JA_FY26-013_Redacted.pdf

J&A No: FY26-013

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

41 U.S.C. 3304(a)(7)

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-111) and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Office of Procurement Operations (OPO), Federal Protective Service (FPS), Acquisition Division (AD) proposes to extend the ordering period of predecessor Multiple Award Contract (MAC) 70RFP218DEC000018 (Triple Canopy), for Armed Protective Security Officer (PSO) services at St. Elizabeths Campus located in Washington, D.C. on a basis other than full and open competition

2. Nature and/or Description of the Action being Approved.

(a) Nature of action:

FPS AD intends to procure PSO services on a noncompetitive basis for two (2) months, from January 1, 2026, through February 28, 2026, to allow the pending awardee of the follow-on effort sufficient time to complete the transition process efficiently and effectively. This action involves a modification to extend the ordering period under the current contract to facilitate the extension of the one remaining task order under this contract vehicle. This extension is necessary to ensure the continuation of critical PSO services at St. Elizabeths Campus in Washington, DC. The task order will be extended only for the duration required, not exceeding two (2) months, to allow sufficient time to award and transition to the follow-on effort. The current contract is set to expire on December 31, 2025, with the follow-on procurement pending award. The follow-on effort will require a transition period of no more than 90 days, ensuring performance begins on March 1, 2026. This extension ensures adequate time for the awardee to complete the transition to the new effort and fulfill the requirements of this procurement.

(b) Name and address of the contractor:

Triple Canopy, Inc.

13530 Dulles Technology Dr. Ste 500 Herndon, VA 20171

1 FAR Class Deviation 25-11 is implemented as a result of Revolutionary FAR Overhaul, referred as RFO, following Executive Order 14275, Restoring Common Sense to Federal Procurement. All citations in this document follow applicable DHS RFO Deviations therefore are referred as RFO.

cover the entire transition period, allowing the new vendor to train and meet all contract requirements before the security personnel begin standing post.

The requirement fulfills existing Government need, and the extension of the existing contract is the most advantageous method of fulfilling the Government’s needs, price and other factors considered. The contract extension also considers the government’s need for continuity of operations and potential costs of disrupting operations. The period of performance for this extension is for two (2) months of additional Armed PSO services from January 1, 2026, through February 28, 2026, at an approximate value of $5,218,803.20.

4. Identification of Statutory Authority Permitting Other Than Full and Open

Competition.

The statutory authority permitting other than full and open competition 41 U.S.C. 3304(a)(1) implemented by the RFO FAR Subpart 6.103-1 entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Identification of Exception to the Buy American Statute

Not Applicable.

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Triple Canopy is currently Armed PSO services under contract 70RFP218DEC000018 at St. Elizabeths Campus in Washington, DC. The contract is set to expire on December 31, 2025. FPS AD has completed the selection process for the competitive follow-on task order and is ready to make award for the follow-on requirement.

However, additional time is required to accommodate the necessary transition period, ensuring uninterrupted security services at St. Elizabeths between the expiration of the current contract and the commencement of full performance by the successful vendor under the follow-on effort.

The follow-on requirement under this contract is expected to be awarded soon, with an anticipated performance start date on March 1, 2026. The follow-on task order will include a mandatory transition period that will commence upon award and conclude in time to ensure performance begins on March 1, 2026. This transition period enables the follow-on contractor to obtain all necessary equipment, licenses, training, and other certification/suitability requirements for its employees to be able to begin standing post at the start of performance. Due to extensive screening, training, health, licensing, and transition requirements required for Armed PSOs under the FPS program, another Armed PSO firm cannot immediately replace the existing contractor without a significant and severe drop in overall security jeopardizing federal government personnel, visitors, and assets. For these reasons, it is also not feasible for any portion of the work to be segregated to allow for competition. The incumbent contractor, Triple Canopy is familiar with the instant requirements, facility locations, have fully qualified staff in place and is the only contractor at this time that can immediately fulfill the requirements without delay and interruption of services. As a result, a short-term extension of services under the current contract is necessary to ensure a seamless transition takes place from the existing requirement to the follow-on Task Order.

