5.1.1-P00001_JOFOC_IDEAL 2.0_6mo-Final_Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

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6.302-3: Industrial mobilization; engineering, development, or research capability; or expert services.

6.302-4: International agreement.

6.302-5: Authorized or required by statute.

6.302-6: National security.

6.302-7: Public interest.

5. Demonstration that the nature of the acquisition requires use of the authority cited.

ICE/OAQ intends to procure additional IT O&M Support Services. Pursuant to FAR 6.302-1:

Only one responsible source and no other supplies or services will satisfy agency requirements.

Contract 70CTD024C00000003 was awarded on September 25, 2024, to ARA on a sole source basis in accordance with FAR 6.302-1 for O&M support services and the continued development of the IDEAL 2.0 system. This contract was to be an interim contract action while the competitive follow-on contract is being procured to avoid a break in service.

It is anticipated that the competitive follow-on contract will be awarded by September 30, 2025. In order to transition to a new vendor, the current contract must be extended to allow for phase-in activities to include on-boarding of new staff, training, and transfer of knowledge of systems, as well as transition-out activities to include delivery of final source code.

ARA is the only source with the needed knowledge and cleared staff capable of providing the extension of IT services without causing a break in services while transitioning to a new vendor. In addition, ARA has developed the current system and is currently the only vendor with access to the current IT application. ARA has modified the system to support the specific needs of the HSI FL. Although a new vendor will be able to provide continued O&M and Enhancement support of the system, it will take several months to transition a new contractor to the daily processes and procedures of the system and require ARA’s assistance to avoid additional extensive delays and unnecessary costs to the Government. If IDEAL is out of commission for even a few weeks, HSI FL’s forensic capabilities will be significantly diminished, which will jeopardize criminal and removal cases since IDEAL is an important technology tool for HSI FL’s forensic examiners. As such, it is in the best interest of the Government to continue receiving support services from ARA until the award and full transition is complete.

6. Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable.

OAQ intends to publicize this requirement, prior to award, as required by subpart 5.2 by posting a notice on sam.gov on August 31, 2025.

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

Page - 3 - of 4

OAQ does not intend to publicize this requirement, prior to award, based on the following 5.202(a) exception: [See FAR 5.202(a) and select one of the 14 exceptions allowed for not publicizing on www.fbo.gov.

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

The Contracting Officer determines that the anticipated price will be fair and reasonable in accordance with FAR 15.404-1(b)(2)(ii): Comparison of the proposed prices to historical prices paid; (iv) Comparison with competitive published price lists for ARA on their General Services Administration (GSA) Multiple Award Schedule (MAS); and (v) Comparison of proposed prices with the Independent Government Cost Estimate (IGCE).

8. Description of market research.

Market research for this effort was conducted from March 22, 2024 through June 21, 2024, to include a Sources Sought Notice to SAM.gov, to gauge industry interest and determine the best strategy to procure this requirement. After significant review of the information by subject matter experts, it was determined that though there are numerous IT vendors in the market that have capabilities and resources to develop an IT application and database such as the library management system (IDEAL 2.0) that was initially developed by DoD and further significantly enhanced by ARA in support of the HSI FL, no other vendors were able to meet the timelines required by the program. Failure to meet program timeline developments would significantly impact operations to include significantly diminished forensic examiner capabilities, jeopardizing criminal and removal cases of the laboratory. ARA has developed the existing system, and their support will be needed to support the transition-in time required to allow for a new vendor. This support consists of the follow-on efforts to on-board new staff, train, and transfer knowledge of systems from ARA to the new vendor, as well as transition-out activities to include delivery of final source code.

9. Any other facts supporting the use of other than full and open competition.

The IDEAL software and database are currently being fully supported and enhancements deployed by ARA to provide laboratory personnel examination capabilities and advanced search tools, which improve efficiency and allow external partners access to this invaluable resource. ARA is currently supporting the partnering with the Transportation Safety Administration (TSA), a critical first step in the process of connecting to external agencies.

The HSI-FL’s document library is the largest repository of travel documents in the U.S. and contains more than 350,000 genuine and fraudulent passports, visas, identification documents, and intelligence information. IDEAL 2.0 serves as the primary means for laboratory personnel to manage these documents. IDEAL is a critical resource necessary to conduct forensic examinations related to counterfeit documents, which can be used to link crimes, streamline investigations, and build powerful prosecutions. IDEAL supports criminal enforcement priorities related to illegal aliens, terrorism, financial fraud, document and benefit fraud, and worksite enforcement. IDEAL 2.0 directly supports Executive Orders (E.O.) 14287 Protecting American Communities from Criminal Aliens, E.O. 14159 Protecting the American People Against Invasion, and E.O. 14161 Protecting The United States from Foreign Terrorists and Other National Security and Public Safety Threats.