I_04_SF1014_IEP 1.5 Bridge 2 Justification8242026FECopyforSAM_Redacted.pdf

DEPARTMENT OF THE TREASURY

SF 1014 - JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

ACQUISITION TITLE: IEP 1.5 Bridge Contract 2

Treasury Standard Form – 1014 (Rev 12/24)

Prescribed by Treasury: DTAP 1016.505 Tracking No.

1. Identification of the requiring activity and the contracting activity:

Internal Revenue Service, Information Technology, ACIO for Enterprise Operations, Office of the Chief Procurement Officer (OCPO), Enterprise Operations (EOPs) Section 2.

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

The purpose of this Justification for an Exception to Fair Opportunity (JEFO) is to obtain approval to award a Bridge contract with Accenture Federal Services (AFS) for the purchase of the services described in 3.a. below. The need date for these services is August 15, 2026.

The period of performance will be twelve (12) months. Refer to the requisition for a copy of the performance work statement and service level objectives. The existing IEP 1.5 Task Order was sole sourced without competition due to the urgent and compelling nature of the need and serves as the vehicle supporting the IRS’s Portal infrastructure, hosting, security, application integration, and program management services.

Since issuance of the current task order, Treasury and IRS strategic direction has evolved.

Specifically, the Agency has been directed to accelerate planning for transitioning the Integrated Enterprise Portal (IEP) infrastructure and related services into IRS-controlled environments to the maximum extent feasible. This shift requires extensive analysis of operational, security, architectural, and financial implications, including identifying transition paths for more than 100 IEP-hosted applications that must remain fully functional for annual Filing Season operations.

The Agency has conducted ongoing assessments and cross-organizational discussions to understand the sequencing, risks, and dependencies associated with transitioning components of the IEP environment. Because each application and service integration point carries different operational sensitivities, the IRS must complete detailed transition planning to ensure optimal value, risk reduction, and operational continuity for the government.

This plan cannot be completed before the current period of performance expires. To avoid disruption of critical filing season services including irs.gov, Modernized e-File (MeF), ICCE, ACA systems, and other mission-essential applications the IRS requires this Bridge contract.

The incumbent’s existing technical environment, tooling, and institutional knowledge are essential to maintain operational stability while the Agency finalizes its long-term transition and acquisition strategy aligned with updated Departmental direction.

This Bridge contract ensures continuity of IEP operations and Filing Season readiness while the IRS completes its analysis, validates its transition roadmap, and aligns the future acquisition strategy with Treasury-mandated objectives.

2.b Name of the vendor: Accenture Federal Services (AFS) 2.c Requisition No.:

2.d Bridge contract: 0 Yes O No 2.e Brand name: 0 Yes O No 3.a A description of the supplies or services required to meet the agency’s needs:

The proposed acquisition is to obtain the full suite of IEP services required to maintain uninterrupted availability of Filing Season critical applications and to ensure operational continuity while the IRS completes its transition planning for portal modernization. The Bridge acquisition will provide the following essential services:

• Portal Infrastructure Services - Provide the hosting environment, compute capacity, storage, and network architecture required to sustain irs.gov, Modernized e-File (MeF), ACQUISITION TITLE: IEP 1.5 Bridge Contract 2

Treasury Standard Form – 1014 (Rev 12/24)

Integrated Customer Communications Environment (ICCE), and Affordable Care Act (ACA), and more than 100 dependent applications. These services are critical because any disruption would directly affect taxpayer access, e-filing operations, and agency-to-agency data interfaces essential for Filing Season operations.

• Portal Web Hosting Services - Maintain the availability and performance of the IRS’s public-facing web presence, including irs.gov. These services are critical to support millions of taxpayer interactions daily, particularly during peak filing season demand.

• Portal Security Services - Deliver continuous monitoring, incident response, vulnerability management, and protection of taxpayer data within the IEP environment. These services are critical to ensure compliance with federal cybersecurity standards and to mitigate risks to sensitive tax information.

• Portal Service and Program Integration Services - Support application integration, coordination across business owners, and maintenance of shared services required for end-to-end functionality. These services are critical because the IEP is a tightly integrated ecosystem, disruptions or misalignment among components would jeopardize Filing Season readiness.

• Portal Applications Services - Provide maintenance, enhancement, and operational support for IEP-hosted applications that enable tax return filing, taxpayer communications, and ACA compliance exchanges. These services are critical to sustain mission-essential applications that must remain fully functional and available.

