JA FY26-0273_Redacted.pdf

J&A #:

February 2026 Page 1

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

(41 U.S.C. 3304(a)(1))

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-111), and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO

6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity. The Department of Homeland Security (DHS), Office of Procurement Operations (OPO), proposes to enter a contract on a basis other than full and open competition on behalf of DHS’s Office of Strategy, Policy, and Plans (PLCY), Office of Homeland Security Statistics (OHSS).

2. Nature and/or Description of the Action being Approved.

(a) Nature of Action: DHS intends to procure services on a sole-source basis to acquire access to a secure data analysis and research environment.

(b) Name and Address of the Contractor: The Coleridge Initiative, Inc., 20 F Street NW, 7th Floor, Washington, District of Columbia, 20001

(c) Contract Type: Firm-Fixed Price

(d) Estimated Total Value (including options):

Period Unit Price Total

$2,000,000 Total $2,000,000

1 In this document, citations to RFO Parts 6, 10, 15, 25 are citations specifically to FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 R1 for FAR Part 15, and FAR Class Deviation 25-09 R1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

J&A #: FY26-0273

February 2026 Page 2

(e) Type of Funding: Operations and Support Funds

(f) Year of Funding: Fiscal Year 2026

(g) Solicitation Number: 70RDA226Q00000087

(h) Background Information About the Requirement: The Foundations for Evidence-Based Policymaking Act of 2018 (Evidence Act) requires federal agencies to build and use evidence to guide decision-making. To comply with this mandate, DHS requires a secure environment to analyze sensitive administrative data and collaborate with expert researchers.

This procurement will provide the necessary platform and expert services to build evidence, generate insights, and inform policy while rigorously protecting data confidentiality.

3. Description of Supplies/Services. The requirement is to implement the FY26 DHS explanatory statement direction regarding the Administrative Data Research Facility (ADRF), printed in the Congressional Record on January 22, 2026, at page H1661 and given effect by Section 4 of the DHS Appropriations Act, 2026, Pub. L. 119-86. The explanatory statement provides $2,000,000 to expand ADRF’s capabilities, including enhanced data-sharing partnerships, expanded security measures, development of advanced analytical tools to support DHS and other agencies’ homeland security research needs, and enhancement of DHS’s ability to securely transmit timely data to ADRF. To implement this direction, DHS requires access to and support for the existing ADRF environment, including secure data hosting, privacy-preserving data linkage, statistical disclosure limitation review of research outputs, and a managed framework for secure collaboration between DHS personnel and vetted external researchers. ADRF is operated by the Coleridge Initiative.

Coleridge Initiative is the only entity that owns, operates, controls, or is otherwise authorized to provide the required access to and expansion of ADRF.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. 3304(a)(1), implemented by RFO 6.103-1, entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements”.

5. Identification of Exception to the Buy American Statute. Not applicable to this acquisition.

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

(a) Rationale for using the authority cited in section 4 of the J&A:

The Coleridge Initiative is the only known source capable of providing the integrated program management, governance, interagency coordination, implementation, operational readiness, and communications support required for the Office of Homeland Security Statistics’ use of the Administrative Data Research Facility (ADRF). These services are inseparable from the ADRF platform and are necessary to establish, operate, and expand a secure administrative data environment for DHS statistical, research, data-linkage, and evidence-building activities.

February 2026 Page 3

The requirement is not limited to generic project management or cloud implementation support. OHSS requires support specifically tied to the ADRF operating model, security framework, governance workflows, data stewardship processes, researcher access model, and statistical-use controls. Coleridge is the developer, operator, and steward of the ADRF platform and associated service model. As a result, Coleridge possesses unique institutional knowledge of the ADRF architecture, workflows, authorization boundary, user onboarding processes, data onboarding methods, disclosure review practices, governance model, and interagency collaboration framework.

Coleridge’s support is required to ensure that OHSS can implement the ADRF in a manner that is secure, repeatable, auditable, and consistent with the platform’s established administrative data research model. The services include project planning, milestone tracking, stakeholder engagement, governance framework development, data provider onboarding coordination, interagency workflow support, operational readiness planning, risk management, reporting, and executive communications. These activities depend on intimate knowledge of ADRF’s technical, governance, and operational processes and cannot be efficiently or effectively performed by another vendor without substantial duplication of effort, schedule delay, and increased risk.

