JEFO_70SBUR21F00000124.pdf

Justification for Exception to Fair Opportunity, Exceeding the Simplified Acquisition Threshold, SPEED Extension/Highlight

REFERENCE: Justification Log Number: FY25-0070 and PR Number: OIT255033

1. Agency and Contracting Activity.

The Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS), Office of Contracting (OCON), 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 Highlight Technologies, Inc. (Highlight) via modification to Task Order No. 70SBUR21F00000124 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.

3. Description of Supplies/Services.

The 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 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 70SBUR21F00000124 on systems which are not limited to the Customer Management Interface System (CMIS), Computer Linked Application Information Management System (CLAIMS3), and the Travel Document Production System (TDPS):

1. Continue to update the reception points to Windows 11 including updating security certificates, creating new Q-Flow sites, testing inactive user reports, and implementing released. Slated for monthly rollouts through December 2025.

2. Continue to revise the I-485 form in accordance with the Director’s accelerated timeline.

Deployments every 1.5 weeks through transition to Resources for InnoVation and Enterprise Readiness (RIVER) task order awardees.

3. Implement automatic biometrics scheduling after I-148 updates. Slated for Q4 of FY25.

www.uscis.gov

Rev: 10/13/2023

JEFO, Exceeding the SAT, SPEED - Highlight Justification Log Number: FY25-0070

4. Continue decommissioning outdated forms from internal systems. Slated to continue through transition to RIVER.

5. Proceed with implementing new interview waiver requirements. Slated to be completed in Q4 of FY25.

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 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. Highlight performs DevSecOps work for three major USCIS systems: CMIS, CLAIMS3, and TDPS. In addition, Highlight 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 they are developed, the scope of work within this order can only be provided at the acceptable quality levels by Highlight.

Despite being agile development work, the work performed on these systems is highly specialized for two reasons. First, the systems Highlight develops are major endpoints for USCIS. Internally, CLAIMS3 is the single point for case intake, assignment, management, and adjudication system for the agency. Any lapse in CLAIMS3 would bring USCIS’ mission to a standstill, making it impossible to assign immigrant benefits and petition cases and therefore to process and adjudicate them. This system has continued to become highly specialized as legacy systems for adjudication and benefit processing have been decommissioned and work has been moved to CLAIMS3 to increase efficiency and reduce redundancy across the agency.

In addition, CMIS works to provide real time administrative information within CLAIMS3 to ensure that addresses and contact information are constantly up to date and in the hands of adjudicators. On the other end of the process, TDPS produces travel documents for petitioners and distributes them with minimal intervention from employees. The advancements made in the processes and procedures of these three systems cannot be understated. Their ability to reduce redundancy, provide accurate information, and utilize automation for administrative tasks has allowed immigration officers to focus on more critical areas of an application and make better informed decisions on behalf of the agency. The transition of this work to the vendors who will be awarded the RIVER task order is slated to take four months given the size and scope. No vendor other than Highlight can complete the work that Highlight 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 continues to route through internal processes.

JEFO, Exceeding the SAT, SPEED - Highlight Justification Log Number: FY25-0070

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 CLAIMS3. 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 CLAIMS3. To transition a new vendor into this position just prior to the transition of all of the work to the new awardees for RIVER 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 Highlight 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 Highlight is capable of providing the supplies or services required.

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

• The agency will continue to experience regular delays in deployment and patches due to the Windows 11 phased updates. The agency has already experienced several instances of delayed deployments and update incompatibilities, and any extension of the delays will further delay implementation of all SPEED development work.

• Patches to the I-485 form in accordance with Director priorities and 508 compliance requirements will go undone. Without 508 and usability update, the work the agency has already completed to digitize the I-485 will have little realized benefit and not be accessible for users.

• Outdated form types will continue to bog down the systems used to upload paper forms and add risk to file adjudicators.

• Time sensitive Requests for Evidence and appointment notices and distributions, which will cripple the biometrics and interview processes for electronic filing.