• Transition of Portal Operations Services - Support planning, analysis, and initial activities for transitioning IEP services into IRS-controlled hosting environments in alignment with Treasury direction. These services are critical to ensure an orderly transition, reduce operational risk, and avoid disruptions to dependent applications during future modernization.

The period of performance for this Bridge acquisition ensures continuation of IEP operations through Filing Season 2027.

Refer to the requisition for a copy of the complete listing of IEP-hosted applications.

3.b Includes IT: 0 Yes O No NAICS – 541512 (Computer System Design Services. PSC DA 01 (IT and Telecom, Business Application/Application Development Support Services) 3.c IGCE/Estimated dollar value:

The Independent Government Cost Estimate (IGCE) for this requirement encompasses a twelve-month base period. The twelve-month base period is estimated at $231,048,350.

4.a Identification of the exception to fair opportunity being used:

□ FAR 16.505(b)(2)(i)(A) – The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

□ FAR 16.505(b)(2)(i)(B) – Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

□ FAR 16.505(b)(2)(i)(C) – The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

□ FAR 16.505(b)(2)(i)(D) – It is necessary to place an order to satisfy a minimum guarantee.

□ FAR 16.505(b)(2)(i)(E) – For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

ACQUISITION TITLE: IEP 1.5 Bridge Contract 2

Treasury Standard Form – 1014 (Rev 12/24)

□ FAR 16.505(a)(4) – The requirement is for an item peculiar to one manufacturer. (i.e., Brand Name specifications)

4.b Supporting rationale:

The Government’s need for continued IEP services is urgent and mission critical, and the urgency is not the result of a failure to plan. Prior to updated Treasury direction, the IRS had been pursuing a long-term strategy in which the existing IEP 1.5 environment would remain in place through the current task order, which expires on August 14, 2026, while the Agency conducted multi-year modernization assessments. Under this plan, the IRS expected to initiate a competitive follow-on acquisition once long-term technical and operational requirements were fully defined.

Beginning in late calendar year 2025 and continuing into early FY26, Treasury issued new guidance directing the IRS to accelerate the transition of IEP services into IRS-controlled environments to the maximum extent feasible. This directive significantly altered the acquisition strategy. It required immediate analysis of transition sequencing, cross-system dependencies, operational impacts, and security considerations for more than 100 interconnected applications. These activities were not foreseeable when earlier acquisition planning was conducted and created new requirements that must be finalized before a responsible competitive solicitation can be issued.

In response, the IRS initiated transition planning in Q1 FY26. Throughout Q2 and Q3 FY26, cross-organizational teams completed technical assessments, dependency mapping, architectural reviews, and operational risk analyses. These efforts demonstrated that essential elements required to conduct a competition, including a finalized Performance Work Statement, validated transition sequencing, and complete technical requirements, could not be completed before the expiration of the current task order. Standard federal acquisition lead times for a full and open competition, including market research, drafting and reviewing solicitation documents, issuing draft and final RFPs, conducting evaluations, and completing pre-award reviews, exceeding the available time before August 14, 2026.

Because transition-planning activities are still underway, the IRS cannot yet issue a well-defined competitive solicitation that accurately reflects updated requirements. Attempting to compete prematurely would introduce avoidable performance risks, destabilize the acquisition strategy, and jeopardize Filing Season readiness. The urgency arises from the timing of Treasury’s updated direction, which occurred shortly before the current performance period ends, while the IEP platform continues to support more than 100 mission essential systems including irs.gov, MeF, ACA systems, ICCE, and other taxpayer-facing services. Any lapse in these services would disrupt taxpayer access, degrade electronic return processing, interrupt interagency data exchanges, and violate established recovery requirements.

The IEP is the principal platform supporting high-volume Filing Season transactions. Based on current workload and incident response data, any interruption beyond the 12-hour Recovery Time Objective would exceed IRS continuity thresholds and impair systems required for taxpayer access, refund processing, ACA compliance, digital submissions, and information return intake. On a peak day, IEP supports approximately 5 million Individual Online Account logins, more than 45,000 Digitalization submissions, over 300 million Information Returns submissions, more than 6,000 Document Upload Tool case uploads, over 2,500 Digital and Mobile Adaptive Forms submissions, and more than 2.9 million MeF refund transactions. A full 24-hour disruption would double the RTO limit and create an unrecoverable one-day

ACQUISITION TITLE: IEP 1.5 Bridge Contract 2

Treasury Standard Form – 1014 (Rev 12/24) backlog across billions of transactions, delaying refunds, revenue intake, authentication services, and ACA reporting flows. Restoring operations would require coordinated IRS and contractor technical, operational, and data validation activities. This level of delay would materially impact Filing Season performance and statutory compliance obligations.

