Redacted - Limited Source Justification.pdf

FOR INTERNAL FRTIB USE ONLY

Limited Source Justification

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CUI//SP-PROCURE

I. AGENCY & CONTRACTING DIVISION

Federal Retirement Thrift Investment Board OCFO Contracting Division 77 K Street N.E., Suite 1000 Washington, D.C. 20002

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

The Federal Retirement Thrift Investment Board (FRTIB) seeks approval to award a sole-source contract to Unison for PRISM Hosting, Operations, and Maintenance Services, including transition of hosting services from the current provider and ongoing support throughout the period of performance.

This action will provide uninterrupted hosting, operations, maintenance, and technical support for the PRISM (Performance Requirements for Information System Management) application, a mission-critical system that supports FRTIB’s core financial and administrative operations. The scope of the requirement includes transition and migration services, secure hosting of production and non-production environments, system operations and maintenance, help desk and incident support, security and compliance support, and service level reporting.

The proposed action is necessitated by the upcoming expiration of the existing Interagency Agreement (IAA) with the Interior Business Center (IBC), under which PRISM is currently hosted. Continued support of PRISM beyond the expiration of the IAA is required to ensure continuity of operations, system availability, data security, and compliance with federal requirements.

This acquisition will result in a contract award to Unison, the original developer, owner, and integrator of the PRISM application. Unison possesses proprietary system knowledge, specialized tools, architectural expertise, and historical configuration data that are essential to performing hosting, operations, and maintenance services without introducing unacceptable technical, security, cost, or operational risk.

The nature of the action is a non-competitive, sole-source award for follow-on services for a proprietary system where no other responsible source can meet the Government’s requirements without substantial duplication of cost or unacceptable risk to mission-critical operations. The contract will establish a sustainable support model for PRISM while minimizing transition risk and ensuring uninterrupted service delivery.

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The estimated total value of this action is $12,465,225.08, inclusive of the base period and all option periods. The period of performance is from November 9, 2026, through November 8, 2031, consisting of a twelve (12)-month base period and four (4) option periods.

III. DESCRIPTION OF THE PRODUCTS/SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS

The Federal Retirement Thrift Investment Board (FRTIB) requires comprehensive hosting, operations, and maintenance (O&M) services to support the PRISM (Performance Requirements for Information System Management) application. PRISM is a mission-critical, highly customized system that supports FRTIB’s core financial and administrative operations and processes sensitive agency data. Continuous availability, operational stability, and compliance with federal security requirements are essential to meeting FRTIB’s mission needs.

The required services include the transition of PRISM hosting services from the current provider, secure hosting of production and non-production environments, and ongoing system operations and maintenance throughout the period of performance. Specifically, the Contractor shall provide secure and resilient hosting infrastructure; system monitoring and administration;

routine maintenance, patching, and updates; application release support; configuration and change management; and compatibility support for all system integrations and interfaces.

In addition, the Contractor shall provide technical support and incident management services, including Tier 1 through Tier 3, help desk support, incident tracking and resolution, root cause analysis, and adherence to defined service level agreements (SLAs) for system availability, response times, and issue resolution. These services are required to ensure timely resolution of issues and to minimize disruption to mission-critical operations.

The scope of services also includes security and compliance support necessary to maintain PRISM in accordance with applicable federal requirements. This includes support for security assessments and audits, vulnerability management and remediation, continuous monitoring activities, and incident reporting, consistent with Federal Information Security Modernization Act (FISMA) and National Institute of Standards and Technology (NIST) standards, and FedRAMP requirements where applicable.

PRISM’s proprietary design, extensive customization, and integration with FRTIB business processes require service delivery by an entity possessing deep application-specific knowledge, historical configuration data, and architectural expertise. These capabilities are necessary to ensure a seamless transition, avoid data loss or system disruption, and sustain long-term system performance and security.

