70CTD020FR0000227 _LIMITED-SOURCES JUSTIFICATION.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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J&A-21-00188

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41

U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity.

Identification of the agency, contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

The Department of Homeland Security, U.S. Immigration and Customs Enforcement (ICE), Office of Acquisition Management (OAQ), on behalf of the Physical Security Operations Unit (PSOU), proposes to modify task order 70CTD020FR0000227 pursuant to FAR 8.405- 6(a), Limiting Sources. This document serves as the “Limited Sources Justification.”

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

(a) Type of action: Modification of Firm-Fixed Price Task Order

(b) Amount the current LSJ is justifying: $9,350,312.06

(c) Brief Description: ICE intends to modify task order 70CTD020FR0000227 on a sole source basis for an increase in value to the following company:

Integrated Security Technologies (IST) 520 Herndon Parkway, Suite C Herndon, VA 20170

3. Description of Supplies/Services.

This requirement will provide enterprise physical access control system (E-PACS) software and hardware upgrades to facilitate the PSOU mission to improve the E-PACS at ICE facilities nationwide. The E-PACS program operates and maintains extensive security components, which includes both software and hardware equipment. This project requires an E-PACS system integrator who fully understands the implementation of highly-specialized IT components to successfully support both Homeland Security Presidential Directive – 12 (HSPD-12) and Federal Information Security Management Act (FISMA). This is a complex implementation, requiring extensive coordination, communication, and technical know-how, expanding this expertise across multiple ICE facilities. This effort requires coordination with PSOU staff, local ICE personnel, and qualified technicians to perform work onsite and to program equipment onto the E-PACS server equipment. The current ICE E-PACS portfolio includes 157 facilities, which are geographically located in 10 GSA Regions in over 38 states. The task order requires the following:

• Program Management

• Enterprise Physical Access Control (E-PACS) implementation experience

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• Migration from Segmented Security Network to Production DHS-ICE Network

• Cyber Security

• Quality Control Processes.

The current task order was awarded to IST on August 8, 2020, in the amount of $4,110,834.50. The proposed action will increase the value of the task order by $9,350,312.06 during Option Period 1, bringing the total amount of the Task Order to $13,461, 146.56.

Period Time Price Total

Base 12 mos. $781,814.65 $781,814.65 Option Year 1 12 mos. $803,334.69 $803,334.69 Option Year 1 Increase 12 mos. 9,350,312.06 9,350,312.06

Option Year 2 12 mos. $825,520.30 $825,520.30 Option Year 3 12 mos. $848,392.06 $848,392.06 Option Year 4 12 mos. $851,772.80 $851,772.80

$13,461,146.56

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

Authority:

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:

In the interest of economy and efficiency, this task order is a logical follow-on to Task Order 70CTD020FR0000227, which was competed against the General Services Administration (GSA), Information Technology Schedule 70, Category 132 62 “Homeland Security Presidential Directive 12 Product and Service Components” , Schedule 84, Category 246 35 7 "Physical Access Control Systems (PACS), FIPS 201 APL and Category 541330SEC, “Security System Integration, Design, Management, and Life Cycle Support. “This task order was awarded to IST on September 16, 2020.

Awarding this Task Order increase to IST is in the interest of economy and efficiency because IST is currently doing work that directly relates to the acquisition of E-PACS.

Programming field devices for the E-PACS involves direct and unrestricted communications to relay technical data to successfully connect software and hardware to the enterprise system. Inserting another vendor into the ongoing E-PACS modernization efforts would lead to conflicting, indirect, and ungainly communication between multiple vendors.

The original Statement of Work (SOW) from 70CTD020FR0000227 required that the agency certified vendor met certain performance standards pursuant to the HSPD-12 mandate. ICE

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OPR has been charged with upgrading the agency's physical access control systems to comply with Federal Identity, Credential and Access Management (FICAM) requirements.

For this reason, it is in the interest of economy and efficiency that the incumbent IST replaces, and updates security hardware components supported by the E-PACS as a logical follow-on to task order 70CTD020FR0000227. Having to recompete the requirement would add unnecessary procurement time, making it less economical.

The existing equipment cannot meet the original SOW’s performance objective without the purchase of this additional equipment. The hardware and software at the field sites are obsolete and end-of-life. The system installer must have experience with field migrations of legacy hardware to new hardware while minimizing operational impacts. For example, under Task Order 70CTD020FR0000227, IST is required to modernize the security infrastructure to comply with HSPD-12. In accordance with HSPD-12, the ICE PACS program requires Public Key Infrastructure (PKI) authentication methods to establish a high degree of confidence in the credentials used for Physical Access to ICE facilities, and as required by the mandate, authentication tools ensuring the binding certificate between the credential and the bearer. As a logical follow-on to the Task Order, this modification updates our existing software and hardware at the local facilities to accomplish the above-stated HSPD-12 mandate.

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 the Task Order modification to IST for the continuation of E-PACS services represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs.

The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates. Discounts to the GSA schedule rates will be requested. Additionally, prior to issuance of the task order modification, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific task being ordered to determine that the total price is reasonable. The contractor’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate (IGCE).

It is likely that award to any other source would result in 1) Substantial duplication of cost to the Government that is not expected to be recovered through competition; or 2) Unacceptable delays in fulfilling the agency’s requirements; 3) Complex and time-consuming coordination between multiple vendors to provide critical services for the E- PACS; in fact, sourcing this requirement through another vendor would severely jeopardize coordination efforts to transition the current E-PACS to the ICE network boundary, thus potentially impacting the E-PACS’ continuity of services, which in turn, could severely and negatively impact business operations for ICE employees nationwide.

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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.

Market research was conducted on idmanagement.gov prior to the award of the modification of Task Order 70CTD020FR0000227. PSOU staff conducted informal market research of the mandated GSA contract vehicles via the internet for all aspects of the proposed modification.

The market research revealed there are 20 potential small businesses and 10 other than small business under SIN 541330SEC (PACS Integrator vendor) that are capable of providing the services. However, IST was the only vendor to submit a proposal and awarded a small-business set-aside task order less than a year ago. The vendor’s products and services have been evaluated and approved under the General Services Administration’s (GSA) FICAM Testing program. It is necessary that agencies procure a FICAM APL compliant PACS solution in accordance with OMB Memorandum M-19-17.

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.

N/A

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.

ICE intends to remove the barriers that lead to restriction completion, by completing the hardware and software upgrades for E-PACS. Upon completion of the required mandates, ICE will eliminate the need for any subsequent limited source acquisition to this vendor and the barriers that lead to restricting competition. ICE will compete future requirements in accordance with the results of market research.

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

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

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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

12. Approval.

Procuring Activity Advocate for Competition Date