JAA- FSS Orders - Atch 1 - IMS-PIC - 07-14-26 Redacted.pdf

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IMS-PIC Bridge RCS-PX-2026-00026

Attachment 1 Sole Source Justification

Federal Supply Schedule Orders Exceeding the Simplified Acquisition Threshold

IMS-PIC Business Support

BACKGOUND

The U.S. Department of Housing and Urban Development (HUD), Office of Public and Indian Housing (PIH), Real Estate Assessment Center (REAC), has an urgent and compelling need to continue Inventory Management System/Public and Indian Housing Information Center (IMS/PIC) Business Support services through a bridge contract consisting of a six-month base period with three two-month option periods. The current contract expires on June 29, 2026, and additional time is required to complete the competitive follow-on acquisition.

IMS/PIC is the system of record for PIH and supports the broader missions of both PIH and REAC. The database maintains information associated with the entire PIH portfolio and serves as the national repository for Public Housing Authorities (PHAs), HUD-assisted families, and HUD-assisted properties.

The system contains tenant information, building information, unit characteristics, and transaction data.

IMS/PIC is one of the largest and most heavily utilized databases within HUD, supporting more than 4,250 HUD users, approximately 44,200 PHA users, 60 software vendors, and processing approximately 10 million Family Report submissions. The system supports affordable housing programs serving more than 3.3 million low-income families nationwide.

The contractor provides mission-essential support that includes:

1. Business support and technical assistance

2. Ad hoc data summaries and analytical reports

3. Data reporting and analysis

4. Data warehouse support and maintenance

5. Maintenance of MicroStrategy schemas and ETL processes

6. Development and maintenance of business intelligence tools and dashboards

7. Maintenance of archives, libraries, and knowledge repositories

8. Data analytics supporting PIH program operations and decision-making

RESTRICTION JUSTIFICATION

The justification for a bridge sole source is required because the new competitive award will not be completed by June 29, 2026, and IMS-PIC Support services cannot have a lapse in service.

There are two principal reasons HUD cannot afford a lapse in IMS/PIC Business Support services:

1. Although no statute specifically requires HUD to maintain a contract, the deliverables provided under this requirement support HUD's ability to carry out responsibilities associated with the United States Housing Act of 1937, annual appropriations acts, the American Rescue Plan Act of 2021, and the Payment Integrity Information Act of 2019.

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2. The contractor performs a critical role supporting the calculations used for Operating Fund grants under Section 9(e)(2)(A) of the United States Housing Act of 1937, including approximately $5 billion in annual Operating Fund disbursements, competitive grant programs, and more than $1 billion in Emergency Housing Voucher monitoring.

A break in service would interrupt the flow of data supporting core PIH business processes and oversight activities.

NOT DUE TO A LACK OF ADVANCE PLANNING

The need for this bridge acquisition is not the result of a lack of advance planning or inadequate procurement execution. HUD had planned for the transition of certain IMS/PIC functions to a new system under OCIO, HIP (Housing Information Portal); however, the anticipated system did not come to fruition and, therefore, was unable to assume the required operational responsibilities. As a result, continued support for the Inventory Management System/Public and Indian Housing Information Center (IMS/PIC), which remains the system of record for PIH, is necessary to ensure continuity of operations.

In furtherance of acquisition planning, the Government initiated a competitive acquisition for IMS/PIC Support. Solicitation No. 86614626Q00001 (RFQ1815996) was posted to GSA eBuy on June 4, 2026, as a competitive GSA Multiple Award Schedule (MAS) Total Small Business Set-Aside. During the solicitation process, the program office was notified by CIO that they wanted to revise the PWS.

Consequently, the solicitation was canceled on June 11, 2026, and removed from GSA eBuy. Vendors were notified that RFQ1815996 had been canceled due to changes required in the Government's requirements and that no further action was required.

The bridge acquisition is therefore required to provide uninterrupted support while the revised requirements are finalized, and the competitive follow-on acquisition is completed.

Failure to provide continued support would result in unacceptable disruption to mission-critical PIH operations and adversely impact HUD's ability to administer and monitor affordable housing programs serving more than 3.3 million low-income families nationwide.

As an incumbent partner contractor, Cloud Nine contractor is uniquely qualified to perform the required IMS/PIC Business Support services including Data Warehouse, reporting, and analytics services.

