5-1-1 FSS Sole Source_APIS Interim Bridge_v5_Final_s - CO.pdf

www.uscis.gov

Rev: 06/10/2026

Federal Supply Schedule (FSS) Sole Source Justification, Exceeding the Simplified Acquisition Threshold, Accounts Public and IdProofing Services (APIS)

REFERENCE: Justification Log Number: FY26-0099 and PR Number OIT279001

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), Office of Contracting (OCON), proposes to award a contract modification, on behalf of the National Security Division (NSD), pursuant to RFO 8.401(b), General and RFO GSAM/R 538.7104-3, Sole source justifications. 1

2. Nature and/or description of the action being approved.

The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), Office of Information Technology (OIT), proposes to extend the current Accounts Public and IdProofing Services (APIS) contract with Capital Technology Group (CTG) on a sole source basis.

CTG is currently providing support under task order 47QTCA18D00AX/70SBUR23F0000138.

3. Description of Supplies/Services.

Accounts Public and IdProofing Services (APIS) consists of teams that provide development, security and operations (DevSecOps) services to support U.S. Citizenship and Immigration Services (USCIS), Information Technology (IT) system delivery. The National Security Division (NSD) requires the contractor to provide development, security and operations (DevSecOps) services, in the form of development teams, to support USCIS Information Technology (IT) system delivery under the task order Accounts Public and IdProofing Services (APIS).

The Accounts Public and IdProofing Services (APIS) Task Order (TO) expires 12/15/2026. The total value of this justification is estimated at $ This bridge modification, with an estimated amount of $ will be for necessary continued services for the period of 12/16/2026 – 10/31/2027. The bridge will include addition option periods to allow for up to an additional 6 months (11/01/2027- 04/30/2028), if needed in case of delay or protest. The estimated price for the full additional 6 months is $

Necessary services, to meet the need, include Key Personnel, and one DevSecOps team. The Accounts Public and IdProofing Services (APIS) contract effort provides comprehensive DevSecOps

1 In this document, citations to RFO Part 8, RFO Part 2, and RFO GSAM/R 538.71 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-20 for FAR Part 8 and RFO-2025-FSS-GSAR for FAR Part 8, 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.

Federal Supply Schedule Sole Source Justification, Exceeding the SAT, APIS Extension Justification Log Number: FY26-0099 services for the development, modernization, and sustainment of large-scale, cloud-based identity management systems that enable secure public access to USCIS applications. Under this effort, the work includes designing, developing, testing, deploying, and operating identity proofing and authentication services compliant with NIST SP 800-63 Digital Identity Guidelines. The contractor integrates security and code quality scanning into the CI/CD pipeline, automates testing and deployment, and ensures Section 508 accessibility compliance. The contract effort ensures the security, reliability, and usability of USCISs public-facing IT systems, enabling the agency to efficiently administer immigration benefits and related services.

4. Authority and supporting rationale.

This acquisition is conducted under the authority of Multiple-Award Schedule Program, 41 U.S.C.

152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies. Pursuant to RFO 8.401(b), General, RFO GSAM/R 538.7104-3(b), Sole source justifications, the circumstance that justifies limiting sources to fewer than those required by RFO GSAM/R 538-7103-3 is:

RFO GSAM/R 538.7104-3(b)(1)(iii) The order should be issued on a sole source basis in the interest of economy and efficiency because it’s a logical follow-on to an FSS Order already issued on a competitive basis.

Rationale:

USCIS requires completion of Zero Trust implementation of Identity Public per DHS mandate and other APIS tasks that directly support USCIS’s mission-critical public-facing web platforms, including account enrollment, authentication, and electronic identity proofing for customers accessing these systems. This work is currently being performed under the APIS task order that will end on December 15, 2026. While much of the current APIS requirement will be completed at that time, some of the ongoing operational work will fall under a new contract called Immigration Biometrics & Identity Services (IBIS). IBIS will not be in place in time to ensure continuous support for O&M activities and continuation of Identity Management services for USCIS public user authentication, which are currently provided by APIS. An extension period of up to sixteen (16) months and 15 days to the APIS task order is needed to complete the remaining items discussed above, ensure system operational support and allow for a proper transition period to the IBIS contract.

In the interest of economy and efficiency, only the current APIS contractor can complete these required taskings. It is also vital that the incoming contractor has time to understand its environment to minimize risk to USCIS. The incumbent contractor has been in place for three (3) years and must be available to communicate the roles, responsibilities, and authorities of the systems as well as the delivery of the code and O&M. The extension will also account for any potential protests received in response to the IBIS solicitation and ensure that there will be no disruption in service to support USCIS operations and services. The work will support O&M efforts with minimal enhancement only.

Federal Supply Schedule Sole Source Justification, Exceeding the SAT, APIS Extension Justification Log Number: FY26-0099

If this bridge extension is not approved, USCIS will not be able to meet its mission objectives, in supporting critical public-facing web platforms. The APIS contract supports the development, operations and maintenance of mission critical systems such as myUSCIS, my E-Verify, E-Verify+ and the Freedom of Information Act (FOIA) Integration Records System (FIRST).

As previously stated, the contractor’s DevSecOps teams provide development, operations, and maintenance services to ensure secure, reliable, and compliant access to these platforms, leveraging industry standards such as NIST SP 800-63 for identity and credential management. Their responsibilities include implementing authentication protocols and maintaining compliance with Section 508 accessibility requirements. The vendor also sustains the CI/CD pipeline, conducts automated testing, and provides Tier-II and Tier-III technical support to resolve complex issues and maintain system availability.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with RFO GSAM/R 538.7102-2(b)(4) and as defined by

RFO 2.101.

The contracting officer has determined that issuing the proposed Task Order extension to CTG for the completion of certain APIS tasks and transition to IBIS represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs. This order modification will be placed in accordance with GSAM/R 538.7 – Federal Supply Schedule Ordering Procedures.

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

Further market research was not conducted as USCIS requires an interim extension for the Accounts Public and IdProofing Services (APIS) contract.

7. Any other facts supporting the sole source justification.

The incumbent’s institutional knowledge and integration with USCIS systems minimize onboarding and transition risks that would otherwise delay the administration of immigration benefits and FOIA responses. Any attempt to transition to a new contractor during the interim period would require extensive ramp-up time and risk loss of continuity in critical operations, making the incumbent the only practical option for maintaining seamless support during the extension.

8. A statement of action, if any, the agency may take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for the supplies or services is made.

The sole source task order modification is only intended to complete certain work while maintaining other services until the award and transition-in is completed. This timeline is designed to minimize reliance on sole source or limited competition actions and to ensure that the period of performance for the current action is limited to the time necessary to complete the new competitive procurement.