Use of another provider for these support functions would create significant operational and security risk. A separate contractor would need to learn the ADRF architecture, security controls, governance model, onboarding procedures, data stewardship workflows, user access model, and disclosure review processes before it could provide meaningful support. This would create duplication of effort, increase the risk of inconsistent governance or workflow implementation, delay OHSS onboarding, and potentially undermine the secure and controlled operating model required for sensitive DHS administrative data. It would also fragment accountability between the platform provider and a separate management or coordination contractor, creating unnecessary complexity for implementation, operational readiness, and stakeholder communications.

(b) Details covering what events lead to the situation: The requirement stems from the need to analyze sensitive data in a manner that maximizes its value while ensuring the highest levels of security and confidentiality. This requires more than a simple cloud hosting environment;

it requires a holistic ecosystem built on trust, established relationships with federal statistical agencies, and niche statistical expertise. The Coleridge Initiative has developed this unique ecosystem over many years, specifically to serve the needs of the federal government. No other entity has made a similar investment or possesses a comparable, proven capability.

Coleridge’s support is required to ensure that OHSS can implement the ADRF in a manner that is secure, repeatable, auditable, and consistent with the platform’s established administrative data research model. The services include project planning, milestone tracking, stakeholder engagement, governance framework development, data provider onboarding coordination, interagency workflow support, operational readiness planning, risk management, reporting, and executive communications.

These activities depend on intimate knowledge of ADRF’s technical, governance, and operational processes and cannot be efficiently or effectively performed by another vendor without substantial duplication of effort, schedule delay, and increased risk.

Coleridge is uniquely positioned to provide these services because it operates the ADRF as

February 2026 Page 4 an integrated Platform-as-a-Service environment designed for controlled access to sensitive administrative data. The ADRF incorporates secure data hosting, controlled research workspaces, privacy-preserving data linkage, data stewardship support, statistical disclosure review processes, researcher onboarding, governance workflows, and secure collaboration capabilities. The required program management and governance services must align directly with these platform functions. A third party could provide general consulting support, but would not possess the same level of operational control, platform knowledge, established processes, or institutional experience necessary to implement and manage the ADRF environment for OHSS.

The Coleridge Initiative also has established experience supporting administrative data environments for government statistical and research purposes. Its ADRF model is built around the “Five Safes” framework: Safe Projects, Safe People, Safe Settings, Safe Data, and Safe Exports. This framework is central to OHSS’s requirement to protect sensitive data, support authorized research access, maintain confidentiality, and enable secure statistical use.

The required governance, coordination, readiness, and communications support must be implemented within this framework. Coleridge is the only source with demonstrated capability to provide these services as part of the ADRF operating environment.

(c) Summarize alternatives considered and why they will not work:

Alternative 1: Develop an in-house capability. This was rejected due to the substantial duplication of cost and unacceptable delay. It would require DHS to not only build and certify a FedRAMP High environment but also to recruit and retain a team of scarce, highly specialized experts in data curation, Privacy-Presenting Record Lineage (PPRL), and statistical disclosure limitation. This process is estimated to take 3-5 years and would divert significant resources from the core mission.

Alternative 2: Use a commercial cloud provider (e.g., Amazon Web Services (AWS), Microsoft Azure, Google Cloud Platform (GCP). While these providers offer secure infrastructure, they do not provide the essential layer of statistical expertise and data stewardship services required. They are not equipped to perform disclosure avoidance reviews, facilitate privacy-preserving data linkage, or manage a collaborative research community in accordance with federal statistical agency standards.

(d) Impact to the mission that would result if the J&A is not approved and, consequently, the product or service not provided: Without access to the ADRF, DHS will be severely limited in its ability to fulfill the mandate of the Evidence Act. The inability to link disparate datasets, collaborate securely with leading researchers, and ensure rigorous confidentiality protection would prevent the agency from generating critical evidence needed to inform policy on national security, trade, and economic security. This would result in a significant loss of potential mission-critical insights.

