (OIT), Border Enforcement and Management Systems Directorate (BEMSD), and the CBP Office of Acquisition’s Procurement Directorate (PD), proposes to award a sole source bridge contract to Steampunk, Inc. under the General Services Administration (GSA) Multiple Award Schedule (MAS) Information Technology (IT) Professional Services pursuant to FAR 8.405-6(a), Limiting Sources.

The Border Enforcement and Management Systems Directorate (BEMSD) requires a Limited- Source Justification (LSJ) to authorize Steampunk, Inc., the existing International Personnel Accountability Service Solution (iPASS) vendor to continue new development and perform operations and sustainment of this critical capability. This limited sources justification is necessary due to the combined impacts of the protest, the corrective action, the ongoing re-evaluation of the Software Application Support Services (SASS) Multiple Award Blank Purchase Agreements (BPAs), and the short time remaining on the current iPASS contract Period of Performance (PoP), which now does not afford the Government sufficient time to competitively award an iPASS support contract. The PoP for the bridge contract that this LSJ proposes is specifically designed to allow the Government to make a competitive award. The short period of time between the decision to take corrective action on SASS and the end of the current PoP made it impossible for the Government to find another vendor that could onboard cleared resources, conduct a transition with the incumbent, and reasonably deliver the required services. A decision not to move forward with this LSJ with Steampunk will have a severe, material impact on iPASS quality and timelines which will negatively impact mission performance.

2. Nature and/or description of the action being approved. Describe the action being approved and include the name and address of the proposed contractor(s).

CBP intends to issue a sole source contract for the mission essential iPASS requirement. As required by the Immigration Advisory Program (IAP), CBP Office of International Affairs (INA) priorities, and International Operations and Advisory Directorate, iPASS is utilized for screening global threats, comprehensive border security and management, plus organizational integration. It is necessary to keep this requirement renewal to avoid a break in the mission essential digital platform and maintenance services for meeting prioritized CBP requirements. If the digital platform and maintenance services expires, the CBP IAP, IOAD, and INA will be unable to fulfill various mission critical requirements. Only one source is capable of providing the supplies or services required at the level of quality required because the services are unique and highly specialized. It is anticipated that an award will be made to Steampunk, Inc. under General Services Administration (GSA) Multiple Award Schedule 518210C. The proposed order is intended to be a Firm Fixed Price sole source bridge order to Steampunk, Inc. with 6-month base period of performance and 3-month option period for continuous iPASS development support for Office of Field Operations (OFO), IOAD, and INA programs with a total estimated price of .

Steampunk Inc.

1753 Pinnacle Drive, Suite 900 McLean, VA 22102-3844

3. Description of Supplies/Services

The proposed task order will provide critical operations and maintenance and ongoing enhancement support for the Container Security Initiative (CSI), IAP, and Global Targeting and Advisory Division (GTAD) units within OFO. The application operations and maintenance support are necessary to support the CBP mission in the following areas:

Strengthens emergency preparedness: iPASS provides real-time reporting on employees’ (and their dependents) location, contact info, and other critical data.

Enhances border & international security: iPASS shortens the length of the pre-deployment process overall, getting officers to their new locations more quickly.

Empowers decision making: CBP leadership and operations staff use iPASS’ data reporting tools and graphics to assess and visualize information across ports or programs. Enables personal data security: CBP employees submit paperwork through iPASS’ secured system instead of using email or paper, preventing misplaced files and safeguarding Personally Identifiable Information

(PII).

Establishes process efficiency: iPASS reduces the time required for administrative tasks, allowing more focus on operations or other duties.

Promotes collaboration: iPASS is the single verification system– all information is centralized for managers and employees.

IPASS supports 856 users in the system and has resulted in a 50% reduction in pre-deployment times for OFO during the timeframe of 2021-2023.

Continued continuity with the progression of enhancements is necessary to meet the objectives of expanding to the entire CBP Enterprise (US Border Patrol, Air and Marine, etc.), whose deployments are managed by Operations Support Office of International Affairs (OS INA).

The following outlines the prioritized tasks required during this period:

Brochure Site Enhancements that use the findings of Phase 5 to gather relevant stakeholders into a working group, finalize requirements, and develop an initial wireframe for future phases to build upon. Additionally, determine an initial set of locations that have sample content to help demonstrate what the rest of the site might look like.

Enhanced Departing Process / NOI Process that will include further disaggregating the departing process into sub-statuses, improving the tasking process of actions in the departing process, and enhancing the process by which eMAP updates Notice of Intent (NOI) records and deployments in iPASS.

Renewal Tasks that will include the ability to customize the task process for a renewal task (Medical, Trainings, Passports, Visa) in such a way that differs from the initial tasks during the pre-deployment process.

