J-and-A-Other-Than-Full-and-Open Deloitte HSPD12 (CO_AM Signed).pdf

Template for Justification and Approval for Other Than Full and Open Competition Completion Instructions: The Department of Health and Human Services (HHS) has established a standard template for the preparation of a J&A for Other Than Full and Open Competition. If this is an 8(a) set-aside, please note this form is not required unless the acquisition is valued (including all options) at greater than $22 million. This template is NOT applicable for actions using simplified acquisition procedures (FAR Subpart 13.5), Federal Supply Schedule orders (FAR 8.4), or task or delivery orders subject to fair opportunity (FAR 16.505).

Tailor all aspects of this template to the individual acquisition. Consult FAR Subpart 6.3 for guidance.

Delete the blue italic portions of this document prior to signature. Do not include these instructions in the final document or contract file.

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

Acquisition Title: HSPD12 Implementation Technology - Automation Services. HSPD12 e745 Services for FICAM Program Support.

Agency: IHS

Acquisition Year: FY2025

Author: Ashley Marth + Brendon Moran

2. Description of Action:

Nature: New Requirement Follow-on Requirement

Modification to Existing Purchase Order/Contract Number:

Pricing: Firm-Fixed Price Time & Materials Cost

Other:

Funds: OMA Other Funds:

Name of Proposed Contractor(s): Deloitte Consulting, LLP

Street Address: 1299 Pennsylvania Avenue NW, 10th Floor

City, State, Zip: Washington, DC 20004

3. Description of Services or Supplies:

Basis for Approval (FAR 6.303-1(d)): Individual Basis Class Basis

The total estimated value of the proposed action, including all options is $ 769,789.55

As applicable, briefly describe the services or supplies required to meet the agency's needs, including make & model number where appropriate. Include quantities of supplies or period of performance for services. Provide information for any options included. If the action is a modification to an existing contract, distinguish clearly between the work covered by the basic order and the work to be obtained by the proposed modification.

The IHS onboarding activities are completed through collaboration between Headquarters Office of Human Resources, Office of Management Services, and Area Offices through manual data updates from multiple systems. IHS will update its process to support the Paper Reduction Act, FASA, Return-to-Work In Person Executive Order (January 2025) and M-25-25 USE IT Act (April 2025) to support mandatory technology solutions required to meet the Executive Orders.

This is a COTS solution supporting FASA under the Deloitte contract, CIO-SP3 HHSN316201200018W. This is similar to the Access

Management System (AMS) data integration that integrated SMCS and AMS data to support SailPoint Identity Management, Order 75H70422F80024. The contractor shall provide all personnel, equipment, tools, materials, supervision, and quality control necessary, to provide e745 automated HSPD-12 document flow to replace the paper HHS-745 Badge Request Form, eScheduling Services for HSPD-12 PIV cards required for authentication, and USA Staffing data integration within the Smart Card Management Services required for enhanced data tracking to support Executive Orders.

Positions IHS will be interoperable with other HHS OpDivs using the eForms and Scheduler solutions Technology modernization to provide process efficiencies and cost-savings while reducing user errors and waste IHS will be adopting a pre-built, cost-effective system framework used and continuously-improved by other HHS OpDivs Reporting provides transparency into workforce productivity and process bottlenecks USAS integration creates pre-existing records in the SCMS resulting in less manual data entry Modern customer self-scheduling interface replaces customer calls/emails to badging office Badging Admin interface enables instant updates to office availability and bulk-processing of appointments System controls to flag and escalate unscheduled and missed badging appointments Automated email workflow tailored to the customer’s request and badging office availability and capabilities Enables streamlined scheduling of Federal Employee PIV appointments Unifies data sourcing and increases data integrity for reliable appointment forecasting

4. Authority and Rationale: Identify the statutory authority, FAR title and FAR citation permitting other than full and open competition. It may be one of the following most commonly used citations by the operating divisions of the Department of Health and Human Services (HHS), but other exceptions may apply per FAR Subpart 6.3.

FAR 6.302-1. See below.

Actions other than simplified acquisition procedures (select only one and provide an explanation):

FAR 6.302-1: Only one responsible source and no other supplies or services will satisfy agency requirements, 41 U.S.C.

3304(a)(1)

Explain why the intended contractor is the only responsible source who can provide the required supplies or services.

