Justification and Approval for Other Than Full and Open Competition __Redacted.pdf

Justification & Approval for Other Than Full and Open Competition Template v3.9 (Feb 2026)

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

(41 U.S.C. 3304(a)(1))

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Revolutionary Federal Acquisition Regulation Overhaul (RFO) 6.103 (FAR Class Deviation 25-111) and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity. The Department of Homeland Security (DHS), Federal Law Enforcement Training Centers (FLETC), Procurement Division (PRO), proposes to enter into a contract on a basis other than full and open competition with CMI Management, Inc.

2. Nature and/or Description of the Action being Approved.

PRO intends to procure a 3-month bridge contract on a sole source basis for Facility Support Services (FSS) with CMI Management, Inc, 5285 Shawnee Rd Ste 510, Alexandria, VA.

22312. The Government has a need to continue Facility Support Services (FSS) without interruption as this is a critical support service for the FLETC mission. The services provided by CMI Management, Inc. are needed in the interim to support FLETC Training Delivery Point (TDP) located in Artesia, NM. This contract will bridge the gap short term to ensure continuity in services until the follow-on FSS acquisition is awarded.

The current contract 70LART21CPFB00001 for Facility Support Services (FSS) was awarded to CMI Management Inc. March 5, 2021 with base and four option years. The contract was extended from September 30, 2025 to March 31, 2026 in accordance with FAR 52.217-8 Option to Extend Services to continue services while the subsequent follow-on acquisition was completed. The contract was extended to June 30, 2026 in accordance with FAR 52.237-3 Continuity Services. Phase 1 of the new solicitation has been successfully completed. Phase 2 of the new solicitation commenced with the receipt of a significant influx of questions and inquiries from stakeholders, which necessitated the allocation of additional time and resources to ensure thorough and effective responses. This unexpected volume of questions has impacted on the projected timeline for completion of the solicitation process.

Furthermore, several necessary changes to the solicitation process have contributed to delays beyond the originally anticipated schedule.

As a result of these factors, a contract extension is required through September 30, 2026.

This extension will allow sufficient time to achieve the newly established solicitation milestones.

1 In this document, citations to RFO Parts 6, 10, 15, 25 are citations specifically to FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 R1 for FAR Part 15, and FAR Class Deviation 25-09 R1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

3. Description of Supplies/Services.

Facilities Support Services (FSS) for FLETC, Artesia, NM to include all personnel, supervision, management, equipment, materials, transportation, and supplies required for Environmental Services, Logistical Support, Grounds Maintenance, Custodial Services, Facility & Building Maintenance, and Bio Waste Services.

(a) Type of Action: Firm-Fixed Price

(b) Period of Performance: 07/01/2026 to 09/30/2026

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 41 U.S.C.

3304(a)(1) implemented by the RFO Subpart 6.103-1 entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

CMI Management, Inc is currently performing Facility Support Services at the Federal Law Enforcement Training Centers (FLETC) in Artesia, NM. The services provided by CMI Management, Inc, are essential to support FLETC’s ongoing training mission during the interim period until the competitive follow-on contract is awarded.

It is in the Government’s best interest and the most practical approach to procure these services on a sole source basis from the incumbent contractor. CMI Management, Inc possesses the requisite staffing, equipment, and materials already on site, which enables continuity of operations and mitigates the risk of any interruption to these critical support services for the FLETC mission. Attempting to secure these services from a different source at this time would result in:

1. Substantial Duplication of Costs: The Government would incur significant additional expenses, such as transition costs and mobilization of new resources, which are not expected to be offset or recovered through competition.

2. Unacceptable Delays: Transitioning to a new provider would likely cause delays in fulfilling agency requirements, potentially impacting the FLETC training schedule and mission-critical operations.

For these reasons, proceeding with a sole source procurement to the incumbent contractor is justified to ensure uninterrupted support for the FLETC mission and to avoid unnecessary costs and delays.

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential

Sources as is Practicable.

The current contract was awarded through a competitive process, ensuring that pricing and terms were established in alignment with prevailing market conditions. Comprehensive market research was conducted during the sources sought and pre-solicitation phases, leveraging historical data and assessing market conditions at the time of solicitation to inform the acquisition strategy.

Given the immediate nature of the current requirement and the urgency to proceed with a sole source award, further market research will not be conducted at this time. The prior competitive award and its extensive market analysis provide sufficient justification for proceeding without additional market research for this specific need.

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(s) will be fair and reasonable based on prior acquisition history and pricing of the current contract that was competitively awarded. The contracting officer has determined that the anticipated prices for this contract extension will be fair and reasonable. This determination is based on a thorough review of prior acquisition history, including the pricing established in the current contract, which was awarded through a competitive process. The historical data and competitive award provide assurance that the pricing reflects current market conditions and is consistent with industry standards. As such, the contracting officer is confident that the proposed prices are justified and represent a prudent use of government resources.

8. Description of Market Research.

The current contract was competitively awarded through comprehensive market research conducted during the sources sought and pre-solicitation phases, leveraging historical data and assessing market conditions at the time of solicitation to inform the acquisition strategy.

9. Any Other Facts supporting the use of other than Full and Open Competition.

No other facts are available for this action.

10. A Listing of the Sources, if Any, That Expressed, in Writing, an Interest in the Acquisition.

As outlined above, a request for proposal (RFP) will be issued to the incumbent contractor, CMI Management, Inc., for 3-month Base, Period of Performance July 1, 2026 to September 30, 2026.

11. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any

Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

A bridge contract awarded on a sole source basis is necessary to ensure the continuity of essential services while the competitive procurement process for the follow-on contract is underway. This interim solution will provide uninterrupted support during the period required to complete the competitive acquisition, with the new contract award anticipated in September 2026.

The bridge contract will allow the agency to maintain critical operations and avoid any gaps in service delivery, thereby supporting mission requirements until the competitive process is finalized and the new contract is in place.

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a) Contracting Officer’s Certification. I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

b) Technical/Requirements Personnel Certification. I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

APPROVAL: