ITS PandG-Limited Sources Justification_Redacted.pdf

DEPARTMENT OF THE TREASURY

LIMITED-SOURCES JUSTIFICATION

This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

Treasury Standard Form – 1012 (Rev 5/18) Prescribed by Treasury: DTAP 1008.405-6

Tracking No.

1. Identification of the agency and the contracting activity:

The requiring activity is the Office of the Comptroller of the Currency’s (OCC) IT Services Office and the contracting activity is OCC’s Acquisitions Management (AQM) Office 2.a Nature and/or description of the action being approved:

The purpose of this limited-sources justification is to obtain approval to award a labor hour bridge contract with PBG Consulting, LLC for continued services described in section 3.a below. The need date for these items is 9/18/2026. The period of performance will be for 6-months, plus the 6-month option under FAR 52.217-8.

2.b Name of the vendor: PBG Consulting, LLC 2.c Requisition No.: TBD 2.d Bridge contract: Yes No 2.e Brand name: Yes No 3.a A description of the supplies or services required to meet the agency’s needs:

This requirement is a key mechanism that will enable OCC to meet and enforce its internal governance directives and its federal statutory obligations, including:

OCC Directives & Policies: Agency-Level Directives; Enterprise IT Governance Directives; OCC Service Delivery Framework; OCC Information Security Policy;

OCC Risk Management & Compliance Policy; OCC Master Security Control Catalog.

Federal & Statutory Requirements: FISMA; Clinger-Cohen Act; E-Government Act;

OMB Circulars A-130 and A-123; NIST SP 800-53, Cybersecurity Framework, and Risk Management Framework.

By leveraging this requirement, OCC will ensure its IT service delivery processes remain secure, compliant, and auditable, directly supporting its mission to oversee the safety and soundness of the U.S. banking system.

3.b Includes IT: Yes No PSC: DD01 NAICS: 541511 3.c IGCE/Estimated dollar value:

The IGCE is for the 6-month period of performance.

4.a Identification of the authority being used (Check the appropriate box that applies).

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

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.

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 or BPA provided that the original order or BPA was placed in accordance with FSS procedures 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.

FAR 8.405-6(b) – Items peculiar to one manufacturer.

This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

4.b Supporting Rationale:

Previous efforts to recompete this requirement prior to the end of contract 2031JW21F00074 were redirected to bring the services in house by OCC employees. After a transition period, the OCC determined contractor support was still needed but was unable to identify an existing contract vehicle in the required timeframe. The continuation of services under PBG’s GSA order 2031JW21F00074 are needed as the OCC continues efforts to recompete the requirement.

PBG’s order was placed in accordance with FSS procedures, was not previously issued under sole-source or limited source procedures, and the instant requirement is a continuation of the current contract needs.

5. A determination by the ordering activity Contracting Officer that the order or BPA represents the best value consistent with FAR 8.404(d):

The Contracting Officer has determined that the order represents the best value consistent with FAR 8.404(d) and lowest overall cost alternative (considering price, special features, administrative costs) to meet the Government’s needs based on obtaining pricing information from the proposed contractor for the purposes of conducting a price analysis against previously awarded prices and current GSA schedule rates.

6. A description of the market research conducted among schedule holders and the results or a statement why market research was not conducted:

No Treasury Mandatory Sources were identified.

Due to the nature of acquisition, Government market research was not conducted. However, the Government is in the process of seeking competition for these services in subsequent acquisitions.

7.a Any other facts supporting this justification:

The requirements for recompeting this contract are currently under review to determine the new level of effort needed to support tasks . Once defined, the OCC will issue a competitive requirement under GSA MAS or under an exiting Treasury IDIQ contract or BPA, as appropriate.

7.b Attachments: Yes No

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

Not applicable, as described above, the Contracting Activity plans to issue a competitive solicitation . As a result, approval of this sole source provides the Government the necessary time to complete the evaluation process and make a new award.

9. Certifications and Approvals:

9.a Program Office Certification (Requiring Activity). I hereby certify that any supporting information and data provided (e.g., the Government’s minimum needs or requirements, or other rationale for the limited sources) and which form the basis for this justification for an exception to fair opportunity, are accurate and complete to the best of my knowledge and belief.

This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401) knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification.

Name: Date:

Signature:

10.e Senior Procurement Executive (if over $68 million) (Contracting Activity). I have reviewed this limited-sources justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, I hereby approve this limited-sources justification.

Name: Date:

Signature: