JOFOC (FAR 6.3) ORR_ONS_CO Signed_CA Signed word_Redacted.pdf

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

Completion Instructions: The Department of Health and Human Services (HHS) has established a standard template for the preparation of a J&A for Other Than Full and Open Competition. If this is an 8(a) set-aside, please note this form is not required unless the acquisition is valued (including all options) at greater than $22 million. This template is NOT applicable for actions using simplified acquisition procedures (FAR Part 13), Federal Supply Schedule orders (FAR 8.4) or task or delivery orders subject to fair opportunity (FAR 16.505).

Tailor all aspects of this template to the individual acquisition. Consult FAR Subpart 6.3 for guidance. An addendum may be added in case additional space is needed.

When this document is printed, the blue italic instructions are automatically deleted on the printed version.

Acquisition Title:

Agency:

Acquisition Year (FY):

Author and Title:

2. Description of Action:

Nature:

New Requirement

Follow-on Requirement

Modification to Existing Purchase Order/Contract Number:

Pricing: ✔Firm-Fixed Price

Cost Time & Materials

Other:

Funds: OMA

See Requisitions ACF345459 and OS345400 ✔ Other Funds:

Name of Proposed Contractor(s): THOMSON REUTERS SPECIAL SERVICES LLC

Street Address:

City, State, Zip:

1410 SPRING HILL RD STE 140

MC LEAN, VA 22102-3008

PSC

Unaccompanied Alien Children Human Trafficking Data Trends Analysis

3. Description of Services or Supplies:

Basis for Approval (FAR 6.303-1(d)): ✔Individual Basis Class Basis

The total estimated value of the proposed action, including all options is $

As applicable, briefly describe the services or supplies required to meet the agency's needs, including make & model number where appropriate. Include quantities of supplies or period of performance for services. Provide information for any options included. If the action is a modification to an existing contract, distinguish clearly between the work covered by the original contract and the work to be obtained by the proposed modification.

The Office of National Security (ONS) and the Office of Refugee Resettlement (ORR) are intend to acquire a software subscription package or modular platform components and services that support mission-critical operations in threat detection, intelligence analysis, and situational awareness. The required capabilities include real-time threat detection and risk modeling, link analysis and investigative mapping, academic research intelligence and innovation tracking, open-source intelligence (OSINT) aggregation with multilingual natural language processing (NLP), and augmented reality geospatial visualization. This justification is for a new award and is not a modification to an existing award. The intended award will be for a Base Period of twelve months and an Option Period for twelve months. The following subscriptions and licensing are included in this acquisition:

-TRSS Subscription: TRSS Data and Technology Solution Used by 1.5 SMEs -RAPID Platform Licenses: 13 UI Licenses for HHS ONS Use -Wirescreen Licenses: 13 UI Licenses for HHS ONS Use -CLEAR licenses: 13 UI Licenses for HHS ONS Use -TRSS Subscription: TRSS Data and Technology Solution Used by 1 SME

4. Authority and Rationale: Identify the statutory authority, FAR title and FAR citation permitting other than full and open competition. It may be one of the following most commonly used citations by the operating divisions of the Department of Health and Human Services (HHS), but other exceptions may apply per FAR Subpart 6.3.

Actions other than simplified acquisition procedures (select only one and provide an explanation):

✔FAR 6.302-1: Only one responsible source and no other supplies or services will satisfy agency requirements, 41 U.S.C.

3304(a)(1) Explain why the intended contractor is the only responsible source who can provide the required supplies or services.

Discuss the unique capabilities, expertise, etc. that support the lack of competition/why no other type of supplies or services will satisfy agency requirements. Explain factors/unique qualifications such as proprietary data or exclusive licensing rights, if applicable. When competition is limited to items particular to one manufacturer, this justification must explain why the particular brand name, product, or feature is essential to the Government's requirements, and that market research indicate s other companies' similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet the agency's needs in accordance with FAR 11.105. If in connection with a follow-on contract for continued development or production of highly specialized equipment, detail the substantial duplication of cost or unacceptable dTeolamyese.t HHS’s mission-critical objectives (human-trafficking/sponsor-fraud detection, situational awareness), Thomson Reuters provides a unique combination of capabilities not reasonably available from other sources, such as:

1. CLEAR’s proprietary and live-gateway data + investigative analytics consolidated in a single platform (including real-time arrest/booking, LPR integrations, credit-header coverage from all three bureaus, and robust entity resolution). These features materially affect detection quality and timeliness.

2. Government-only TRSS services (U.S. subsidiary with independent board and FOCI mitigation) that deliver specialized risk and network analysis, supply-chain assessments, and national-security grade support, which are capabilities HHS requires to frame complex trafficking/sponsor-fraud patterns at scale.

