JA 21-00250_FAR 8.4_LSJ_final signed_Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

LIMITED-SOURCES JUSTIFICATION

ORDERS OR BPAS EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

Page 1 of 4 Version 2.0

J&A-21-00250

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.

Identification of the agency, contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

The Department of Homeland Security, U.S. Immigration and Customs Enforcement (ICE), Office of Acquisition Management (OAQ), on behalf of the Homeland Security Investigations (HSI), Worksite Enforcement Unit (WSEU) and National Gang Unit (NGU) proposes to award an order or BPA pursuant to FAR 8.405-6(a), Limiting Sources.

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

(a) Type of action: Contract modification – period of performance extension

(b) Amount the current J&A is justifying: $314,535.19

(c) Brief Description: OAQ intends to procure, on a sole source basis, Intelligence Analyst

(IA) and Subject Matter Expertise (SME) services from the following company.

SRA International Inc. (a General Dynamics Information Technology (GDIT) Company) 4300 Fair Lakes Court Fairfax, VA 22033-4232

3. Description of Supplies/Services.

The requirement is to provide an additional six months of IA and SME services at a total cost of $314,535.19. These services are required to facilitate WSEU’s and NGU’s mission as described in the “rationale” section below.

Period Time Price

Current Extension 6 mos. $314,535.19 Total Contract value $2,815,619.33

LIMITED-SOURCES JUSTIFICATION

ORDERS OR BPAS EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

Page 1 of 4 Version 2.0

The chart above details the entire contract value; however, this limited source justification is only required to support the six month extension in accordance with FAR 52.217-8 Option to Extend Services, which will be added to the contract by modification.

4. Authority and supporting rationale and a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

Authority:

Select only one of the following circumstances justifying limiting sources pursuant to FAR 8.405-6(a)(1)(i) below and demonstrate the proposed contractor’s unique qualifications to provide the required supply or service.

8.405-6(a)(1)(i)(A) An urgent and compelling need exists, and following the ordering procedures would result in unacceptable delays.

8.405-6(a)(1)(i)(B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

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.

Rationale:

The WSE SME assists the WSE program in engaging with a wide range of stakeholders and guides the determination of systems and business processes that affect the WSEU’s ability to support/meet organizational threats. The SME participates in strategy sessions, strategic assessments, and designs reviews to validate approaches and associated work products.

Further, the WSEU SME provides counsel in the areas of organizational and vulnerability assessments; intelligence and threat analysis; and the resolution of complex policy issues.

WSEU is in a state of transition as it works to define its place in the new administration. To that end, the WSEU is in the process of working with Department of Homeland Security Headquarters, U.S. Citizenship and Immigration Services as well as other stakeholders to create new regulatory language that will affect how all businesses in the country facilitate their hiring. Additionally, the WSEU is in the process of drafting new policy and procedures as it relates to the execution of the worksite enforcement mission and its role in the new administration. The need for a SME versed in not only immigration related policy but more specifically immigration law and policy as it relates to worksite enforcement is invaluable and any lapse in service would affect operations and an orderly transition moving forward.

The work being done on this contract supports the NGU which serves as HSI conduit to the Federal Bureau of Investigation analytical component at Joint Task Force Vulcan. Task Force Vulcan’s mission is to coordinate law enforcement agencies’ efforts against MS-13, with the ultimate goal of dismantling the organization. Currently HSI is the driving force in Task Force Vulcan. HSI has ongoing investigations that are not yet complete for which this

LIMITED-SOURCES JUSTIFICATION

ORDERS OR BPAS EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

Page 1 of 4 Version 2.0 contractor is providing intelligence analyst support services on. It is unacceptable to the agency to end this work prior to the completion of the tasks already started by this contractor, as they relate to pending prosecutions. The expertise held by the current contractor and work they have already performed and are continuing progress on would be dismantaled if a new award was made this fiscal year. Awarding a new contract at this time would disrupt ongoing investigations as it would require a new contractor time to familiarize themselves with Task Force operations effectively as they would not have the knowledge and insight into investigations already started. Adding FAR 52.217-8, Option to Extend Services (Mar 2000), to the current contract and extending it by six months would allow planning time to ramp down current investigations and bring them to a close. A new acquisition for these services is planned for fiscal year 2022.

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 modification to SRA International for the continuation of IA and SME services represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs. General Services Administration (GSA) has already determined the rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by FAR 8.405-2(d). This requirement was met at time of initial award as this order was competitively awarded with base and four one-year option periods evaluated at time of award. The extension of services for six months will be at the same rate as Option Period Four, which was evaluated at time of award.

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.

Market research was conducted, however there are no vendors who can perform this work for the immediate six month extension required; September 25, 2021 through March 24, 2022.

The Government intends to begin the recompete for this requirement in the first quarter of fiscal year 2022.

7. Any other facts supporting the limited-sources justification. Additional facts may be stated in this section. If there are no additional facts, you must state that here.

Not applicable.

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.

Competition was achieved on the initial task order award. Competition is not available for the extension. The Government will be recompeting for this effort in early fiscal year 2022.

APFS record has been posted.

LIMITED-SOURCES JUSTIFICATION

ORDERS OR BPAS EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

Page 1 of 4 Version 2.0

9. DHS intends to post this requirement on Fedbizopps pursuant to FAR 8.405-6(a)(2).

10. Technical/Requirements Personnel Certification.

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

______________________________ 8/18/2021 VITALIY VIKOVAN Date Primary COR

11. Contracting Officer Certification and/or Approval *

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and complete to the best of my knowledge and belief:

______________________________ 8/18/2021 TRACY D. RILEY Date Contracting Officer

TRACY D

RILEY

Digitally signed by TRACY D

RILEY

Date: 2021.08.18 14:32:45 -05'00'

VITALIY S

VIKOVAN

Digitally signed by

VITALIY S VIKOVAN

Date: 2021.08.18 15:43:54 -04'00'