70RSAT18FR0000150 (RSLF-27-00005) - 6 mon Ext JEFO.pdf

Justification for Exception to Fair Opportunity Exceeding the SAT pursuant to Revolutionary FAR Overhaul (RFO) 16.507-6(b)

JEFO No.: FY27-0009

Date: November 3, 2026 PR Number: RSLF-27-00005

This Justification for an Exception to Fair Opportunity is prepared in accordance with the Revolutionary Federal Acquisition Regulation Overhaul (RFO) Federal Acquisition Regulation (FAR) 16.507-6 (b)(3), RFO FAR Class Deviation 26-04, Rev. 1 for RFO FAR Part 16.1

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Office of Procurement Operations (OPO) Science and Technology Acquisition Division (S&TAD) prepared this Justification for an Exception to Fair Opportunity on behalf of the DHS Science and Technology (S&T) Directorate’s Laboratories and Academic Centers.

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

DHS OPO intends to award a six-month extension modification without considering other awardees under task order 70RSAT18FR0000150 awarded against General Service Administration (GSA) One Acquisition Solution for Integrated Services (OASIS) Indefinite Delivery Indefinity Quantity (IDIQ) Contract No. GS00Q14OADU108 provides administrative services and professional support. This task order supports both the Plum Island Animal Disease Center (PIADC) operations and Plum Island Closure & Support (PICS) Program including execution of Program Management Office (PMO) functions, cost estimating, project management, technical program coordination, executive assistant support, procurement/acquisition support and budget support. Without this extension, PIADC would lose critical support services resulting in an unacceptable negative mission impact.

3. A description of the supplies or services required to meet the agency’s need (including the estimated value).

PIADC requires technical and administrative support services to assist with program operations to ensure continued mission execution as the PICS program advances toward facility closure.

Services include support for media inquiries, Congressional visits, community engagements, stakeholder visits and coordinating actions with DHS Press Office and other public affairs-type activities to foster trust in relationships. The six-month extension will provide consistent communications and other required services as a logical continuation of the initial task order. The initial task order and the extension result in the same scope of work to be performed and a continuation of the same requirement.

The value of this six (6) month extension is $685,726.23.

1 FAR Class Deviation 26-04, Rev. 1 for FAR Part 16 was issued as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025. Any subsequent citations to FAR Part 16 in this document will be cited as "RFO FAR" for brevity, and are referring specifically to FAR Class Deviation 26-04, Rev. 1 for FAR Part 16.

4. Identify the exception to fair opportunity and supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited.

RFO FAR 16.507-6(b)(3). The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

Rationale:

Task Order 70RSAT18 FR0000150 was competitively awarded to Booz Allen Hamilton, Inc.

under GSA’s OASIS Indefinite Delivery Indefinite Quantity (IDIQ) contract no.

GS00Q14OADU108. The period of performance for this Task Order is 10/29/2018 - 11/09/2026.

This extension, 11/10/2026 - 05/09/2027, is to continue the provision of administrative and professional services to assist in supporting the mission and operations of the Plum Island Animal Disease Center and closure objectives of the Plum Island Closure and Support Program.

Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires the information cited RFO FAR 16.507-6(d)(2).

Without the contract extension, the PIADC mission and operations supporting Plum Island closure objectives are jeopardized and significant setbacks in preparing the property for conveyance to GSA will occur. This extension is required to allow for continued market research and development of the best acquisition strategy to support PIADC in its transition to final GSA conveyance.

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

The Contracting Officer will determine that the anticipated cost will be fair and reasonable based on a priced analysis per RFO FAR 15.404-1 (b)(5). In addition, the labor rates under the extension are consistent with the labor rates determined to be fair and reasonable at the time of award.

6. Any other facts supporting the justification.

There are no other facts supporting the justification.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

To ensure offers are solicited from as many potential responsible sources as practicable before any subsequent acquisition, PIADC will complete acquisition planning and market research activities to identify qualified vendors, assess the current marketplace, and develop the acquisition strategy. These efforts will include reviewing available contract vehicles, evaluating potential small business participation, assessing vendor capabilities, refining the Government’s requirements, and determining the most appropriate acquisition strategy for the follow-on effort.

This extension is necessary only to provide continuity of critical services while completing the required pre-award activities for the competitive follow-on acquisition. Extending the current task order will allow sufficient time to complete market research, finalize the acquisition strategy, prepare the solicitation, conduct evaluations, complete award documentation, and make a competitive award in accordance with applicable procurement requirements.

8. DHS intends to post this justification on SAM.gov pursuant to FAR RFO 16.507-6(f).

9. Technical/Requirements Personnel Certification.

Pursuant to RFO 16. 507-6(d)(2)(ix), I certify that this requirement meets the Government' s minimum need and that the supporting data, which forms a basis for the Justification for Exception to Fair Opportunity, are accurate and complete.

/s/ Technical Representative

10. Contracting Officer Certification and Approval Pursuant to RFO 16. 507-6(d)(2)(viii), I certify that this Justification for Exception to Fair Opportunity is accurate and complete to the best of my knowledge and belief.

/s/ Contracting Officer