5_1_1_IIMD Facilitation Support - BPIMSS- JEFO Exceeding the SAT_Redacted.pdf

www.uscis.gov

Rev: 10/13/2023

Justification for Exception to Fair Opportunity, Exceeding the Simplified Acquisition Threshold, IIMD Facilitation Support

REFERENCE: Justification Log Number: FY25-0020 and PR Number: IMD250006

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to modify an existing task order on behalf of the Immigration Records & Identity Services Directorate (IRIS), Identity and Information Management Division (IIMD) pursuant to Federal Acquisition Regulation (FAR) 16.505(b)(2), Exceptions to the fair opportunity process.

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

The proposed action is for an out-of-scope modification to the Business Process Improvement and Management Support Services (BPIMSS) in support of USCIS/IRIS. Specifically, this modification adds facilitation and project management support services to help realize significant efficiency gains throughout operational processes within the immigration domain. This modification to the BPIMSS Task Order will add a contract line-item number (CLIN) for facilitation and management services to support the Identity and Information Management Division (IIMD) during Option Year Three (3).

The BPIMSS task order is 70SBUR21F00000237, with Federal Management Partners, LLC (FMP), at 2900 South Quincy Street, Suite 200, Arlington, VA 22206-2283. The task order was awarded to support the USCIS Immigration Records & Identity Services (IRIS), Verification Division (VER), and Field Operations Directorate (FOD). The order was awarded as a Firm Fixed Price (FFP) task order under the General Service’s Administration (GSA) One Acquisition Solution for Integrated Services (OASIS) Small business contract.

3. Description of Supplies/Services.

USCIS, Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP) rely on highly specialized contract support in developing project plans and processes, identifying risks and mitigations, and facilitating cross functional meetings to ensure the integrity of an end-to-end digital process. The nature of the requirement is complex and requires large-scale facilitation and coordination amongst the tri-bureau project teams. Specialized facilitation across the tri-bureau is vital to ensure IIMD’s project teams are aware of any issues, new requirements and are following through with enhancing their services based on emerging user needs. IIMD Project teams manage the A-number validation service, which quickly tells officers if an individual already has an A-number, in addition to the A-number issuance service that allows officers to quickly issue the

JEFO, Exceeding the SAT, IIMD Facilitation Support Justification Log Number: FY25-0020 individual an A-number if one does not already exist. Also, IIMD project teams manage the electronic records repository that is utilized for Southwest Border digital A-file processing.

Specialized contract support will be required to facilitate coordination across the tri-bureau and each IIMD project team.

The total dollar amount of the proposed action is The services will be for five (5) months during the BPIMSS Option Year Three (3).

4. Statutory exception and supporting rationale.

The applicable statutory FAR citation and basis for using an exception to fair opportunity process is FAR 16.505(b)(2)(i)(B), only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

Rationale:

IIMD has a need for FMP to facilitate the management of multiple projects in support of redesign and expansion of biometrics, identity and records management services. Develop project plans and processes, identify risks and mitigations, facilitate cross functional meetings, and conduct training.

Facilitating collaborative planning and implementation sessions with stakeholders, within and outside of USCIS, to support the implementation of redesigned USCIS processes. One of the projects is facilitation and project management aspects to support the Southwest Border (SWB) digital A-file efforts current expansion. These high-priority facilitation and consulting services for the SWB digital A-file effort continue to expand, and IIMD will require this support until a new task order is awarded, which will include these services as part of the broader requirement. Since June 2021, USCIS/IRIS/IIMD has partnered with CBP and ICE to transition from paper A-file creation at the SWB to the creation of electronic A-files. The benefits of transitioning to digital immigration processing have enormous impact across components. A conservative estimate of processing time savings is a combined 25 minutes per file between time needed to assemble a paper file, time needed to intake, audit, and ship a paper file, and reduction in time required to validate an identity or consolidate a duplicate of A-number erroneously issued. In addition, there is a conservative cost savings of $25 per file in shipping and management costs. Additionally, with the upcoming change in the Presidential administration there are changes anticipated for this effort, and it will be critical to have facilitation and project management support for these changes.

While these facilitation and project management services were not found to be in scope of the task order due to the number of changes already made and the increase in value that could have changed the extent of competition at the time of award, FMP currently supports IRIS on multiple projects in relation to the tri-bureau for the same type of services. If a contract modification cannot be executed with FMP, it will introduce unacceptable delays which will cause a ripple of negative impacts to the DHS and USCIS SWB mission. The nature of the requirement is complex and requires large-scale facilitation and coordination amongst multiple project teams. There is a significant learning curve associated with commencing support of these projects due to the complexity of immigration operations. FMP will not require any learning curve or training in order to provide value to the tri-bureau. For example, the proposed FMP staff has a proven track record of leading and facilitating

JEFO, Exceeding the SAT, IIMD Facilitation Support Justification Log Number: FY25-0020 multi-day event-storming sessions that involve every component of the tri-bureau to include senior leadership, business and technical subject matter experts. The event-storming facilitation requires in-depth knowledge of the entire end-to-end immigration process to identify the project requirements and associated risks and dependencies. The proposed FMP staff is already intrinsically engrained in the tri-bureau culture with the extensive knowledge of leadership goals and expectations which help drive results across the tri-bureau. Only FMP is capable of providing required services and staffing, at the level of quality required, that is unique and highly specialized. Obtaining a similar service from a different vendor would not meet the needs of the Government. The inability to continue performance would result in failure to deliver on DHS’s Chief Information Officer’s (CIO) SMART Goals, which include, “Streamlining Expedited Removal (ER)/Credible Fear (CF) to increase throughput” and “Full adoption of Electronic A-Files for all new enforcement cases”.

Without contractor support, USCIS, CBP, ICE and DHS HQ will lose contractor support for its vital mission of providing accurate and seamless immigration processing across the SWB of the United States and support for the implementation of any new policy changes by the new Presidential administration. USCIS, ICE and CBP rely on the highly specialized contract support in developing project plans and processes, identifying risks and mitigations, facilitating cross functional meetings to ensure the integrity of an end-to-end digital process. Specialized facilitation across the tri-bureau is vital to ensure IIMD’s project teams are aware of issues, new requirements and are following through with enhancing their services based on emerging user needs. IIMD Project teams manage the A-number validation service, which quickly tells officers if an individual already has an A-number, in addition to the A-number issuance service that allows officers to quickly issue the individual an A-number if one does not already exist. Also, IIMD project teams manage the electronic records repository that is utilized for SWB digital A-file processing. Specialized contract support is required to facilitate coordination across the tri-bureau and each IIMD project team. It can’t be stated enough, this is a high priority initiative for DHS and USCIS Leadership. If FMP’s unique and specialized support is not obtained, goals will not be met, momentum to fully adopt Electronic A-Files for all new enforcement cases across the SWB will be paused, implementation of any new policy changes from the new Presidential administration, and the integrity of services that support timely receipt of benefits will ultimately be at risk.

Market research was completed prior to the contract award. No additional market research was conducted for this action. While there are other vendors capable of performing these services, FMP is the only one capable of providing the services and staffing, at the level of quality required, that is unique and highly specialized.

5. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer determines that the anticipated prices will be fair and reasonable based on an evaluation for reasonableness utilizing one (1) or more analysis techniques identified in FAR Subpart 15.404-1. Since certified cost or pricing data is not required based on the exception at FAR 15.403-1(b)(3), the Contracting Officer may request other than certified cost and pricing data if determined to be necessary in the assessment of fair and reasonable pricing.

6. Any other facts supporting the justification.