JEFO_70SBUR21F00000122.pdf

Justification for Exception to Fair Opportunity, Exceeding the Simplified

Acquisition Threshold, SPEED Extension/Customer Value Partners

REFERENCE: Justification Log Number: FY25-0068 and PR Number: OIT256046

1. Agency and Contracting Activity.

The Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to modify an existing task order on behalf of the Office of Information Technology (OIT) / Systems Delivery Division (SDD) pursuant to Federal Acquisition Regulation (FAR) 16.505(b)(2), Exceptions to the fair opportunity process.

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

This action seeks approval for a sole source extension to Customer Value Partners, Inc (CVP) via modification to Task Order No. 70SBUR21F00000122 to continue the system maintenance and security work currently within the technical scope being performed. The current task order was competitively awarded in June 2021 through a small business set aside solicitation under the Chief Information Officer—Solutions and Partners 3 (CIO-SP3) Small Business (SB) Government-Wide Acquisition Contract (GWAC). Prior exception to fair opportunity was issued in accordance with FAR 16.505(b)(2)(i)(C), logical follow-on to an already issued order. The final completion date of the order was extended from 01/01/2025 to 06/30/2025 non-competitively via modification P00029.

Prior exception to fair opportunity was issued in accordance with FAR 16.505(b)(2)(i)(C), logical follow-on to an already issued order.

3. Description of Supplies/Services.

The Services for Product Engineering and Enterprise Delivery (SPEED) Performance Work Statement (PWS) details Information Technology Development, Security, and Operations (DevSecOps) services to operate and maintain major USCIS systems. The Government requires these services for six (6) months, with two two-month and two one-month option periods for a total performance period from 7/1/2025 through 12/31/2025. The total estimated price for this performance period is . The performance period of the proposed extension is allowable under the CIO-SP3 SB GWAC which remains valid through April 29, 2026.

This justification seeks approval to continue the following work unique to 70SBUR21F00000122 on Customer Relationship Interface System (CRIS) and Benefits Hub systems:

1. Continue investigation for Plan of Action and Milestones (POA&M) on an internal tool which was mandated for modernization within the Information Security Division (ISD).

Work is required to be completed by September 2025.

2. Continue the shift for the connection between AT&T ECX system and CSOL API IVR, estimated to be completed in Q4 of FY25.

3. Continue to implement Director priority for processing time page updates based on public feedback, completed ongoingly through Q4 of FY25.

www.uscis.gov

Rev: 10/13/2023

JEFO, Exceeding the SAT, SPEED - CVP Justification Log Number: FY25-0068

4. Continue to patch high security vulnerabilities for SRMT, COA, CSOL, and eRequest in accordance with the Security Assessment Report findings, slated to be completed in Q1 of

FY26.

5. Finish deployment for individual application zero downtime initiative, slated to be completed in Q1 of FY26.

4. Statutory exception and supporting rationale.

The applicable statutory FAR citation and basis for using an exception to fair opportunity process is:

☒ FAR 16.505(b)(2)(i)(B). Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

Rationale:

The work performed on this order covers the entire agile development process, from planning and establishing user stories and acceptance criteria through maintenance of code and systems after enhancement. CVP performs DevSecOps work for three major USCIS systems: myUSCIS, Customer Relationship Interface System (CRIS), and Benefits Hub. In addition, CVP performs the maintenance and development on the networks that connect and integrate information to and from these systems. Due to the urgent nature of the information contained within these systems as it relates to the mission and the multi-vendor environment in which the vendors and systems operate, the scope of work within this order can only be provided at the acceptable quality levels by CVP.

Despite being agile development work, the work performed on these systems is highly specialized for two reasons. First, the systems CVP develops are major endpoints for USCIS. myUSCIS is the primary external system by which petitioners can submit petitions and claims, monitor the status of their claim, sign up for biometrics appointments and receive digital notices, and submit administrative changes to their applications. Over the course of the SPEED task order, several vendors have contributed to growing and rewriting both the myUSCIS website and application. It has been integrated such that it is a single point for digital notices and application submissions as the agency has made significant progress in the effort to digitize and increase the efficiency of the immigration process.

Internally, CRIS and Benefits Hub operate to improve Agency’s ability to process all petitions and benefits. Continuous development of CRIS allows for an increasing number of administrative factors such as address or phone number to be updated without the assistance of an immigration services officer. As such, USCIS can ensure it constantly has up to date information for petitioners and allow officers to focus the majority of their processing time on more relevant adjudication factors. Because of the work SPEED vendors have completed in four years, the Benefits Hub dashboard is now a modern interface for case management, pre-adjudication activity, case assignment, and other mission essential activities completed via Computer Linked Application Information Management System (CLAIMS3). The work has reduced redundancy and processing times for the Agency as well as enhanced the quality of information officers use to make their adjudication decisions.

