JEFO FY26-0057 - Redacted.pdf

JEFO, Exceeding the SAT, ODOS III – ADG-REI Justification Log Number: FY26-0057

This justification seeks approval to continue the following work unique to 70SBUR22F00000112 on ELIS and the Global enterprise case management system:

1. Continue to develop security capabilities that will enhance vetting and identification of national security and public safety threats (social media vetting).

2. Continue to maintain and scale the major enterprise benefits case management system.

3. Continue to support interactive capabilities, such as real-time communication, data sharing, and workflow integration with partner agencies like Immigration and Customs Enforcement (ICE), Customs and Border Protection (CBP), and the Department of State (DoS).

4. Continue to provide proactive monitoring, timely security patching, and incident response.

5. Continue to develop the Gold Card and D1/D2 initiatives such as adding the adjudications capabilities for the investor program.

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:

The work performed on this task order is mission critical as it provides development and support in IT development, security integration, and maintenance efforts for sustaining ELIS and the Global enterprise case management system. ADG-REI provides ELIS and non-ELIS related Outcome- Based Delivery and DevSecOps design, User Experience Design (UXD), and Operations and Maintenance (O&M) for the delivery of solutions that adapt to the changing business needs and efficiently deliver business results. A total of 104 contractor-personnel support DevSecOps, service delivery, and infrastructure needs under this task order for secure and efficient case processing and vetting of applicants.

As a result of the RFO initiative in support of Executive Order (E.O.) 14275, Restoring Common Sense to Federal Procurement, there were significant changes made to the acquisition strategy, period of performance, total estimated procurement value, and total number of teams needed for ODOS IV. While the Agency continues to finalize its long-term strategy for ODOS IV, it was determined that it was in the Government’s best interest to pursue a smaller, competitive version of ODOS (referred to as ODOS 3.1).

The succeeding competitive procurement, ODOS 3.1, was expected to be in place prior to the expiration of the current task order but has faced numerous delays in both the solicitation and evaluation phases, consequently prolonging the Government’s efforts to transition work from the ODOS III 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 ODOS III requirements under the ADG-REI task order until the ensuing awards are made and sufficient time is given to the new awardees to transition in.

This justification supports the agency’s requirement to continue ODOS III support commencing on 03/25/2026. Market research that was conducted for the competitive recompete that’s currently in-progress indicated that there are contractors capable of performing the services required by ODOS on multiple EAGLE Next Generation (Next Gen) contracts as well as the General Services Administration (GSA) Multiple Award Schedule (MAS). However, it has been concluded that only ADG-REI has the specific skills, knowledge and experience needed to provide the required specialized services at the level of quality required at this time and within the timeframe required to continue needed performance while the follow-on contract effort is pursued.

The nature of the requirement is complex and requires large-scale coordination and mobilization of development teams and there is a significant learning curve associated with commencing to support these projects. The time between a potential competitive short-term award action and the need date for services (03/25/2026) would not allow sufficient time for recruiting, hiring, background checks and entry-on-duty, and most importantly, a transition period with knowledge transfer. The inability to conduct a proper in-depth transition will result in failure to deliver on key USCIS priorities. ADG- REI is currently capable of providing the required staffing and the level of quality within this short timeline with all necessary teams in place as well as extensive program knowledge to continue operations to complete the projected tasks and to transition ongoing activities to the new competitive awardee.

As referenced above and for greater context, this task order is essential for USCIS to continue its adjudicative mission as the Agency would experience unacceptable losses that could not be overcome by Government personnel. Without this task order, DHS and USCIS would lose the services needed to develop and maintain the ELIS and Global enterprise case management systems;

these systems currently process over 90% of the Agency’s adjudication workload. If the task order is not extended, USCIS would be unable to continue supporting the following initiatives that fulfill multiple Executive Orders, including the development of security capabilities that will enhance vetting and identification of national security and public safety threats (Social Media Vetting), as well as the development of Gold Card, and D1/D2 initiatives such adding the adjudications capabilities for the investor program.

Additionally, losing the infrastructure support services provided by ADG-REI under this task order will severely inhibit the Agency’s ability to maintain and scale its major enterprise benefits case management system, which would be unacceptable and detrimental to the mission of the Agency.

USCIS does not have the bandwidth or skillsets required to design, build, secure, and maintain the foundational IT systems that power business operations. Some of ADG-REI’s core duties include managing servers, networks, storage, and cloud environments within Amazon Web Services AWS to ensure high reliability, scalability, and monitoring of performance. Not only would the loss of these services increase the risk of system downtime and operational disruption, but it would also severely impact the ability to recover from system failures. The inability to support interactive capabilities, such as real-time communication, data sharing, and workflow integration, will directly affect USCIS’s ability to work effectively with its partner agencies like ICE, CBP, and DoS. This would negatively affect the Agency’s ability to fulfill its mission and compromise the seamless exchange of mission-critical information. Furthermore, without the continued support provided by ADG-REI under ODOS III, USCIS will face increased vulnerability due to the absence of proactive monitoring, timely security patching, and incident response, putting sensitive data and essential services at risk.

The Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable by utilizing one or more of the techniques identified in RFO 15.404-1. The labor rates awarded on the CIO-SP3 SB GWAC were determined fair and reasonable by the awarding Contracting Officer. Further, the labor rates resulting from the ODOS III competition were determined fair and reasonable by the ordering Contracting Officer. The total price, labor mix, number of hours, and other direct costs proposed by the contractor for the 6-month extension are equal to the total price, labor mix, number of hours, and other direct costs being used under the FAR 52.217-8 6-month option period.

6. Any other facts supporting the justification.

Only one awardee is capable of providing the required services at the level of quality required because the services are unique are not due to poor planning, but due to events outside the control of the contracting office. The ODOS IV Integrated Product Team (IPT) was formed in October 2023.

Program staff released a Request for Information (RFI) in February 2024 and spent approximately seven (7) months using the responses, in conjunction with meetings with vendors, to complete market research and formulate a plan for the acquisition. The acquisition strategy was briefed to the Head of Contracting Activity and approved in October 2024. The recompete acquisition experienced unanticipated and significant delays with the review and approval of the acquisition plan due to the new policies and procedures that have recently been implemented. More specifically, the ODOS IV acquisition plan was pending review by DHS and the Department of Government Efficiency (DOGE) liaison since March 2025.

As briefly discussed in Section 4, the succeeding competitive procurement, ODOS 3.1, was expected to be in place prior to the expiration of the current task order but has faced numerous delays in both the solicitation and evaluation phases, consequently prolonging the Government’s efforts to transition work from the ODOS III contractors to new awardees.

or services is made.

Any barrier to competition will be removed upon finalization of the source selection and a transition to a new awardees. No other competitive barriers are known at this time, which would lead to a future fair opportunity exception. This sole source extension is only intended to continue the current services until the award and transition-in of the in-process competitive procurement is completed.

intends to post this requirement on Sam.gov pursuant to RFO 16.507-