5.5.1 P00004 JA Telephony OM Modification_Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

LIMITED-SOURCES JUSTIFICATION

ORDERS OR BPAS EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

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4. Authority and supporting rationale and a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

Authority:

Select only one of the following circumstances justifying limiting sources pursuant to FAR 8.405-6(a)(1)(i) below and demonstrate the proposed contractor’s unique qualifications to provide the required supply or service.

☐ 8.405-6(a)(1)(i)(A) An urgent and compelling need exists, and following the ordering procedures would result in unacceptable delays.

☒ 8.405-6(a)(1)(i)(B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

☐ 8.405-6(a)(1)(i)(C) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

Rationale:

The current Task Order for Telephony O&M support (70CTD020FR0000159) ends on

ICE planned to competitively award the recompete in but delays in the technical evaluation shifted the award date to Issuing a four-month interim Task Order to Beacon Telecom Inc will prevent a lapse of service and provide continuity until the new contract is awarded and the transition to the new awardee is completed.

SEVP requires continuous Telephony O&M support. The SRC serves as a single point of contact for all stakeholders seeking information related to F, M, and J inquiries, and SEVP operations. The Telephony O&M support standardizes the support, instruction and regulatory guidance that SEVP disseminates to its key stakeholders, and improved customer service. Currently, the call center provides rapid answers to thousands of queries that fall into seven primary subject areas:

1. Student issues

2. Policy and School Certification issues

3. F, M and J Fee payment status issues

4. SEVIS Batch technical questions and help

5. SEVIS Password technical questions and help

6. Form I-901 Fee payment inquires (Completing the I-901, payment status, general questions.)

7. All other non-IT technical issues

LIMITED-SOURCES JUSTIFICATION

ORDERS OR BPAS EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

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Beacon Telecom is the only contractor qualified to continue providing these services to SEVP on an uninterrupted basis and to allow for continuation of services until the new Task Order is awarded. The time required for a new contractor to receive security clearances and come up to speed with ICE and SEVP policies would result in unacceptable delays. Beacon is currently the only company with the requisite knowledge of SEVP and cleared personnel to immediately continue services. Keeping this contractor in place pending the award and transition of the new contract will ensure continuity of services without extensive delays due to their knowledge and understanding of ICE and SEVP’s environment.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

The Contracting Officer has determined that issuing a modification for continued Telephony O&M support represents the best value and will result in the lowest overall costs, considering price and administrative costs, to meet the Government’s needs. The quoted price will be compared to historical prices and the Independent Government Cost Estimate (IGCE).

Additional discounts will also be requested. As a result, ICE anticipates the proposed price will be fair and reasonable.

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

There are no other facts supporting the justification.

7. Any other facts supporting the limited-sources justification. Additional facts may be stated in this section. If there are no additional facts, you must state that here.

ICE intends to use the time afforded by this extension to provide responses to a pre-award protest received challenging an upcoming new Task Order award.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made.

Once the new award is issued and the transition is completed, ICE will no longer require Telephony O&M support from Beacon and will eliminate the need for any subsequent limited source acquisition to this vendor. ICE is including additional option periods in this Task Order to address any future delays as well as ensure there is sufficient time to transition the requirement if needed.

9. DHS intends to post this requirement on sam.gov pursuant to FAR 8.405-6(a)(2).

LIMITED-SOURCES JUSTIFICATION

ORDERS OR BPAS EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

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10. Technical/Requirements Personnel Certification.

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

Technical Representative/COR Date

11. Contracting Officer Certification and/or Approval

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and complete to the best of my knowledge and belief:

Contracting Officer Date