JEFO_Exceeding_SAT_Redacted.pdf

HSAM 3016.507-6

JUSTIFICATION FOR EXCEPTION TO FAIR OPPORTUNITY

EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

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PR Number:

JEFO No.:

Date: February 12, 2026

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Cybersecurity and Infrastructure Security Agency (CISA), Chief of Contracting Office (COCO) prepared this justification for an exception to fair opportunity.

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

This Justification for an Exception to Fair Opportunity is prepared in accordance with Federal Acquisition Regulation (FAR) 16.507-6(d)(2), FAR Class Deviation 26-04, Revision 1 for FAR Part 16.0F

1 CISA/COCO intends to award a hybrid firm-fixed-price and labor-hour task order to the incumbent contractor, Leidos, Inc. (Leidos) under the mandatory DHS Strategic Sourcing Vehicle (SSV), General Services Administration (GSA) Alliant 2 Governmentwide Acquisition Contract (GWAC) contract number 47QTCK18D0008, without considering other awardees pursuant to RFO FAR 16.507-6(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.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

In support of its mission, the CISA Office of the Chief Information Officer (OCIO) requires the continuation of Cybersecurity Operations Support Services (COSS). The core required services include network monitoring and security event analysis, email security monitoring and analysis, computer security incident response and management, vulnerability assessment, security engineering, cyber intelligence support, intrusion analysis, and continuity of operations for Security Operations Center (SOC) services. The continued COSS is required to maintain CISA Information Security. The period of performance is anticipated to be March 1, 2026, through January 26, 2027. The total estimated value is

4. Identify the exception to fair opportunity and supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited.

1 FAR Class Deviation 26-04, Revision 1 for FAR Part 16 was 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. Any subsequent citations to FAR Part 16 in this document will be cited as “RFO FAR” for brevity, and are referring specifically to FAR Class Deviation 26-04, Revision 1 for FAR Part 16.

EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

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Pursuant to RFO FAR 16.507-6(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:

Leidos is currently providing support under task order 70RCSJ25FR0000014 under its GSA Alliant 2 GWAC contract number 47QTCK18D0008. The current task order will end on February 28, 2026. The required support is within scope of the Leidos, GSA Alliant 2 contract, a mandatory DHS SSV. The proposed task order will continue vital services during the time required for the DHS Office of Procurement Operations (OPO) to award a new Network Operations and Security Center (NOSC) enterprise security SSV under which COCO will issue a competitive follow-on solicitation. That SSV is currently in the source selection process and the anticipated date of award is third quarter of fiscal year 2026.

Only Leidos is capable of providing the services required at the level of quality required because the services ordered are highly specialized. The services required are highly specialized because CISA is building out a world-class SOC that incorporates commercial technology enriched with specialized data flows and practices to defend CISA from some of the most skilled attackers.

Leidos has been instrumental to OCIO by configuring and maintaining the Cybersecurity Enclave (CSE), which OCIO relies on to monitor and protect CISA information technology systems. CISA requires uninterrupted support of its mission essential COSS; otherwise, CISA OCIO Information Security support functions would cease. The task order for continued services will allow the SOC to provide continuity of specialized services that directly support the Cybersecurity mission.

Leidos’s continued support will prevent a lapse in service and disruption to daily operations. The Contractor's employees are highly-specialized subject matter experts that have the requisite experience and expertise to perform the work are currently cleared to perform. Without the Contractor’s specialized workforce, CISA will not be able to detect and respond to actors exploiting previously unknown zero-day attacks against CISA’s infrastructure. An immediate change of contractors would require substantial time and effort to develop the knowledge base necessary to meet the operational requirements. Additionally, substantial risk of critical mission impairment would result due to CISA’s suitability and onboarding process, which would be expected to require over 100 days to complete before commencing performance. There are currently no Federal staff available to provide these services.

For these reasons described above, Leidos is uniquely qualified to meet OCIO’s requisite and immediate needs.

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

Pursuant to RFO FAR 16.506(f), if the service prices were not established at the IDIQ level, then the Contracting Officer will establish prices for the order using the policies and methods in RFO

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FAR 15.4. The Contracting Officer anticipates a fair and reasonable price will be achieved based on utilization of the rates established by the GSA Alliant 2 GWAC, consideration of historical pricing, and comparison of the labor mix and level of effort with the Independent Government Cost Estimate (IGCE).

6. Any other facts supporting the justification.

None noted.

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.

Other than Leidos, there are currently no known small or other than small businesses capable of supporting the CISA specific tasks within the term of this requirement. For consistency and because of the nature of this support, CISA fully intends to utilize the forthcoming DHS enterprise vehicle for long term support; however, the DHS effort remains within source selection. While Leidos is currently contracted for SOC support throughout DHS, this task order will be structured in such a way that the current support can be transitioned in a timely, cost-effective manner once the new DHS enterprise vehicle is available to its components.

At this time, the exception to fair opportunity is necessary to support CISA's mission.

8. DHS intends to post this requirement on SAM.gov pursuant to pursuant to RFO FAR 16.507-6(f)(1).

9. Technical/Requirements Personnel Certification.

Pursuant to RFO FAR 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.

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10. Contracting Officer Certification and Approval *

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

11. Approval.

Pursuant to RFO FAR 16.507-6(e)(2), I certify the circumstances support exception to fair opportunity and I approve this justification.