(e) Rationale for use of the nonavailability exception to the Buy American statute: Not applicable to this acquisition.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

February 2026 Page 5

OHSS conducted market research between June 2026 and August 2026 to determine whether sources other than the Coleridge Initiative could satisfy the requirement for a secure administrative data research environment and the associated program management, governance, interagency coordination, implementation, operational readiness, and communications support needed to operate the Administrative Data Research Facility (ADRF) for DHS.

The Government reviewed available marketplace information, including federal contract databases, industry publications, vendor capability information, product literature, and the FedRAMP Marketplace. OHSS also engaged knowledgeable individuals in industry and participated in DHS vendor outreach activities to better understand available commercial and government-facing solutions for secure data enclaves, cloud-based research environments, data governance, statistical data services, and analytical collaboration platforms.

The market research identified several vendors and solution categories that provide portions of the requirement. For example, some vendors offer secure cloud hosting, FedRAMP-ready infrastructure, data management services, analytics tools, or public sector data-as-a-service capabilities. These included government cloud and analytics platforms, commercial cloud providers, and data service providers. However, the research did not identify another source capable of providing the full integrated requirement: a FedRAMP-authorized secure administrative data research platform combined with established governance workflows, data stewardship, privacy-preserving linkage, statistical disclosure limitation support, researcher onboarding, secure collaboration, and ADRF-specific program management and operational readiness services.

A sources sought notice was not issued because the Government’s research confirmed that the requirement is uniquely tied to Coleridge’s ADRF platform and operating model. The required services are not generic support services that can be separated from the platform without significant risk. Program management, governance, interagency coordination, implementation planning, operational readiness, and communications support must be performed by an entity with direct control over and knowledge of ADRF’s architecture, authorization boundary, data onboarding workflows, user access processes, disclosure review practices, and secure research governance model.

The Government considered whether other potential sources could provide comparable support through alternative approaches, including use of a commercial cloud provider, use of a third-party consulting or systems integration contractor, or development of an in-house DHS capability. These alternatives were determined not to be practicable. Commercial cloud providers can provide secure infrastructure, but they do not provide the ADRF’s integrated statistical data stewardship, privacy-preserving linkage, disclosure review, and research governance services. A third-party integrator could provide general project management or governance support, but would lack direct operational control of the ADRF platform and would require significant time and resources to understand and coordinate with Coleridge’s proprietary workflows, security processes, and platform configuration. Developing an in-house capability would require substantial duplication of cost and an unacceptable delay, including development of a secure platform, authorization activities, governance processes, and recruitment of specialized statistical and data stewardship expertise.

Accordingly, the Government determined that soliciting offers from additional sources would not

February 2026 Page 6 be practicable because no other known source can meet the Government’s minimum needs without unacceptable delay, duplication of cost, fragmented accountability, and increased operational, security, privacy, and mission risk. Coleridge is the only source capable of providing the complete, integrated ADRF platform and associated support services required by OHSS within the required timeframe. A pre-solicitation announcement is estimated to be posted no later than September 4, 2026, in accordance with Federal Acquisition Regulation (FAR) 5.101(c) (FAR Class Deviation 25-172).

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable. The contracting officer determines that the anticipated price will be fair and reasonable. The price reasonableness will be established by comparing the proposed prices to the Independent Government Cost Estimate (IGCE) and by analyzing pricing data from previous contracts for similar services provided by the Coleridge Initiative to other federal agencies.

9. Description of Market Research.

Market research was conducted between June 2026 and August 2026 to determine whether commercial, non-developmental, or government-facing solutions were available to meet the Office of Homeland Security Statistics’ requirement for a secure administrative data research environment supporting controlled access to sensitive data, statistical analysis, data linkage, governance, and secure collaboration.

The research focused on identifying sources capable of providing an integrated Platform-as-a- Service capability comparable to the Administrative Data Research Facility (ADRF). The Government reviewed the availability of secure data enclave platforms, FedRAMP-authorized or FedRAMP-ready cloud environments, public sector data analytics platforms, data-as-a-service providers, and commercial cloud-based government data solutions. The research also examined whether available vendors could provide the associated services required by OHSS, including program management, governance support, interagency coordination, data onboarding, metadata management, secure data stewardship, privacy-preserving record linkage, disclosure review, user onboarding, training, and operational readiness support.

