JA_Detention Inspections Services_FINAL 6.12.26_Redacted.pdf

Department of Homeland Security Office of Inspector General

Sole Source Justification

In accordance with the Federal Acquisition Regulation (FAR) 8.4 and General Services Administration Acquisition Manual (GSAM) 538.7104-3(b), the following justification documents the decision to award a Federal Supply Schedule (FSS) order on a sole source basis.

(1) Mission Area and Contracting Activity.

Requisition Number: REQOIE-26-00-003

Requesting Activity Agency: Department of Homeland Security (DHS), Office of Inspector General (OIG), Office of Inspections and Evaluations (OIE)

Contracting Activity: DHS OIG Acquisitions Division

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

This justification authorizes and approves the award of a new sole-source time-and-materials order that will provide contractor support services in support of DHS OIG’s oversight of U.S.

Immigration and Customs Enforcement (ICE) detention facilities. Given the significant growth in the immigration detention environment and an increase in allegations of facilities not meeting standards, there is an immediate and urgent need for DHS OIG to increase the number of inspections it conducts to ensure appropriate oversight of detainee health, safety, security, and other relevant standards. DHS OIG acts as the sole independent oversight entity over immigration detention in the United States.

The suggested contractor is:

Vander Weele Group LLC 2848 Summit Avenue Highland Park, IL 60035 Unique Entity Identifier: K8TJVCR1N334

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The primary objective of this order is to allow DHS OIG to immediately and significantly increase the number of unannounced ICE detention facility inspections it conducts per year. This order will provide contractor support services to perform on-site walk-throughs, document observations and deficiencies, conduct interviews, request and collect data for further analysis, and reporting. This work is essential to DHS OIG’s oversight of ICE detention facilities and helps inform ICE, Congress, and the public about facilities’ operational and administrative practices and policies, compliance with relevant ICE detention standards, and other related perspectives.

The order is expected to include a one-year base period and a one-year option period. In addition to labor costs, contractor personnel will be required to travel extensively to detention facilities

SOURCE SELECTION INFORMATION - SEE FAR 3.104

Sole Source Justification located across the U.S. Thus, the order will include not-to-exceed travel amounts for each performance period. The total estimated value of the order is $24.6 million, as shown below (in millions).

Period Services Travel Total Base $9.207 $0.650 $9.857

Option 1 $9.207 $0.650 $9.857 Subtotal (Base + Option) $18.414 $1.300 $19.714

Evaluation of FAR 52.217-8 $4.604 $0.325 $4.929 Grand Total $23.018 $1.625 $24.643

(4) Identify the statutory authority permitting other than full and open competition.

The statutory authority supporting the placement of an FSS order that exceeds the Simplified Acquisition Threshold (SAT) on a sole source basis is: GSAM 538.7104-3 (b)(i) - The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need.

(5) Demonstrate that the nature of the acquisition requires using the authority cited.

The statutory authority above applies due to an urgent need for DHS OIG to immediately increase its oversight of an immigration detention system that has rapidly expanded in recent years. As the numbers of detainees, detention facilities, and detainee deaths have increased, so too must DHS OIG’s oversight program to meet the unprecedented challenges of the modern immigration detention environment. Unannounced inspections have direct bearing on the safety and security of human life, health, and wellbeing.

ICE’s detainee population has increased significantly from 2024 to 2026, with 58,000 detainees currently in custody. This surge in custody levels has resulted in overcrowding at existing detention facilities; building more facilities including tent camps; increased use of non-traditional (e.g., military bases) and non-dedicated (e.g., local jails, Federal prisons) facilities;

and the need to quickly hire more staff. The number of detention facilities has almost doubled in the past year, from roughly 100 at the beginning of 2025 to 240 as of May 2026.

This expansion in detainees and facilities has stressed the system’s staffing support. Some detention facilities are being operated by new contractors, including some with little-to-no experience in immigration detention. There has been a significant increase in the number of detainee deaths in FY 2025 and FY 2026, including one alleged homicide. Facilities are experiencing lower than required staffing numbers, specifically medical staff, risking the health and safety of human life. This is occurring at the same time when detainee populations are increasingly more vulnerable. For the first time since 2021, juveniles and families are being held long-term at a family detention center. ICE also detains pregnant females more frequently.

