FY21-0061_CWMS JEFO_Redacted.pdf

CISAM 3016.505-90(b)(4) Justification for Exception to Fair Opportunity

Exceeding the SAT pursuant to FAR 16.505(b)(2)(ii)(B)

JEFO No: FY21-0061 Page 2 of 4 Rev: 10/22/2020

In accordance with FAR 16.505(a)(4), the Contracting Officer must justify restricting consideration to an item peculiar to one manufacturer (e.g., a particular brand-name, product, or feature of a product that is peculiar to one manufacturer) and this justification is fulfilling this requirement.

Rationale:

iOS is Apple's proprietary mobile OS that runs on the iPad and is peculiar to the Original Equipment Manufacturer, Apple, and therefore only Apple’s and its authorized resellers (in this case WidePoint) can fulfill this requirement. If USCIS could no longer procure Apple iPads, using the iOS OS, it would prevent USCIS from being able to issue new carrier service, replace broken devices, or upgrade users with expiring OS’s. This will prevent USCIS from performing its mission with impacts to all Strategic Goals, with special emphasis on Goal 3 and 4, which is to ensure fair and efficient adjudication of benefits, delivery of information, and to continuously improve key processes, programs, and systems. Failure to upgrade devices with expiring OS’s creates an unnecessary security risk that would require all outdated devices to be disposed of and service turned off. In addition to security concerns, business processes have been developed specifically to support the ELIS and Asylum Virtual Interview process created in response to COVID-19 and attempting to change hardware and software at this time without sufficient transition time would put the agency at risk for not completing its mission.

Apple products use the iOS OS, which is the only operating system that has been configured with Airwatch. Airwatch is the USCIS software that provides Mobile Device Management (MDM) and security for all smartphones and tablets. OIT is unable to deploy any smartphone or tablet into the environment without being properly managed and secured, as doing so would cause a serious security incident. There are two operating systems that support mobility devices, Android and iOS. Derived Personal Identity Verification (PIV) credentials are required at the Department level to secure all mobility devices and at this time the USCIS AirWatch MDM platform, used to manage and secure all mobility devices, can only support Derived PIV credentials on iOS devices.

Market Research indicates that while there are two operating systems that support all mobility devices, iOS and Android, only iOS devices support the use of a Derived PIV card credentials using AirWatch as an MDM platform. Therefore there are no solutions that will support a non-iOS device at this time. A brand name or equal procurement will not be able to fulfil this requirement as Android devices will not allow for Derived PIV credential and AirWatch.

The USCIS OIT Engineering staff has not been able to successfully implement a solution that can support non-iOS devices i.e. Android OS devices. iOS is proprietary to Apple and the Android OS cannot be modified to meet the needs of the government. It is a DHS security risk to provision an Android device into the USCIS environment without properly securing the device through using a Derived PIV credential and AirWatch.

CISAM 3016.505-90(b)(4) Justification for Exception to Fair Opportunity

Exceeding the SAT pursuant to FAR 16.505(b)(2)(ii)(B)

JEFO No: FY21-0061 Page 4 of 4 Rev: 10/22/2020

10. Contracting Officer Certification

Pursuant to FAR 16.505(b)(2)(ii)(B)(8), I certify that this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer Date

APPROVAL: Pursuant to FAR 16.505(b)(2)(ii)(B)(10), I hereby determine the circumstance identified in Section 4 applies to the order.

Procuring Activity Advocate for Competition Date

STUART SELLEARS Digitally signed by STUART SELLEARS Date: 2021.04.29 07:45:06 -04'00'

DONATA A SIKON-AMATO

Digitally signed by DONATA A SIKON-

AMATO

Date: 2021.04.30 12:03:24 -04'00'