CPSTR Justification and Approval REDACTED FINAL.pdf

www.uscis.gov

Rev: 10/13/2023

Other than Full and Open Competition Justification, IAW 41 U.S.C. 3304(a)(1), Card Personalization System Technology Refreshment (CPSTR)

REFERENCE: Justification Log Number: FY24-0045 and PR Number:

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 justification for 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 Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS), Office of Contracting (OCON), proposes to enter a contract on a basis other than full and open competition on behalf of Program Office: Office of Intake and Document Production (OIDP), Document Management Division (DMD).

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

(a) Nature of action:

USCIS OCON intends to procure on a sole source basis ongoing maintenance, optional testing (Contractor’s Functional Qualification Test (FQT), Government System Acceptance Test (SAT), User Acceptance Test (UAT)), and equipment consumables for the Card Personalization System Technology Refreshment (CPSTR) located at the USCIS Production Facilities in Corbin, Kentucky (CPF), and in Lee’s Summit, MO (LPF) to General Dynamics Information Technology (GDIT). CPSTR is an identification card personalizing system which receives card holder data (downloaded from front-end IT systems), personalizes the cards, prepares them for mailing, and provides the systems feedback regarding completion and mailing of cards.

(b) Name and address of the contractor:

General Dynamics Information Technology 3211 Jermantown Rd.

Fairfax, VA 22030

(c) Contract type: Firm Fixed Price

Other than Full and Open Competition Justification, Card Personalization System Technology Refreshment (CPSTR) Justification Log Number: FY24-0045 changes to ensure that the systems can be operated without disruption to other USCIS information systems.

c. CPSTR Software Release and Upgrade Support:

This requirement is to provide support for any new CPSTR software releases (including upgrades to or new data tables), any associated software security hardening, and Security Authorization testing. This requirement also includes upgrades to system software based on changes to the USCIS information systems. The Contractor shall participate in the SELC process and provide all required documentation to accommodate system changes that impact card production operations. This requirement also includes the conversion of any existing CPSTR documents still in Information Technology Lifecycle Management (ITLM) formats to the most recent SELC and Agile template formats as required. When planning for any software releases or upgrades, should these changes drive a hardware change, the Contractor shall ensure uniformity between the CPF and LPF workstations regarding form, fit, function, and equipment consumables.

d. Technical Support:

This requirement is to provide CPSTR related technical support for continuing USCIS operations to include all Section 508 test requirements and all SELC documentation and testing (Technical support includes consulting for the Program Office and any required collaboration with the CPSTR Contractor).

e. Creation of Reports:

This requirement is to provide for development of Oracle queries or Structured Query Language (SQL) code for the creation of customized reports, ad hoc reports, and reports by specific card type or recipient which would pull the data from the CPSTR database.

f. On-site Support:

This requirement is to provide on-site support to perform hands-on hardware and software maintenance on the CPSTR systems at the CPF and the LPF in direct support of the card operations shift scheduling to include 2nd shift or 3rd shift as necessary.

g. Training:

This requirement is to provide system operations training and training documentation packages to the operating staffs of the CPF and the LPF when needed due to software changes, if such changes affect the user interfaces or procedures for any of the CPSTR workstations. The training program and associated material shall be structured such that the trained staff will have the ability to train subsequent hires (“Train the Trainer”). The training shall present material relevant to system operators, inventory controllers, production operators, mailing operations, quality assurance, maintenance, and networking as a minimum.

h. CPSTR Equipment Consumables:

This requirement is to make available with warranty, toner cartridges compatible with the printers currently used in the CPSTR systems, as well as maintenance kits and fusers, card

Other than Full and Open Competition Justification, Card Personalization System Technology Refreshment affixing labels or stamps, postal sealing solution, batching labels, and mailer printer maintenance kits.

4. Authority and supporting rationale.

The statutory authority permitting other than full and open competition is 41 U.S.C. 3304(a)(1) pursuant to FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

GDIT is the only entity authorized to provide maintenance services on all GDIT-owned intellectual property.

5. Identification of exception to the Buy American Statute.

Buy American Statute is not applicable.

