Limited Sources Justification-Final.pdf

LIMITED-SOURCES JUSTIFICATION FOR FEDERAL SUPPLY SCHEDULE

PROGRAM

Identity Verification Support Services

Procurement Request Number: MC-I-24-000050

Spend Plan ID: FY24-I-CS-025

The following justification is prepared in accordance with Federal Acquisition Regulation (FAR) 8.405-6(c). The Contracting Officer hereby approves the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3 pursuant to the authority of 41 U.S.C. 251 as implemented by FAR 8.405-6(a)(1)(i)(B).

AUTHORITY

FAR 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.

This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C. 251, et seq. and 40 U.S.C. 501).

1. Identification of the agency and the contracting activity.

Contracting Office Department of Transportation (DOT) Federal Motor Carrier Safety Administration (FMCSA) Office of Acquisitions Management (OAM) 1200 New Jersey Avenue, S.E., Washington, DC 20590.

Program Office

DOT, FMCSA, Office of the Chief Technology Officer (CTO)

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

FMCSA is seeking to award a single firm-fixed price order off of General Services Administration’s (GSA) Multiple Award Schedule (MAS) Federal Supply Schedule (FSS) for Identification Verification Support services in order to reduce and/or eliminate the increased fraud and freight theft throughout the Commercial Motor Vehicle (CMV) industry.

The required support services must be operational as of the date of proposal submission to FMCSA and ready on Day One of the contract. Additionally, the solution must be able to integrate with all of FMCSA’s application programming interfaces (APIs).

3. A complete description of the supplies and/or services required to meet the agency’s needs.

The objective of FMCSA’s requirement is to verify and secure individuals' identities in digital space through the implementation and integration of identity proofing solution with its mission-critical applications and processes. The overarching objectives of the acquisition and implementation of an identity proofing solution are:

• Verify Legitimacy: Ensure that the person claiming an identity is who they say they are, preventing unauthorized access and fraudulent activities. Safeguard individuals from unauthorized use of their personal information for fraudulent purposes.

• Prevent Fraud: Identify and mitigate instances of fraud, including account takeover, false identity creation, and other deceptive practices.

• Enhance Security: Mitigate the risk of unauthorized access, data breaches, and fraudulent transactions by implementing robust identity verification processes. Enable trustworthy and secure digital transactions by ensuring that individuals engaging in online activities are authenticated and authorized.

• Protect Sensitive Data: Prevent the exposure of confidential data by ensuring that only authorized individuals have access to specific resources or services.

The full suite of services required include the identity verification accessible by both mobile device utilizing biometrics and in person at a convenient location. Because of the urgency to get the services in place, the requirement must be currently deployed and operational.

4. An identification of the Limited Source Justification (LSJ) rationale, and if applicable, a demonstration of the contractor’s unique qualifications to provide the required supply or service.

• FAR 8.405-6 (a)(1)(i) (B) – Only one source is capable of responding due to the unique or specialized nature of the work.

IDEMIA Identity & Security USA LLC (IDEMIA) is the sole manufacturer, developer, and provider of the IDEMIA Identity & Verification (ID&V) Platform Product, Workflow Engine, Initial External Interface, Supplemental External Interfaces, and the Document Authentication Software, as well as all supporting Labor Categories.

IDEMIA does not use or own any of the personal data collected during the transaction for anything outside of the required workflow. In the 2023 NIST Report, IDEMIA’s Facial recognition algorithms, which are part of the IDEMIA ID&V Platform Product, achieved the best accuracy of 99.88% in the largest datasets and attained the highest accuracy of 99.9% ever achieved in FRVT (Face Recognition Vendor Test) and far outranked the rest of the submissions in unbiased matching relative to race, gender, and age.

IDEMIA supports and manages directly with 36 State Department of Motor Vehicle (DMV) organizations, making them the only vendor with direct access to 36 DMV Systems of Record (SOR), so they are already very familiar with FMCSA, supporting both the CDL issuance and helping a number of our US State clients with their FMCSA grant applications.

IDEMIA has 1500+ physical locations across the US and US territories available for any applicant needing in-person assistance throughout the FMCSA application process. These centers also provide Transportation Worker Identification Credential (TWIC) Credentialing, which IDEMIA is the only company approved to do so.

Due to the proprietary nature of the software components, the overall system design, system uptime requirements, and the integration required to achieve the defined outcomes for FMCSA, IDEMIA is the only company authorized to provide, install, upgrade, or maintain the software for the IDEMIA ID&V as a Service.

IDEMIA does not have other sales channels, partners, or resellers for this technology. No other vendor is authorized to sell through the IDEMIA GSA Schedule Contract Number GS- 35F-0523U.

5. A determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d) and FAR 8.405-2(d).

The requirement will be awarded utilizing GSA MAS Schedule. GSA has already determined the prices and rates to be fair and reasonable. The CS/CO will consider the level of effort and labor mix proposed to determine the total price reasonableness.

6. A description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted. A statement must be made that the supplies and services are available from the FSS.

FMCSA conducted extensive market research from June 2023 – December 2023. Based on such research, IDEMIA is the only vendor qualified to provide the mission critical services required by FMCSA. IDEMIA has been successfully deployed and serving DHS and TSA’s critical national security identity services and is uniquely positioned and ready to deliver a service quickly since this technology is currently in production and operational. Additionally, IDEMIA has 1500+ physical locations across the US and US territories available for any applicant needing in-person assistance throughout the FMCSA application process. These services are available on the GSA MAS Schedule.

7. Any other facts supporting the limited source justification.

There has been a significant increase in fraud and freight theft throughout the CMV industry.

The fraud occurs in a variety of ways, to include identity theft, hijacking of FMCSA accounts, selling of MC numbers and PIN numbers, fraudulent/fake registrations, etc. The fraud occurring today also includes foreign actors. A recent meeting w/ the FBI identified additional concerns, beyond the monetary loss to the industry and public. Therefore, it is imperative that these services are secured to mitigate all opportunities for fraud and theft.

8. A statement of the actions, if any, the agency will take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for supplies and services is made.

IDEMIA is the only vendor that can provide the full suite of activities required by FMCSA.

Towards the end of the order’s period of performance, the contracting office and program office will work together to complete additional market research to see if any other vendors have deployed comparable solutions while this award is in place.

9. The ordering activity Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief and evidence that the supporting data that form a basis for the justification have been certified as complete and accurate by technical/program personnel.

[SIGNATURE PAGE FOLLOWS]

Certification

Senior Program Official (or designee): I certify that the facts and representations under my cognizance, which are included in this LSJ, and which form a basis for it, are complete and accurate.

Signature Date

Contracting Officer’s Representative (COR): I certify that the facts and representations under my cognizance, which are included in this justification, and which form a basis for this justification, are complete and accurate.

Signature Date

Contract Specialist: I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Signature Date

Contracting Officer: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Signature Date

Chief of the Contracting Office (if over $750,000): I have reviewed this justification and find it be accurate and complete to the best of my knowledge and belief.

Signature Date

Activity Competition Advocate (if > $750K and < $15M): I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Signature Date

Head of Procuring Activity or designee (if $15M < $75M): I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Since this LSJ does not exceed $75M, this review serves as approval.

Signature Date

Date_7: 06/02/24