3. Proven relevance to anti-trafficking missions. Thomson Reuters publicly documents CLEAR’s use to support investigations including human-trafficking cases, reinforcing mission fit.

4. Native integration paths (CLEAR System-to-System API, Batch Services, and sanctions/World-Check features) that allow HHS to preserve and extend existing FY25 workflows with minimal disruption and at required performance levels. Competing tools do not offer the same combination of datasets, live feeds, and integrations already in use by HHS.

5. Continuity with existing HHS toolset (TRSS Rapid, CLEAR, and existing integrations with third-party tools such as WireScreen). TRSS offers government solutions and integrations that align with CLEAR and HHS workflows; CLEAR’s APIs allow continued connectivity to current third-party sources. This continuity mitigates operational risk and preserves prior investments in training and data pipelines.

Because the level and quality of the combined datasets, live gateways, entity resolution, and government-only expertise materially influence investigative outcomes and timeliness, only Thomson Reuters (TRSS) can meet the requirement without loss of performance, unacceptable schedule risk, or costly re-engineering., FAR 6.302-2: Unusual and compelling urgency, 41 U.S.C. 3304(a)(2) If unusual and compelling urgency is the basis for the justification, explain the chronological events leading up to the requirement and explain why time constraints cannot permit even a limited competition. Describe the detrimental effects/ serious injury to the mission of the requiring activity or to the government, financial or otherwise, that will result if this justification is not approved. Describe impact of required delivery/performance date. Describe the detrimental effects/ serious injury to the mission of the requiring activity or to the government, financial or otherwise, that will result if this justification is not approved and the product or service cannot be provided by the intended sole source contractor. Failure to plan for expiring funds is not a valid reason for citing this exception. May not exceed one year, including all options, unless the head of the agency determines that exceptional circumstances apply.

FAR 6.302-5: Authorized or Required by Statute, 41 U.S.C. 3304(a)(5) Provide a citation to the statutory authorization and a brief description of its content, or identify the specified source or other agency.

Other (See FAR Subpart 6.3 for additional authority) Provide the authority and citation to the applicable section of FAR 6.3.

Provide a full explanation to justify use of the exception.

4. Agency Actions to Take or Remove Barriers That Led to Other Than Full and Open Competition (If applicable):

Describe the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration prior to any subsequent acquisition for the supplies of services is made. If no such actions have been taken, explain why.

To overcome barriers that led to restricted consideration, the agency may take several proactive steps prior to any subsequent acquisition.

These include conducting broader market research to identify emerging vendors or technologies that could meet the specialized requirements, engaging in industry outreach through Requests for Information (RFIs), and encouraging competition by sharing future requirements with potential suppliers. The agency may also explore opportunities to collaborate with other federal entities to identify alternative solutions or invest in modular procurement strategies that allow for interoperability with future vendors. HHS remains committed to reassessing the market landscape periodically to ensure future acquisitions are as competitive and inclusive as possible.

5. Bridge Contracts:

For contract extensions or bridge contracts when a competitive follow-on is in the process of being developed, summarize history of current contract and explain the reasons for any delays in the acquisition. Include discussion of the milestones f or the follow-on action; the milestones should be as efficient as possible. Discuss why it would be neither cost effective nor realistic to expect another contractor to perform during the brief interim period; include issues such as start -up costs, phase-in, transfer of GFP, recruitment and staffing, etc. If the action is because of a protest, provide a brief discussion of the protest including the date the protest was filed and the basis of the protest. Explain that the action will provide the minimum quant ity or performance period.

N/A

6. Actions to Increase Competition:

Describe efforts made to compete the action, including whether a notice was or will be publicized as required by FAR Subpart

5.2 or which exception under FAR 5.202 applies. If a notice was publicized, discuss the number of written responses to the synopsis and the results of the assessment of the written responses. List sources, if any, that expressed, in writing, an interest in the acquisition. Provide rationale if interested sources were rejected. If applicable, state that no other sources have expressed interest, but all offers received shall be considered. Describe what actions will be taken to increase competition before subsequent acquisition of the supplies or services is required. You may state that an action is a one-time requirement, but if a similar requirement arises, every effort will be made to compete it to the maximum extent possible. If action is sole source because of proprietary data or licensing rights and there will be a continuing need for the requirement, there must be evidence that advanced planning has been initiated to overcome the barriers to competition, or there should be documentation to support an analysis that replacement costs/licensing purchase costs outweigh the benefits of competition. If the action is a contract extension or bridge, explain actions to compete the follow-on. If action is an urgent new requirement and a competitive follow-on is anticipated, explain that efforts are underway to facilitate a full and open competition.

A notice of intent to sole source was publicized on SAM.gov. There were no interested sources indicated on the posting at time of intended award on September 29, 2025. As no sources expressed interest in writing, HHS was not able to consider other offers. As indicated in Section 5 above, HHS will make continued efforts to increase competition for any potential future acquisitions for these licensing and subscriptions.

