Limited Source Justification - CLEAR_FINAL_signed.pdf

LIMITED-SOURCES JUSTIFICATION

TO: Kiaira Stallworth, Contracting Officer, IG/M/AOO

FROM: Curtis Lafferty, Director, IG/I/OSD

DATE: July 9, 2025

SUBJECT: Thompson Reuters’ CLEAR Software Limited-Source Justification

In accordance with FAR 8.405-6, the proposed contractual action is pursuant to the statutory authority under the Multiple Award Schedule Program.

1. This document provides the facts and rationale for using limited sources in accordance with FAR 8.405-6.

This is a Limited Source Justification request to utilize Thomson Reuters' GSA schedule, GS-

02F-026DA. The requiring activity is USAID OIG Office of Investigations (OI).

2. The nature and/or description of the action being approved:

This request is for a limited-source acquisition for subscription to access Thomson Reuters’ investigative software services, CLEAR. The action to be awarded is a new, firm-fixed price task order under Thomson Reuters' GSA schedule, GS-02F-026DA, with a total estimated value for the base period of $59,571.39 beginning 8/1/25 through 7/31/26. The contract will have a one-year base period with four one-year option periods. . The services provided by CLEAR include investigative analytics, asset tracing, person and business locators, risk assessments, and fraud detection tools.

3. Description of the supplies or services required to meet the agency’s needs, including the estimated value:

Special agents and analysts in OI require access to Thomson Reuters CLEAR, an investigative research platform offering comprehensive, real-time access to critical public records and proprietary databases essential for investigative functions. It is intended to acquire these investigative tools for a period of one-year base period with up to four (4) one-year option periods to Thompson Reuters in the total estimated amount of $329,187.84.

4. Authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

Only One Source Capable - FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of providing the supplies or services at the level of quality required because the supplies or services are unique or highly specialized.

Thomson Reuters CLEAR is uniquely capable of fulfilling the requirements of OI due to its proprietary access to certain databases, advanced analytics, and unique investigative tools that are not available from other commercial providers.

CLEAR's specialized capabilities, such as proprietary data linking technology, real-time updates from multiple government and private-sector databases, and superior data accuracy, are essential to the agency's investigative effectiveness. Switching providers would significantly degrade investigative capabilities, disrupt ongoing operations, and pose substantial risk to mission-critical activities aimed at combating fraud, waste, and abuse.

Market research and past performance evaluations have confirmed that no other commercially available product provides the same level of comprehensive data integration, accuracy, and investigative functionality as CLEAR. Other systems reviewed lacked either the breadth of available data, the reliability of information, or the analytical capabilities essential for OI operations.

Additionally, reprocuring from another provider would incur substantial operational slow-down requiring investigative personnel to be retrained and redeveloping investigative protocols in addition to the added cost of the training charged by the provider. This reprocurement would also risk mission disruptions and reduced investigative efficacy since OI would lose access to the proprietary databases, advanced analytics, and unique investigative tools Thompson Reuters provides.

5. Determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d).

Under the Federal Supply Schedule (FSS) program, the General Services Administration (GSA) meticulously establishes prices for supplies, fixed-price services, and hourly-rate services. This rigorous process ensures that the prices offered through its schedule contracts are, by definition, fair and reasonable. Consequently, ordering activities are generally relieved of the burden of conducting an independent fair and reasonable price determination. The GSA's pre-negotiated pricing inherently satisfies this requirement, with the singular exception of the price evaluation mandated by FAR 8.405-2(d), which does not apply to the purchase requested herein.

By adhering to the procedures outlined in FAR 8.405 for placing an order against an FSS contract, an ordering activity affirmatively concludes that the order represents the best value—as precisely defined in FAR 2.101—and constitutes the lowest overall cost alternative to fulfill the government's requirements.

While the GSA's comprehensive negotiation process already guarantees fair and reasonable pricing, ordering activities shall pursue further discounts prior to placing an order, as articulated in FAR 8.405-4. The contracting team shall seek a price reduction from Thompson Reuters

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, including reviews of investigative solutions available through

GSA Advantage and GSA eLibrary, consultations with vendors, and review of investigative platforms. Several comparable providers were identified: LexisNexis Risk Solutions, which offers comprehensive public records searches, investigative analytics, fraud detection, and identity verification; TransUnion TLOxp, known for real-time investigative data, location tracking, asset verification, and background investigations; Accurint for Government

(LexisNexis), a direct competitor providing data analytics, background checks, asset tracing, fraud detection, and public records aggregation; IDI Core, which delivers investigative data analytics, public records access, person and asset locators, and fraud detection tools; and Dun

& Bradstreet, specializing primarily in business intelligence, vendor risk assessments, business entity profiling, compliance, and supply-chain investigations. Despite these alternatives, CLEAR was determined uniquely qualified due to its comprehensiveness, superior data accuracy, proprietary analytics capabilities, and specialized investigative tools essential for meeting IG/I’s specific needs.

7. Any other facts supporting the justification:

Thompson Reuters’ CLEAR software’s unique features and their impact on OI’s operations are further detailed below:

Integration with Law Enforcement Databases: CLEAR uniquely integrates with local, state, federal, and international law enforcement and regulatory databases, significantly enhancing cross-agency collaboration, which is vital to OI’s investigative scope covering fraud, corruption, and abuse involving international development and foreign assistance funds.

Continuous Monitoring and Real-Time Alerts: CLEAR offers continuous monitoring capabilities and customizable real-time alerts, critical for proactively identifying emerging risks or suspicious activities, thus directly supporting the OI’s mission to swiftly detect and mitigate fraud schemes.

Data Security and Compliance: CLEAR meets stringent federal data security, privacy, and compliance standards, including FedRAMP and CJIS compliance, ensuring secure handling of sensitive investigative data critical to protecting the integrity of ongoing OI investigations.

Historical Data Continuity: The historical data and ongoing investigations data stored within

CLEAR's proprietary systems cannot easily be transferred or replicated without substantial data migration costs, disruption risks, and potential loss of historical investigative insights critical for ongoing cases.

Expertise and Specialized Training: Investigative staff have received specialized training on

CLEAR's platform. Transitioning to another system would require substantial retraining and incur downtime, adversely impacting ongoing investigative productivity.

Court-Admissible Documentation: CLEAR provides documentation and evidence packages formatted specifically for court admissibility standards, reducing the time and resources required for USAID OIG investigators to prepare and present evidence in judicial proceedings.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

OI will actively monitor developments in investigative software solutions and market conditions to identify potential alternatives capable of meeting agency requirements. It will engage in periodic market assessments, vendor demonstrations, and reviews of emerging technology to determine if alternative solutions can deliver comparable capabilities, accuracy, and effectiveness. Additionally, OI will remain informed through interactions with other federal investigative agencies regarding best practices and software solutions utilized elsewhere in government to enhance competitive sourcing opportunities in future procurements.

9. Technical or Requirement Personnel Certification:

In accordance with FAR 8.405-6(c)(2)(x), I hereby certify the technical statements included above, forming the basis for this justification, are complete and accurate.

Curtis Lafferty Date

Director, IG/I/OSD

10. Contracting Officer’s Certification:

In accordance with FAR 8.405-6(c)(2)(ix), the justification is accurate and complete to the best of my knowledge and belief. Based on the limited source circumstances described above, and in accordance with FAR 8.405-6(c)(2)(xi) and FAR 8.405-6(d)(1), this certification serves as the justification approval.

Kiaira Stallworth Date

Contracting Officer

Reviewed By:

Kelsie Cooley Date

Attorney, Office of General Council