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The products and services described above are required to ensure uninterrupted PRISM operations following the expiration of the current Interagency Agreement and to establish a sustainable, low-risk support model that meets FRTIB’s technical, operational, security, and continuity requirements.

IV. AUTHORITY PERMITTING OTHER THAN FULL AND OPEN COMPETITION

The Federal Retirement Thrift Investment Board is not subject to the Competition In Contracting Act, 41 U.S.C. sec. 3301 et seq., but follows its framework where in the best interest of the participants and beneficiaries of the Thrift Savings Plan. 41 U.S.C. sec.

3101(c)(1)(B); 5 U.S.C. secs. 8472(h) and 8474(c)(1).

Check all that are applicable.

a. Only one responsible source (e.g. – vendor):

Only one responsible source and no other products or services will satisfy FRTIB requirements. Provide an explanation based on the below instructions:

The Federal Retirement Thrift Investment Board (FRTIB) requires continued hosting, operations, and maintenance support for the PRISM (Performance Requirements for Information System Management) application, a mission-critical system that supports the agency’s core financial and administrative operations. PRISM is a highly customized, proprietary application that is deeply integrated with FRTIB business processes and external financial systems. Any disruption to PRISM operations would directly impair FRTIB’s ability to execute its statutory financial management responsibilities.

FRTIB’s current hosting arrangement is provided under an Interagency Agreement (IAA) with the Department of the Interior’s Interior Business Center (DOI-IBC), which expires on November 8, 2026. At the time the IAA was established, DOI-IBC planned to operate PRISM as a shared service for multiple federal agencies, allowing costs and infrastructure to be distributed across multiple customers. Subsequent to contract award, DOI-IBC revised its strategic direction and elected not to onboard additional PRISM customers, resulting in FRTIB becoming the sole tenant in the hosting environment. This materially altered the original assumptions underlying the IAA, including scalability, cost efficiency, and long-term sustainability, and necessitated a reevaluation of hosting options prior to contract expiration.

In response, FRTIB conducted extensive market research over an extended period to identify potential alternatives capable of meeting the agency’s minimum requirements. Alternatives considered included continuing with a federal shared service provider model, transitioning PRISM to other federal shared service providers, using commercial or government-aligned

FOR INTERNAL FRTIB USE ONLY Page 4 of 12 hosting vendors, relying on in-house resources, replacing PRISM with an alternative system, or suspending operations during transition. Each alternative was evaluated against PRISM’s technical architecture, version compatibility, security requirements, integration dependencies, transition complexity, and continuity of operations.

The option of suspending PRISM operations was determined to be unacceptable, as PRISM supports essential financial management functions and processes sensitive agency data. Any interruption would result in immediate operational impacts, including delayed financial processing, increased manual workarounds, heightened risk of data integrity issues, and non-compliance with internal control and reporting requirements.

Use of in-house personnel to host and maintain PRISM was also determined to be infeasible.

FRTIB does not maintain internal infrastructure or personnel with the specialized technical expertise, proprietary system knowledge, and operational tooling required to host and support PRISM independently. Developing this capability would require significant time, cost, and duplication of effort, and would introduce unacceptable risk during the transition period.

Replacing PRISM with an alternative system was likewise determined to be impractical. PRISM is extensively customized to FRTIB’s business processes and replacing it would require a multi-year system acquisition, development, and implementation effort, including data migration, retraining, reauthorization, and interface redevelopment. Such an effort could not be completed within the timeframe required to avoid service disruption upon expiration of the existing IAA and would introduce substantial cost and operational risk.

FRTIB also evaluated other federal shared service providers and commercial hosting vendors.

Market research demonstrated that other providers operate different versions and configurations of PRISM and related systems. Transitioning PRISM to these environments would require significant system modification, version alignment, interface redevelopment, and extensive knowledge transfer. In particular, analysis confirmed that integrating PRISM hosted by one provider with related systems hosted by another would be technically complex, highly disruptive, and cost prohibitive. These alternatives would materially increase transition risk, extend implementation timelines, and elevate the likelihood of service degradation or outage.