7. Market Research:

Describe the extent of the market research conducted to identify all qualified sources and the results thereof. “Market Research” is defined as those attempts you made to ascertain whether other qualified sources exist, and can include contact with knowledgeable experts regarding similar or duplicate requirements, contact with industry, results of a sources sought synopsis, or draft solicitations. Research of the marketplace may consist of written, electronic (i.e. email) telephonic, or world wide web inquiries. Lack of advanced planning is not an acceptable reason for the lack of market research, but true urgency may necessitate abbreviated market research that is limited to readily available historical and commercial information. If ac tion is a contract extension or bridge contract, describe the market research efforts underway or completed for the follow-on. See FAR 10.002(b)(2).

Extensive market research was conducted considering GSA vehicles, open market sources, and HHS mandatory use/consideration vehicles to determine whether alternative sources could meet the Government’s specialized requirements. This research included reviewing GSA eLibrary entries, analyzing vendor capabilities through SAM.gov, and consulting industry publications and technical documentation.

Despite these efforts, no other vendors were identified that could offer products or services with the unique features, proprietary data integrations, or mission-specific functionality required by the agency. Comparable products either lacked the necessary features or could not be feasibly modified to meet operational needs. Additionally, a notice of intent to sole source was published on SAM.gov to further market research efforts.

8. Procurement History:

Purchase order or contract number: This is a new requirement

Was action competed? Yes

No

If action was not competed, state the cited authority, summarize rationale, and describe the actions that were supposed to be taken to increase competition and the results thereof:

9. Additional Information to support the justification:

If applicable, explain why technical packages or specifications to facilitate competition were not developed or available;

describe actions taken to remedy the situation.

Additional factors supporting this justification include the urgency of the agency’s mission requirements, the proven track record of the vendor in delivering results within federal environments, and the substantial investment already made in integrating these solutions into existing workflows. TRSS has demonstrated consistent compliance with federal security standards, including data protection and operational integrity. Their platforms are not only technically superior but also uniquely aligned with agency-specific use cases, minimizing risk and ensuring continuity. Attempting to replace or replicate these capabilities would result in significant delays, increased costs, and potential disruption to critical operations, further reinforcing the need to limit sources for this acquisition.

10. Technical / Requirements Certification: By my signature below, I certify that the supporting data included in this J&A is accurate and complete.

Program Manager

Name:

Position Title:

Email address:

Phone:

Program Manager Supervisor (or one level above Program Manager)

Name:

Position Title:

Email address:

Signature:

Date: 09/30/2025

11. Fair and Reasonable Price/Cost Determination: As Contracting Officer, by my signature below, I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable.

Provide the basis for this determination, e.g., describe techniques to be used to determine fair and reasonable price (FAR Subpart 15.402), such as price analysis, cost analysis, cost realism. Per FAR Subpart 15.403-4(a)(1), the threshold for obtaining cost or pricing data is $750,000.

A fair and reasonable determination will be made using price analysis techniques as FAR subpart 15.404 and comparison to the Independent Government Cost Estimate (IGCE).

Name: Phone:

Date: 09/30/2025

12. Contracting Officer's Approval (Required for proposed contract not to exceed $700,000 (value calculated including all options)): I hereby certify that this justification is accurate and complete to the best of my knowledge. I approve this justification subject to availability of funds, and provided that the services and supplies herein described have otherwise been authorized for acquisition.

Signature: Date:

13. Legal Review:

All J&As greater than $68 million must have a legal review from the General Law Division of the Office of the General Counsel prior to sending it to the Department.

14. OPDIV Competition Advocate Approval (Required for proposed contract over $700,000 but not exceeding $13.5 million (value calculated including all options)):

I have reviewed this justification and find that it adequately supports other than full and open competition.

Date:

All J&As greater than $68 million must have a review from the Office of Small & Disadvantaged Business Utilization (OSDBU) prior to sending it to the Department. The OSDBU at their discretion may review any J&A.

15. Office of Small and Disadvantaged Business Utilization Review: (Required for contracts exceeding $68 million (value calculated including all options)):

Concur:

Non-Concur:

16. OPDIV HCA Approval (Required for proposed contract over $13.5 million but not exceeding $68 million (value calculated including all options)):

Name: Phone:

Signature: Date:

17. Department Competition Advocate (Required for contracts exceeding $68 million (value calculated including all options)):

Concur:

Non-Concur:

(The below approval paragraph is required if the cumulative contract value, including all options, exceeds $68 million.)

18. HHS Senior Procurement Executive (SPE) Approval:

Based on the foregoing justification, I hereby approve other than full and open competition for the above stated procurement, subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

State supplies/services being procured:

State the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304: