47QMCG26Q0001_USAi_J-and-A_SIGNED.pdf

Federal Acquisition Service

Office of Shared Services Delivery (FD)

LIMITED SOURCES JUSTIFICATION AND APPROVAL

GSAR 538.7104-3(b)(ii) - Only One Source

1. Identification of the agency and the contracting activity.

This Limited Sources Justification is on behalf of the General Services Administration (GSA) Federal Acquisition Service (FAS) and will be executed by the Office of Shared Services Delivery (FD) Office of Contracting Operations

(FDB).

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

This activity intends to award a non-competitive task order against GSA Multiple Award Schedule (MAS) contract 47QTCA25D00CR to Flexion, Inc. for continued agile software development and maintenance services.

3. A description of the supplies or services required.

USAi is a federal artificial intelligence (AI) shared service that enables federal agencies to adopt trustworthy AI rapidly and responsibly. USAi offers shared, reusable capabilities to include chat, application programming interfaces (APIs), management console, flexible model choice, practical model evaluations, and governance support through a secure, multi-tenant platform built for federal use.

USAi is operated as a service that federal agencies depend on. The program is transitioning from an initial trial into a cost-recoverable AI shared service and agency partners expect predictable delivery, secure and trustworthy solutions, reliable operations, and measurable adoption. USAi is delivered through an integrated team of federal and contractor staff. Contractor capacity represents roughly half of the program's delivery capacity. The Government manages strategy, priorities, risk acceptance, model and provider direction, security posture, architecture direction, and agency commitments. The contractor implements within this framework in collaboration with government personnel.

The purpose of this acquisition is to obtain continued platform engineering;

trustworthy delivery; production operations; and agency adoption, evaluation, and governance support that enables USAi to operate as a reliable federal shared service that enables trustworthy AI adoption by agencies.

This support is currently provided under Blanket Purchase Agreement 47QPCA22A0002, Call Order 47QPCA25F0017, in conjunction with other support unrelated to USAi. While Call Order 47QPCA25F0017 includes options, Docusign Envelope ID: 6472A41E-B62B-8118-836E-C0DC37D74FD4 carrying the period of performance beyond September 30, 2026, USAi can no longer be supported under the order. As a result of the FAS 2.0 reorganization, USAi will transition from GSA IT to the Office of Shared Service Delivery in August 2026. The initial contract supporting GSA IT was funded with monies that only the Technology Transformation Services (TTS) has access to under a BPA that is also limited to TTS contracting personnel. The period of performance under the order for these services expires 9/30/2026.

This action will continue to build upon the USAi support delivered under Call Order 47QPCA25F0017 to ensure continued support of this vital program, while allowing GSA adequate time to place a competitive contract action for future support.

It is anticipated that the resultant GSA task order will be for a one-year period of performance from October 1, 2026 - September 30, 2027. The Independent Government Estimate (IGE) was developed utilizing the anticipated level of effort and prices paid for a total of $11,096,486.00. This estimate accounts for a base price of $4,502,976.00 and optional sprints, to be exercised as needed, in the amount of $6,593,510.00. It is anticipated that the resultant order will include FAR clause 52.217-8, Option to Extend Services, allowing for an extension of performance by no more than six months for an estimated $5,548,243.00. If all options are exercised to the fullest extent possible, the total estimate is $16,664,729.00.

4. The authority and supporting rationale.

In accordance with the General Services Administration Regulation (GSAR) 538.7104-3(b)(ii), only one source is capable of fulfilling this need at the level of quality required by the required start date of October 1, 2026, because the services are highly specialized. Flexion, Inc. has been the sole contractor supporting this effort and is the only source capable of transitioning to a new contract action for continued support within the short timeframe. USAi provides agency-facing AI capabilities including chat and APIs across multiple models and providers, supported by a multi-tenant platform with agency isolation, identity, observability, API support, and administrative controls. The platform is cloud-native and runs on a FedRAMP-authorized cloud infrastructure using Cloud Native Computing Foundation (CNCF) projects and AWS FedRAMP -authorized managed services. The service currently sources models from FedRAMP authorized IaaS providers including AWS, GCP, and Azure. Flexion, Inc. is in the unique position to already possess an in-depth knowledge of the USAi framework and they currently maintain the staff appropriate to immediately begin supporting this effort. Additionally, as Flexion is currently performing this work, they already meet the Homeland Security Presidential Directive 12 (HSPD-12) requirements and personnel have passed the required Tier 2 (Moderate Risk) suitability determination required before access to Government data and systems can be provided.

It is vital to the federal agencies across the Government that USAi maintain this support beyond September 30, 2026 to ensure agencies continue to have a controlled environment that meets Federal security standards so they can test AI risks without exposing sensitive government data. Continuation of this service also prevents individual departments from wasting taxpayer money by procuring, authorizing, and building separate AI platforms. Lastly, it streamlines government workflows and upskills the federal workforce to deliver faster, better services to the public.

5. A determination by the ordering activity contracting officer that the order represents the best value.

This requirement will be awarded as a task order under the contractor’s approved GSA schedule. GSA has already determined pricing under schedule contracts to be fair and reasonable, therefore ordering activities are not required to make a separate determination of fair and reasonable pricing. The CO and requiring activity will review the quoted level of effort and the mix of labor for this requirement and make a determination that the total order price is reasonable and in accordance with, or includes discounts off of Flexion, Inc. 's approved GSA Schedule pricing. It has been determined that pursuing a non-competitive order with Flexion, Inc. is in the best interest of the government and represents the best value solution.

6. 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 the supplies or services is made.

The Office of Shared Services Delivery intends to award a long-term contract vehicle for continued and future USAi support. It is anticipated that this contract action will be competed. The purpose of this non-competitive action is to ensure continued support while the long-term competitive acquisition is put in place.

7. The contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

By signing this justification, the Contracting Officer hereby certifies that this justification is accurate and complete to the best of their knowledge.

8. Signatures and Approval

Reviewed By:

Douglas Schmidt Date Procurement Analyst Operational Guidance Division

Michael Evans Date Assistant General Counsel Office of General Counsel (LP)

Approved By:

Reagan P. Criddle Date Contracting Officer (CO) Office of Contracting Operations (FDB)

Docusign Envelope ID: 6472A41E-B62B-8118-836E-C0DC37D74FD4

8/26/2026 | 17:41:12 BST

8/26/2026 | 17:53:36 BST

8/26/2026 | 17:40:48 BST