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

a. The Card Personalization System Technology Refreshment (CPSTR) is a complex card identification system that is integrated with several USCIS information technology legacy systems to receive data, personalize and issue USCIS Secure Identification Documents which include the USCIS’ Permanent Resident Card (PRC) and the Employment Authorization Document (EAD) cards. The CPSTR system also provides systems feedback regarding completion and mailing of cards, design and is based on an industry unique islands-of-automation architecture that provides a Continuity of Operations (COOP) capability and adds additional production capacity to the overall USCIS production capacity. The CPSTR system is a combination of custom developed hardware, software, and some commercial-off-the-shelf (COTS) systems. The CPSTR system uses an Oracle database server to control the data flow in and out of the CPSTR architecture (This server is Government Furnished Equipment (GFE) but was programmed/configured by General Dynamics Information Technology (GDIT)). The CPSTR system includes data processing, laser etching, envelope stuffing/mailing and robotic technologies, all of which must be properly maintained to reliably produce millions of cards per year, which provide proof of immigration status and benefits for millions of people. The applicable statutory authority that permits other than full and open competition is 41 U.S.C. 3304(a)(1) pursuant to FAR 6.302-1(b)(2) Limited Rights in Data, patent rights, copyrights, or secret processes; the control of basic raw material; or similar circumstances, make the supplies and services available from only one responsible source and no other supplies or services will satisfy agency requirements. This authority suits the requirement best because USCIS does not own the unlimited right to share the detailed software source code/specifications necessary to enable other firms to perform the required services. The CPSTR equipment is mission critical, and the facilities are experiencing higher than normal volumes of card production. Replacing the complete system during the increase in volume production would create an immense backlog in PRC and EAD volumes, greatly impacting the applicants waiting for their immigration documents.

Other than Full and Open Competition Justification, Card Personalization System Technology Refreshment

b. GDIT designed the underlying CPSTR system in USCIS’ Corbin Production Facility (CPF) to include the application software, encoding, and all drivers within the separate workstations that comprise the complete system, tying all components together. GDIT is the sole manufacture of the CPSTR system, and the Government does not possess a detailed Technical Data Package (TDP) for this system. As a result, only GDIT has the technical expertise, inclusive of the software coding knowledge necessary to perform the required maintenance.

c. The CPSTR system cannot be maintained by any other sources because technical data/drawings, test equipment, and training for repair of these Non-Developmental Items were not acquired. While FAR clause 52.227-14 Rights in Data – General was included in the originally competed CPSTR, it did not afford the unlimited right for USCIS to share the detailed software source code/specifications necessary to enable other firms to perform the required services. Thus, GDIT is the only firm with capability to provide software development and equipment maintenance. While USCIS owns the installed system and associated manuals allowing for competition of the operation and day-to-day service maintenance (dusting, lubrication, etc.), the extensive hardware/software maintenance described above requires understanding of the mechanical systems and access to the unique source code developed by GDIT. Without unlimited access to the underlying drawings and specifications to include the source code, no other firm can perform the required services.

d. Maintenance must be performed regularly with corrective actions taken immediately, to ensure the CPSTR system is capable, accurate, and available to meet production requirements 20 hours per/day, 6 days/week and 50 weeks/year. The CPSTR system must also produce over 1200 to 1600 cards per hour (depending on card type) per laser marking station and address envelope inserts with the correct card recipient address information at a rate of up to 1,200 cards per hour.

Without proper preventive maintenance the system would become unreliable, vulnerable to failure, and eventually incapable of producing cards.

e. Buy American Statue is not applicable.

7. Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable.

a. USCIS posted Request for Information (RFI) 70SBUR24I00000006 to GSA eBuy! and SAM.gov on November 3, 2023, which remained open until November 17, 2023, as required by FAR Subpart 5.2. Although six (6) responses were received from interested vendors, it was later determined that the acquisition would only require maintenance of the equipment already in use. GDIT is the Original Equipment Manufacturer (OEM) of the USCIS CPSTR equipment. GDIT is the only entity authorized to provide maintenance services on all GDIT-owned intellectual property including software and hardware, user acceptance testing and qualification testing.

b. In accordance with FAR 12.603, a combined synopsis/solicitation will be issued to the GPE. Any response to the combined synopsis/solicitation will be evaluated in accordance

Other than Full and Open Competition Justification, Card Personalization System Technology Refreshment with the solicitation to determine whether the conclusions of this justification remain accurate prior to proceeding to award.

c. USCIS intends to make this justification openly available pursuant to FAR 6.305 on SAM.gov within 14 days after contract award.

8. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer determines that the final anticipated price(s) to the Government of actions awarded under this J&A will be fair and reasonable based on analysis performed in accordance with FAR 15.404. The basis for this determination will be derived from historical prices paid by the Government over the past 10 years, other than certified cost or pricing data, and technical evaluations.

9. Description of Market Research.

The current CPSTR contract (70SBUR19D00000001) was awarded to GDIT as a sole-source contract on June 13, 2019, which provides the technical expertise, inclusive of software coding knowledge necessary to perform the required maintenance.

Market Research was conducted to support the determination that General Dynamics Information Technology (GDIT) is the only vendor who can meet the agency’s requirements.

As mentioned in Section 7 above, USCIS posted RFI 70SBUR24I00000006 to GSA eBuy!

and SAM.gov on November 3, 2023. When the RFI was issued, the CPSTR requirement included purchasing new equipment. The RFI requested vendors to provide their experience with identification card production, secure document production operations, and centralized high-volume personalized notice printing operations. When the RFI closed on November 17, 2023, six (6) vendors had responded to the RFI. As a result of discussions with the program office and the Procuring Activity Advocate for Competition (PAAC), it was determined that this requirement would be revised and only be for the maintenance of the current equipment that USCIS already has for CPSTR in order to maximize opportunities for competition. Once it was determined that this requirement would only be for the maintenance of the current CPSTR equipment, GDIT’s Senior Program Manager provided an attestation letter confirming GDIT is the Original Equipment Manufacturer (OEM) of the USCIS CPSTR equipment. GDIT is the only entity authorized to provide maintenance services on all GDIT-owned intellectual property including software and hardware, user acceptance testing and qualification testing. GDIT also provides the consumables to ensure shelf life and quality are maintained, and to track production lot issues to differentiate between equipment and consumable issues.

Other than Full and Open Competition Justification, Card Personalization System Technology Refreshment

10. Any other facts supporting the use of other than full and open competition.

As addressed in Section 9, GDIT is the Original Equipment Manufacturer (OEM) of the USCIS CPSTR equipment. GDIT is the only entity authorized to provide maintenance services on all GDIT-owned intellectual property including software and hardware, user acceptance testing and qualification testing. The CPSTR system was designed and developed solely by GDIT with their specific data interfaces, capabilities, and physical footprint/infrastructure. In accordance with FAR 6.302-1 (b)(1)(i) there is a reasonable basis to conclude that the agency’s minimum needs can only be satisfied by unique supplies or services available from only one source.

The requested performance period is necessary to support the equipment and required printing services throughout the development of alternative card-printing technologies that will allow for full and open competition on future requirements.

In order for USCIS to use an alternate source, USCIS would have to procure new equipment, software, and integrate a new system. This would cause substantial duplication of cost to the Government that is not expected to be recovered through competition and would substantially increase the cost of this procurement. The CPSTR equipment is mission critical, and the facilities are experiencing higher than normal volumes of card production. Replacing the complete system during the increase in volume production would create an immense backlog in PRC and EAD volumes, greatly impacting the applicants waiting for their immigration documents.

11. A listing of the sources, if any that expressed, in writing, an interest in the acquisition.

The RFI that was issued on November 3, 2023, asked potential vendors if they had experience with identification card production operation services, high volume personalized notice printing operations and more technical questions. When the RFI closed on November 17, 2023, the following six (6) vendors had responded to the RFI: Transcend IT, LLC., Denamita, SRR International, Inc., Data Cloud Tech, Muhlbauer, and GDIT. As previously mentioned above, it was determined that this requirement would be revised and only be for the maintenance of the current equipment that USCIS already has for CPSTR. Once it was determined that this requirement would only be for the maintenance of the current CPSTR equipment, GDIT’s Senior Program Manager provided an attestation letter confirming GDIT is the Original Equipment Manufacturer (OEM) of the USCIS CPSTR equipment. GDIT is the only entity authorized to provide maintenance services on all GDIT-owned intellectual property including software and hardware, user acceptance testing and qualification testing.

A combined synopsis/solicitation will be issued in SAM.gov on or about Thursday August 28, 2024. Should any response be received to the combined solicitation/synopsis discussed in Section 7 above, the Contracting Officer will verify that the conditions under which this Justification were approved are still applicable prior to proceeding to award.