JEFO FY26-0158 - Redacted.pdf

www.uscis.gov

Rev: 02/10/2026

Justification for Exception to Fair Opportunity, Exceeding the Micro-purchase Threshold, elopment, Security, and Operations

Services III Extension/Alpha Omega

REFERENCE: Justification Log Number: FY26-0158 and PR Number:

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), Transformation Delivery Division (TDD) 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 seeks approval for a sole source extension to Alpha Omega Integration, LLC (Alpha Omega) via modification No. P00042 to Task Order No. 70SBUR22F00000197 to continue the system maintenance and security work currently within the technical scope being performed. The current task order was competitively awarded in September 2022 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 RFO 16.507-6(b)(2), only one awardee is capable of providing the supplies or services at the level of quality required because the supplies or services ordered are unique or highly specialized. The final completion date of the order was extended from 05/01/2026 to 09/30/2026 non-competitively via modification P00039. The period of performance end date was subsequently modified to 09/24/2026 via modification P00041 to align with the period of performance end dates of the other three (3) ODOS III task orders.

The III Performance Work Statement (PWS) details Information Technology (IT) Development, Security, and Operations (DevSecOps) services to operate and maintain major USCIS systems such as the Electronic Immigration System (ELIS) and the Global enterprise case management system. The Government requires these services for an additional three (3) months from 09/25/2026 through 12/24/2026. The total estimated price for this performance period is .

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 SAT, ODOS III – Alpha Omega Justification Log Number: FY26-0158

The performance period of the proposed extension is allowable under the CIO-SP3 SB GWAC, which remains valid through 10/29/2026 with an additional period of performance available of up to 12/31/2028.

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 67 contractor-personnel support DevSecOps, service delivery, and infrastructure needs under this task order for secure and efficient case processing and vetting of applicants. Due to the urgent nature of the information contained within ELIS and the Global case management system as it relates to the mission, the scope of work within this task order can only be provided to the acceptable quality levels by Alpha Omega.

The succeeding competitive procurement, ODOS 3.1, was expected to be in place prior to the expiration of this task order so the work could be transitioned to awardees of the ODOS 3.1 task orders; however, USCIS received a pre-award protest under the DevSecOps and UXD/IxD Services requirement of the ODOS 3.1 recompete, which pauses the transition until the protest is resolved. No vendor other than Alpha Omega can complete the work that Alpha Omega performs on this task order at full capacity at acceptable quality levels without sufficient transition time. The Government does not have sufficient time for an interim fair opportunity solicitation and award while the protest is pending.

This justification supports the agency’s requirement to continue ODOS III support commencing on 09/25/2026. Market research that was conducted for the competitive recompete that’s currently in-

JEFO, Exceeding the SAT, ODOS III – Alpha Omega Justification Log Number: FY26-0158 process 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). The Government surveyed industry, Government experts, and similar requirements; however, the market research conclusions remained unchanged in supporting 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 awarded and the protest is resolved.

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 (09/25/2026) 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. 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 while the protest is ongoing and to transition ongoing activities to the new competitive awardees.

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.