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JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

10 U.S.C. § 3205

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by Revolutionary FAR Overhaul (RFO) 16.507-6(b)(2) (FAR Class Deviation 26-04 Rev. 11), this justification for an exception to fair opportunity is supported as follows:

1. Agency and Contracting Activity.

Department of Homeland Security, United States Coast Guard (USCG), Headquarters COCO Office 13.

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

(a) Nature of the action: USCG intends to procure on a sole source basis Contractor

Business Operations Support (CBOS) for USCG Financial Service Center (FSC).

(b) Information Technology Coalition, Inc, Doing Business As: ITC Federal 4114 Legato Rd, Ste 850 Fairfax, VA 22033

(c) Contract Type: Firm Fixed-Price Contract

(d) Estimated total value (including options): See table below

Period Duration Unit Price Total Base Period 1 September 2026 – 28 February 2027

6 Months $1,137,510.51

$6,825,063.06

Option Period 1 1 March 2027 – 31 March 2027

1 Month $1,137,510.51 $1,137,510.51

Option Period 2 1 April 2027 – 30 April 2027

1 Month $1,137,510.51 $1,137,510.51

Option Period 3 1 May 2027 – 31 May 2027

1 Month $1,137,510.51 $1,137,510.51

Total $10,237,594.59

(e) Type of funding: Operations and Support

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: 70Z02326Q80000004

(h) Background information about the requirement: The current contract for CBOS was awarded under HSHQDC-17-D-P2004 Order 70Z02322F80000004 and is a firm fixed price task order that expires on 31

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August 2026. It was competed using FAR 16.505 procedures and awarded under the PACTS II vehicle (Functional Category 1, Service-Disabled Veteran-Owned Small Business (SDVOSB) set-aside.

3. Description of Supplies/Services.

The requirement is to obtain professional support services for the FSC. These services support the DHS Financial Systems Modernization Solution (FSMS) within a highly complex, customized Oracle Federal Financials EBS environment. Information Technology Coalition (ITC Federal) delivers mission-critical services, including Department of Homeland Security (DHS)-mandated United States Coast Guard (USCG) Tier 0 support, as well as Trio Tier 1 and Tier 2 helpdesk support.

The Contractor also manages user account administration, incident resolution, root cause analysis, master data maintenance, financial reporting, and audit support for approximately 19,000 users. These services are essential for the USCG, Transportation Security Administration (TSA), and Countering Weapons of Mass Destruction Office (CWMD) to maintain compliant, audit-ready, and reliable financial operations.

4. Exception to Fair Opportunity.

The exception to fair opportunity is RFO 16.507-6(b)(2) – Only one source is capable of responding, due to the unique or specialized nature of the work.

5. Identification of Exception to the Buy American Statute.

N/A

6. Supporting Rationale of the Exception.

Awarding this 9-month bridge contract is the sole mechanism available to avert a critical lapse in mission-essential support for the DHS FSMS. Given the highly customized nature of the USCG, TSA, and CWMD financial environments, the incumbent is the only source that possesses the requisite institutional knowledge and immediate technical fluency required to maintain operations without disruption. Transitioning to a new provider for this short duration would trigger an unacceptable operational risk, introduce a prohibitive learning curve, and result in immediate delays to procurement and audit functions.

ITC Federal, possesses unique, irreplaceable, and in-depth knowledge of the highly complex DHS FSMS (Oracle EBS) environment, its intricate interface dependencies, and the specific business processes unique to USCG, TSA, and CWMD. Its personnel are already cleared, provisioned, and actively delivering DHS Tier 0, 1, and 2 production support to 19,000 users. Because they function as a shared service provider handling master data administration, financial system reporting, and general ledger analysis, their immediate proficiency is paramount. Introducing a new contractor at this

Last Updated 07/23/26 3 juncture would require a minimum 90-to-120-day knowledge transfer and onboarding period. This steep learning curve would immediately result in the exact lapse of service this bridge seeks to prevent, introducing unacceptable risks including stalled financial operations, high transaction error rates, and critical audit deficiencies.

(a) Events Leading to the Situation:

The necessity of this sole-source bridge is driven by an unavoidable convergence of external disruptions: a major organizational restructuring compounded by unprecedented legislative and budgetary volatility.

• Organizational Complexity: The recent transition from the Finance Center

(FINCEN) to the FSC dramatically expanded the organization's scope of technical authority. This restructuring was a major undertaking that re-aligned the entire command into six distinct “product lines,” each with a dedicated focus on a specific area of financial operations:

• Vendor Payment Service Line (VPSL)

• Member and Miscellaneous Payment Service Line (MMPSL)

• Federal Payment and Collections Service Line (FPCSL)

• Public and Member Receivables Service Line (PMRSL)

• External Services Service Line (ESSL)

• Property Management Service Line (PMSL)

This realignment increased both the complexity and interdependencies across these product lines, further contributing to the extended timeline necessary to fully transition, define, and competitively re-procure the associated requirements.

