U.S. Department of Homeland Security Justification and Approval for Other Than Full and Open Competition Office of the Chief Procurement Officer Version 3.9

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

41 U.S.C. 3304(a)(1)

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-111), and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security, Office of Procurement Operations, proposes to enter into a contract on a basis other than full and open competition.

2. Nature and/or Description of the Action being Approved.

The Department of Homeland Security intends to procure on a sole source basis from Aon, located at 2001 K Street, NW, Ste 625 North, Washington DC 20006. This contract will be a single award contract, with an estimated total value of $331,000. Aon previously provided compensation design and support services for the Cybersecurity Talent Management System (CTMS) program from May 25, 2021, through May 24, 2026. There is an urgency to award this contract to avoid potential disruptions in the administration of the CTMS program and develop a smooth transition to hiring and training internal resources. Aon is uniquely qualified to continue to provide compensation support services based on their national expertise in cybersecurity compensation and their history with designing and administering compensation services specifically for CTMS.

CTMS is a market sensitive pay system that requires ongoing analysis of cybersecurity compensation data across industries. Maintaining the system and competitive compensation requires expertise in compensation practices and the cybersecurity labor market.

The Department intends to hire personnel in the future to support the CTMS compensation program. However, due to the impact of the government wide and DHS shutdowns, this transition has not been implemented. Additionally, this function requires highly specialized expertise and market awareness, best provided by external expert(s). Due to its extreme specialization and fluctuating workload, hiring a full-time employee within a short time frame is not practical.

1 In this document, citations to RFO Parts 6, 10, 15, 25 are citations specifically to FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 R1 for FAR Part 15, and FAR Class Deviation 25-09 R1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

U.S. Department of Homeland Security Justification and Approval for Other Than Full and Open Competition

(a) Nature of action: DHS intends to procure on a sole source basis from Aon a 12-month continuation of CTMS contractor support.

(b) Name and address of the contractor. 2001 K Street NW, Suite 625 North, Washington

DC, 20006

(c) Contract type: Labor-Hour (LH) and Firm-Fixed-Price (FFP)

(d) Estimated total value (including options). Provide breakdown as shown below:

Period Unit Price Total

Base Year 12 mo. $331,000

$331,000

Total $331,000

(e) Type of funding: Operations and Sustainment (O&S)

(f) Year of funding: FY26

(g) Solicitation number: RUHC-26-CS006

(h) Background information about the requirement: The previous contract with Aon, 70RDAD21C00000007, ran from 5/25/2021-5/24/2026. The sole source request is on a very limited scope (a 94% reduction from the last option period) and reduces tasking under the SOW to provide operation, analysis and design on CTMS as well as assistance on compensation processes. Aon’s participation, even in a limited role, is vitally important as DHS seeks to utilize federally hired resources for these activities once budgets and hiring plans are authorized.

3. Description of Supplies/Services.

The objective of this contract is to support the Department of Homeland Security (DHS) in the ongoing operation of the Cybersecurity Compensation System, a critical component of the Department’s Cybersecurity Talent Management System (CTMS). Please note that CTMS is a federal civilian personnel system, not an information technology system.

Similarly, the Cybersecurity Compensation System is not an IT system; rather, it consists of business rules, processes, and policies for administering compensation.

The Strategic Cybersecurity Compensation System enables DHS to offer competitive compensation to attract and retain essential cybersecurity talent, while remaining responsive to changes in the cybersecurity labor market and the evolving needs of the DHS mission. The system is designed to balance internal and external equity and incorporates leading

U.S. Department of Homeland Security Justification and Approval for Other Than Full and Open Competition compensation practices, including those proven effective in cybersecurity-focused organizations and those emphasizing skills, competencies, and capabilities.

Aon is an expert leader in compensation program design and administration. DHS partnered with Aon to implement the current CTMS pay system and is most qualified to continue to provide guidance and support. Aon employs expert compensation professionals who are fully versed in market pay practices within the cybersecurity industry and vital to maintaining a market sensitive pay system that is responsive to changes in the cybersecurity labor market.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 41 U.S.C.

3304(a)(1) implemented by the FAR Subpart 6.103-1 (FAR Class Deviation 25-11) entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.” Aon was the original contractor selected to develop the compensation program for the Cybersecurity Talent Management System (CTMS) and is uniquely qualified to provide follow-on services for this program. Aon has proven to be an excellent partner, providing the type of compensation expertise needed to develop and maintain a cybersecurity market sensitive pay system. Engaging any other company to provide these services would result in additional costs and delays associated with training and educating new personnel on the CTMS compensation program, its processes, and tools.

5. Identification of Exception to the Buy American Statute.

N/A

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Full and open competition was conducted for the original contract to provide compensation design and support services for the Cybersecurity Talent Management System (CTMS) program. Through this process, Aon was selected as the best and most cost-efficient provider for the required compensation support. Although the original five-year contract has expired, ongoing support is still essential for the CTMS compensation program.

Many of the services delivered under the original contract will eventually transition to internal DHS resources or potentially another long-term contract. However, hiring and training the personnel will require time. Due to the government shutdown and budgets restrictions, OCHCO was not able to implement a transition plan. In the interim, DHS needs continued access to Aon's services and expertise, particularly their insight into the cybersecurity compensation market, which only a large consulting firm like Aon can provide.

Engaging a different consultant would require significant training and onboarding, require the use of limited DHS resources and result in increased time and cost. It would not be

U.S. Department of Homeland Security Justification and Approval for Other Than Full and Open Competition feasible to create a transition plan using a different company than the one that developed the current structures.

Without Aon's continued support, the process and timeline for hiring cybersecurity professionals will be adversely affected. Compensation packages will take longer to develop, especially when competing with other compensation initiatives. There is also an increased risk to the accuracy of compensation data, as limited internal resources may not be able to perform audits and quality checks effectively. The processes established with Aon ensure both speed and accuracy in fulfilling compensation functions; transitioning away from Aon at this time would require additional resources, increase risks, and potentially delay critical hiring efforts.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable. This section should include the following information:

An announcement has been made in sam.gov on June 30, 2026. No interested parties have responded to the notice of intent to sole source within the specified timeframe.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The Contracting Officer determines that the anticipated prices will be fair and reasonable based on prior acquisition history. The prior contract (no. 70RDAD21C00000007) was competitively solicited and the prices and rates established under the contract were deemed fair and reasonable at the time of contract award and during each exercise of option. Those historical rates will be used to evaluate the price fairness and reasonableness for the upcoming sole source contract.

9. Description of Market Research.

Due to the February 2026 Government shutdown and anticipated alternative hiring plans, extensive market research was not conducted. Market research is not required since the estimated purchase value is below the simplified acquisition threshold.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

None.

11. A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

None.

U.S. Department of Homeland Security Justification and Approval for Other Than Full and Open Competition

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

The Department of Homeland Security plans to utilize federally hired resources for these activities once budgets and hiring plans are authorized.

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U.S. Department of Homeland Security Justification and Approval for Other Than Full and Open Competition

13. Contracting Officer’s Certification. I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Contracting Officer Date

14. Technical/Requirements Personnel Certification. I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Technical Representative

APPROVAL:

Date

Contracting Officer Date