Justification and Approval FY26-0103.pdf

Justification for Exception to Fair Opportunity Exceeding the SAT pursuant to Revolutionary FAR Overhaul (RFO) 16.507-6(b)

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JEFO No.: FY26-0103

Date: May 8, 2026, PR Number: RSLF-26-00033

This Justification for an Exception to Fair Opportunity is prepared in accordance with Federal Acquisition Regulation (FAR) RFO 16.507-6(b)(3).

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Office of Procurement Operations (OPO) Science and Technology Acquisition Division (S&TAD) prepared this Justification for an Exception to Fair Opportunity on behalf of the DHS Science and Technology (S&T) Directorate’s Office of National Laboratories.

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

DHS OPO intends to award a 29-day extension modification without considering other awardees under task order 70RSAT18FR0000150 awarded against General Service Administration (GSA) One Acquisition Solution for Integrated Services (OASIS) Indefinite Delivery Indefinity Quantity (IDIQ) Contract No.

GS00Q14OADU108 to provide administrative services and professional support. This task order supports both the Plum Island Animal Disease Center (PIADC) operations and Plum Island Closure & Support (PICS) Program including execution of Program Management Office (PMO) functions, cost estimating, project management, technical program coordination, executive assistant support, procurement/acquisition support and budget support.

As a result of the multiple DHS shutdowns, a 29-day extension is needed to maintain critical support services.

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

PIADC requires technical and administrative support services to assist with internal and external communications and program operations to ensure continued mission execution as the PICS program advances toward facility closure.

The value of this requirement is $99,912.69 for a twenty-nine (29) day period.

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.

RFO FAR 16.507-6(b)(3). The order shall be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

1 FAR Class Deviation 26-04, Rev. 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, Rev. 1 for FAR Part 16.

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Rationale:

Task Order 70RSAT18FR0000150 was competitively awarded to Booz Allen Hamilton, Inc. under GSA’s OASIS Indefinite Delivery Indefinite Quantity (IDIQ) contract no. GS00Q14OADU108. The period of performance for this Task Order is 10/29/2018-5/8/2026. The contract extension is requested to continue the provision of administrative and professional services to assist in supporting the mission and operations of the PIADC and closure objectives of the PICS Program.

This extension is requested due to delays in executing previous requests for supplemental funding and schedule not completed prior to the current period of performance deadline. Several factors caused delays including two USG and DHS furlough events (over 90 days total) and changes to funding approval process requirements.

DHS/S&T intends to recompete this task order at a later date if support of this type is still an ongoing need for the PICS Program.

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 price via proposal provided by Booz Allen Hamilton on 5/8/2026 to the Government will be fair and reasonable based on a priced analysis per RFO FAR 15.404-1 (b). In addition, the labor rates under the extension are consistent with the labor rates determined fair and reasonable at the time of award.

6. Any other facts supporting the justification.

There are no other facts supporting the justification.

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.

Comprehensive market research is underway. A Request for Information (RFI) acquisition package is under review with the Program Office. The RFI will provide results that will aid in developing the acquisition strategy. The Program Office’s market research is still in its initial phase, as they are exploring the options of a re-compete for the administrative and professional core services provided on task order #70RSAT18FR0000150. Market research has started to explore a recompete of this requirement or determine another acquisition approach that would be in the Government’s best interest. However, additional time is needed to finalize the acquisition approach.

8. DHS 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 for Exception to Fair Opportunity, are accurate and complete.

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Max Rasmussen Date Contracting Officer Representative Department of Homeland Security Plum Island Animal Disease Center

10. Contracting Officer Certification and Approval

Pursuant to RFO 16.507-6(d)(2)(viii), I certify that this Justification for Exception to Fair Opportunity is accurate and complete to the best of my knowledge and belief.

Jason Rios Date Contracting Officer Department of Homeland Security Office of Procurement Operations