CUI//SP-SSEL

Version 02/26/2026

FEDERAL SUPPLY SCHEDULE (FSS)

SOLE SOURCE JUSTIFICATION

Logical Follow-on to a Previously Competed

Order

Solicitation 47QFCA26Q0014

St. Elizabeths Program Support II Bridge

(SEPS II Bridge) in support of:

Department of Homeland Security (DHS)

United States (U.S.) General Services Administration (GSA)

Federal Acquisition Service (FAS)

Assisted Acquisition Services (AAS)

Interagency Agreement Number 47QFCA26K0062

Controlled by AAS Contracting Officer Brendan Miller: brendan.miller@gsa.gov

Version 02/26/2026

The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this

Federal Supply Schedule (FSS) Sole Source Justification for orders pursuant to Federal

Acquisition Regulation (FAR) 8.4 (GSA Class Deviation Revolutionary FAR Overhaul (RFO)-

2025-08) and General Services Acquisition Regulation (GSAR) 538.7104-3 (GSA Class

Deviation RFO-2025-FSS-GSAR 538).

1. Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of DHS

Contracting Activity:

GSA AAS Contracting Office (FADBA)

2. Nature and/or Description of Action Being Approved:

The Government intends to enter into a Federal Supply Schedule (FSS) Follow-on Task

Order (TO) to CLMS, Inc citing the rationale below. The Government expects to issue a

Firm-Fixed Price (FFP) type Task Order against the Contractor’s FSS contract This TO is expected to be a 12-month base period and approximately $2.4M in value.

The Government requires program management services to assist DHS in overseeing the

HQ consolidation effort, primarily in relation to the IT infrastructure integration under the

St. Elizabeths Technology Services (SETS) II TO. This entails interaction between the overall DHS HQ consolidation, SETS II TO, and external stakeholders.

The contractor will provide program management services to increase the capability and achieve higher levels of effectiveness of the DHS in overseeing the implementation of the

DHS HQ consolidation program and the successful integration of IT solutions. The contractor shall enable the Government to achieve a more comprehensive level of oversight of contracts, TOs, budgets, and schedules that comprise the overall DHS HQ consolidation.

Additionally, the contractor shall aid the Government in monitoring Other Government

Contractors’ (OGCs) performance.

3. The Authority and Supporting Rationale:

The acquisition is conducted under the authority of the Multiple-Award Schedule (MAS)

Program. Consideration of schedule contractors will be restricted in accordance with:

GSAR 538.7104-3(b)(1)(iii) (GSA Class Deviation RFO-2025-FSS-GSAR

538) – In the interest of economy and efficiency, the new work is a logical follow-on to an original FSS order provided that the original order was placed on a competitive basis.

4. Determination by the Ordering Activity Contracting Officer that the Order

Represents a Fair and Reasonable Price Consistent with GSAR 538.7102-2(d)(2) and

538.7104-2(a)(3) (GSA Class Deviation (GSA Class Deviation RFO-2025-FSS-GSAR

538)

The Government intends to build an IGCE that incorporates the existing GSA FSS labor rates and level of effort currently being received by the client. The Government will ensure fair and reasonable pricing by confirming proposed labor does not exceed the existing labor

Version 02/26/2026 rates for the categories proposed and the level of effort being in line with the existing Task

Order. As those rates are considered fair and reasonable, the Government intends to ensure that those rates are not exceeded to determine a fair and reasonable price.

5. Description of the Market Research Conducted Among Schedule Holders and the

Results of the Research:

The Government surveyed other GSA schedule holders, but given the changing nature of the RFO and it’s impact on contracting regulations, along with changes to the client’s mission, and GSA/FAS’s reorganization, the timing for a competitive acquisition would not be in the best interest of the Government. The Government expects to utilize the first six months of this acquisition to better understand the client’s levels of support and how the new RFO requirements and executive orders will impact delivery of that support. The

Government will build the resultant competitive requirements from that initial analysis of this follow-on sole source.

6. Any Other Facts Supporting the Justification:

In compliance with Executive Order 14402 Promoting Efficiency, Accountability, and

Performance in Federal Contracting , the Government is shifting this procurement from a

Labor Hour Type TO to a Firm-Fixed Price TO. With that, there are challenges with how this TO can be funded, as FFP contracts must be fully funded at the time of award/. As such, the Government intends to utilize this logical follow-on to observe the impacts to the client’s budgeting cycle to ensure that a competitive procurement utilizes appropriate length optional periods of performance, in the case that funding is not available for a full year of funding.

7. Statement of the Actions, if Any, the Agency May Take to Remove or Overcome any

Barriers that Led to the Restricted Consideration Before Any Subsequent Acquisition for the Supplies or Services is Made:

Due to some changing client requirements, RFO updates, and Executive Orders, the

Government is implementing a new contract type and plans to utilize as little of the base year as possible to learn of the impacts to the client and its funding cycle, and incorporate those lessons learned into the next competitive action.

8. Contracting Officer Certification that the Justification is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

I hereby certify that this Justification is accurate and complete to the best of my knowledge, and I determine on the basis of the findings above that the limited sources approach is in accordance with the requirements and is in the best interest of the Government.

______________________________________________ ___09 July 2026___

Brendan Miller Date

Contracting Officer, AAS Civilian