JEFO FY26-0059 - Redacted.pdf
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- Solicitation number
- FY26-0059
About this file
This is a Justification for Exception to Fair Opportunity (JEFO) document seeking approval for a sole-source extension to an existing task order under the CIO-SP3 Small Business GWAC.
The Department of Homeland Security's U.S. Citizenship and Immigration Services (USCIS) proposes to modify Task Order No. 70SBUR22F00000197 awarded to Alpha Omega Integration, LLC through modification P00039. The extension will continue IT development, security integration, and maintenance services for the Electronic Immigration System (ELIS) and Global enterprise case management system for a performance period from May 1, 2026 through September 30, 2026, with two optional periods: one two-month option (July 1–September 30, 2026) and one three-month option. The services include development of enhanced security capabilities for national security and public safety threat vetting (Notice to Appear filings), development of D1/D2 initiatives including I-131 and I-485 processing capabilities, and maintenance of the Refugee, Asylum, and International Operations Directorate (RAIO) primary case management system. Approximately 96 contractor personnel will support DevSecOps, service delivery, and infrastructure needs. The justification cites RFO 16.507-6(b)(2) (unique or highly specialized supplies/services) as the basis for sole-source authority. The rationale emphasizes that Alpha Omega possesses the specific skills, knowledge, and program experience required to maintain continuity while the competitive ODOS 3.1 successor procurement, which has experienced significant delays in solicitation and evaluation phases, is finalized. The Contracting Officer has determined anticipated costs will be fair and reasonable based on labor rates established through the CIO-SP3 SB GWAC competition and prior ODOS III pricing determinations. USCIS intends to post this requirement on sam.gov pursuant to RFO 16.507-6(f).
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JEFO, Exceeding the SAT, ODOS III – Alpha Omega Justification Log Number: FY26-0059
This justification seeks approval to continue the following work unique to 70SBUR22F00000197 on ELIS and the Global case management system:
1. Continue the development of security capabilities that will enhance vetting and identification of national security and public safety threats (Notice to Appear (NTA)).
2. Continue the development of D1/D2 initiatives such as developing the ability to process the remaining categories of the I-131 and I-485 along with High Value Questions.
3. Continue to maintain the Refugee, Asylum, and International Operations Directorate (RAIO) primary case management system.
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 case management system. Alpha Omega 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 96 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 Alpha Omega 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 05/01/2026. Market research that was conducted for the competitive recompete that’s currently in-
JEFO, Exceeding the SAT, ODOS III – Alpha Omega Justification Log Number: FY26-0059 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 Alpha Omega 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 (05/01/2026) 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. Alpha Omega 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 (Notice to Appear (NTA), as well as the development of D1/D2 initiatives such as developing Get Work and Global pull strategy which provide the capabilities of having one location for work that will allow better case alignment processing times across different centers and offices. The first product to use this approach is the I-
130. Furthermore, the loss of Global support will severely impact the agency’s ability to maintain Refugee, Asylum and International Operations Directorate (RAIO) primary case management system.
Additionally, losing the DevSecOps support services provided under the ODOS III 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, develop, test, and deliver software products. The cooperative effort of Alpha Omega is vital for creating high-quality software that meets the needs of the Agency and implementing executive orders and any Congressional mandated requirements, while adhering to strict project timelines and budgets.
fair and reasonable.
The Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable. The labor rates awarded on the CIO-SP3 SB GWAC were determined fair and
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