JEFO_70SBUR21F00000123 P00046.pdf

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

REFERENCE: Justification Log Number: FY26-0089 and PR Number:

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 Ekagra Partners, LLC (Ekagra) via modification No. P00046 to Task Order No. 70SBUR21F00000123 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 . 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.

This justification seeks approval to continue the following work unique to 70SBUR21F00000123 on Benefits Hub and related systems:

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

JEFO, Exceeding the SAT, SPEED - Ekagra Justification Log Number: FY26-0089

1. Continue to develop by repairing the detailed view, editing capacity, and receipting.

2. Continue to resolve duplicate notices.

3. Manage production release of

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 task order covers the entire agile development process, from planning and establishing user stories and acceptance criteria through maintenance of code and systems after enhancement. Ekagra performs DevSecOps work for Benefits Hub, a major USCIS network. In addition, Ekagra 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 they are developed, the scope of work within this task order can only be provided at the acceptable quality levels by Ekagra.

Despite being agile development work, the work performed on the Benefits Hub network is highly specialized for two reasons. First, the system Ekagra develops is a major endpoint for USCIS.

Benefits Hub operates off of data maintained by Computer Linked Application Information Management System (CLAIMS3) cases. Through the relationship, Benefits Hub continues to be the consolidation point for managing and adjudicating immigration benefits claims. CLAIMS3 and Benefits Hub work in conjunction to create dashboards for digital cases and data lake information, supporting the Agency’s goal to digitize immigration and decrease processing times. Benefits Hub also supports the Enterprise Print Management Service (EPMS) and Interim Case Management System (ICMS), distributing information and providing real time updates to adjudicators and petitioners.

The outlined data work on Benefits Hub, and its subsequent support for ICMS and EPMS, 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, pausing the transition until protests are resolved. No vendor other than Ekagra can complete the work that Ekagra 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. Multiple contractors operate within Benefits Hub and

JEFO, Exceeding the SAT, SPEED - Ekagra Justification Log Number: FY26-0089

CLAIMS3. 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 Ekagra is capable of providing the required services.

Should this task order not be extended, the following forms and tools which are critical to the USCIS mission will not be supported:

preventing seamless online filing and reducing the benefit the Government receives from its investment.

• The , putting stress on the person-to-person customer service system at USCIS.

• The would not be monitored for bug fix requirements, increasing the risk of inoperability.

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