Discuss the unique capabilities, expertise, etc. that support the lack of competition/why no other type of supplies or services will satisfy agency requirements. Explain factors/unique qualifications such as proprietary data or exclusive licensing rights, if applicable. If brand name, explain why an adequate purchase description or other information suitable to solicit by full and open competition has not been developed or are not available. If in connection with a follow-on contract for continued development or production of highly specialized equipment, detail the substantial duplication of cost or unacceptable delays.

The IHS Headquarters requires the technology solutions to meet M-25-25 USE IT Act requirements for data occupancy tracking and PIV card enforcement and to support the Executive Order Return-to-Work In-Person. This is a commercial off the shelf (COTS) solution that supports Federal Acquisition Streamlining Act (FASA) and the Paperwork Reduction Act. This solution is only offered by one vendor, Deloitte.

FAR 6.302-2: Unusual and compelling urgency, 41 U.S.C. 3304(a)(2) If unusual and compelling urgency is the basis for the justification, explain the chronological events leading up to the requirement and explain why time constraints cannot permit even a limited competition. Establish that the action will cover only the minimum quantity or period of performance necessary; in most cases options are unacceptable when citing urgency.

Describe impact of required delivery/performance date. Describe the detrimental effects/serious injury to the mission of the requiring activity or to the government, financial or otherwise, that will result if this justification is not approved and the product or service cannot be provided by the intended sole source contractor. Failure to plan for expiring funds is not a valid reason for citing this exception.

N/A.

FAR 6.302-5: Authorized or Required by Statute, 41 U.S.C. 3304(a)(5) Provide a citation to the statutory authorization and a brief description of its content, or identify the specified source or other agency.

N/A.

Other (See FAR Subpart 6.3 for additional authority):

Provide a citation to the applicable section of FAR 6.3 and a full explanation to justify use of the exception.

N/A.

5. Bridge Contracts:

For contract extensions or bridge contracts when a competitive follow-on is in the process of being developed, summarize history of current contract and explain the reasons for any delays in the acquisition. Include discussion of the milestones for the follow-on action; the milestones should be as efficient as possible. Discuss why it would be neither cost effective nor realistic to expect another contractor to perform during the brief interim period; include issues such as start-up costs, phase-in, transfer of GFP, recruitment and staffing, etc. If the action is because of a protest, provide a brief discussion of the protest including the date the protest was filed and the basis of the protest. Explain that the action will provide the minimum quantity or performance period.

N/A.

6. Actions to Increase Competition:

Describe efforts made to compete the action, including whether a notice was or will be publicized as required by FAR Subpart

5.2 or which exception under FAR 5.202 applies. If a notice was publicized, discuss the number of written responses to the synopsis and the results of the assessment of the written responses. List sources, if any, that expressed, in writing, an interest in the acquisition. Provide rationale if interested sources were rejected. If applicable, state that no other sources have expressed interest, but all offers received shall be considered. Describe what actions will be taken to increase competition before subsequent acquisition of the supplies or services is required. You may state that an action is a one-time requirement, but if a similar requirement arises, every effort will be made to compete it to the maximum extent possible. If action is sole source because of proprietary data or licensing rights and there will be a continuing need for the requirement, there must be evidence that advanced planning has been initiated to overcome the barriers to competition, or there should be documentation to support an analysis that replacement costs/licensing purchase costs outweigh the benefits of competition.

If the action is a contract extension or bridge, explain actions to compete the follow-on. If action is an urgent new requirement and a competitive follow-on is anticipated, explain that efforts are underway to facilitate a full and open competition.

Limited, as utilization of the CIO-SP3 solution is required for implementation of the requirement. This contracting solution offered via CIO-SP3 is known to be of a Sole Source nature, which was recently confirmed via market research and the associated Information Technology Business Needs Statement produced by the Program Office. Information provided was verified by the Buyer. A Notice of Intent will be posted to www.SAM.gov.

7. Market Research:

Describe the extent of the market research conducted to identify all qualified sources and the results thereof. “Market Research” is defined as those attempts you made to ascertain whether other qualified sources exist, and can include contact with knowledgeable experts regarding similar or duplicate requirements, contact with industry, results of a sources sought synopsis, or draft solicitations. Research of the marketplace may consist of written, electronic (i.e. email) telephonic, or world wide web inquiries. Lack of advanced planning is not an acceptable reason for the lack of market research, but true urgency may necessitate abbreviated market research that is limited to readily available historical and commercial information. If action is a contract extension or bridge contract, describe the market research efforts underway or completed for the follow-on.

