U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC) Federal Emergency Management Agency (FEMA) February 2026

SSJ No: 26-111

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

Authority 10 U.S.C. 3204(a)(7)

SSJ No.: 26-111

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103, FAR Class Deviation 25-11 and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under

RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:1

1. Agency and Contracting Activity.

The Office of Chief Financial Officer (OCFO), Financial System Division (FSD), Financial

Systems Modernization (FSM), proposes to enter a contract on a basis other than full and open competition to provide critical support to the FSM effort under authority 10 U.S.C. 3204(a)(7).

Over the past eleven years, Guidehouse has provided continuous FSM PMO, functional, and technical support through the final stages of system implementation. This continuity of support is critical given the program’s current phase and proximity to system go-live. As FEMA approaches deployment, maintaining uninterrupted support across active workstreams is necessary to ensure system stability, data integrity, audit readiness, and operational continuity.

Any disruption to this continuity at this stage would introduce unacceptable risk to program execution and mission delivery.

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

FSM is prepping for an October 1, 2026, go-live, which has been accelerated several times, and requires close and rapid execution to meet this aggressive timeframe. Given the current stage of the FSM program and proximity to system go-live, maintaining continuity of contractor support is critical to ensure successful implementation and transition to sustainment.

The intricacies involved in integrating advanced technology with existing processes necessitate a level of proficiency that FEMA may not currently have. This gap in knowledge could hinder the agency's ability to implement the necessary changes, ultimately affecting its operational efficiency. Therefore, the procurement of Guidehouse's services on a Sole Source basis is essential to ensure the successful modernization of FEMA’s financial systems, thereby

1 In this document, citations to RFO Part 5, RFO Part 6, RFO Part 8, RFO Part 10, RFO Part 15, RFO Part 25, and HSAR Part 3006 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-

17 for FAR Part 5, FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-20 for FAR Part 8, FAR Class Deviation 25-06 for FAR Pary 10, FAR Class Deviation 26-08, Revision 1, for FAR Part 15, FAR

Class Deviation 26-09, Revision 1, for FAR Part 25, and Homeland Security Acquisition Regulation (HSAR)

Class Deviation 25-01 for HSAR Part 3006, which were issued as part of the Revolutionary FAR Overhaul

(RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal

Procurement, signed April 15, 2025.

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC) enhancing the agency's operational capabilities and efficiency. The sole source procurement would be for a bridge contract, and services would only be needed until a competitive award can be made.

(a) Name and address of the contractor.

Guidehouse Inc.

1676 International Dr. STE 800

McLean, VA 22102-3600

(b) Contract type.

FEMA intends to procure a Firm Fixed Price (FFP) Contract.

(c) Estimated total value (including options).

Period Unit Price Total

Base Year

8 mo.

$618,789.08

$4,950,312.65

Total $4,950,312.65

POP End Date is February 17, 2027.

(d) Type of funding.

Operations and Support (O&S) and Procurement, Construction, & Improvement (PC&I).

(e) Year of funding.

Fiscal Year 2026.

(f) Solicitation number.

Multiple Award Schedule: GS-00F-045DA.

(g) Background information about the requirement.

The budget and financial management services procured through this solicitation have been provided to FEMA by Guidehouse since 2015. BPA 70FA4019A00000001 previously supported this work but expired in the Fall of 2024. Multiple task orders from the BPA, which currently facilitate this work, are set to expire in 2026. The intent of this requirement is to continue the support needed. This function is mission-critical; any delays or errors could compromise Department of Homeland Security’s (DHS) ability to track and report billions in procurement spending, risk audit findings, and jeopardize

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC) disaster response. Without this contract, FEMA would face significant challenges in supporting state response efforts, accurately estimating, tracking, and billing cost shares, and ensuring compliance with financial regulations.

3. Description of Supplies/Services. Describe the supplies or services to be acquired. Include the purpose the supplies or services are intended to fulfill or the function the supplies or services provide.