• Legislative Delays: This planned re-procurement was critically delayed by

119 days of government shutdowns (43-day full shutdown in late 2025, and a 76-day partial DHS shutdown in early 2026). These lapses in appropriations required a freeze on all non-exempt procurement activities. Critically, this included halting work on developing new requirements and conducting necessary activities for the re-procurement of a follow-on contract. While incumbent contractors continued to support existing, day-to-day operations, all forward-looking acquisition planning ceased.

(b) Alternatives Considered and Why They Will Not Work:

i. Conducting a New Short-Term Competition: This alternative is neither operationally viable nor fiscally responsible. A competitive procurement (solicitation, evaluation, award) followed by the mandatory mobilization, security clearance processing, and training of a new workforce would take several months. This timeline guarantees a systemic lapse in service.

Furthermore, it is highly uneconomical for the Government to pay duplicative

Last Updated 07/23/26 4 start-up, onboarding, and knowledge-transfer costs for a temporary contractor who would only perform for a matter of months before the long-term, contract is awarded.

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ii. Utilizing In-House Government Personnel: There is no organic capacity within the FSC Government workforce to absorb the incumbent's workload. The daily volume of financial transactions, the specific Oracle EBS technical competencies required, and the bandwidth needed to support 19,000 users far exceed the capabilities of the current civilian and military staff. The federal hiring timeline is entirely too lengthy to address this immediate, critical need.

(c) Impact to the Mission:

If this sole-source justification is not approved, the resulting lapse in service will effectively paralyze the core financial and procurement operations of the USCG, TSA, and CWMD. The catastrophic impacts include:

Incident Management: The absence of contractor support for incident management and financial processing activities would impede FSC’s ability to operate as a reliable, shared service provider, degrading operational continuity for DHS TRIO components. As financial system issues go unaddressed, the accuracy, timeliness, and integrity of DHS component financial data will be compromised, hindering procurement activities, disrupting mission critical payments, and introducing material risk to ongoing audit remediation efforts.

Collapse of Tier 0-2 Support: Critical USCG and DHS TRIO helpdesk functions, master data maintenance, and payment batch processing will cease. Unresolved ServiceNow (SNOW) tickets will exponentially backlog, users will lose access, and financial period maintenance will fail.

Audit and Compliance Failure: As business system issues go unaddressed, the accuracy, timeliness, and integrity of DHS component financial data will be immediately compromised. This disruption will introduce material weaknesses, trigger audit deficiencies, and severely undermine the Department's ongoing financial management and operational resilience initiatives.

7. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable.

These prices were compared to the extension prices provided by the incumbent ITC Federal and found to be consistent with market rates. The contracting officer determines that the anticipated price(s) will be fair and reasonable based on reviewed price lists from GSA schedules of vendors providing similar services.

8. Description of Market Research.

The Government has knowledge of the marketplace for professional accounting support services and recognizes that multiple vendors may be capable of competing for the long-term

Last Updated 07/23/26 6 requirement. Request for Information (RFI) indicates that at least 6 vendors are capable of competing for this requirement, supporting the expectation of robust competition for the consolidated procurement. However, for this short-term action, the issue is not whether other vendors can perform the work. The issue is whether another vendor can continue uninterrupted services in the interest of economy and efficiency as a logical follow-on. Based on the short duration of the follow-on requirement, the current expiration date, the complexity of the accounting support functions, and the need for continuity, ITC Federal is the only practical source for the immediate follow-on period.

9. Other Facts Supporting the Use of Other Than Full and Open Competition.

N/A

10. Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

The FSC is finalizing its requirements in support of the acquisition strategy for the future competitive procurement. The competitive solicitation is on track for release to industry on or about September 28, 2026, and there are no known barriers or concerns that would prevent timely release.

11. 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.

Todd Gerick Date Technical Representative

12. 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.

Carrie Lopez Date Contracting Officer

13. Recommended for Approval or Approval

GERICK.TODD.M.12

73016402

Digitally signed by

GERICK.TODD.M.1273016402

Date: 2026.08.24 14:18:53 -04'00'

LOPEZ.CARRIE.MARIE.1

366321060

Digitally signed by

LOPEZ.CARRIE.MARIE.1366321060

Date: 2026.08.24 14:24:41 -04'00'

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Shreena L. Morris Date Procuring Activity Advocate for Competition (PAAC)

Digitally signed by

MORRIS.SHREENA.LYONS.1144950301

Date: 2026.08.25 15:29:33 -04'00'

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