Deloitte Consulting LLP is the current provider to HHS for Derived Credentials token issuance on mobile devices. Additional market research confirmed that Deloitte CIO-SP3 contract HHSN316201200018W, task order 75P00121F800070 is still providing this service for HHS. No other existing contracting vehicles were identified.

The only vendor allowed to perform integration services into the HHS Smart Card Management System platform is Deloitte. The work conducted by the vendor in this system is considered proprietary. As such, the only vendor capable of receiving award under this requirement is Deloitte.

8. Procurement History:

Purchase order or contract number: N/A.

Was action competed? Yes No

If action was not competed, state the cited authority, summarize rationale, and describe the actions that were supposed to be taken to increase competition and the results thereof:

N/A.

9. Additional Information to support the justification If applicable, explain why technical packages or specifications to facilitate competition were not developed or available;

describe actions taken to remedy the situation.

This is a one-time enhancement that will reach end-of-life before the five fiscal-year budget cycle ends. There is an estimated count of 5 FTE using up to 25% of the time for up to a 30 day period during implementation. The costs are based on the IGCE and this is a Sole Source, Other Than Full and Open Competition type requirement. The estimated time will be about 40 hours of FTE work, estimated to be approx. $16,000.00 of pay and benefits. The work is coordinating between offices, writing the acquisition, implementation and training and no other required time is expected. The trainees are already using the system, already use the eForms for other HHS OpDiv appointments and will only require minimal instructions to switch from manually filling out the HHS 745 Badge request Form to e745 and emailing/calling to set up PIV appointments to the using the eScheduler. Once the enhancement is complete, all system maintenance, patching, or other costs are included under the HHS Contract paid via SLA. IHS does not expect any additional costs related to these enhancements.

Failure to modernize the IHS on-boarding process has many high likelihood, high-impact risks. It will result in non-compliance with the USE IT Act M-25-25 memorandum directing agencies to procure technology solutions to monitor building occupancy through technology solutions and monitor employees' compliance with the Return to Work In-Person executive order through PIV card technologies. Office of Direct Service and Contracting Tribes (ODSCT) and Area Lead Negotiators (ALN) require advanced written process for Tribal Employees to get a PIV card, once required for access to the new PATH EHR systems as required by the IT Modernization Act of 2025, and IHS is required to provide consultation to Tribes, per ISDEAA. The SCMS tracks Tribal employees for cost shares. Failure to provide a platform for HSPD-12 automated communication will result in relying on individuals within IHS to manually discuss and email on-boarding data, causing continuous delays to gain access to health systems. The same risks apply to IHS employees and contractors, creating additional risks to the IHS strategic plan goals and objectives related to recruitment. It's a high likelihood and impact that IHS will continue to lose candidates and contractors during the on-boarding process due to delays.

Benefits include replacing the paper-based credential request process with a streamlined digital workflow system to expedite onboarding and credentialing, automates signature collection, file encryption, and instant file transfer and validation, appointments within the SCMS instead of Outlook calendar invites; customer self-scheduling interface replaces customer calls/emails to badging office; built-in system controls to flag and escalate unscheduled and missed badging appointments; and automated email workflow for appointments. The USAS data will populate SCMS with tentative offers and EOD data instead of relying on emails from HR staffing. Reporting provides transparency into workforce productivity and accountability; and all other HHS OpDivs already use the same e745/e828, eScheduler and integration.

10. Technical / Requirements Certification: By my signature below, I certify that the supporting data under my review which is included in this J&A is accurate and complete.

Program Manager

Name: Crystal Sandoval

Position Title: Program Specialist

Email address: Crystal.Sandoval@ihs.gov

Phone: (301) 443-2571

Program Manager Supervisor (or one level above Program Manager)

Name: Ashley Marth

Position Title: Acting Director - Division of Administrative and Emergency Services

Email address: Ashley.Marth@ihs.gov

Signature

Date: Jul 24, 2025

11. Fair and Reasonable Price Determination: As Contracting Officer, by my signature below, I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable.

Provide the basis for this determination, e.g., describe techniques to be used to determine fair and reasonable price (FAR Subpart 15.402), such as price analysis, cost analysis, cost realism. Per FAR Subpart 15.403-4(a)(1), the threshold for obtaining cost or pricing data is $750,000.

