ID Validation Services LSJ_redacted_20240626.pdf

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ID Validation Services
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70SBUR24F00000157
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This document is a Limited-Sources Justification for exceeding the Simplified Acquisition Threshold for ID Validation Services for the myE-Verify system under the U.S. Citizenship and Immigration Services (USCIS) office of the Department of Homeland Security.

USCIS intends to limit the number of sources solicited and award a task order for Experian Precise ID, Level of Assurance 3 (LOA3), with Knowledge Based Authentication (KBA) ID Validation Services. Experian is the only vendor capable of providing the unique and highly specialized services required that are tightly integrated into the current USCIS IT infrastructure. Changing providers would require significant reengineering costs and time, with risks of system outages. The period of performance is July 1, 2024 to June 30, 2027 with a total value of $. Market research was conducted, and only Experian could meet the requirements. The contracting officer determined this order represents the best value and lowest overall cost for USCIS.

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www.uscis.gov

Rev: 10/13/2023

Limited-Sources Justification, Exceeding the Simplified Acquisition Threshold, ID Validation Queries for myE-Verify

REFERENCE: Justification Log Number: FY24-0076 and PR Number: VER240027

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to award a task order, on behalf of USCIS/Office of Information Technology (OIT), pursuant to FAR 8.405-6, Limiting Sources.

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

USCIS intends to limit the number of sources solicited pursuant to FAR Part 8.405-6 for the procurement of Experian Precise ID, Level of Assurance 3 (LOA3), with Knowledge Based Authentication (KBA) ID Validation Services. USCIS intends to solicit ID Validation Services from the authorized Federal Supply Schedule (FSS) seller. The proposed source is as follows:

Experian Information Solutions, Inc.

475 Anton Blvd Costa Mesa, CA 926-7037

SAM UEI: JZDMDG543QU1

GS-23F-0356P

SIN: 561450

3. Description of Supplies/Services.

Experian is currently providing Precise ID LOA3 KBA ID validation services to USCIS. ID Validation services are needed for customers seeking access to their personal data concerning their eligibility for employment to establish an account with USCIS. Accounts are established through the myE-Verify system. The validation services ensure the security and privacy of sensitive personal data. It is imperative that the identity of anyone establishing an account with USCIS is validated. To gain access to the myE-Verify system customers must first establish accounts through a government web location; once the account is established their identity must be verified through the validation provider before gaining access to myE-Verify. Once an ID is verified the customer will not have to go through this process again. The period of performance of this task order will be 07/01/2024 – 06/30/2027 with a total value of $

Period of Performance

CLIN Quantity Unit Price

Total

7/1/24-6/30/25 0001 753,308

Limited-Sources Justification, Exceeding the SAT, Justification Log Number: FY24-0076 ID Validation Queries for myE-Verify provider. The Experian solution is tightly integrated into the current OIT architecture, utilizing a different provider for this effort in such a short time frame would risk system failure. Due to the unique and highly specialized nature of the Experian solution, the significant reengineering costs, and the short time frames involved, Experian Precise ID is the only solution capable of providing the services required at the level of quality required.

Should myE-Verify go offline because there is no working system in place, US citizens and prospective citizens will no longer be able to check their work authorization status prior to being hired and employers would not be able to confirm the eligibility of their employees to work within the United States. Should the program go offline, an estimated 62,000 queries per month would be unanswered causing a significant impact to both employees and employers, as well as a severe mission impact for USCIS.

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 the proposed task order for Experian ID Validation Services represents the best value and will result in the lowest overall cost, considering price, administrative costs, re-engineering costs and other high-level priorities set by the agency. This order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.” The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates. Discounts to these GSA schedule rates will be requested.

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.

The results of the recent market research, described below, indicates that Experian is the only source capable of providing the unique and highly specialized services required at the level of quality required. Any alternate solution involves significant reengineering costs and time. There are risks of system outages and operational incompatibilities requiring a large trouble shooting investment.

Market research was conducted by the OIT. Multiple vendors that provide KBA were asked to provide their capabilities and pricing data, to include ID.me, Experian, Equifax and TransUnion. All but ID.me responded and were reviewed for capability and pricing. These vendors do provide knowledge-based identity verification services; however, Experian is currently the only vendor that provides services compatible within the OIT infrastructure.

Through market research, the program team discovered that significant reengineering costs would be required if USCIS were to change ID Validation services providers. These costs include significant reengineering efforts for development, testing and deployment work to replace the current Experian solution. The technical team has estimated that it will require nine Agile Sprints, or roughly eighteen weeks costing an estimated $450,000 to complete the development and testing work required to replace the current Experian solution with an alternate solution. This financial calculation does not consider incurred costs due to moving labor from active projects to the reengineering effort. Again, due to the unique and highly specialized nature of the Experian solution, the significant

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