P00001 47QACA26F0029 Data Science and Analytics Support - J and A-Redacted.pdf

Exception to Fair Opportunity Justification Federal Supply Schedule (FSS) BPA Call Order Modification

Authority: RFO-2025-FSS-GSAR 538.7104-3 and 538.7104-4

(1) Identification of Agency and Activity

• Requesting Agency: Office of Personnel Management (OPM) Human Resources Solutions

(HRS)

• Contracting Activity: GSA Office of Centralized Acquisition Services

• Compliance Statement: This justification is executed pursuant to FAR 8.401 and the requirements for documenting exceptions to fair opportunity under the Federal Supply Schedule program as prescribed in RFO-2025-FSS-GSAR 538.7104-3.

(2) Description of Action

a. Action Type: Modification of FSS BPA Call Order 47QACA26F0029 against BPA No.

47QTCA21D003G_47QTSA25A0030, awarded competitively to Excella Inc. under GSA Multiple Award Schedule (MAS) Contract No. 47QTCA21D003G, for Data Science and Analytics Support Services in support of OPM Human Resources Solutions (HRS).

b. The Call encompasses 30 contractor full-time equivalents (FTEs) performing work under three BPA task areas:

Task Area 2 (Data Acquisition, Preparation, and Analysis); Task Area 4 (Data

Visualization, UI, and UX Design); and Task Area 9 (Project Management and Change Management), as detailed in the Call Performance Work Statement (PWS) dated July 22, 2026.

The Call supports OPM’s mission to maintain the EHRI, eOPF, and HRLOB systems and related services and to collaborate with the OPM Core Human Capital Management (HCM) team to determine which existing capabilities should be integrated, maintained, or retired as part of the governmentwide Core HCM project.

The period of performance is six (6) months from the date of award (December 7, 2026 – June 6, 2027). The Call will be Firm-Fixed Price against BPA hourly rates established in BPA 47QTCA21D003G_47QTSA25A0030 Call Order 47QACA26F0029.

EHRI and eOPF are mission-critical, statutorily required capabilities upon which Federal agencies and Congress depend for human capital decision-making, employees depend for timely access to official personnel records, and the general public rely on for access to timely data about the federal workforce.

c. Estimated Value: [Total estimated value inclusive of base year and all option years.]

i. Estimated Value: The total estimated value for the six month period of performance is $4,984,070.40.

ii. Statutory Basis: This Call order is placed under the authority of FAR Subpart

8.4 (Federal Supply Schedules) against a multiple-award BPA established under FAR 8.405-3. The total estimated value exceeds the Simplified Acquisition

Threshold, requiring this written justification per RFO-2025-FSS-GSAR 538.7104-3(b)(2).

(3) Performance Outcome & Requirement

a. Requirement: [Concise, outcome-based description of services required; see below.]

This Call funds completion of mid-stream work across three related OPM programs (eOPF, HRLOB, and EHRI) - the products and processes OPM currently uses to meet statutory requirements for managing federal workforce data and providing current and former employees access to their personnel records. Each program will be partially replaced by the new governmentwide Core HCM system, now in implementation. In the meantime, significant work is required to maintain existing systems and to determine which processes are retained, replaced, or modified under Core HCM. Each workstream has discrete deliverables that must reach defined completion points before transitioning to a competitively awarded successor. Switching vendors mid-stream would create unacceptable risk to mission-critical systems, statutory deadlines, and the Administration's Core HCM implementation schedule.

eOPF: Four (4) discrete workstreams are mid-stream and must each reach a defined endpoint: (1) Core HCM/eOPF integration, concluding at first customer production in March 2027; (2) three major development projects; external API development to replace current data feeds (December 2027), security model redesign and eOPF account creation (May 2027), and the electronic employee medical folder (eEMF), with delivery required by June 2027 per NARA/OMB mandate; (3) eOPF Operations and Maintenance through system decommissioning in September 2028; and (4) delivery of the Introduction to the Guide to Personnel Recordkeeping training course through December 2027 as a prerequisite to Core HCM customer onboarding.

HRLOB: Seven (7) active workstreams are mid-stream: (1) GPPA Navigator, a live production tool launched July 2026 with approximately 3,100 - 3,400 users per week, in continued development; (2) Data Standards Tool, in active development ahead of a planned late fall 2026 release; (3) GPPA chapter and GHRR updates, including a foundational EHRI Reference Number restructuring that must be carried through all affected chapters before any coherent release can be published; (4) Human Capital Information Model (HCIM) and EHRI Data Standard updates, which feed production payroll and HR systems government-wide; (5) Core HCM program support through the March 2027 go-live milestone; (6) integrated program and project management across all HRLOB workstreams; and (7) ongoing stakeholder communication with agency POCs, OPM policy offices, Federal payroll and HR shared service providers, and GSA.