Only the incumbent possesses the operational infrastructure, cross-system integrations, validated disaster recovery runbooks, and platform-specific architectural knowledge required to maintain availability and ensure recovery within mandated RTO and RPO parameters. The current IEP environment aggregates hosting, operations, security, and application integration functions under unified architecture. Transitioning to a new vendor would require several months of onboarding and reengineering, which cannot occur within the limited time remaining before task order expiration. Accordingly, providing fair opportunity at this time would result in operational degradation and delays that the IRS cannot absorb without significant mission impact.

No other vendor can assume operational control within the remaining timeframe without introducing unacceptable cost, schedule, and security risks. Duplicating the incumbent’s tightly integrated environment and interdependencies would require months of transition. As required by FAR 16.505(b)(2)(i)(B), delaying award for a full and open competition would create severe harm to the Government by jeopardizing Filing Season readiness, causing cascading delays across dependent systems, and risking taxpayer-facing outages. A bridge is the only viable mitigation while the IRS finalizes and executes its competitive acquisition strategy.

To support the competitive follow-on acquisition, the IRS has established specific milestones that will be completed during the bridge period. The Draft Performance Work Statement is scheduled for completion in July or August 2026, followed by technical and procurement reviews through August and September 2026. Market research activities, including refinement of previous industry feedback and targeted engagement with qualified vendors, are underway and will be completed by Q3 FY26. The IRS anticipates releasing a Draft Solicitation in Fall 2026 and issuing the Final Solicitation no later than December 2026, enabling a competitive award well before the bridge expires. These milestones align with transition planning deliverables, including finalization of the transition sequencing plan and technical dependency analysis, scheduled for completion during the first half of the bridge period.

Collectively, these actions demonstrate measurable progress toward a full and open competition and ensure the Government is positioned to award a long-term competitive solution without requiring additional bridge actions.

5. A determination that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer determines that the anticipated prices will be fair and reasonable in accordance with FAR 15.402(a)(2) based on multiple price-analysis techniques, including comparison to the Independent Government Cost Estimate (IGCE), analysis of historical pricing from the prior IEP 1.5 Bridge Task Order (205AE9-25-F-00190), and review of labor rate structures established under the IEP 1.5 IDIQ contract (TIRNO-17-D-00004). Additional analysis will include use of GSA labor-pricing tools, market-based resources, and verification against pre-negotiated labor categories and ceiling rates available under the Alliant Best-in- Class (BIC) Governmentwide Acquisition Contract (GWAC). Alliant labor rates have been previously evaluated as fair and reasonable at the master contract level and will be further evaluated at the task-order level for this acquisition. The bridge requirement reflects a narrowed scope limited solely to sustainment activities necessary to maintain operational

ACQUISITION TITLE: IEP 1.5 Bridge Contract 2

Treasury Standard Form – 1014 (Rev 12/24) continuity of the Integrated Enterprise Portal (IEP). No new application development is within scope. Although new development work was removed from scope, the remaining sustainment activities continue to rely on labor categories and technical skillsets consistent with the existing IEP 1.5 IDIQ structure, enabling reliable price comparison to historical and established contract baselines.

The availability of historical pricing, established labor structures under the Alliant GWAC, and continuity of the remaining sustainment activities support the determination that the anticipated cost for this bridge action is fair and reasonable. Additionally, the Contracting Officer will seek out additional discounts to what is proposed.

6.a Any other facts supporting this justification:

The need for this bridge is driven by updated Departmental direction and ongoing transition-planning requirements, not by a failure to plan or any intent to avoid competition.

This bridge action is distinguishable from the prior bridge because the IRS has now initiated formal transition-planning activities in response to Treasury’s directive requiring accelerated movement of IEP services into IRS-controlled environments. These activities include detailed analysis of technical dependencies, security requirements, sequencing constraints, and operational risks associated with transitioning more than 100 interconnected applications that must remain fully functional for Filing Season operations.

Transition planning conducted to date has identified new architectural constraints, integration risks, and system interdependencies that require additional time to fully evaluate and refine.

These analyses must be completed before the Government can finalize technical requirements suitable for a competitive acquisition. As these requirements continue to evolve, competition at this stage would not accurately reflect the Government’s needs and would increase operational and performance risk.

This bridge requirement has been deliberately scoped to the minimum sustainment support necessary to maintain uninterrupted IEP operations while transition activities are completed.

The IRS evaluated alternate approaches, including reducing scope further or transitioning additional functions immediately to Government control, but these options were determined to present unacceptable risk to Filing Season readiness and system availability.