The contractor also has knowledge of the historical documentation, scripts, queries, report logic, and SharePoint-based knowledge repositories developed during prior performance. This institutional knowledge is not independently replicated within HUD or available through other contractors without significant reconstitution of system understanding and reengineering of existing processes.

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In addition, the contractor has established workflows, security protocols, and validated processes for interfacing with HUD systems and tools, including SQL-based querying, MicroStrategy reporting environments, Oracle APEX, Power BI, SAS, and other integrated reporting platforms. These capabilities are fully embedded within the current operational environment and are required to ensure continuity, accuracy, and integrity of PIH data reporting. The contractor is also responsible for ongoing system monitoring, data warehouse operations, and Extract, Transform, and Load (ETL) processes that support daily data ingestion, validation, and reporting functions across the IMS/PIC environment.

Transitioning this requirement to another source during the bridge period would require extensive onboarding, replication of data structures, recreation of report logic, and transfer of highly specialized system knowledge. Such efforts would introduce unacceptable risk of service degradation, data inconsistency, and operational disruption to a mission-critical system of record supporting millions of HUD-assisted households.

Accordingly, Cloud Nine is uniquely positioned to provide uninterrupted performance due to its embedded technical expertise, system-specific knowledge, and continuity of personnel and processes within the IMS/PIC environment.

Market research supporting the competitive follow-on IMS/PIC Business Support acquisition has been completed.

RFO Part 8 and Part 10 In accordance with RFO Part 10, agencies must procure commercial products and commercial services to the maximum extent practicable. Using the results of market research, agencies will determine, in the following order of priority, whether

(1) A commercial product or commercial service on an existing governmentwide contract can Meet the agency's requirements;

(2) The requirements could be modified so the agency could use an existing governmentwide contract;

(3) A commercial product or commercial service is available from another source;

(4) A commercial product or commercial service could be modified to meet the agency's requirements; or

(5) The requirement can only be satisfied by a nondevelopment item.

the agency's requirements;

In accordance with RFO Part 8 when supplies or services are unavailable from the mandatory sources listed in RFO 8.102 Mandatory Sources for Services, agencies should procure services or supplies on an existing contract or Blanket Purchase Agreement awarded for Governmentwide use (such as the Federal Supply Schedule, Governmentwide Acquisition Contract, or other Indefinite-Delivery, Indefinite- Quantity contracts.

a. There were no HUD Strategic Sources

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b. Government wide vehicles such as GSA Federal Supply Schedules

GSA MAS and other GWAC/IDIQ vehicles were considered in the market research for the follow-on acquisition. However, to avoid a lapse in service, they are not suitable for this urgent bridge requirement due to transition time, onboarding requirements, and associated performance risk.

Cloud Nine Technologies, Inc, is a small business entity on a GSA Schedule. Therefore, HUD can continue to obtain contract services with one of the contractors that is currently performing the services. This continuity helps preserve institutional knowledge and reduces transition risk during the bridge period.

Accordingly, pursuant to GSAM 538.7104-3(b), sole source consideration to the current small business contractor who is also a partner contractor on the current contract is necessary to maintain continuity of operations and avoid unacceptable delays while the competitive follow-on acquisition is completed.

The services were solicited as competitive acquisition.

The Government initiated a competitive acquisition for IMS/PIC Support. Solicitation No.

86614626Q00001 (RFQ1815996) was posted to GSA eBuy on June 4, 2026, as a competitive GSA Multiple Award Schedule (MAS) Total Small Business Set-Aside.

During the solicitation process, the program office was notified by CIO that they wanted to revise the PWS. Consequently, the solicitation was canceled on June 11, 2026, and removed from GSA eBuy.

Vendors were notified that RFQ1815996 had been canceled due to changes required in the Government's requirements and that no further action was required.

The restricted consideration under this Sole Source Justification is strictly temporary and is driven by the urgent need to prevent a lapse in mission-critical services supporting the IMS/PIC system of record. The barrier necessitating this bridge action is the insufficient time to complete a full competitive acquisition and execute an orderly transition without service disruption.

The services will be resolicited as a competitive GSA Schedule acquisition after the revisions required by CIO have been completed.

Trevor Simon Date Contracting Officer êñîëñîðîê