1_1_5_ Financial System Modernization_Sole Source Justification redacted.pdf

Federal Supply Schedule (FSS) Sole Source Justification, Exceeding the Simplified Acquisition Threshold, USCIS OCFO Financial System

Modernization Support Services

REFERENCE:

1. Agency and Contracting Activity.

The Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS), Office of Contracting (OCON), proposes to award a Task Order, on behalf of the Office of the Chief Financial Officer (OCFO) pursuant to RFO 8.401(b), General and RFO GSAM/R 538.7104-3, Sole source justifications and RFO GSAM/R 538.7104-3(b)(ii), Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.

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

USCIS OCON intends to procure on a sole source basis Financial Systems Modernization Support Services from Immersion Consulting LLC., by placing a task order against their General Services Administration (GSA) Multiple Award Schedule (MAS) contract # GS-35F-142BA. Immersion Consulting LLC is located at 2200 Somerville Road Suite 100, Annapolis, MD 214014561.

3. Description of Supplies/Services.

This action will provide continued Financial Systems Modernization implementation support services in support of USCIS OCFO, including activities required to complete design, configuration, data conversion, testing, cutover planning, and initial production stabilization for the USCIS transition to the Departmental SAP S4/HANA environment. SAP S/4HANA is an enterprise resource planning software for large enterprises originally developed by SAP SE, doing business as SAP. The task order will include:

Support for configuration of the USCIS solution within the DHS SAP environment, including validation of configuration decisions and alignment with USCIS business rules.

Data cleansing, master data preparation, data mapping, and migration planning for legacy financial data.

1 In this document, citations to RFO Part 8, RFO Part 2, and RFO GSAM/R 538.71 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-20 for FAR Part 8 and RFO-2025-FSS-GSAR for FAR Part 8, which were 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.

www.uscis.gov

Rev: 06/10/2026

Federal Supply Schedule Sole Source Justification, Exceeding the SAT, Execution support for data conversion activities, including conversion validation, reconciliation, and traceability of converted data to source systems.

Support for system integration testing, user acceptance testing, regression testing, and defect triage and resolution.

Cutover planning and execution support, including readiness assessments, go or no-go decision support, and production deployment coordination.

Initial post go live stabilization and hyper care support to address production issues, monitor controls, and support audit readiness.

The anticipated period of performance is from September 30, 2026, through September 29, 2028.

Performance Period Performance Period Dates Total Value

Base Period (12-months) 09/30/2026 – 09/29/2027

Option Period One (1) (6-months) 09/30/2027 – 03/29/2028

Option Period Two (2) (6-months) 03/30/2028 – 09/29/2028

Total Estimated Price

4. Authority and supporting rationale.

This acquisition is conducted under the authority of Multiple-Award Schedule Program, 41 U.S.C.

152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies. Pursuant to RFO 8.401(b), General, RFO GSAM/R 538.7104-3(b), Sole source justifications, the circumstance that justifies limiting sources to fewer than those required by RFO GSAM/R 538-7103-3 is:

RFO GSAM/R 538.7104-3(b)(1)(ii) Only one source is capable of providing the products, services, or solutions required at the level of quality required because the products, services or solutions are unique or highly specialized.

Rationale:

USCIS is entering the final and most critical phase of its Financial Systems Modernization initiative, targeting an accelerated production go live date of October 1, 2027. This phase involves several interdependent activities on the program’s critical path, such as solution design, business process validation, system configuration, data cleansing, data conversion, testing, defect resolution, cutover planning, and organizational readiness. The incumbent contractor, Immersion Consulting, LLC, has been fully integrated into the program since October of 2023, supporting design and implementation and working closely with USCIS personnel. Through this involvement, the contractor has developed deep, program-specific knowledge that is not fully captured in project documentation and cannot be effectively transferred to a new contractor within the available timeframe.

The incumbent is responsible for essential functions like data cleansing, migration planning, and conversion validation, which require detailed understanding of legacy data, business rules, and prior decisions. Replacing the contractor at this stage would introduce significant risks, including potential misunderstandings of data assumptions, mapping logic, and exception handling, which could compromise data integrity, financial reporting, internal controls, and overall deployment success.

Transitioning to a new contractor would require at least three months, substantial federal and contractor support, and incur unnecessary duplicative costs, diverting critical resources from ongoing implementation activities and causing delays to key milestones.

These milestones—including final configuration, data conversion rehearsals, system testing, cutover readiness, and the production go live date—are driven by Department of Homeland Security requirements, legacy system constraints, and audit schedules. Market research confirmed that while other vendors have general capabilities, none possess the unique combination of USCIS-specific knowledge, experience, system access, and operational readiness required to assume these responsibilities without a disruptive transition period. Therefore, awarding another contractor would create unacceptable risks and delays, jeopardizing the program’s success.