EHRI: Two (2) primary workstreams are active: (1) Federal Workforce Data site launched in January 2026 that provides the public access to a comprehensive data on the federal workforce and (2) EHRI data ingestion and development where OPM coordinates the monthly receipt, transformation, and analysis of EHRI data sent from 89 data providers covering Executive branch agencies. These workstreams are expected to continue throughout the full period of performance and transition at the end of the period of performance.

The unfinished mission is completing the transition of OPM's eOPF, HRLOB, and EHRI data programs into the governmentwide Core HCM implementation. Core HCM is a

$395.8M, multi-year effort now underway. Specific workstreams across all three programs began under the prior Call and have defined, not-yet-reached completion points.

eOPF: Core HCM/eOPF integration, concluding at first customer production in March 2027. External API development to replace current data feeds, due December 2027. Security model redesign and eOPF account creation, due May 2027. The electronic employee medical folder (eEMF), required by NARA/OMB mandate in June 2027. The Introduction to the Guide to Personnel Recordkeeping training course, a prerequisite to Core HCM customer onboarding, due December 2027.

HRLOB: The Data Standards Tool, in active development ahead of a planned late fall 2026 release. The EHRI Reference Number restructuring, mid-progress across multiple GPPA chapters that must be reconciled together before a coherent release can be published. HCIM and EHRI Data Standard updates feed production payroll and HR systems governmentwide. Core HCM program support through the March 2027 go-live milestone.

EHRI: OPM is beginning work to redesign EHRI's data intake structure for Core HCM, targeted for completion in Fall 2027. This includes consolidating the current 89-provider, 89-feed ingestion model into a significantly smaller number of feeds. This requires mapping which current provider-specific feeds, transformation rules, and validation logic carry forward, consolidate, or retire under the new structure. This work began under the prior Call and is not complete.

These are discrete deliverables with fixed completion points. Several are externally imposed by statute or governing program milestones, including NARA/OMB and the Core HCM go-live. They were in flight under the prior Call and remain incomplete

b. Statutory Exception (Exceeding SAT): Per FAR 8.405-3(c)(3), FAR 8.405-6(a)(1)(i), and RFO-2025-FSS-GSAR 538.7104-3(b)(1), the applicable exception to the requirement for providing fair opportunity is:

i. Urgency: Unusual and compelling urgency, where following the procedures would result in unacceptable delays [Citation: RFO-2025-FSS-GSAR 538.7104- 3(b)(1)(i)].

ii. Unique/Specialized: Not applicable to this action[Citation: RFO-2025-FSS- GSAR 538.7104-3(b)(1)(ii)].

iii. Minimum Guarantee: The order is necessary to satisfy a minimum guarantee established in the FSS BPA [Citation: RFO-2025-FSS-GSAR 538.7104- 3(b)(1)(iv)].

iv. Statutory Authorization: A law expressly authorizes or requires that the purchase be made from a specified source [Citation: RFO-2025-FSS-GSAR 538.7104-3(b)(1)(v)].

(4) Best Value and Pricing

a. Baseline Fair and Reasonable: Ordering activities are not required to make a fair and reasonable price determination for FSS products, services, or solutions at the order level or BPA level as FSS contract pricing has been determined fair and reasonable per RFO- 2025-FSS-GSAR 538.7102-2(d)(2).

b. Order-Level Materials (OLMs): Any OLMs included are not the primary purpose of the order and a price reasonableness determination will be made for each OLM in accordance with RFO-2025-FSS-GSAR 538.7104-2(a)(3).

(5) Future Competition

a. Barriers: Actions to remove or overcome barriers to competition for future acquisitions of these supplies or services are documented here as required by RFO-2025-FSS-GSAR 538.7104-3(c)(2)(vi).

OPM HRS will take proactive steps to ensure that successor data science and analytics support requirements are competed on a full and open basis prior to or upon expiration of BPA 47QTCA21D003G_47QTSA25A0030 on May 30, 2028. Market research will begin no later than Q1 2027, an RFI will be issued no later than Q2 2027, and a competitive solicitation will be targeted for release no later than Q3 2027. Documentation of institutional knowledge will be embedded throughout the follow-on period of performance through quarterly documentation sprints, structured knowledge transfer sessions, and a phased 90-day transition plan executed in the final quarter of performance.

(6) Approvals & Signatures

Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief [Citation: RFO-2025-FSS-GSAR 538.7104-3(b)(iii)].

Signature: _Antonio G. Heredia___ Date: _11/054/2026___

ANTONIO G. HEREDIA