The FSM program will eliminate legacy deficiencies and system gaps by replacing the legacy financial system with a modern Enterprise Resource Planning (ERP) COTS solution, which is essential to the Program Office to fulfil its statutory purposes to modernize its aging 25-year-old financial system that does not support new technology. It is imperative that DHS and FEMA support the modernization of FEMA’s financial system which enables the OCFO, and DHS decision makers, to have current accurate financial information to support disbursement of payments during disaster recovery and the Homeland Security mission (e.g., to prevent terrorism and enhance national and economic security; secure and manage our borders; enforce and administer our immigration laws; safeguard and secure cyberspace; and ensure resilience to disasters).

To successfully implement and sustain FSM, FEMA requires a comprehensive set of services spanning program execution, system support, and operational readiness. These services support the full FSM lifecycle, including final system preparation, go-live execution, and post-go-live stabilization and sustainment.

Required support areas include:

• Program Management

• Project Management

• SAP Functional Support Management

• Organizational Change Management

• Existing sustainment and reporting branch activities

• Audit Readiness

• Communications

• Collaboration and Engagement

• G-Invoicing Support

• E-Gov Travel Service (ETS) ETSNext Support

• General OCFO Functional Support Management

• Optional FSM Services Support

• Help Desk and End-User Support

• Post-Go-Live Sustainment Support

• Reporting and Analytics Support

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

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

The statutory authority permitting other than full and open competition is 41 U.S.C. 3304(a)(2) implemented by the FAR Subpart 6.103-2, entitled “Unusual and Compelling Urgency.”

5. Identification of Exception to the Buy American Statute

N/A

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

(a) Rationale for using the authority cited in section 4 of the J&A;

Pursuant to FAR 6.103-2, Unusual and Compelling Urgency, FEMA has an urgent and compelling need to continue support for the Financial Systems Modernization (FSM) program through a sole-source bridge contract as a logical follow-on to the current effort.

This requirement supports a mission-critical DHS and FEMA OCFO priority to deliver a new financial management system by October 1, 2026. Given the program’s proximity to go-live, FEMA cannot risk disruption in contractor support without jeopardizing system implementation, post–go-live stabilization, and ongoing financial operations.

Continuity of support is essential not only to ensure a successful FSM deployment, but also to mitigate risk to DHS consolidated financial reporting and audit opinion, to which

FEMA is a significant contributing component. Any disruption at this stage would increase the likelihood of audit findings, reporting delays, and reduced confidence in financial data across DHS, which is required by law to obtain an audit opinion.

(b) Details covering what events lead to the situation requiring use of other than full and open competition procedures including whether any portion of the work can be segregated to allow for competition;

At this advanced stage of execution, Guidehouse provides a uniquely qualified workforce possessing specialized skills, certifications, and institutional knowledge that are directly aligned to FSM requirements and cannot be replicated within the remaining timeline.

Guidehouse personnel are fully embedded across all critical FSM workstreams and bring:

• Certified SAP functional and technical expertise (e.g., SAP S/4HANA, FI/CO, FM, and Grants Management), including configuration, integration, and defect resolution tailored to FEMA’s implementation

• Federal financial management and audit expertise, including Certified Public

Accountants (CPAs), Certified Government Financial Managers (CGFM), and professionals experienced in DHS and FEMA financial policies, internal controls

(FMFIA), and audit readiness requirements

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

• Data migration and financial data validation expertise, including reconciliation of legacy-to-target system data, traceability, and audit support

• Organizational Change Management (OCM) and training expertise, including

PROSCI-certified practitioners supporting user adoption in a complex federal environment

• Program and project management leadership, including PMP-certified professionals executing integrated master scheduling, risk management, and governance across FSM workstreams

• Direct experience supporting FEMA OCFO operations, including budget execution, disaster funding, and financial reporting processes

In addition to these credentials, Guidehouse personnel possess deep, program-specific institutional knowledge of FEMA’s FSM configuration, financial business processes, data structures, reporting requirements, and audit landscape. Much of this knowledge is developed through hands-on execution and real-time decision making and is not fully captured in system documentation.

