1_5_1_FAR Part 6 Justification and Approval for Other Than Full and Open Competition REDACTED Final v3 - DHS Analysis Tool_20260626.pdf

This is a Justification and Approval (J&A) for sole source procurement under 41 U.S.C. 3304(a)(1), permitting other than full and open competition. The Department of Homeland Security's U.S. Citizenship and Immigration Services (USCIS) Office of Contracting proposes to award a firm fixed-price purchase order to Empirical Corporation (137 National Plz Ste 300, National Harbor, MD 20745-1153) for an Accounting Reconciliation & Close tool known as DHS Analysis. The procurement covers tool licenses for 25 users (minimum quantity), support services, and professional services over a base year of nine months, with funding from Operations and Support appropriations in Fiscal Year 2026.

The DHS Analysis tool is proprietary software developed exclusively by Empirical Corporation with sole ownership and no authorized resellers. The tool was designed specifically to address capability gaps in USCIS's legacy Federal Financial Management System (FFMS) to enable monthly, quarterly, and annual account reconciliation and financial statement closure during the agency's transition to the SAP S4/HANA system. USCIS originally targeted October 2026 for migration to SAP but delays have shifted the timeline to fiscal year 2028, requiring continued FFMS operations until SAP implementation. The tool is cost- and time-prohibitive to replicate due to its proprietary algorithms and the significant resources required for redevelopment. No formal solicitation was issued; instead, the contractor provided quoted prices in advance to meet Department policy requiring S1 approval before contract awards. The Contracting Officer determined pricing is fair and reasonable based on historical actuals and comparison to the vendor's GSA schedule and similar IT contract rates. A pre-solicitation notice announcing the sole source intent will be posted, and the redacted justification will be posted to SAM.gov post-award as required by regulation.