Market research methods included review of the FedRAMP Marketplace, review of vendor catalogs and product literature, analysis of publicly available capability statements and technical descriptions, participation in DHS vendor outreach activities, and engagement with knowledgeable individuals in industry. The Government also considered information regarding federal contract vehicles, industry publications, and online resources related to secure research environments and statistical data services.

The research identified vendors and solution categories that could satisfy discrete portions of the requirement. For example, several commercial cloud providers and FedRAMP-ready platforms can provide secure hosting, cloud infrastructure, database services, storage, identity management, and analytics tooling. Other vendors offer public sector data-as-a-service products, 2 FAR Class Deviation 25-17, FAR Part 5 was issued as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025. Any subsequent citations to FAR Part 5 in this document will be cited as “RFO FAR” for brevity, and are referring specifically to FAR Class Deviation 25-17, FAR Part 5.

February 2026 Page 7 data enrichment, geospatial or business data, or general analytics capabilities. Some vendors also provide consulting, systems integration, project management, or data governance support.

However, the research did not identify any source other than the Coleridge Initiative capable of meeting the full integrated requirement. OHSS requires more than secure hosting or general data analytics. The requirement is for a secure administrative data environment that combines a FedRAMP-authorized cloud-based research platform with specialized statistical services, privacy-preserving data linkage, data stewardship, statistical disclosure limitation support, governance workflows, researcher onboarding, controlled export processes, and secure collaboration among DHS personnel and approved researchers.

The Coleridge Initiative’s ADRF was identified as the only known solution purpose-built for this type of federal administrative data research use case. ADRF provides an established secure research environment hosted in AWS GovCloud and incorporates the “Five Safes” framework:

Safe Projects, Safe People, Safe Settings, Safe Data, and Safe Exports. The platform supports secure workspaces, controlled access, data onboarding, metadata management, data linkage, disclosure review, and collaborative research workflows. Coleridge also provides the platform-specific program management, governance, implementation, operational readiness, and communications support necessary to configure and operate the environment for OHSS.

The Government considered alternatives, including developing an in-house capability, using a commercial cloud provider, or separating the platform from support services through a third-party integrator. These alternatives were determined not to meet the Government’s minimum needs. Developing an in-house capability would require substantial cost, staffing, security authorization, and development time. Commercial cloud providers can provide infrastructure but do not provide the specialized statistical, governance, data stewardship, and disclosure review services required. A third-party integrator could provide general implementation support but would not have direct operational knowledge or control of the ADRF platform, increasing cost, schedule, security, and coordination risk.

Based on this research, the Government concluded that the Coleridge Initiative is the only source capable of providing the complete integrated ADRF capability required by OHSS within the required timeframe. While other vendors may provide individual components of the requirement, no other known source can provide the full combination of secure platform operations, administrative data governance, privacy-preserving linkage, statistical disclosure limitation, interagency collaboration, and ADRF-specific implementation and operational support.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

Additional facts support the determination that use of other than full and open competition is appropriate for this requirement.

The Office of Homeland Security Statistics requires an integrated secure administrative data research environment that combines technology, governance, data stewardship, statistical expertise, and controlled research access within a single operating model. The requirement is not limited to acquisition of cloud hosting or general analytical tools. It includes secure platform operations, program management, governance support, interagency coordination, data onboarding, metadata management, privacy-preserving data linkage, statistical disclosure

February 2026 Page 8 limitation support, user onboarding, training, export controls, and operational readiness services.

These functions must operate together to protect sensitive administrative data and support OHSS’s statutory and mission requirements for evidence-building and statistical reporting.

The Coleridge Initiative’s Administrative Data Research Facility is uniquely suited to meet these requirements because it is an established, FedRAMP-authorized, cloud-based research analytics and collaboration environment designed specifically for controlled access to sensitive administrative data. ADRF is hosted in AWS GovCloud and incorporates security, access control, monitoring, and governance processes intended to support sensitive government data analysis. The ADRF operating model also follows the “Five Safes” framework: Safe Projects, Safe People, Safe Settings, Safe Data, and Safe Exports. This framework directly supports OHSS’s need to ensure that approved users conduct approved statistical activities within a controlled environment and that outputs are subject to appropriate disclosure review before release.