Services are being procured via a HHS Best in Class contracting vehicle, CIO-SP3. Services procured via this contracting vehicle are subject to a higher level of financial scrutiny than standard Open Market solutions. Pricing will be compared to

12. Contracting Officer's Approval (Required for proposed contract not to exceed $700,000 (value calculated including all options)): I hereby certify that this justification is accurate and complete to the best of my knowledge. I approve this sole source justification subject to availability of funds, and provided that the services and supplies herein described have otherwise been authorized for acquisition.

Name: Brendon Moran Phone: (240) 478-1994

Signature: Date: Jul 24, 2025

13. Legal Review:

All J&As equal to or greater than $68 million must have a legal review from the General Law Division of the Office of the General Counsel prior to sending it to the Department.

N/A.

14. OPDIV Competition Advocate Approval (Required for proposed contract over $700,000 but not exceeding $13.5 million value calculated including all options):

I have reviewed this justification and find that it adequately supports other than full and open competition.

Name: Phone:

Signature: Date:

15. Office of Small and Disadvantaged Business Utilization I have reviewed this justification and find that it adequately supports other than full and open competition.

Name: Phone:

Signature: Date:

16. OPDIV HCA Approval (Required for proposed contract over $13.5 million but not exceeding $68 million value calculated including all options):

Name: Phone:

Signature: Date:

(The below approval paragraph is required if the cumulative contract value, including all options, equals or exceeds $68 million.)

HHS Senior Procurement Executive (SPE) Approval Based on the foregoing justification, I hereby approve the procurement of (state supplies/services being procured) on an other than full and open competition basis pursuant to the authority of (state the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304), as implemented by FAR 6.301), subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

Name: Phone:

Signature: Date:

Template for Justification and Approval for Other Than Full and Open Competition Completion Instructions: The Department of Health and Human Services (HHS) has established a standard template for the preparation of a J&A for Other Than Full and Open Competition. If this is an 8(a) set-aside, please note this form is not required unless the acquisition is valued (including all options) at greater than $22 million. This template is NOT applicable for actions using simplified acquisition procedures (FAR Subpart 13.5), Federal Supply Schedule orders (FAR 8.4), or task or delivery orders subject to fair opportunity (FAR 16.505).

Tailor all aspects of this template to the individual acquisition. Consult FAR Subpart 6.3 for guidance.

Delete the blue italic portions of this document prior to signature. Do not include these instructions in the final document or contract file.

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

2. Description of Action:

Nature:

Pricing:

Funds:

3. Description of Services or Supplies:

Basis for Approval (FAR 6.303-1(d)):

As applicable, briefly describe the services or supplies required to meet the agency's needs, including make & model number where appropriate. Include quantities of supplies or period of performance for services. Provide information for any options included. If the action is a modification to an existing contract, distinguish clearly between the work covered by the basic order and the work to be obtained by the proposed modification.

4. Authority and Rationale: Identify the statutory authority, FAR title and FAR citation permitting other than full and open competition. It may be one of the following most commonly used citations by the operating divisions of the Department of Health and Human Services (HHS), but other exceptions may apply per FAR Subpart 6.3.

Actions other than simplified acquisition procedures (select only one and provide an explanation):

Explain why the intended contractor is the only responsible source who can provide the required supplies or services. Discuss the unique capabilities, expertise, etc. that support the lack of competition/why no other type of supplies or services will satisfy agency requirements. Explain factors/unique qualifications such as proprietary data or exclusive licensing rights, if applicable. If brand name, explain why an adequate purchase description or other information suitable to solicit by full and open competition has not been developed or are not available. If in connection with a follow-on contract for continued development or production of highly specialized equipment, detail the substantial duplication of cost or unacceptable delays.

If unusual and compelling urgency is the basis for the justification, explain the chronological events leading up to the requirement and explain why time constraints cannot permit even a limited competition. Establish that the action will cover only the minimum quantity or period of performance necessary; in most cases options are unacceptable when citing urgency. Describe impact of required delivery/performance date. Describe the detrimental effects/serious injury to the mission of the requiring activity or to the government, financial or otherwise, that will result if this justification is not approved and the product or service cannot be provided by the intended sole source contractor. Failure to plan for expiring funds is not a valid reason for citing this exception.