The proposed sole source action is strictly limited to the services and period necessary to complete implementation, production cutover, and initial stabilization. It is not intended to cover unrelated work or extend beyond the immediate need for continuity. This approach ensures that critical path activities continue without interruption, safeguarding the program’s schedule and minimizing risk during this final phase.

The option periods are needed to support post go-live stabilization and subsequent deployment waves. After initial deployment, USCIS will require support for defect resolution, reporting validation, data reconciliation, user support, Standard Operating Procedures (SOP) refinement, and knowledge transfer. Wave 1 will provide the minimum viable product and core functionality for the October 1, 2027 go-live. Wave 2, planned six months later, will add additional reporting, interfaces, and workflow functionality. Wave 3, planned six months after Wave 2, is expected to provide full operational capability and transition toward sustainment. The support required past October 1, 2027 cannot be reasonably segregable, and as stated above the activities are so interdependent making the transition effort unsuitable for a stand-alone competition.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with RFO GSAM/R 538.7102-2(b)(4) and as defined by

RFO 2.101.

Prior to award, the Contracting Officer will determine that the anticipated price is fair and reasonable. The determination will be based on one or more of the following:

Comparison of proposed labor categories, rates, and level of effort to prices paid under the incumbent task order 70SBUR23F00000183 for similar services.

Comparison to the Independent Government Cost Estimate (IGCE) for the requirement.

Evaluation of the relationship between proposed price and the scope, complexity, and risk of the required services.

Use of the price analysis techniques described in RFO 15.404, including comparison to historical prices, catalog or market prices, or other relevant data.

The Contracting Officer will request additional discounts/price reductions before award consistent with RFO GSAM/R 538.7102-2(b)(4) and RFO GSAM/R538.7102-2(c)(2). The Contracting Officer will document the basis for the fair and reasonable price determination in the contract file.

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.

The government conducted market research by reviewing Federal Supply Schedules, DHS -wide vehicles, government-wide agency vehicles and other mandatory strategic sourcing vehicles. During market research it was discovered that Treasury was designated as the Quality Service Management Office (QSMO) for core financial management (FM QSMO) in June 2020. In May 2022, the General Services Administration (GSA), in partnership with U.S. Department of the Treasury (Treasury), established a new Special Item Number (SIN) under the GSA Multiple Award Schedule (MAS) contract vehicles to provide access to commercial information technology offerings of the FM Marketplace. Executive order 14249, “Protecting America’s Bank Account Against Fraud, Waste, and Abuse” was issued in March 2025 and directs agencies to consolidate their core financial systems and use standard solutions available through the FM Marketplace. The FM Marketplace Catalog serves as a storefront showcasing standards-based offerings evaluated by the FM QSMO to support financial system modernizations, sustain current operations, and fulfill a variety of other financial management needs.

A request for capabilities was sent to all 13 Small Business (SB) vendors on FM Marketplace; five responses were received. The Program Management Office evaluated the vendors’ abilities to determine if/how many SB are potentially able to meet USCIS’ requirement.

Based on market research and the current status of the Financial Systems Modernization effort, Immersion Consulting is the only vendor capable of meeting the Government’s requirement within the required timeframe and without unacceptable disruption to the program. USCIS is entering the final FSM phase, Implementation, and Immersion Consulting possesses the incumbent knowledge, project-specific data familiarity, mapping logic, exception-handling history, and implementation context necessary to continue performance without a transition period.

7. Any other facts supporting the sole source justification.

The USCIS Financial Systems Modernization effort is a department level priority that directly supports USCIS ability to maintain reliable financial management, meet statutory financial reporting requirements, and support Department level audit objectives.

Failure to maintain continuity of incumbent support during this final implementation phase would materially increase the risk of:

Delays to the Department directed migration schedule.

Incomplete or inaccurate data conversion and financial reporting.

Disruption to transaction processing and internal controls.

Increased audit findings or inability to support audit assertions.

The schedule constraints necessitating this exception are driven by Departmental timelines, legacy system limitations, and coordination with the Department SAP solution, and are not attributable to a lack of acquisition planning or to the potential expiration of funds.

11. Contracting Officer Certification

Pursuant to RFO GSAM/R 538.7104-3, I certify that the Sole source justification is accurate and complete to the best of my knowledge and belief.

Waynette Goodman

Contracting Officer

APPROVAL: Pursuant to RFO GSAM/R 538.7104-3, I hereby determine the circumstance identified in Section 4 applies.

Amanda K. Duquette Procuring Activity Advocate for Competition Head of the Contracting Activity USCIS, Office of Contracting

WAYNETTE A

GOODMAN

Digitally signed by WAYNETTE A

GOODMAN

Date: 2026.09.08 10:59:23 -06'00'

AMANDA K

DUQUETTE

Digitally signed by

AMANDA K DUQUETTE

Date: 2026.09.09 08:20:39 -04'00'