Finally, media has reported on detainees’ hunger strikes to protest conditions and treatment at existing facilities.

Sole Source Justification

DHS OIG acts as the sole independent oversight body over immigration detention. Other oversight elements within DHS (the Office of Civil Rights and Civil Liberties and Office of Immigration Detention Ombudsman) have been substantially reduced or have had functions eliminated, although ICE’s Office of Detention Oversight (ODO) continues its Congressionally mandated program of detention facility inspections. DHS OIG’s inspections differ from those of ICE ODO in that they are unannounced, can inspect any detention standard, and are managed by federal staff.

However, DHS OIG alone cannot rapidly scale its inspections to appropriately oversee the expanded immigration detention system. DHS OIG’s Office of Inspections and Evaluations, which manages the inspection program, lost four employees to the Deferred Resignation Program in early 2025. Currently, OIE has eight inspectors dedicated to inspecting ICE detention facilities. To expand the inspection program to the level mandated by Congress, it essential for DHS OIG to obtain the services of a contractor with skilled personnel to provide critical inspection support services. The contractor support will operate under the direction of and be led by a federal inspector.

Awarding this order on a sole source basis is necessitated by the urgency of the circumstances and conditions, not by a lack of performance specifications or planning by the Government. Only recently (April 30, 2026) did the Homeland Security and Further Additional Continuing Appropriations Act, 2026, provide funding for these additional inspections and oversight of detention facilities (Pub. L. 119-86, 140 Stat. 775) for a two-year period (through September 30, 2027). Beyond the rapid staffing support afforded via contracting, the limited duration of the funding also supports a contractor support approach rather than permanent federal employees.

A sole source schedule order to Vander Weele Group LLC will allow DHS OIG to rapidly deploy contractor inspection support necessary to increase oversight capacity within required operational timelines. Conducting broader Schedule ordering procedures would materially delay deployment of inspection capability beyond operationally acceptable timelines established. Such delay is unacceptable because DHS OIG would be limited in its ability to conduct detention inspections at the scale required to address emerging oversight risks affecting detainee health, safety, security, and wellbeing, increasing the potential for harm and attendant liabilities.

(6) A determination by the Contracting Officer that the order represents a fair and reasonable price.

Although GSAM 538.7102-2(d) waives a formal determination, the Contracting Officer anticipates that pricing will be fair and reasonable since the order is being placed against the contractor’s GSA Schedule. The Contracting Officer will ensure the final price is fair and reasonable by verifying labor category and rate alignment, confirming any applicable discounts, and reviewing the final pricing prior to award.

Sole Source Justification

(7) A description of the market research conducted among schedule holders and the results, or a statement of the reason Market Research was not conducted.

DHS OIG sought to identify vendors with relevant experience, expertise, and the ability to rapidly onboard staff within thirty days of award. Market research was conducted by reviewing governmentwide contracting data and GSA’s market research as a service capability.

Thirty-nine interested vendors responded to the request for information. DHS OIG conducted follow-up engagement using a standardized capability presentation format with a subset of vendors to validate deployment readiness, staffing availability, relevant experience, organizational suitability, and ability to support accelerated mobilization requirements. Based on this validation and the urgent operational timeline, DHS OIG determined that award to Vander Weele Group LLC represented the approach most likely to satisfy immediate mission requirements while minimizing execution risk and avoiding unacceptable delay.

(8) Any other facts supporting use of other than full and open competition.

None.

(9) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition of the supplies or services required.

The sole source order’s period of performance is aligned to the fact that Congress provided funding for this increased level of oversight for the next two years only. If Congress decides to make these budget increases permanent, DHS OIG will conduct acquisition planning and market research to compete a longer-term contract.

(10) Certifications & Approvals

Technical / Requirements Personnel Certification

I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Date

Chief Inspector, DHS OIG

6/12/26

Sole Source Justification

(11) Contracting Officer’s Certification

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Date

Contracting Officer, DHS OIG

(12) Legal Review and Concurrence

I have reviewed this justification and deem it legally sufficient.

Date

Office of General Counsel, DHS OIG

(13) Head of the Contracting Activity (HCA)

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, as HCA, I hereby approve this justification.

Date

Head of the Contracting Activity Director of Acquisitions, DHS OIG

6/12/26

6/12/26

6/12/26