These activities—spanning SAP configuration, data migration, internal control implementation, audit readiness, OCM, and end-user training—are highly interdependent and actively in progress. Continuity of this integrated team is essential to maintaining system integrity and meeting go-live requirements.

While market research confirms that other vendors possess general capabilities in financial system modernization, no other contractor combines the specific SAP implementation knowledge, FEMA OCFO operational experience, federal financial audit expertise, and embedded program continuity required to execute successfully within the remaining timeline.

(c) Summarize alternatives considered and why they will not work; and

Transitioning to a new contractor would require extensive onboarding, including security clearances, system access provisioning, and knowledge transfer across multiple interdependent workstreams. Given the complexity and maturity of FSM and with the extensive short timeline for go-live of October 1, 2026, this transition would introduce unacceptable risk.

(d) Impact to the mission that would result if the J&A is not approved and, consequently, the product or service not provided.

Any disruption at this stage would introduce significant operational, financial, and mission risk, including but not limited to:

• Compromised data integrity during critical migration activities

• Delays or failure to achieve system readiness for go-live

• Increased likelihood of audit findings due to incomplete internal control implementation

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

• Disruption to FEMA’s ability to accurately track and disburse disaster funding

This risk is further compounded by Guidehouse’s integrated support across multiple FSM and OCFO workstreams, where personnel operate in coordinated, cross-functional roles.

Replacing the incumbent would require simultaneous transition across these interconnected activities, significantly reducing the likelihood of successful knowledge transfer.

Given these constraints, the use of other than full and open competition is not based solely on incumbent familiarity, but on the unique combination of certified expertise, program-specific experience, embedded workforce integration, and mission-critical timing.

Guidehouse represents the only responsible source capable of meeting FEMA’s requirements without unacceptable disruption to mission execution.

This risk is further heightened by the introduction of a new DHS auditor during this period, requiring continuity in financial reporting, internal controls, and audit readiness through go-live and stabilization.

Additionally, the overlap with hurricane season (June 1–November 30) and the fiscal year-end (September 30) requires uninterrupted OCFO support. These periods demand stability in personnel and execution to ensure FEMA can continue delivering timely financial assistance to states, tribes, local governments, and disaster survivors.

Using other than full and open competition for this requirement is meant to eliminate anticipated delays in:

• Soliciting, procuring, and implementing a new contract vehicle

• Onboarding new contractor personnel to include security screenings, background checks, interviews, fingerprinting, badging appointments, and equipment distribution

• Training new contractor personnel on systems, policies, and procedures specific to

FEMA

• Integrating new contractor personnel into existing work breakdowns structures and alignments inherent to FEMA

If this J&A is not approved, and there is disruption in contractor personnel and the services administered by said personnel, FEMA’s adherence to numerous congressionally enacted policies and regulations such as the the Chief Financial Officer Act (CFO); Government

Performance and Results Act (GPRA); GPRA Modernization Act of 2010 will result in noncompliance. The inherent knowledge and intimacy with the current modernization effort of moving FEMA from a financial systems architecture that is complex and has been in place starting in 1994 is key to deploying the modern software, stabilizing operations in a new integrated financial system, and ensuring all deliverables are met, including auditability of the modernization and FEMA’s financial statements. The financial system is a critical component of disaster response and any change to contractor personnel at this time, within 4 months of minimum viable product delivery, or Go-Live on October 1, 2026, and subsequent additional required capabilities to build to the full initial operating capability risks disruption

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC) to disaster services. This sole source bridge contract is necessary to ensure uninterrupted progress toward the October 1 go-live deadline, as Guidehouse requires additional time to complete the modernization efforts. This action is not due to a lack of planning, but rather to maintain continuity during this critical phase. Any other vendor would likely be unable to meet FEMA’s specific needs or ensure a seamless business and technical transition for the go-live.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential

Sources as is Practicable.

