CMS JA Bridge Redacted.pdf

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304(a)(1)

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.3 and in accordance with the requirements of FAR 6.303-1, the use of the statutory authority under FAR Subpart 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

1. Agency and Contracting Activity.

The Transportation Security Administration (TSA), Contracting and Procurement (C&P), seeks approval to award a bridge contract for Credentialing Management Support (CMS) in support of the Office of Enrollment Services and Vetting Programs (ESVP) renamed Trusted Traveler & Credentialing (TTC). The bridge will consist of a three-month base with 3 additional one-month options.

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

(a) Nature of action:

This action is a bridge contract to provide technical and biometric capabilities in order to design, produce, and support biometric smart card technology for the Transportation Worker Identification Credential Program (TWIC®). TSA intends to issue the bridge contract for six (6) additional months (implemented as a three-month base period and three one-month options, if necessary) to ensure uninterrupted support while a competitive follow-on task order is finalized and awarded.

(b) Name and address of the contractor:

Identification Technology Partners, Inc. (IDTP) 20251 Century Boulevard, Suite 330 Germantown, MD 20874

(c) Contract type:

Firm Fixed Price (FFP)

(d) Estimated Contract Value:

The estimated value of this bridge is based on the current monthly level of effort reflected in the CMS contract:

Total Action Obligation Value:

Total Contract Action Value:

These amounts are consistent with the established staffing profile and rates under the existing order and do not introduce any new scope or increased level of effort.

(e) Type of funding:

Transportation Worker Identification Credential Program fees

(f) Year of funding:

Fiscal Year 2026

(g) Solicitation number:

70T04026Q7500N005

(h) Background information about the requirement

The TSA Credentialing Management Support (CMS) contract was awarded on 8/23/2021 with a twelve-month base period and four one-year option periods. The contract is currently in the last year of the contract, and the Program Office was in the process of preparing the follow-on documents for the new award. To date, the CMS development has had many delays and setbacks that have impacted the preparation and planning for the follow-on effort. Reduction in Force, Voluntary Early Retirement, employees on extended leave and mandates issued by the Secretary of Homeland Security to reduce spending have impacted Contracting with its ability to execute contract awards according to the milestones set. When the non-exempt employees were required to not perform any work during the 2026 furloughs, the package development could not progress through the procurement phases. The 2026 TSA organizational change and the furloughs have resulted in a shifting of the workforce resulting in multiple Contracting Officers being assigned to this procurement.

An updated acquisition strategy to compete the CMS work was determined the best way forward.

As the current CMS order approaches its August 2026 end date, TSA intends to issue a interim bridge contract for potentially an additional six months (3-month base plus 3 one-month options) to provide the time necessary to compete a new follow-on award without a gap in mission critical support.

(i) Description of Supplies/Services.

TSA requires a bridge contract to provide up to six (6) additional months of continued Credentialing Management Support (CMS) with a three-month base plus three (3) one-month options, for the Office of Trusted Traveler and Credentialing/Program Implementation Branch (TTC/PIB). This short bridge will sustain the full scope of credential management support currently being performed while the competitive follow-on CMS task order is finalized and awarded.

Under this bridge, the contractor will continue to provide non-personal professional services that include, but are not limited to:

Specifications: Annual, review, version update, and publication of a formal TWIC® Security Threat Assessment Program Credential Specification document to include sections detailing:

o Modes of operation o Comparison between PIV, PIV-I, TWIC®, and Next Generation (NEXGEN) TWIC® models o Card application data model and description o Card application command set o Card object identifiers o Details on TWIC® privacy key processing o Considerations for the use of the TWIC® card o Reader requirements, including performance requirements o Support to TSA during Government Accountability Office (GAO) audits of the program o Testing of vendor applets in the event TSA seeks a multisource contract for supply of polycarbonate cards o Access control system requirements, including performance requirements o Information required to support interface or system control documentation o Maintenance after product deployment o Mobile Application production o Projected maintenance/ update schedule to remain compatible

Authentication Publication: Develop enhancements and maintain a publication for facility security officials and stakeholders about access control solutions that incorporate the TWIC® card or application. Write, research and interview subject matter experts on but limited to the following topics:

o History of PIV and TWIC® for identity management o Components and types of access control and systems, with focus on physical access o System modes or types of operation(s) for inspection (validation, verification and authentication) o Strengths and weaknesses of modes or types of inspection o Comparison of biometric and electronic inspection o Key considerations for implementing access control systems o Guidance for transitioning facilities from requiring PIV PIN access to the TWIC profile in access control systems

Post-Publication/Production TWIC Card: Provide support for post-implementation technology matters. The contractor shall be actively involved in the reviewing of code, systems testing, user acceptance testing, providing comments and feedback, and performing quality checks.

