LSJ ECFS BPA Renewal signed _Redacted.pdf

Limited-Sources Justification (LSJ) For orders or BPAs exceeding the Simplified Acquisition Threshold

LSJ No: FY22-00292

Total Estimated Contract Value:

4. Authority and supporting rationale.

This acquisition is being conducted under the authority of the Multiple Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies in accordance with 8.405-6(a)(1)(i)(B), Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized. It is necessary to limit competition for new work described herein as a sole source because OPEXUS is the proprietary owner of eCase and provides the associated hosting environment, which is used for the DHS ECFS solution.

The intellectual property, licensing, hosting, and maintenance rights for eCase/ECFS reside solely with OPEXUS; there are no authorized third parties that can lawfully provide, host, maintain, or modify this solution or its codebase, nor deliver required security patches, roadmap updates, or configuration management for the currently deployed ECFS environment. As a result, DHS cannot procure this software or the associated services from another vendor. Obtaining equivalent “capabilities” from any other source would necessarily involve acquiring a different case management product and re-implementing the solution— requiring a full and open competition, data migration, interface redevelopment, user retraining, and a new authorization to operate—activities that DHS plans to pursue separately under the PRM2 initiative. Therefore, only OPEXUS can meet the immediate requirement for continued operation and support of the existing ECFS solution.

Awarding a sole source BPA will allow DHS uninterrupted ECFS support and provide sufficient time for execution of a new competition, establishment of a new Authority To Operate (ATO), and transition to a fully implemented new electronic contract filing tool. The follow-on to ECFS, Procurement Records Management (PRM2), is anticipated to be awarded in 4th Quarter FY26. This sole source award allows for the follow-on competition in Fiscal Year 2026; authorization to operate for the new system in Fiscal Year 2027 and migration to the new system in Fiscal Year 2028.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

The Contracting Officer has determined that issuing the proposed BPA to OPEXUS, for the ECFS solution and associated services represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs.

This BPA will be placed in accordance with FAR 8.404, “Use of Multiple Award Schedules.” The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates. Discounts to these GSA schedule rates will be requested.

Additionally, prior to issuance of orders under the BPA, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific tasks being requested

Limited-Sources Justification (LSJ) For orders or BPAs exceeding the Simplified Acquisition Threshold

LSJ No: FY22-00292

12. Approval.

Pursuant to FAR 8.405-6(c)(2)(xi), I hereby determine that the circumstance in FAR 8.405- 6(a)(1)(i)(C) applies.

Procuring Activity Advocate for Competition, or designee

SHANDRA N HERROD

Digitally signed by SHANDRA N

HERROD

Date: 2025.10.08 11:25:08 -04'00'