Administrative Dashboard & Controls that will include an enhanced user-management module to give users the ability to self-manage iPASS-related permissions and roles and retrieve live counts of iPASS users.

Enhanced Notification Banner that will allow for targeted in-application home screen notifications for different roles (i.e., IAP, CSI, Preclearance) rather than just one for Employee and one for Administrators.

System Integration Enhancements that will include reviewing the SAP integration and associated reports and dashboards to improve accuracy and impact on budget authorization and voucher actuals, with potential to update the data set being pulled into iPASS.

Miscellaneous Application Enhancements that will include additional system-wide validation rules and guardrails to ensure better data quality across the application. This also includes efforts to improve speed and efficiency of existing processes, standardize all processes on the same development design patterns, and remove un-used components from the codebase.

iPASS Help Desk Module Enhancements will include additional process-routing improvements, links to materials stored within the iPASS Communications (Comms) Site based on topic or issue, as well as enhancements to the user interface.

Change Management Support that will consist of creating new learning journeys and development of training materials for the iPASS application; expansion of the iPASS Comms Site; developing iPASS Marketing Campaigns; developing the iPASS Brand Identity; launching feature and release-specific campaigns and communications; supporting ongoing measurement activities and ad-hoc sustainability activities; and developing surveys, newsletters, and other communication materials. Assisting with certain specific features in the list above.

Brochure Site Enhancements to continue refinement of the wireframe established during the 6-month extension.

Admin Controls that will allow Deployments, Relocation, and Travel (DRT) Admins to manage checklist tasks for Admin Portal users.

Enhanced File Management will enable IOAD to manage files that can be made available for deploying employees to download in the Employee Portal.

Training Module to include a section within the application to store reference materials, training guides and knowledge articles, how-to’s, FAQs, links to resources, and more, that are maintained in the iPASS Comms Site.

System Integration to determine the feasibility to integrate with Office of Human Resources Management (HRM) applications (e.g. Table of Organization) to enable the autocreation and auto-population of data within iPASS (i.e. Losing Position, Gaining Position, EOT Position, etc.)

for Deployments and Profiles per data streamed from HRM apps.

Ongoing Miscellaneous Application Enhancements will include additional system-wide validation rules and guardrails to ensure better data quality across the application. This effort will continue measures to improve speed and efficiency of existing processes, standardize all processes on the same development design patterns, and remove un-used components from codebase.

Ongoing Change Management Support that will consist of creating new learning journeys and development of training materials for the iPASS application; expansion of the iPASS Comms Site; developing iPASS Marketing Campaigns; developing the iPASS Brand Identity; launching feature and release-specific campaigns and communications; supporting ongoing measurement activities and ad-hoc sustainability activities; and developing surveys, newsletters, and other communication materials. Assisting with certain specific features in the list above.

Administrative Portal Minimum Viable Product (MVP) that will include the necessary technical adjustments to the existing Admin Portal of iPASS for the purposes of INA’s business needs. Items within this scope include the definition of new roles and permission sets; the modification of the data model and data fields on iPASS objects; the establishment of new record types and page layouts; flows and process adjustments, etc.

Permanent Change of Station (PCS) Deployment MVP that will include the appropriate data model updates to existing infrastructure to allow “admin users” the ability to input and manage CBP deployees, their dependents, and their associated taskings and documents through the deployment lifecycle, from selection to onboard to re-integration.

Employee Portal MVP that will include the necessary technical adjustments to the existing Employee Portal to allow for additional CBP users outside of OFO the ability to login and access their deployment records, update information for themselves and their dependents, and work with their assigned CBP “admin” during the pre-deployment, onboard, and re-integration phases.

Systems Integrations to include migrating additional sets of data from CGE Concur and SAP to support the operations and management of additional CBP employees deployed on mission.

Additionally, Steampunk will support INA’s effort with pulling data out of iPASS for the purposes of visualizing data in eGIS. Finally, the following systems have been discussed for integrating with Salesforce but need more discovery and technical evaluation to determine the feasibility of integration: NexGenTracker (Gotham), FACTS, CPRO, and ECC.

Data Management and Migration to include collecting, transforming, and migrating the necessary data elements to ensure core iPASS functionality is working properly for the purposes of INA. Data tables include Position, Profile, Duty Location, Deployment, Tasks.

Automated Email Alerts to include the implementation of the base set of email templates that INA currently automates in their deployment processes.

Reports & Dashboards for MVP to be discussed and determined with the INA Product Owner.

Likely candidates of reports and dashboards are to be based on IOAD’s current offerings of position management, emergency preparedness, financial data such as voucher obligations and commitments.

Voucher Management MVP to include a method for employees to submit voucher receipts to be received, reviewed, and approved by INA admin users.