The agency’s minimum requirements include uninterrupted PRISM availability; preservation of system configurations and historical data; compatibility with existing interfaces; compliance with federal security and audit requirements; and the ability to execute a transition with minimal operational disruption. Market research concluded that these minimum requirements cannot be met by alternative sources without substantial duplication of cost or unacceptable risk to mission-critical operations.

Timing considerations further constrain the feasibility of competition. While FRTIB began evaluating alternatives well in advance of contract expiration, the complexity of the PRISM system, the need for a carefully managed transition, and dependencies on external approvals

FOR INTERNAL FRTIB USE ONLY Page 5 of 12 significantly limit the time available for a competitive procurement and transition. Even with additional time, competition would not eliminate the fundamental technical and proprietary constraints that restrict the pool of capable sources. Conducting a competitive procurement would require a lengthy phase-in period for any new contractor to acquire system knowledge, rebuild operational understanding, and stabilize the environment, increasing the likelihood of service disruption during transition.

PRISM is a proprietary application, and Unison is the original developer, owner, and integrator of the system. Unison possesses unique knowledge of PRISM’s architecture, historical configurations, interfaces, and operational behavior that is not available to other potential sources. This proprietary knowledge, combined with specialized tools and system documentation, is essential to performing hosting, operations, and maintenance services without introducing unacceptable technical, security, or operational risk.

In addition to the technical and proprietary constraints that limit competition, FRTIB evaluated the cost impacts associated with the available alternatives. While cost was not the determining factor in the decision to use other than full and open competition, the analysis demonstrated that contracting directly with Unison avoids substantial duplication of costs that would be incurred under alternative approaches.

As a result, contracting directly with Unison is expected to reduce operations and maintenance costs by $473,239.90 in FY 27 when compared to continuing the current hosting approach, while simultaneously reducing technical risk and ensuring continuity of mission-critical operations. These cost efficiencies further support the determination that award to Unison represents a reasonable and prudent approach for meeting the agency’s requirements, although the sole-source justification is based on the lack of other responsible sources capable of meeting FRTIB’s minimum requirements without unacceptable risk.

Transitioning PRISM to an alternative provider would require significant system reconfiguration, version alignment, interface redevelopment, and extended stabilization efforts, resulting in increased transition and lifecycle costs. By leveraging Unison’s existing proprietary system knowledge, operational tooling, and historical configuration data, FRTIB avoids these duplicative efforts.

If this justification were not approved and the agency were required to pursue full and open competition, FRTIB would face a high probability of service interruption, increased costs associated with system modification and stabilization, delayed financial processing, and increased operational risk during transition. These impacts would directly affect FRTIB’s ability to perform its financial management responsibilities and maintain compliance with applicable federal requirements. Such outcomes cannot be tolerated given the mission-critical nature of

PRISM.

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Accordingly, based on the system’s proprietary nature, the extensive customization and integration of PRISM, the lack of viable alternative sources capable of meeting minimum requirements, and the unacceptable risk associated with competing this requirement, FRTIB has determined that award to Unison under other than full and open competition is necessary and justified under FAR 6.302-1.

b. Proprietary Software and/or related services:

Proprietary software and/or related services. (Same authority as above).

Limited explanations are needed for these types of products and/or services.

c. Unusual and compelling urgency:

Unusual and compelling urgency (delay in award of a contract would result in serious injury, financial or other, to the FRTIB; not to be used for failure to plan).

Provide an explanation based on the below instructions:

d. Limited Sources (e.g. Offerors):

Provide an explanation based on the below instructions:

V. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED

FROM AS MANY POTENTIAL OFFERORS AS DEEMED PRACTICABLE

The Federal Retirement Thrift Investment Board (FRTIB) conducted comprehensive market research and outreach in accordance with FAR Part 10 to identify and evaluate potential sources capable of providing hosting, operations, and maintenance support for the PRISM (Performance Requirements for Information System Management) application. These efforts were undertaken to ensure all viable alternatives were thoroughly considered prior to determining the need for other than full and open competition.