(a) N/A

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

The contracting officer determines that the anticipated prices will be fair and reasonable based on the acquisition history of prior procurements for similar budget and financial management services. Specifically, the eleven labor categories and corresponding hourly rates from the previous Guidehouse BPA, 70FA4019A00000001, were compared to year 10 pricing from

Guidehouse GSA schedule GS-00F-045DA. This process was guided by the assumption that current rates would be higher as the original BPA was solicited in 2017/2018. When considering all anticipated rate increases, including the Industrial Funding Fee associated with the GSA schedule, it is determined the year 10 rates from GS-00F-045DA are still fair and reasonable.

This point is elaborated in section 9 below.

9. Description of Market Research.

FEMA conducted targeted market research to assess the availability of qualified vendors capable of providing financial management, program management office (PMO), and financial systems modernization support services. This research included review of historical FEMA acquisition data, analysis of vendor capabilities under existing contract vehicles (including the GSA

OASIS+ Unrestricted Contract Vehicle), and evaluation of prior contractor performance supporting FEMA and other CFO Act agencies.

FEMA determined that, while other vendors may be capable of performing similar services under a competed procurement, no other vendor could reasonably transition into this role within the required timeframe without introducing unacceptable risk. A contractor transition at this stage would require an estimated 3–6 months for clearance processing, onboarding, system access, and effective knowledge transfer—exceeding the remaining timeline prior to system go-live. Given the limited time remaining prior to system go-live, these activities could not be completed at a level sufficient to ensure continued program stability and success. The sole source non-competitive award would be a bridge contract for short-term services in order to maintain continuity of services to get this project to completion for go live of 10/1/2026.

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

Without having these services in tack through completion of the project would put the program at risk of not being able to meet the go-live deadline date.

Additionally, Guidehouse personnel are currently embedded across multiple FSM and OCFO functions, with resources supporting concurrent, interdependent activities spanning technical, functional, and program management domains. This level of integration further limits the feasibility of segmenting or transitioning portions of the work to another contractor without disrupting ongoing operations.

As a result, while market research confirms the existence of qualified vendors, it also supports the conclusion that competition at this stage of program execution is not practicable. This is due to critical timing constraints, the current maturity of the program, and the necessity for uninterrupted continuity of services to meet mission objectives and avoid disruption during this pivotal phase. Therefore, use of other than full and open competition is necessary to ensure successful completion of the FSM program through go-live and initial stabilization. Conducting a competitive procurement at this stage would introduce schedule delays and transition risk inconsistent with successful delivery of a mission-critical financial system.

Based on the current GSA data, the hourly rates from GS-00F-045DA are fair and competitive.

Following this research, the program office determined that GSA schedule GS-00F-045DA is most suited for the work required and has a fair and reasonable rate.

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

Based on thorough market research and direct engagement with industry, it is clear that GSA

OASIS+ Unrestricted Contract Vehicle offers the most effective and strategic path forward for this procurement. Although no formal Request for Information (RFI) was issued, extensive outreach—including direct conversations, capability reviews, and analysis of past performance—confirmed the availability of highly qualified vendors with proven experience delivering similar services to FEMA and other federal agencies.

Vendors under the GSA OASIS+ Unrestricted Contract Vehicle bring the right mix of technical expertise, program management acumen, and federal financial systems knowledge necessary to successfully support FEMA’s mission-critical transformation. These firms have consistently demonstrated the ability to manage complex financial initiatives, implement internal controls, and advise on system modernization efforts for CFO Act agencies.

While the GSA OASIS+ Unrestricted contract vehicle provides access to multiple qualified vendors capable of delivering similar services, this requirement is being executed under FAR

6.103-2, Unusual and Compelling Urgency, due to the time-sensitive nature of the FSM program and the proximity to system go-live. As such, competition under OASIS+ is not practicable without introducing unacceptable risk to program execution.

