JEFO Exceeding the MP_PLANXS Extension_Redacted for Posting.pdf

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

Justification for Exception to Fair Opportunity, Exceeding the Micro-purchase Threshold, Predictive Lake Analytics Nextgen eXchange Services (PLANXS)

REFERENCE: Justification Log Number: and PR Number: OIT266039

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 RFO 16.507-6(b), Exceptions to the fair opportunity process.1

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

This action will extend task order 70SBUR21F00000194 (PLANXS) via modification P00022 on a sole source basis to Octo Metric LLC.

PLANXS was competitively awarded in September 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). The initial award was 60 months.

This action extends the order for up to 6 months.

3. Description of Supplies/Services.

This extension will provide data and business intelligence support services that deliver advanced analytics to enhance USCIS’s predictive and prescriptive capabilities for managing the enterprise data lake and the enterprise Citizenship and Immigration Services Centralized Operational Repository (eCISCOR) data repository. This work is currently being completed under the PLANXS task order. The services will maintain interoperability by enabling a data hub which integrates and shares seamlessly. The contractor will use advanced analytical tools to support interactive decision making, continuous monitoring and improvement of predictive machine learning models, and improvement of search capabilities for complex data management. The contractor will support agency wide data management, visualization, and cross functional collaboration. Lastly, the order will ensure that support ensures the agency can continue modernization efforts for customer support mechanisms and service delivery under future orders.

1 In this document, citations 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.

JEFO, Exceeding the MPT, PLANXS Justification Log Number:

The relevant task areas for this extension to meet the above requirements are:

Advanced Data Analytics Incorporation of Artificial Intelligence and Machine Learning Dashboard Metrics and Reports Development Modernization of digital services and security operations (DevSecOps) Enterprise Solution and Code Delivery Legacy Operational Maintenance Automated Testing and Deployment Activities Configuration Management and Change Control User Training

The total performance period of this action will be 08/12/2026 – 02/11/2027. The estimated cost for this action is

4. Statutory exception and supporting rationale.

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

RFO 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:

Through market research and review of the PLANXS Performance Work Statement (PWS), the Government determined that only Octo Metric is capable of performing the PLANXS services at the level of quality required within the timeframe required.

The PLANXS requirement has a number of factors which make it highly specialized. First, the work requires an understanding of USCIS’s Business Intelligence and Data Warehouse. eCISCOR is a collection of databases which houses all of the agency’s data in both relational and dimensional format. In addition to understanding the size and scope of the data, PLANXS requires a vendor to be experienced in USCIS’s implementation of Databricks as the primary component for extracting value at increasingly faster processing times to meet the agency’s increased reporting needs. The requirement also includes data visualization and dataset merging. The work under this extension will maintain the described warehouse environment which is built uniquely to USCIS’s Data and Business Intelligence Section (DBIS) specifications. By utilizing the task areas and meeting the goals outlined in section three, this work will maintain the current investment USCIS has made in improving the reportability and usability of its data lake such that, under a future competitive award, a vendor can continue to improve process, program, and procedure and support agency wide data management and visualization.

The ever-changing nature of eCISCOR and the agency’s reporting requirements necessitate deep understanding of how the agency uses Standard Management Analytics and Reporting Tools (SMART), the SAS Predictive Modeling Environment, eCISCOR BigData (unique to USCIS), and eCISCOR BigData Analytics (unique to USCIS) to perform the PLANXS requirement. Data management within USCIS also requires knowledge and experience with legacy tools and systems as the agency continues to modernize its data pool and reporting tools. There continues to exist multiple ad-hoc, unique, and legacy tools integrated into the data management and visualization pools that require training and knowledge to use successfully. As such, the data management practices under PLANXS are highly specialized, and vendors with experience in data visualization and management would not be able to successfully complete this work without extensive transition.

To perform the PLANXS requirement to the level of quality required to maintain the agency’s data reporting stature, only a vendor with experience both in the identified tools and the USCIS data environment would be successful under the required timeline. Resulting from a protest against the follow on to the PLANXS requirement, PLANXS II, the agency must continue to maintain the PLANXS requirement. As such, any other vendor would have less than 30 days to understand the data environment and transition services currently performed by 70 FTEs. The Government previously identified that a new entrant would need no less than 90 days of transition to perform the PLANXS requirement to acceptable quality levels.

Octo Metric has been identified as capable of performing the above outlined requirement within the identified time frame through review of CPARs ratings and discussion with the program office. The vendor has adequately achieved performance metrics required by the PWS.

The Government conducted market research, the results of which are contained within the file, by surveying Government experts and similar requirements. This research confirmed that only Octo Metric is capable of performing the work in the PLANXS PWS at the level of quality required within the timeframe required. The agency would not be able to competitively resolicit, determine capability, onboard another vendor, and complete adequate transition within 30 days. The agency has already competitively re-competed the requirement and is currently defending the protest against the award. During the protest period, the agency has issued a stop work order on this award. Should the agency not extend the PLANXS order, eCISCOR and the agency’s data reporting capabilities would not continue to be a dynamic environment and the agency would not extract maximum, real-time value from the intersection of its massive amounts of data. Given the agency’s data reporting requirements, and the need to make decisions based on the most accurate, newest, intersectional data, this requirement must continue through its transition.

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 proposed labor categories, rates, and level of effort were previously found to be fair and reasonable and in accordance with the CIO-SP3 SB contract ceiling rates and against the independent Government estimate. Further, price reasonableness was established through competition at the order level. This prior analysis will be used as the basis for evaluating the subsequent proposal to determine this sole source extension as fair and reasonable.

6. Any other facts supporting the justification.

This extension will only include the work necessary to maintain eCISCOR and the agency’s data reporting capabilities and landscape. The agency has already competitively resolicited this requirement in accordance with conclusions made from market research. The added barrier of a highly compressed timeline limits the Government’s ability to maintain the PLANXS requirement and DBIS program without a non-competitive extension to the current award.

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 agency will continue to defend the protest against PLANXS II, which was competitively solicited and awarded. The swift resolution will allow for minimal non-competitive extension to the PLANXS order.

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.

Prabha Rajendran Date Branch Chief, DBIS

10. Contracting Officer Certification

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 Kurtz Date Contracting Officer USCIS Office of Contracting

APPROVAL: Pursuant to RFO16.507-6(e)(2), I hereby determine the circumstance identified in Section 4 applies to the order.

Amanda Duquette Date Head of Contracting Activity USCIS Office of Contracting