FRTIB engaged multiple Federal Shared Service Providers (FSSPs), including the Department of the Interior’s Interior Business Center (IBC), the Federal Aviation Administration Enterprise Services Center (FAA ESC), and the Department of the Treasury’s Administrative Resource Center (ARC). These engagements included system demonstrations, technical questionnaire reviews, interagency discussions, and evaluations of hosting approaches, system compatibility, and cost considerations. FRTIB also coordinated with the Financial Management Quality

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Service Management Office (FM QSMO) to assess governance requirements and approval processes associated with transitioning financial system service providers.

In parallel, FRTIB assessed commercial and government-aligned providers through market research activities, including review of GSA contract vehicles and available industry offerings.

This analysis focused on identifying providers with demonstrated experience supporting mission-critical, highly customized government systems within secure operating environments.

FRTIB further conducted technical discovery sessions with PRISM subject matter experts, the incumbent contractor, potential alternative providers, and internal stakeholders. These sessions addressed system version compatibility, configuration requirements, interface dependencies, transition complexity, and operational risks. Findings from these efforts were documented, analyzed, and presented to agency leadership to support acquisition decision-making.

The results of the market research indicated that alternative providers either supported incompatible versions of PRISM, lacked the proprietary system knowledge necessary to meet FRTIB’s minimum requirements, or would require significant system modifications, duplicated efforts, and extended stabilization periods. These factors introduced unacceptable technical, operational, and continuity risks for this mission-critical system.

Based on these findings, FRTIB determined it had solicited and considered all practicable sources. Unison was identified as the only responsible source capable of meeting the requirement without substantial duplication of cost or unacceptable risk to operations.

FRTIB will synopsize its intent to award a sole-source contract to Unison on SAM.gov and will consider any capability statements received prior to award.

VI. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED

COST TO THE AGENCY WILL BE FAIR AND REASONABLE

The Government has determined that the anticipated cost of the proposed sole-source contract to Unison for PRISM Hosting, Operations, and Maintenance Services is fair and reasonable.

FRTIB evaluated cost reasonableness using multiple techniques, including comparison to historical costs under the current Interagency Agreement (IAA) with the Department of the Interior’s Interior Business Center (IBC), review of Rough Order of Magnitude (ROM) estimates obtained during market research, analysis of license and hosting cost components, and assessment of the scope and complexity of the required services. These analyses considered the full lifecycle cost of hosting, operations, maintenance, security compliance, and transition support necessary to sustain PRISM as a mission-critical system.

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The cost analysis demonstrated that contracting directly with Unison avoids substantial duplication of costs that would be incurred under alternative approaches, including system reconfiguration, version alignment, interface redevelopment, and extended stabilization efforts.

By leveraging Unison’s proprietary system knowledge, historical configuration data, and existing operational tooling, the Government avoids unnecessary transition and sustainment costs that would otherwise be required to enable another provider to perform the work.

As a result, the proposed approach is expected to reduce operations and maintenance costs by $473,239.90 in FY 27 when compared to the current hosting model, while also reducing technical and operational risk. Although cost savings were not the basis for the sole-source determination, they provide additional support for the reasonableness of the proposed contract action.

Based on this analysis, the Government concludes that the anticipated price is fair and reasonable in relation to the services to be provided and reflects prudent stewardship of Government resources.

VII. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS, OR A

STATEMENT OF THE REASONS MARKET RESEARCH WAS NOT CONDUCTED

In accordance with Federal Acquisition Regulation (FAR) Part 10, the Federal Retirement Thrift Investment Board (FRTIB) conducted extensive market research to identify potential sources capable of providing hosting, operations, and maintenance services for the PRISM (Performance Requirements for Information System Management) application. Market research was conducted to assess the availability, technical capabilities, security posture, operational feasibility, cost considerations, and associated risks of alternative service providers and support models.