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

This requirement represents a logical follow-on to existing FSM support currently performed by

Guidehouse under expiring task orders. Continuation of services through a bridge contract ensures alignment with the original program structure, avoids disruption in scope, and maintains consistency in execution during a critical transition period.

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

The requirement also coincides with externally driven operational and reporting constraints, including the overlap of hurricane season (June 1–November 30) and the federal fiscal year-end

(September 30). During this time, FEMA’s financial systems must operate without disruption to support disaster response, grants management, and timely disbursement of funds. These operational demands further limit the feasibility of introducing contractor transition risk.

(a)

Additionally, FEMA is subject to government-wide financial management and reporting requirements, including contributions to DHS consolidated financial statements and audit performance. As a significant component of DHS financial reporting, FEMA’s system readiness and stability directly impact DHS’s ability to meet statutory audit requirements and maintain its audit opinion.

From an acquisition perspective, executing a competitive procurement at this stage would not align with federal best practices for Enterprise Resource Planning (ERP) system implementation, which emphasize stability, continuity, and controlled transition through go-live and initial sustainment. Attempting to introduce competition under current conditions would result in unacceptable disruption without providing measurable benefit to the Government.

Accordingly, these factors—logical follow-on continuity, external operational constraints, DHS-level reporting impact, and acquisition best practices—further support the use of other than full and open competition for this requirement.

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

N/A

12. 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.

Once the modernization completes initial operating capability and stabilizes in the new environment, any follow-on efforts are expected to be competed under full and open support to include any operations and sustainment support operations. Due to the complexity of the financial system modernization and inherent audit risk that is actively being mitigated, switching vendors at this time would increase the risk of failure of the system to stabilize operations, risk disaster operations support, and risk the interconnectivity of the financial system environment with the new modern software. Once stabilized, other vendors will be able to support the new modern financial system and accompany system architecture of all sizes with at least fifteen vendors having the ability to provide sustainment support outside of the Department of

Homeland Security’s provided support, as required by mission needs.

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

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U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

13. 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.

Contracting Officer Date

14. 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.

Technical Representative Date

APPROVAL:

Contracting Officer Date

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

Note: The Contracting Officer is the final approving official when the action does not exceed $900K.

Procuring Activity Advocate for Competition Date

Note: The Procuring Activity Advocate for Competition (PAAC) is the final approving official when the action exceeds $900K but is less than or equal to $20M.

Approval by the PAAC is not required if the J&A is reviewed and approved by an official designated by the Component who is a member of the armed services at the general or flag officer level or a civilian in a grade above the GS-15 (or equivalent) level. However, this exception does not apply to justifications citing that cite RFO

6.103-2 Unusual and Compelling Urgency as the authority.

Head of Contracting Activity Date

Note: The HCA is the approving official when the action exceeds $20M but is less than or equal to $90M (less than or equal to $150M for USCG). The HCA is not required to approve the justification if the Component PAAC is a member of the armed services at the general or flag officer level or is a civilian in a grade above the GS-15 (or equivalent) level. HCA may also delegate approval to a member of the armed services at the general or flag officer level or a civilian in a grade above the GS-15 or equivalent level. However, this exception does not apply to justifications that cite RFO 6.103-2 Unusual and Compelling Urgency as the authority per HSAR 3006.104-270 (HSAR Class Deviation 25-01).

Chief Procurement Officer Date

U.S. Department of Homeland Security Justification & Approval for Other Than Full and Open Competition (JOFOC)

Note: The Chief Procurement Officer is the final approving official when the action exceeds $90M (exceeds $150M for USCG) and must also sign the justification when it results in the invocation of the exception to the Buy

American statute at RFO 25.103(b)(2) or 25.202(a)(2), regardless of dollar amount. When CPO approval is required only because RFO 25.103(b)(2) or

25.202(a)(2) is applicable to the procurement, the J&A shall be routed for review and approval using the Buy American Reporting Tool in OCPO’s Enterprise

Reporting Application.