Reliability Evaluation & Testing: Assist in evaluating the use and revocation of TTC biometric credentials and/or identifiers issued by TSA and support card reliability evaluation and failure testing activities, observations, and methods in the field to include:

o Technical research, and recommendations on security threat assessment program credential design and functionality to provide operational assistance on the use of the credential in the field and revocation.

o Assist with the identification and resolution of card usage, revocation, and functionality issues in the field, including card reader failures and incompatibility issues. This assistance shall include policy guidance and support related to the revocation of the TWIC®, specifically processes associated with the TWIC® Canceled Card List (CCL), Visual Canceled Card List (VCCL), and Certificate Revocation List (CRL).

o Administer, use, and update the TWIC® program’s card test methodology (i.e., card failure toolkit) to include the conduct of testing activities/steps to review the status of the TWIC® card’s operation and integration with facility and/or vessels access controls and physical access control systems.

o Analyzes cards using nondestructive techniques to identify potential failure modes and suggest changes to specifications that will minimize future failures and increase the reliability of the cards. Conduct failure analysis and provide statistical analysis to preemptively identify failure trends to reduce the issuance failure rates.

o Conduct testing for the following:

Standards Testing - FIPS201, ISO, ANSI, ICAO, and other standard based physical and electrical tests for smart cards Compliance Testing - Testing for compliance to existing specifications and preparation of specifications for future iterations of smart cards Mechanical, Durability, and Reliability Testing (e.g. Accelerated testing, wear testing, and service life prediction) Radio Frequency Tests

Physical Parameters Testing (e.g. Height, width, thickness, corners, bending stiffness, temperature/humidity stability, etc.)

Magnetic Encoding and Stripe Parameters testing IC Card and ID Device Tests (e.g. Static electricity exposure, Bending properties, Torsion properties, Profile of contacts, etc.)

Durability/Life Tests (e.g. Abrasion tests, Flexure tests, Embossed character retention, Chemical resistance, and Environmental exposure, among other testing activities.)

Electrostatic Discharge (ESD) Radio Frequency Tests Mobile Compatibility (Android/ iPhone etc.)

App Compatibility

Derived Credential Assessment: Conduct and develop assessments on costs, benefits, and feasibility of derived credentials for the TWIC® program. TTC is required to issue a physical “biometric transportation security card” for TWIC®, derived credentials may provide more flexible and secure authentication for transportation workers and the vessels and facilities that perform TWIC® inspections.

These services are essential to maintaining continuous, compliant operation of TSA’s vetting and credentialing programs and to ensuring that existing initiatives, performance monitoring, and governance processes remain stable during the transition to the new CMS task order. The Independent Government Cost Estimate (IGCE) provides a detailed cost estimate for the 6 month bridge (three-month base + 3 one-month options, including labor categories, level of effort, and associated costs, and supports the determination that the anticipated cost for this action is fair and reasonable.

3. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. § 3304(a)(1), implemented by the FAR Subpart 6.302-1 entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

4. Identification of Exception to the Buy American Statute

Not applicable to this requirement.

5. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The incumbent contractor is the only responsible source capable of providing uninterrupted support for TTC and CMS during the transition to the new contract. Identification Technology Partners Inc.

currently provides the full spectrum of credential production, issuance and reliability testing of a derived digital or physical credential, smart card technology security features, diagnostics, enrollment services, identity verification and authentication standards under current contract 70T02021F7500N015 and has built detailed, working knowledge of TSA’s vetting and credentialing mission, systems, workflows, and stakeholder environment. The contractor’s staff are already cleared, fully onboarded, and embedded across TTC and CMS operations, including complex TWIC® management workflows, and integrated reporting and analytics that directly support contractor to recruit and clear staff, learn TSA’s mission, tools, and procedures, and rebuild the existing reporting, analytic, and program support cadence – all for a very short bridge period – which beyond the remaining period of performance and conflict with the timing of the planned competitive

CMS

operational environment.

A lapse in support, or a hurried change of contractor for only a brief interim, would pose significant vital national security activities; cause loss of continuity in ongoing initiatives and performance monitoring; and drive additional cost for resources away from completing the c Awarding a bridge contract for a short, defined period is therefore the only practical means to ensure continuous, stable support for TTC and CMS while TSA completes and awards the new competitive CMS task orders.

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

This award will be executed in accordance with FAR 6.302-1 and is limited to the minimum duration necessary to complete the competitive actions.

The long-term requirement is not being acquired on a sole source basis. TSA will compete the follow-on CMS order under full and open competition. together the CMS PWS and the associated Market Research Reports, will form the basis for that competition for the follow-on requirement. A notice will be issued through SAM.gov to notify vendors of the Intent to Sole Source and allow vendors to respond.

7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The bridge contract will be priced at the existing contract rates (as applicable within the GSA MAS structure), which were previously determined to be fair and reasonable through competition and price analysis at award.

The cost for the six-month bridge is based on:

The current order’s labor mix and FTE levels;

The IDTP CMS labor categories and discounted ceiling rates; and The same level of effort is necessary to sustain operations for the additional six months.

Because no significant changes to the level of effort, labor categories, or scope are anticipated for the bridge, and because the duration is strictly limited, the Contracting Officer will be able to determine that the anticipated cost to the Government is fair and reasonable.

8. Description of Market Research.

Market research for this requirement is documented in:

CMS Market Research-ESVP-Credentialing Management Support

This report conclude that the requirement is a commercial services effort under NAICS 54151S (IT Professional Services) and PSC R414 (Support - Professional: Systems Engineering/Technical

Assistance). The research identifies multiple capable small and large business sources under GSA MAS and notes that labor rates and pricing structures are transparent and can be benchmarked against GSA MAS schedules.

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

None.

10. A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

None.

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

No barriers to competition have been identified for the long-term requirement. TSA is already taking concrete steps to ensure full competition, providing fair opportunity and evaluating offers in accordance with FAR ordering procedures. No additional actions are required beyond executing this planned competitive process for the follow-on order.

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.

Date

13. 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

APPROVAL:

28 July 2026