The market research included a comprehensive review of existing contractual and technical documentation associated with the current Interagency Agreement (IAA) with the Department of the Interior’s Interior Business Center (IBC), analysis of historical system performance, and evaluation of PRISM’s architecture, customization level, integrations, hosting requirements, and security controls. Lessons learned from the current hosting arrangement were used to inform the assessment of alternative solutions and to identify critical success factors and constraints.

FRTIB evaluated multiple potential alternatives, including other Federal Shared Service Providers (FSSPs), commercial and government-aligned hosting vendors, and the original developer and owner of the PRISM application. These efforts included participation in system demonstrations, review of technical questionnaires, interagency meetings, and coordination with federal stakeholders such as the Federal Aviation Administration Enterprise Services Center

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(FAA-ESC), the Department of the Treasury’s Administrative Resource Center (ARC), and the Financial Management Quality Service Management Office (FM QSMO).

As part of the market research, FRTIB also reviewed Rough Order of Magnitude (ROM) cost estimates, license cost analyses, and integration considerations associated with hosting PRISM alongside other financial systems. Findings from these analyses were documented and presented to agency leadership to support informed acquisition decision-making.

The results of the market research demonstrated that while multiple entities are capable of providing general enterprise hosting and operations and maintenance services, the number of sources capable of meeting FRTIB’s specific requirements for PRISM is significantly limited.

Evaluated alternatives operated different versions and configurations of PRISM or lacked the proprietary system knowledge required to support PRISM without extensive system modification, duplication of effort, and prolonged stabilization periods. These factors would introduce unacceptable technical, operational, security, and continuity risks.

The market research further confirmed that transitioning PRISM to an alternative federal shared service provider or third-party hosting environment would require substantial system reconfiguration, interface redevelopment, and knowledge transfer, resulting in increased cost and heightened risk of service disruption. By contrast, Unison, as the original developer and owner of the PRISM application, possesses proprietary system knowledge, architectural expertise, specialized tools, and historical configuration data necessary to meet FRTIB’s minimum requirements while minimizing risk.

Based on the results of the market research, FRTIB concluded that no other responsible source is capable of meeting the agency’s requirements without substantial duplication of cost or unacceptable risk to mission-critical operations. These findings support the determination to use other than full and open competition for this requirement.

VIII. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION

In addition to the factors described in the preceding sections of this justification, several additional considerations further support the determination that use of other than full and open competition is necessary to meet the Federal Retirement Thrift Investment Board’s (FRTIB’s) requirements for PRISM Hosting, Operations, and Maintenance Services.

PRISM is a mission-critical system that supports essential financial and administrative functions and processes sensitive agency data. The system has been extensively customized over time to align with FRTIB-specific business processes and external integrations. This level of

FOR INTERNAL FRTIB USE ONLY Page 10 of 12 customization significantly limits the feasibility of transferring hosting and operational responsibility to a third party without extensive system modification, redevelopment of interfaces, and prolonged stabilization efforts. Any degradation in PRISM performance or availability would require the agency to implement manual workarounds, increase reliance on staff resources, and elevate the risk of data integrity and internal control issues.

The proprietary nature of the PRISM application further constrains competition. Key aspects of PRISM’s architecture, configuration, and operational behavior are based on proprietary designs, tools, and historical implementation decisions that are not fully documented or transferable to other providers. Access to this proprietary knowledge is necessary to perform hosting, operations, and maintenance activities without introducing unacceptable technical or security risk.

Additionally, the agency’s experience under the current Interagency Agreement demonstrates that PRISM hosting requires close coordination between application knowledge and infrastructure management. Separation of these responsibilities across multiple providers or transition to an unfamiliar hosting environment would materially increase operational complexity and risk. Consolidating responsibility with the application owner reduces coordination challenges, improves accountability, and strengthens continuity of operations.

