ITAC LSJ (EPMS Logical Follow On)_REDACTED.pdf

Limited-Sources Justification (LSJ)

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LSJ No.:

This acquisition is 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.

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Office of Procurement Operations (OPO), Information Technology Acquisition Center (ITAC) proposes to award an order pursuant to FAR 8.405-6(a), Limiting Sources.

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

DHS/OPO intends to limit the number of sources solicited pursuant to FAR Part 8.405- 6(a) for the procurement of highly specialized technical services in support of the Enterprise Platforms Management Support (EPMS) Services requirement to proposed contractor: ECS Federal, LLC, 2750 Prosperity Avenue, Suite 600, Fairfax, VA 22031.

3. Description of Supplies/Services.

This requirement is to continue receiving Enterprise Platforms Management Support (EPMS) Services, highly specialized technical contractor support services to assist the Office of the Chief Information Officer (OCIO), Solutions Development Division (SDD) in executing and accomplishing its mission objectives. These services include management and technical support for the migrations, modernizations, refactoring, and operations and maintenance for all SDD integrated services based on agile methodologies. The customer base consists of a large and diverse user base that requires customer centric support and delivery. Current cloud services include SharePoint Online, Microsoft Power Platform/Microsoft Dynamics, and the ServiceNow Platform.

This requirement requires a wide range of skillsets and capabilities across various domains, including but not limited to: management of cloud-based computing services, end to end technical requirements management for enterprise IT services, support of Government Off The Shelf (GOTS) / Commercial Off The Shelf (COTS) application integration and interoperability for customer developed components, expertise in program management, business and requirements analysis, integration, testing, change management, innovative architectural support, and ongoing operations and maintenance.

The estimated total value is , for a 12-month period of performance of September 1, 2025 – August 31, 2026.

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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 FAR 8.405-6(a), Limiting Sources. An award will be made as a logical follow-on to Call Order number 70RTAC23FC0000050, pursuant to FAR 8.405- 6(a)(1)(i)(C) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

The current Blanket Purchase Agreement (BPA) supporting this Call Order, the DHS Architecture, Development, and Platform Technical Services (ADaPTS) strategic sourcing vehicle Contract # 70RTAC19A00000009, expired on February 28, 2025, and a replacement vehicle has not yet been awarded. In the absence of a new BPA, this follow on is needed to maintain continuity of services for SDD and its customers. This one-year order is a temporary solution to maintain consistent operational performance, reduce programmatic risk, and allow enough time to devise a new procurement strategy, solicit the requirement using competitive procedures, make the award and transition to a new order.

The original award was competitively solicited and awarded using the ordering procedures at FAR 8.405. It is necessary to limit competition for new work described herein and award as a logical follow-on as continuity of services is vital to the success of the DHS mission. Continuing the existing service with the incumbent, ECS Federal, LLC, is in the best interest of the Government as it allows for economy and efficiency.

Moreover, in terms of economy, which speaks to the quality of the resources being used to generate the greatest benefit to the Government, it has has determined that continuing the existing service is crucial to ensure expert system support personnel are available for the EPMS services. Doing so will reduce the risk of disruption of service, duplication of efforts, transition delays, and increased cost. Continuity of operations would be negatively affected by a lapse in support. In terms of efficiency, only the incumbent can properly provide for continuity of services at a level sufficient to meet mission requirements for system performance which includes ongoing management and technical support for the migrations, modernizations, refactoring, and operations and maintenance for all SDD integrated services. This requirement supports the continued use of tools/techniques developed under the current order and bringing in a new contractor for a one-year period would further be an inefficient use of Government and contractor resources. The costs and risk of getting a new contractor up to speed with the work to be done under the EPMS requirement would be an inefficient use of contractor and Government resources for a one-year period.

The incumbent is currently working with several customers sites that will be directly

LSJ No: - 3 -impacted by software features and functions that will reach End of Life in Q2 of FY26. If a new vendor is selected, the entire impact assessment and planning process will need to be redone, causing disruptions to several lines of business. This new work will involve extensive coordination with affected customers to ensure a smooth transition, including detailed impact assessments, development of mitigation plans, and execution of transition strategies to minimize service disruptions.

A gap in service or abrupt transition to a new vendor would create risk to several lines of business (CFO, USM, CHCO) experiencing service disruptions due to the End of Life status of current features and functions. These disruptions could manifest as reduced system functionality, increased downtime, and potential data integrity issues. Critical business operations that rely on these features may face significant delays, impacting overall productivity and service delivery. Additionally, there may be increased support requests and escalations from affected users, further straining resources.

Due to the extensive domain knowledge of the incumbent the process of “fixing” would be nearly impossible and would ultimately require reverse engineering. The reverse engineering process could take 2-6 months depending on the nature of the problem and quantity of systems affected. Reverse engineering a process or solution is duplication of efforts by having to pay another vendor to duplicate the efforts of the incumbent to understand a technical solution.