The timeline required for transition planning, coupled with the need to develop a complete Performance Work Statement and supporting acquisition documentation, necessitates a short-term bridge to ensure continuity of operations. The IRS has already begun updating its market research, refining service delivery models, and incorporating transition-focused deliverables into this requirement to support development of a fully competitive follow-on acquisition.

These actions collectively support the Government’s ability to remove barriers to competition and ensure that subsequent requirements are competed to the maximum extent practicable.

This bridge therefore provides essential operational continuity while enabling the IRS to complete transition planning, finalize technical requirements, and prepare a well-defined, competitive solicitation aligned with Treasury’s updated direction.

6.b Attachments: 0 Yes O No Refer to the acquisition package

7. A statement of the actions, if any, the Requiring Activity and Contracting Activity may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies and services is made:

The Government has reviewed and reanalyzed its prior market research to ensure that it remains current and continues to accurately reflect industry capabilities relevant to IEP services. The research, which included broad industry outreach and consideration of multiple

ACQUISITION TITLE: IEP 1.5 Bridge Contract 2

Treasury Standard Form – 1014 (Rev 12/24) vendor submissions, has been reassessed considering evolving operational requirements and remains valid for informing future competitive strategies. The updated analysis confirms that several vendors possess capabilities applicable to future competitive opportunities once the Government finalizes its long-term technical and operational requirements.

While the Agency continues to refine the long-term service delivery model, it has taken concrete steps under this bridge to reduce barriers to competition. The bridge includes targeted transition-related deliverables intended to advance the development of the Government’s operational roadmap, including activities to identify transition sequencing, define technical dependencies, and support the establishment of a sustainable Government-managed operating model. These deliverables will provide the information necessary to finalize well-defined, actionable requirements suitable for a fully competitive acquisition.

In addition, transition activities currently underway under the existing bridge will be utilized in a manner that is consistent with contractual obligations and will be coordinated closely with the Procurement office to ensure that all support from the incumbent is used appropriately and within established boundaries. This structured and responsible use of incumbent assistance ensures continued progress in transition planning without creating reliance that would inhibit future competition.

These actions revalidated and updated market research, incorporation of transition-focused deliverables into this bridge requirement, refinement of the sustainment-only scope, and close coordination with Procurement on the use of ongoing transition activities collectively advance the Government’s ability to remove barriers to competition. This bridge provides the necessary time to complete the operational roadmap, finalize technical requirements, and develop an acquisition strategy that will promote competition to the maximum extent practicable consistent with mission needs.

8. Certifications and Approvals:

8.a Program Office Certification (Requiring Activity). I hereby certify that any supporting information and data provided (e.g., the Government’s minimum needs or requirements, or other rationale for the limited sources) and which form the basis for this justification for an exception to fair opportunity, are accurate and complete to the best of my knowledge and belief.

Name: Date:

Signature:

8.b Contracting Officer Certification and Approval. I certify this justification for an exception to fair opportunity is accurate and complete to the best of my knowledge and belief.

Therefore, unless additional approvals are required as prescribed below, as the authorized contracting officer for this acquisition, I hereby approve the processing of this requirement based on the authority specified in 4.a above.

Name: Aaron Lewis Date:

Signature:

ovals (As applicable):

9.a Bureau Chief Information Officer or Authorized Designee (for IT requirements that are over $5 million, but not exceeding $90 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and

ACQUISITION TITLE: IEP 1.5 Bridge Contract 2

Treasury Standard Form – 1014 (Rev 12/24) belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification. (Note: The Bureau CIO may delegate their authority for proposed contracts over $5 million, but not exceeding $20 million to the Associate Bureau CIO(s).)

Name: Date:

9.b Advocate for Competition (if over $900,000, but not exceeding $20 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the ordering activity’s Advocate for competition, I hereby approve this justification based on the authority specified in 4.a above.

Name:

Date: 7/22/2026

9.c Head of the Procuring Activity or Authorized Designee (if over $20 million, but not exceeding $90 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the head of the procuring activity or authorized designee, I hereby approve this justification based on the authority specified in 4.a above.

9.d Treasury Chief Information Officer (for IT requirements that are over $90 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification.

9.e Senior Procurement Executive (if over $90 million) (Contracting Activity). I have reviewed this justification for an exception to fair opportunity and find it to be accurate and complete to the best of my knowledge and belief. Therefore, as the senior procurement executive, I hereby approve this justification based on the authority specified in 4.a above.

Name: Date:

Signature: '