The required support services are inseparable from the ADRF platform. Program management, governance, implementation, operational readiness, and communications support must be performed by a contractor with direct knowledge of the ADRF architecture, authorization boundary, onboarding workflows, user access model, data stewardship processes, research workspace configuration, disclosure review practices, and secure collaboration framework.

Coleridge, as the developer and operator of ADRF, is the only source with the necessary operational control and institutional knowledge to perform these services without unacceptable delay, duplication of effort, or increased risk.

Market research confirmed that other vendors may provide individual components of the requirement, such as secure cloud infrastructure, data analytics tools, data management services, or general project management support. However, no other known source provides the full integrated capability required by OHSS. Commercial cloud providers can offer secure infrastructure but do not provide the embedded statistical data stewardship, privacy-preserving linkage, disclosure avoidance, researcher onboarding, and federal statistical governance support that are integral to the requirement. Similarly, a third-party systems integrator or consulting contractor could provide generic governance or implementation services, but would not have direct control over ADRF platform operations or the platform-specific knowledge required to implement OHSS’s environment efficiently and securely.

The Government also considered whether the requirement could be satisfied by developing an in-house capability. This alternative was determined not to be practicable because it would require DHS to build or acquire a secure research enclave, complete security authorization activities, establish governance and disclosure review processes, develop data onboarding and linkage methodologies, and recruit specialized personnel with expertise in data curation, privacy-preserving record linkage, statistical disclosure limitation, and administrative data research. The estimated cost and time required to duplicate Coleridge’s capabilities would be substantial, with an estimated duplication cost of and an estimated implementation period of Such delay would significantly impair OHSS’s ability to meet mission needs and support Evidence Act objectives.

The mission impact of not acquiring ADRF from Coleridge would be significant. Without timely access to the ADRF capability, OHSS would be limited in its ability to securely ingest, link, February 2026 Page 9 analyze, and manage sensitive administrative data from DHS Components and interagency partners. This would impair OHSS’s ability to address decentralized reporting, inconsistent data definitions and vintages, duplicative data requests, delayed public releases, and other data management challenges affecting DHS-wide statistical reporting and evidence-building. It would also limit OHSS’s ability to collaborate securely with approved researchers and produce reliable, timely, and policy-relevant statistical analyses.

Use of any other source would introduce unnecessary operational complexity and risk by separating platform ownership from implementation, governance, and operational support. This fragmentation could delay onboarding, increase coordination burdens, create inconsistent governance processes, and heighten security, privacy, and compliance risks. Coleridge’s integrated model provides a single accountable provider for the platform and the associated services required to configure, operate, govern, and support the OHSS environment.

For these reasons, the Coleridge Initiative is the only responsible source capable of satisfying the Government’s minimum needs. Award on a sole-source basis is necessary to obtain the integrated ADRF platform and associated support services within the required timeframe, avoid substantial duplication of cost and delay, maintain continuity of security and governance controls, and support OHSS’s mission to provide secure, reliable, and evidence-based homeland security statistics.

It is estimated that duplicating the Coleridge Initiative’s capability would cost the Government over and take approximately This includes the cost of software development, achieving a FedRAMP High ATO, and hiring a team of at least highly specialized (and scarce) PhD-level statisticians and data scientists with expertise in these niche fields.

11. A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

No sources have expressed written interest as no synopsis or sources sought notice was issued for this unique requirement.

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any

Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required. The barriers to competition are the contractor's unique qualifications and deep-rooted institutional expertise, which are not easily replicated. DHS will continue to monitor the marketplace for new entrants that may be able to provide a comparable integrated service in the future. During the period of performance, the agency will document the processes, data governance requirements, and analytical methodologies used, which could potentially inform a competitive follow-on acquisition should the market evolve.

February 2026 Page 10

13. 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.

Contracting Officer Date

14. 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.

Technical Representative Date

APPROVAL:

Procuring Activity Advocate for Competition Date