All project planning activities and customer communications would need to be repeated if a vendor turnover occurs. This includes re-evaluating current project scopes, timelines, and resource allocations. Detailed impact assessments and risk analyses would have to be conducted again to understand the implications of the new vendor's software on existing systems. Customer engagement efforts, such as meetings, briefings, and training sessions, would also need to be redone to ensure all stakeholders are informed and prepared for the transition.

Onboarding an entirely new staff can take anywhere from 2 to 6 months depending on the time associated with finding the candidate, submitting for approval from the Government, completing the limited background, account creation, obtaining GFE and PIV card, and obtaining necessary knowledge to become operational.

These delays could extend project timelines, affecting the delivery of critical features and functions. Furthermore, there may be a learning curve associated with a new vendor's software, requiring additional time for training and adaptation by both technical staff and end-users. Overall, these delays could significantly impact the continuity and efficiency of business operations.

From a cost perspective, when discussing a gap in service or switching to a new vendor, there are several variables that need to be accounted for, including internal agency costs, the transition period, and the risk associated with unfinished projects.

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Internal agency costs include the expenses related to the time and resources spent by agency staff to manage the transition. This can involve project management, coordination meetings, and the reallocation of personnel to oversee the changeover. Additionally, there may be costs associated with updating internal systems, documentation, and training materials to align with the new vendor's processes and requirements.

The transition period can incur significant costs due to the overlap between the old and new vendors. This might include dual-running costs where both vendors are operational simultaneously to ensure a smooth handover. There may also be expenses related to the setup and configuration of new systems, data migration, and the potential need for temporary staffing to handle increased workloads during the transition phase.

Switching vendors can pose risks to ongoing projects, particularly if they are left unfinished during the transition. These risks include potential delays, increased costs to complete the projects (to include reverse engineering), and the possibility of losing critical knowledge or expertise if the original vendor's staff are no longer available.

Additionally, there is a risk of decreased service quality or disruptions that could impact the agency's operations and stakeholder satisfaction. Mitigating these risks requires careful planning, clear communication, and contingency strategies to ensure continuity and minimize negative impacts.

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 order to ECS Federal, LLC, for the procurement of services described herein is in the best interest of the Government and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs. This order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.” The General Services Administration (GSA) Multiple Award Schedule (MAS) contract no. GS-00F-072CA has already negotiated fair and reasonable pricing rates. Discounts to these GSA MAS rates will be requested. Additionally, prior to issuance of the task order, the ordering activity will consider the level of effort, and the mix of labor proposed to perform the specific tasks being ordered in order to determine that the total price is reasonable. The contractor’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate.

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.

During the market research phase, conducted December 2024 - February 2025, DHS/OPO reviewed the current EPMS Call Order 70RTAC23FC0000050 under the DHS ADaPTS BPA vehicle 70RTAC19A00000009. Reviewing the acquisition history aided

LSJ No: - 5 -the program office in identifying what options were available for the follow-on requirement and the most feasible approach in the best interest of the Government.

DHS/OPO also interviewed knowledgeable individuals within the Government to determine the best acquisition strategy and to confirm the Governments requirement. The Contracting Officer, Contract Specialist, and Program Office personnel were key in identifying the best approach to conduct market research to support this requirement and plans going forward. During the interview with SDD Management and Subject Matter Experts it was determined that a logical follow-on is necessary to continue to build on the work initiated under the current contract. The previous contract for this support was provided by large businesses with Satisfactory or above Contractor Performance Assessment Reporting System ratings. To avoid a lapse in service that would have a negative impact to the continuity of services currently being provided, there is a need for an established company with a history of reliability and financial stability.

In review of existing DHS-wide and Multi-Component Contract Vehicles with the DHS Strategic Solutions Office and/or on the DHS Enterprise-wide Contract Vehicle Portal, it was determined that the vehicles are not able to provide these services. This requirement requires large scale resources. While the small business vendor community may have the individual knowledge, skills and ability to support pieces of this requirement they are not able to support the full scale of this requirement.

During the interview with SDD Management and Subject Matter Experts it was determined that a logical follow-on is necessary as this requirement is a natural continuation of the previous contract.

The replacement vehicle to the ADaPTS BPA, a follow-on procurement titled DHS ADaPTS 2.0, is in progress and is expected to be awarded in 2025 to continue to provide a contract vehicle for these highly specialized services for DHS into the year 2029 (including options). Once the DHS ADaPTS 2.0 vehicle is awarded, new EPMS requirements will be competed amongst the BPA holders.

7. Any other facts supporting the limited-sources justification. There are no additional facts to state.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made.

This order is a short-term contract to continue services while the ADaPTS BPA 2.0 is in the preaward process. The need for this order is not due to poor planning. The ADaPTS BPA 2.0 is in process and current milestones show an award date of July 2025.

However, there are concerns of milestone slippage in the ADaPTS 2.0 award due to the high volume of quotations received in Phase II of the evaluations. Phase II of the solicitation requires a technical evaluation which will require more time than originally