Title 40 United States Code (U.S.C.) §1315 gives DHS the responsibility to protect Federal facilities and the people thereon. Presidential Policy Directive 21 (PPD-21), and the National Infrastructure Protection Plan (NIPP) further refine DHS’s responsibility to protect buildings, grounds, and property that are owned, occupied, or secured by the Federal Government.

These documents also establish U.S. policy for the protection and resilience of the Nation’s critical infrastructure and provide a framework for integrating efforts designed to enhance the safety of critical infrastructure. Given the reality of terrorist threats, it is in the best interests of DHS and the public to continue to allow Triple Canopy to provide services until the follow-on task order (TO) is appropriately awarded and transitioned. Effective Armed PSO services are integral to the FPS mission to respond to terrorist attacks, domestic workplace violence, trespassing, disorderly conduct, and emergency medical situations. Armed PSO services also mitigate threats by detecting firearms, hazardous materials, and suspicious packages at these locations. Due to these critical roles, a modification to extend the current ordering period under contract 70RFP218DEC000018 with Triple Canopy is required to allow extension of the existing task order to provide continued services and to ensure uninterrupted service, a seamless transition, and to eliminate potential disruption in Armed PSO services at St. Elizabeths Campus.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

The circumstance restricting competition for this acquisition is that “only one responsible source and no other supplies or services will satisfy agency requirements,” pursuant to RFO 6.103-1. Therefore, RFO 5.301 notification requirement applies, and FPS AD posted this requirement on SAM.gov on 11/28/2025. FPS AD intends to make this justification publicly available pursuant to RFO 6.301.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The vendor has agreed to continue providing Armed PSO Services for the two (2) month extension at on current task order. The Contracting Officer has determined that the bill rates will be fair and reasonable based on comparison of the current prices to historical prices paid for the same or similar items in accordance with RFO 15.404- 1(b)(2)(ii)(B). The total estimated price for this additional two-month period is based on the estimated total value of the one remaining task order that needs to be extended as reflected in the chart below. The total estimated value of the task order extension is $5,218,803.20.

based. It is noted that there are additional training and other requirements for PSOs unique to St.

Elizabeths compared to these other contracts resulting in additional costs. In accordance with RFO FAR 15.403-2(b)(3), no certified cost or pricing data will be required because the service is commercially available to the general public.

Overall, based on the detailed analysis above, the maximum billing rates are in line with the current range of prices for similar types of services under other contracts for PSO services and are determined to be fair and reasonable.

9. Description of Market Research

FPS AD has conducted its market research for the new requirement and is familiar with other potential sources and their qualifications. Based on FPS AD’s market research, other firms could provide Armed PSO Services at St. Elizabeths Campus, but not by January 1, 2026, causing unacceptable delays or potentially jeopardizing the safety of government employees, government facilities, and its visitors. Accordingly, no other contractors can provide the services without an unacceptable interruption in service at this time.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

Since it is essential that services continue without interruption for the security of the campus, its tenants, and visitors, and the fact that the current contractor, Triple Canopy, is as documented under the Contractor Performance Assessment Report (CPAR), it is in the best interest of the government to extend the ordering period for two (2) months under contract 70RFP218DEC000018 with the current contractor.

11. A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

Not Applicable

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

This requirement is for the sole purpose of issuing a modification to continue Armed PSO services under contract 70RFP218DEC000018 to accommodate the necessary transition period of the competitive follow-on task order. FPS AD plans to make the award shortly, with the new Task Order award to start on March 1, 2026. The TO will only be extended under this contract for the two (2) months necessary. It is essential that Armed PSO services continue without interruption for the security of St. Elizabeths Campus located in Washington, DC to ensure the safety of government employees, government facilities, and its visitors at this location.

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