Provide a citation to the statutory authorization and a brief description of its content, or identify the specified source or other agency.

Provide a citation to the applicable section of FAR 6.3 and a full explanation to justify use of the exception.

5. Bridge Contracts:

For contract extensions or bridge contracts when a competitive follow-on is in the process of being developed, summarize history of current contract and explain the reasons for any delays in the acquisition. Include discussion of the milestones for the follow-on action; the milestones should be as efficient as possible. Discuss why it would be neither cost effective nor realistic to expect another contractor to perform during the brief interim period; include issues such as start-up costs, phase-in, transfer of GFP, recruitment and staffing, etc. If the action is because of a protest, provide a brief discussion of the protest including the date the protest was filed and the basis of the protest. Explain that the action will provide the minimum quantity or performance period.

6. Actions to Increase Competition:

Describe efforts made to compete the action, including whether a notice was or will be publicized as required by FAR Subpart 5.2 or which exception under FAR 5.202 applies. If a notice was publicized, discuss the number of written responses to the synopsis and the results of the assessment of the written responses. List sources, if any, that expressed, in writing, an interest in the acquisition. Provide rationale if interested sources were rejected. If applicable, state that no other sources have expressed interest, but all offers received shall be considered. Describe what actions will be taken to increase competition before subsequent acquisition of the supplies or services is required. You may state that an action is a one-time requirement, but if a similar requirement arises, every effort will be made to compete it to the maximum extent possible. If action is sole source because of proprietary data or licensing rights and there will be a continuing need for the requirement, there must be evidence that advanced planning has been initiated to overcome the barriers to competition, or there should be documentation to support an analysis that replacement costs/licensing purchase costs outweigh the benefits of competition. If the action is a contract extension or bridge, explain actions to compete the follow-on. If action is an urgent new requirement and a competitive follow-on is anticipated, explain that efforts are underway to facilitate a full and open competition.

7. Market Research:

Describe the extent of the market research conducted to identify all qualified sources and the results thereof. “Market Research” is defined as those attempts you made to ascertain whether other qualified sources exist, and can include contact with knowledgeable experts regarding similar or duplicate requirements, contact with industry, results of a sources sought synopsis, or draft solicitations. Research of the marketplace may consist of written, electronic (i.e. email) telephonic, or world wide web inquiries. Lack of advanced planning is not an acceptable reason for the lack of market research, but true urgency may necessitate abbreviated market research that is limited to readily available historical and commercial information. If action is a contract extension or bridge contract, describe the market research efforts underway or completed for the follow-on.

8. Procurement History:

Was action competed?

If action was not competed, state the cited authority, summarize rationale, and describe the actions that were supposed to be taken to increase competition and the results thereof:

9. Additional Information to support the justification If applicable, explain why technical packages or specifications to facilitate competition were not developed or available; describe actions taken to remedy the situation.

10. Technical / Requirements Certification: By my signature below, I certify that the supporting data under my review which is included in this J&A is accurate and complete.

Program Manager Name:

Position Title:

Email address:

Phone:

Program Manager Supervisor (or one level above Program Manager) Name:

Position Title:

Email address:

Signature Date:

11. Fair and Reasonable Price Determination: As Contracting Officer, by my signature below, I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable.

Provide the basis for this determination, e.g., describe techniques to be used to determine fair and reasonable price (FAR Subpart 15.402), such as price analysis, cost analysis, cost realism. Per FAR Subpart 15.403-4(a)(1), the threshold for obtaining cost or pricing data is $750,000.

12. Contracting Officer's Approval (Required for proposed contract not to exceed $700,000 (value calculated including all options)): I hereby certify that this justification is accurate and complete to the best of my knowledge. I approve this sole source justification subject to availability of funds, and provided that the services and supplies herein described have otherwise been authorized for acquisition.

Name:

Phone:

Signature:

Date:

13. Legal Review:

All J&As equal to or greater than $68 million must have a legal review from the General Law Division of the Office of the General Counsel prior to sending it to the Department.

14. OPDIV Competition Advocate Approval (Required for proposed contract over $700,000 but not exceeding $13.5 million value calculated including all options):

I have reviewed this justification and find that it adequately supports other than full and open competition.

Name:

Phone:

Signature:

Date:

15. Office of Small and Disadvantaged Business Utilization I have reviewed this justification and find that it adequately supports other than full and open competition.