INA Change Management Support that will consist of initial benchmarking, to include establishing a set of success criteria for initial adoption of iPASS by INA staff as well as baseline measurement of as-is process; creation of an “Intro to iPASS” user guide; the expansion of the iPASS Comms Site; and the establishment of iPASS Release Campaigns.

Phase 2 Temporary Duty Yonder (TDY) Deployment MVP that will include the appropriate data model development to allow “admin users” the ability to input and manage TDY deployments on behalf of CBP deployees, their dependents, and their associated taskings and documents through the deployment lifecycle.

Phase 3 Foreign Service National (FSN) Deployment MVP that will include the appropriate data model development to allow “admin users” the ability to input and manage Foreign Service Nationals and their associated documents to ensure consistency in tracking their employment status with CBP abroad.

The Period of Performance will consist of a six (6) month base period, followed by one (1) three-month option period; beginning March 30, 2024 through September 29, 2024.

The above proposed Period of Performance is based on the timeline of the anticipated iPass recompete award date and the ending of iPass current task order. The performance period, if needed, will allow time for the competitive procurement of the required iPass services to be completed. Below is an estimate of the proposed iPass bridge contract cost with options.

Performance Period Base Period, Six Months

Option Period, Three Months Total Cost, Nine Months:

4. Authority and supporting rationale pursuant to FAR 8.405-6(a)(1)(i)(B)

The complexity of this work requires a Contractor team to have a strong understanding of the CBP mission and technology landscape.

Per 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. To expound, this acquisition is being conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C.

501, Services for Executive Agencies. An award will be made to Steampunk, Inc. as the sole-source is required to complete enhancements and support efforts, as described in Section 3.

Because of the multiple applications dependent on the iPASS platform to conduct daily business operations across CBP, at this time Steampunk, Inc. is the only source capable of meeting these requirements.

Rationale:

On September 27, 2023, Customs and Border Protection (CBP) awarded the Software Application Support Services (SASS) Multiple Award Blank Purchase Agreements (BPAs) to four (4) awardees. These awardees could have provided support services that could have met CBP’s iPASS requirements. BEMSD planned to compete and award the iPASS contract on the

SASS BPA.

On October 6, 2023, CBP received five (5) Government Accountability Office (GAO) Protests challenging the SASS BPA award. During the pendency of the GAO protest, the performance of competitively awarded BPAs, 70B04C23A00000072, 70B04C23A00000073, 70B04C23A00000074, and 70B04C23A00000075 has been stayed. The stay of the SASS awards left BEMSD without a contract vehicle on which to compete this critical work. BEMSD still attempted to execute a competitive award—a process that started in early November 2023.

The sole source contract PoP that this LSJ supports includes a six-month base period and one three-month option period. This bridge provides the Government sufficient time to plan, execute, and competitively award a long-term iPASS support services contract. It also provides sufficient time to conduct a transition between vendors if Steampunk, Inc. is not selected. As noted above, BEMSD has already begun planning and has taken the initial steps required for a competitive award. The bridge contract PoPs ensure that this competition will be conducted correctly and that the best and most fully qualified vendors are selected.

iPASS plays the key management role in the ability for CBP to deploy its Officers and their families internationally, tracking them during these deployments, and re-integrating them to a stateside post after their assigned tour of duty is complete. The circumstances noted above that prevented the Government from conducting a re-compete for iPASS support have resulted in Steampunk being the only company capable of providing the required services at the level required until such time as the competitive action is awarded. Steampunk’s unique abilities to perform iPASS work include unique knowledge of iPASS application architecture, unique understanding of the IOAD and INA iPASS business, the proven delivery methods and experience in developing both product roadmaps, and the unique ability to execute continuous delivery via the Salesforce Developer Experience (DX) in the CBP ecosystem. The combination of these positions and skills allows Steampunk to continue their high quality of delivery at high speed.

The proposed bridge contract includes critical iPASS Operations and Maintenace (O&M) tasks.

Without continuous O&M support, IOAD would lose access to training, end user support, integrations troubleshooting, reports or dashboards assistance, and other key capabilities. These O&M tasks impact day-to-day support of IOAD operations. For example, the Steampunk development team has received and responded to over 160 help desk support tickets in the last 11 months, which range from resolving production functionality and performance issues to training and user access. Without this support, IOAD would quickly see degraded system performance.

In the event of a critical production issue, IOAD could lose overall system functionality. There is currently no other vendor with the required knowledge of iPASS architecture to take on O&M responsibilities at the level of quality required for the limited period between the current contract expiration and the anticipated award of the competitive procurement.