This work is iterative in nature, and as such without continuous incremental updates and security patches, the Agency is unable to reap the full benefit of its investment. The transition of this work to the vendors who will be awarded Resources for InnoVation and Enterprise Readiness (RIVER) and Rapid Application & Product Integration Delivery (RAPID) task orders is slated to take up to four months given the size and scope. No vendor other than CVP can complete the work that CVP performs on this task order at full capacity at acceptable quality levels without sufficient transition time. The Government does not have sufficient time to competitively award an order while RIVER and RAPID continue to route through internal processes.

Second, the work is highly specialized in that it operates in a multi-vendor environment with a consistently changing division of work. No less than three vendors have teams which complete work on both myUSCIS and Benefits Hub. As such, these vendors have division of work stand-ups, discussions, and have developed methods and relationships that allow them to execute deployments several times per week in the case of myUSCIS. To transition a new vendor into this position just prior to the transition of all of the work to the new awardees for RIVER and RAPID would not be feasible and result in an almost entire lapse of acceptable services should this order not be extended.

In summary of the established Acceptable Quality Levels and PWS, the contractor is required to release code on a weekly (or greater) basis, release code without error, collaborate and cooperate with other SPEED contractors, and understand the work well enough to being innovative in problem solving and efficient in resource use. The Government does not anticipate recovery of competition costs for this short extension as the best value remains most achievable with CVP under this task order. The contractor remains uniquely capable of maintaining staffing and providing satisfactory services specified in the PWS without having to compromise performance standards that may otherwise be anticipated with a change in contractors to complete initiatives already in progress.

Another major risk associated with staffing is that the Agency’s Entrance On Duty timeline for new contractors is roughly 90 days. This, coupled with the requirement for transition to a new contractor at the end of the proposed performance period, would render the next 6 months as valueless in terms of development, testing and deployment progress.

The Government performed market research through June 2025 using techniques including surveying industry and Government experts and surveying similar requirements. The conclusions pertaining to economy and efficiency described above are supported by that market research. The market research conclusions remain unchanged in supporting that only the current contractor is capable of providing these highly specialized services at the quality level required. It is concluded that only CVP is capable of providing the supplies or services required.

Should this task order not be extended, the following initiatives would not be supported:

• The Processing Times page available to immigrants who file electronically would not remain operational. Automation of processing time information has been a major initiative and benefit to the Government and has allowed officers to focus more on tasks that require critical thinking and given the immigrant better access to case information.

• The migration to the AT&T ECX system would not be completed as security vulnerabilities would not be patched. This system is mid migration and without completion could cause widespread internal inoperability.

• The eRequest accommodation, which is near completion and allows virtual and non-manual administrative changes to electronic files, would not be functional. The agency would have to continue dedicated thousands of manpower hours to manually performing administrative changes, eliminating any benefit from the work and require officers spending hours working managing administrative updates.

• The Security Vulnerabilities Report, which identified vulnerabilities in several major internal systems, would not receive action

5. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable. The Independent Government Cost Estimate (IGCE) for this work was based on two factors. One, four years of acquisition history for the SPEED procurement which shows that the vendor did not require additional funding to complete the requirement as outlined in the PWS. Two, the original award was made on a competitive basis and determined to be the best value to the Government. The pricing for labor to complete this requirement is competitive such that it is readily available within the marketplace.

The labor rates awarded on the CIO-SP3 SB GWAC were determined fair and reasonable by the awarding Contracting Officer. Further, the discounted labor rates resulting from the SPEED competition were determined fair by the ordering Contracting Officer. The Government will use any price analysis technique(s) found within FAR 15.404-1(b) to evaluate the extension proposal and may conduct negotiations as necessary to ensure that the pricing provided is fair and reasonable.

6. Any other facts supporting the justification.

The recompete for this work, RIVER, has been competitively solicited and is scheduled to be awarded in August 2025. Another requirement for myUSCIS, RAPID, is also scheduled to be awarded in August 2025. The Government has faced numerous delays in awarding the new contracts that further necessitates this sole-source extension. The Government will continue to prioritize the competitive recompete award. The Government has determined that a non-competitive extension to the current award is the most efficient method to continue system maintenance and the current iteration of SPEED requirements under the CVP task order.

The Government initiated the integrated product team (IPT) meeting for the RAPID requirement in FY23 Q1. Following extensive examination of competition requirements, the acquisition history of the requirements housed under SPEED, particularly myUSCIS, necessitated that the RAPID requirement be split into RAPID and RIVER, whereby only RIVER would be set aside for small businesses. The customer realized organizational benefit from code challenges for DevSecOps acquisitions and worked with OCON to revisit acquisition strategy for the RAPID and RIVER, finalizing the acquisition plan in August 2024. The RIVER requirement services two customers and as such, there were several delays in building out a coding challenge. The above listed delays, combined with system delays outside of the control of OCON and OIT, contributed to the current need for an exception to fair opportunity.