The evolving federal policy environment related to financial system consolidation and shared services governance also contributes to the impracticability of alternative approaches. Delays and uncertainty associated with required approvals for transitioning to other Federal Shared Service Providers introduce additional risk and limit the agency’s ability to ensure a timely, orderly transition prior to expiration of the current hosting arrangement.

Finally, while cost savings were not the basis for the sole-source determination, the proposed approach avoids substantial duplication of costs associated with system reconfiguration, retraining, and redevelopment that would be required under alternative solutions. This reinforces the conclusion that the selected approach represents prudent stewardship of Government resources while maintaining operational stability.

Taken together, these factors further demonstrate that full and open competition would not satisfy the agency’s minimum requirements and would expose FRTIB to unacceptable technical, operational, security, and continuity risks. Accordingly, these additional facts support the determination that award to a single responsible source under other than full and open competition is necessary and justified.

IX. LIST OF SOURCES, IF ANY, THAT EXPRESSED INTEREST IN THE

PROCUREMENT

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As a result of the market research conducted, the Federal Retirement Thrift Investment Board (FRTIB) engaged with and evaluated multiple potential sources capable of providing hosting, operations, and maintenance services for the PRISM (Performance Requirements for Information System Management) application. These engagements occurred through demonstrations, technical discussions, questionnaires, and interagency consultations.

Federal entities that were engaged during the market research process included the Department of the Interior’s Interior Business Center (IBC), the Federal Aviation Administration Enterprise Services Center (FAA-ESC), and the Department of the Treasury’s Administrative Resource Center (ARC). These entities participated in discussions and information exchanges related to shared services capabilities; however, none expressed interest or demonstrated the ability to meet FRTIB’s minimum technical and operational requirements for PRISM without substantial system modification, duplication of effort, or unacceptable risk.

In addition, commercial and government-aligned hosting providers were considered through market research activities, including the use of GSA contracting solutions. These sources did not express formal interest in the procurement or were determined to be incapable of meeting the agency’s requirements due to the proprietary nature of the PRISM application and the absence of application-specific expertise.

Unison, as the original developer, owner, and integrator of the PRISM application, expressed interest in providing the required hosting, operations, and maintenance services and was determined to be the only responsible source capable of meeting the agency’s minimum requirements.

X. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE

OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE MAKING

SUBSEQUENT PROCUREMENTS FOR THE REQUIRED PRODUCTS AND

SERVICES

The Federal Retirement Thrift Investment Board (FRTIB) recognizes the importance of promoting full and open competition to the maximum extent practicable and will continue to assess opportunities to reduce barriers to competition for future procurements related to PRISM hosting, operations, and maintenance services.

To the extent practicable, FRTIB will document system configurations, interfaces, and operational procedures throughout contract performance to reduce reliance on contractor-specific knowledge and to improve the transferability of system information. FRTIB will also continue to evaluate opportunities to standardize processes, improve documentation, and enhance system transparency in support of potential future competition.

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Additionally, FRTIB will continue to monitor the federal shared services marketplace and evolving policy guidance related to financial system consolidation and governance. Changes in federal policy, system architectures, or service delivery models may enable broader competition in future acquisition cycles.

Prior to any subsequent procurement, FRTIB will conduct market research in accordance with FAR Part 10 to reassess the availability of alternative sources and to determine whether changes in the marketplace, technology, or system configuration would allow for full and open competition. If future competition becomes practicable without introducing unacceptable technical, operational, security, or continuity risk, FRTIB will pursue competitive acquisition strategies consistent with applicable procurement regulations.

FRTIB will make this justification publicly available consistent with FAR 6.305. Prior to posting, the Contracting Officer will review and redact contractor proprietary, security-sensitive, source selection, and other protected information as appropriate.”