During the next six months, IOAD has planned vital enhancements as part of the IOAD iPASS phase 6 release – capabilities that cannot be delayed. Further, CBP had planned to scale iPASS to support the entire CBP Enterprise via new development in support of INA (INA iPASS Phase

1) capabilities without which CBP’s sustainment of its international mission would be degraded.

There is currently no other vendor with the required domain knowledge of IOAD and INA requirements to execute IOAD Phase 6 and INA Phase 1. Given the short transition timeline that the stay of the SASS award drove, there is insufficient time and no other vendor with whom Steampunk could conduct knowledge transfer. Despite Steampunk’s thorough documentation efforts, any gap in iPASS coverage could result in key resources currently assigned to iPASS work being reassigned to other duties, resulting in difficulty to replace knowledge loss.

Steampunk, Inc.’s ability to build iPASS rapidly and efficiently hinges on this vendor’s skill with an advanced Salesforce delivery methodology called Salesforce DX. Currently, Steampunk is the only vendor in the CBP ecosystem that can deliver using Salesforce DX. Once again, the inability to re-compete the iPASS work that the SASS contract situation created prevents the Government from finding another vendor that could perform iPASS work.

Based on the criticality of the existing and planned functionality, CBP requires iPASS support during the period of the stay. This continuation with the existing vendor is aimed at ensuring continuity of critical software development, modernization, enhancement, and O&M services.

As the incumbent, Steampunk, Inc.is the only vendor with the necessary technical skill, available CBP cleared resources, and required domain knowledge to continue performing iPASS contract work. Establishing a bridge contract with the existing vendor allows CBP sufficient time to carry out the competitive acquisition for these services and ensure a low-risk transition.

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

The contracting officer has determined that, issuing the proposed bridge task order via sole source to Steampunk is the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs. This order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules” and an exception to DHS Strategic Sourcing Contract Vehicle is greater savings as well as lower costs. GSA MAS has already negotiated fair and reasonable pricing rates. Discounts to these GSA schedule rates will be requested. Additionally, prior to issuance of the task order, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific task being ordered to determine that the total price is reasonable. The contractor’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate.

Any other solution would result in schedule delay, duplicative costs on overlapping awards, higher costs and the potential for other changes to the platform. To expound, BEMSD performed an analysis of a DHS strategic sourcing contract vehicle that Steampunk, Inc. holds, NITAAC CIO-SP3 Small Business. An estimate of Steampunk, Inc.’s current GSA MAS price list was reviewed for labor needed and resulted in an average hourly rate . The hourly rates included an approximate 1% to 2% discount from Steampunk, Inc.’s GSA MAS labor rates.

Steampunk, Inc.’s CIO-SP3 price list was reviewed as well with the same analysis metrics and resulted in an average hourly rate of . GSA MAS represented a 7.4% savings to CBP.

Theses continued projected savings are particularly important during a time of budget constraints for CBP. The data comparison of GSA MAS and CIO-SP3 small business contract reflects real-time cost savings by continuing the use of GSA MAS contract vehicle for this short-term bridge task order.

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 conducted with three identified schedule holders in GSA MAS. However, none of the vendors available under the schedule would be readily available in the time needed for iPass as mentioned in Section 5. CBP would have to procure new maintenance and specialized services at a prohibitive cost of iPass at this time under current contractor, Steampunk, Inc. The short-term services would be best provided by Steampunk, Inc. as CBP pursues a long-term competitive solution.

7. Any other facts supporting the limited-sources justification. Additional facts may be stated in this section. If there are no additional facts, you must state that here.

If the Agency is unable to execute a sole source contract with Steampunk Inc., encompassing the iPASS support, CBP will not be able to provide operational and maintenance support to the iPASS system, resulting in an impact to the CBP mission and safety of personnel in the event of emergency events in locations where CBP are deployed.

As previously discussed, it is in the Government’s best interest and critical to participating CBP’s iPASS stakeholders’ missions to continue with the current contract as the sole source provider for iPASS services for the purpose of continuity, cost-efficiency, knowledge, cleared personnel and an understanding of historical details of system development, including crucial data services, infrastructure, and end-user capabilities. No other vendor can provide these services in the timeframe required because of the necessary transition.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made.

There are no barriers to future competition. CBP is committed to issuing competitive awards and that utilizing limited sources is only requested if it is absolutely necessary where a competitive action would interrupt critical services. The interim contract proposed under this LSJ is only for the minimum duration for the aforementioned reasons.

9. CBP intends to post this requirement on Government Point of Entry pursuant to FAR 8.405- 6(a)(2)(i).

10. Technical/Requirements Personnel Certification:

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

11. Contracting Officer Certification and/or Approval: *

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and to the best of my knowledge and belief.

LSJ Approvals:

13. COMPETITION ADVOCATE (Per FAR 8.405-6(d)(2) -

Approved Disapproved