Name:

Phone:

Signature:

Date:

16. OPDIV HCA Approval (Required for proposed contract over $13.5 million but not exceeding $68 million value calculated including all options):

Name:

Phone:

Signature:

Date:

(The below approval paragraph is required if the cumulative contract value, including all options, equals or exceeds $68 million.)

HHS Senior Procurement Executive (SPE) Approval Based on the foregoing justification, I hereby approve the procurement of (state supplies/services being procured) on an other than full and open competition basis pursuant to the authority of (state the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304), as implemented by FAR 6.301), subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

Name:

Phone:

Signature:

Date:

11.0.0.20130303.1.892433.887364 Justification & Approval - Other Than Full and Open Competition Health and Human Services Justification & Approval - Other Than Full and Open Competition

This is a COTS solution supporting FASA under the Deloitte contract, CIO-SP3 HHSN316201200018W. This is similar to the Access Management System (AMS) data integration that integrated SMCS and AMS data to support SailPoint Identity Management, Order 75H70422F80024. The contractor shall provide all personnel, equipment, tools, materials, supervision, and quality control necessary, to provide e745 automated HSPD-12 document flow to replace the paper HHS-745 Badge Request Form, eScheduling Services for HSPD-12 PIV cards required for authentication, and USA Staffing data integration within the Smart Card Management Services required for enhanced data tracking to support Executive Orders.

Positions IHS will be interoperable with other HHS OpDivs using the eForms and Scheduler solutions Technology modernization to provide process efficiencies and cost-savings while reducing user errors and waste IHS will be adopting a pre-built, cost-effective system framework used and continuously-improved by other HHS OpDivs Reporting provides transparency into workforce productivity and process bottlenecks USAS integration creates pre-existing records in the SCMS resulting in less manual data entry Modern customer self-scheduling interface replaces customer calls/emails to badging office Badging Admin interface enables instant updates to office availability and bulk-processing of appointments System controls to flag and escalate unscheduled and missed badging appointments Automated email workflow tailored to the customer’s request and badging office availability and capabilities Enables streamlined scheduling of Federal Employee PIV appointments Unifies data sourcing and increases data integrity for reliable appointment forecasting

The only vendor allowed to perform integration services into the HHS Smart Card Management System platform is Deloitte. The work conducted by the vendor in this system is considered proprietary. As such, the only vendor capable of receiving award under this requirement is Deloitte.

use the eForms for other HHS OpDiv appointments and will only require minimal instructions to switch from manually filling out the HHS 745 Badge request Form to e745 and emailing/calling to set up PIV appointments to the using the eScheduler. Once the enhancement is complete, all system maintenance, patching, or other costs are included under the HHS Contract paid via SLA. IHS does not expect any additional costs related to these enhancements.

Failure to modernize the IHS on-boarding process has many high likelihood, high-impact risks. It will result in non-compliance with the USE IT Act M-25-25 memorandum directing agencies to procure technology solutions to monitor building occupancy through technology solutions and monitor employees' compliance with the Return to Work In-Person executive order through PIV card technologies. Office of Direct Service and Contracting Tribes (ODSCT) and Area Lead Negotiators (ALN) require advanced written process for Tribal Employees to get a PIV card, once required for access to the new PATH EHR systems as required by the IT Modernization Act of 2025, and IHS is required to provide consultation to Tribes, per ISDEAA. The SCMS tracks Tribal employees for cost shares. Failure to provide a platform for HSPD-12 automated communication will result in relying on individuals within IHS to manually discuss and email on-boarding data, causing continuous delays to gain access to health systems. The same risks apply to IHS employees and contractors, creating additional risks to the IHS strategic plan goals and objectives related to recruitment. It's a high likelihood and impact that IHS will continue to lose candidates and contractors during the on-boarding process due to delays.

Benefits include replacing the paper-based credential request process with a streamlined digital workflow system to expedite onboarding and credentialing, automates signature collection, file encryption, and instant file transfer and validation, appointments within the SCMS instead of Outlook calendar invites; customer self-scheduling interface replaces customer calls/emails to badging office; built-in system controls to flag and escalate unscheduled and missed badging appointments; and automated email workflow for appointments. The USAS data will populate SCMS with tentative offers and EOD data instead of relying on emails from HR staffing. Reporting provides transparency into workforce productivity and accountability; and all other HHS OpDivs already use the same e745/e828, eScheduler and integration.