JEFO_70SBUR21F00000122 P00040.pdf

Justification for Exception to Fair Opportunity, Exceeding the Micro-purchase

Threshold, SPEED - CVP

REFERENCE: Justification Log Number: FY26-0088 and PR Number: OIT265039

1. Agency and Contracting Activity.

The Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to award a delivery/task order or modify an existing delivery/task order on behalf of Office of Information Technology (OIT) / Systems Delivery Division (SDD), pursuant to RFO 16.507-6(b), Exceptions to the fair opportunity process.1

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

This action seeks approval for a sole source extension to Customer Value Partners, LLC (CVP) via modification No. P00040 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). Three prior exceptions to fair opportunity were issued; the first was in accordance with FAR 16.505(b)(2)(i)(C), logical follow-on to an already issued order; the second and third were in accordance with FAR 16.505(b)(2)(i)(B), only one awardee is capable of providing the services required at the level of quality required because the services ordered are unique or highly specialized.

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 one two-month period and two two-month option periods for a total performance period from 07/01/2026 through 12/31/2026. The total estimated price for this performance period is $3,487,323.43. The performance period of the proposed extension is allowable under the CIO-SP3 SB GWAC which remains valid through 10/29/2026, with periods of performance available up to 12/31/2028.

1 In this document, citations and references to RFO Part 16, RFO Part 10, RFO Part 11 and RFO Part 15 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 26-04, Rev. 1 for FAR Part 16, FAR Class Deviation 26-12, Rev. 1 for FAR Part 10, Rev. 1 for FAR Part 11, Rev. 1 for FAR Part 15, which were 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.

www.uscis.gov Rev: 02/10/2026 http://www.uscis.gov/

JEFO, Exceeding the MPT, SPEED - CVP Justification Log Number: FY26-0088

This justification seeks approval to continue the following work unique to 70SBUR21F00000122 on the Benefits Hub systems:

1. Continue to implement Director priority for processing time page updates based on public feedback.

2. Continue to patch high security vulnerabilities for SRMT, COA, CSOL, and eRequest in accordance with the Security Assessment Report findings.

4. Statutory exception and supporting rationale.

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

☒ RFO16.507-6(b)(2). 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 Benefits Hub, a major USCIS network. In addition, CVP performs the maintenance and development on the network of data processing pipelines and systems which make up BenefitsHub as a central point for intake, adjudication, and document production relating to benefits requests. Due to the urgent nature of the information contained within these systems as it relates to the mission and the multi-contractor environment in which the contractor 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 the Benefits Hub network is highly specialized for two reasons. First, Benefits Hub is a major endpoint for USCIS. Internally, the Benefits Hub operates to improve Agency’s ability to process all petitions and benefits. 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 CVP and others 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 maintenance, development, and expansion of Benefits Hub was to be transitioned to awardees of the Resources for InnoVation and Enterprise Readiness (RIVER) task orders; however, USCIS received protests under both the initial award and the re-award of RIVER, thus pausing the transition until protests are resolved. 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 for an interim fair opportunity solicitation and award while the protests are pending.

Second, the work is highly specialized because it operates in a multi-contractor environment with a consistently changing division of work. Three contractors have teams which complete work on Benefits Hub. As such, these contractors have division of work stand-ups, discussions, and have developed methods and relationships that allow them to execute deployments several times per week. To transition a new contractor into this position would not be feasible and would result in an unacceptable lapse of acceptable services should this order not be extended.

The established Acceptable Quality Levels and PWS require the contractor 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 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 because of the protests and resulting work suspension on RIVER. Considering a 90 day Entrance On Duty timeline for a new contractor, the agency must extend the current orders to allow for system maintenance and then transition. Without both of these factors, a new contractor would not be successful in transitioning into the SPEED portfolio work within the allotted transition timeline. Resulting, Benefits Hub would not continuously meet the agency’s requirements for a system which maintains and tracks the data and adjudications for current, revised, and new benefits petitions.

The Government performed market research through January 2026 using techniques including surveying industry and Government experts and surveying similar requirements. 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 required services.

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 applicant better access to case information.

• The eRequest accommodation, which 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 Government will use any price analysis technique(s) found within RFO 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. The cost estimate 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.

6. Any other facts supporting the justification.

Due to filed protests, USCIS has issued stop work order on the RIVER awards. This continues to delay the Government’s efforts to transition work from SPEED contractors to new awardees. 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 until the pending protests are resolved and sufficient period is given to new awardees to transition in.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

The Government will continue to work on pending protests and hopes for a swift resolution that will allow it to remove the stop work orders on RIVER without further delay. This extension includes only the work necessary to maintain Benefits Hub and complete in progress work on the system. The agency continues to reduce the cost of sole source extensions by efficiently transitioning work to new awards as they are available.

8. USCIS intends to post this requirement on SAM.gov pursuant to RFO 16.507-6(f).

9. Technical/Requirements Personnel Certification.

Pursuant to RFO 16.507-6(d)(2)(ix), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the justification, are accurate and complete

MARILYN D

TEUNIS

Digitally signed by MARILYN D

TEUNIS

Date: 2026.06.25 13:02:47 -04'00'

Marilyn Teunis, Chief, OIT/TDD

10. Contracting Officer Certification

Date

Pursuant to RFO 16.507-6(d)(2)(viii), I certify that this justification is accurate and complete to the best of my knowledge and belief.

MONTY N KURTZ

Digitally signed by MONTY N

KURTZ

Date: 2026.06.25 11:09:51 -06'00'

Monty Kurtz, Lead Contract Specialist Date Contracting Officer

APPROVAL: Pursuant to RFO 16.507-6(d)(2)(x), I hereby determine the circumstance identified in Section 4 applies to the order.

AMANDA K DUQUETTE

Digitally signed by AMANDA K

DUQUETTE

Date: 2026.06.26 10:47:21 -04'00'

Amanda Duquette, Head of Contracting Activity Date Procuring Activity Advocate for Competition