Justification_Exception-to_FSAR_Opportunity_Exceeding_SAT_JB_Approved.pdf

U.S. Department of Homeland Security Federal Emergency Management Agency (FEMA)

Justification for Exception to Fair Opportunity (JEFO) February 2026

JEFO > SAT

JEFO No. 26-082

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

JEFO No.: 26-082

Date: May 18, 2026, PR Number: WX00805Y2026T

Pursuant to the Federal Acquisition Regulations (FAR) 16.5, FAR Class Deviation 26-04, Revision 1 for FAR Part 16 and in accordance with the requirements of RFO 16.507-6(b), the justification for the use of the authorities under RFO 16.507-6(b) is justified by the following facts and rationale required under RFO 16.5.1

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for an Exception to Fair Opportunity.”

The Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA), Recovery Technology Programs Division (RTPD) in collaboration with the Office of Chief Component Procurement Officer (OCCPO) proposes to award an order pursuant to FAR 8.405-6, Limiting-Sources.

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

DHS/FEMA intends to award a task order without considering other awardees under contract number _GS-35F-0212U pursuant to RFO 16.507-6(b)].

Ardent Management Consulting Inc 1735 N Lynn St Arlington, VA 22209

Firm-Fixed Price

3. The purpose of this decommissioning effort is to formally disposition and decommission the Field Assessment Collection Tools (FACT) system. The FACT system will need to be restored to an operational state in order to disposition and properly decommissioned to meet federal laws, regulations, and policies. Production data for Disaster Survivor Assistance (DSA), Disaster Recovery Center Site Selection Inspection (DRC SSI), Shelter Resident Assessment Tool (SRAT), and Preliminary Damage Assessment (PDA) will be migrated to the Response Geospatial Mapping and Analysis Center (MAC) system.

1 In this document, citations to RFO Part 15 and RFO Part 16 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 26-08, Revision 1 for FAR Part 15 and FAR Class Deviation 26-04, Revision 1 for FAR Part 16, 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.

Justification for Exception to Fair Opportunity (JEFO) February 2026

JEFO > SAT

JEFO No. 26-082

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

Period Total Cost

Base Year $405, .00

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 16.507-6(b)(1). The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

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. [The justification must demonstrate that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited].

X RFO 16.507-6(b)(3). The order must 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. The system needs to be decommissioned and the last vendor who operated the working environment is the best vendor to perform this task in terms economically and efficiency because Arden has access to the system and the knowledge to perform the decommission of this system so the Government can retain access to its data; and the follow-on is logical (e.g., in terms of scope, period of performance, or value)]:

RFO 16.507-6(b)(4). It is necessary to place an order to satisfy a minimum guarantee.

RFO 16.507-6(b)(5). For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

Rationale: The FACT system was established to support FEMA Recovery Directorate’s field operations. The original contract, awarded through fair opportunity procedures, provided for system development, maintenance, and support, including the management of all environments and production data. Due to an administrative delay in the approval of the Financial Authority Obligation memorandum, the contract lapsed unexpectedly, resulting in the abrupt shutdown of the FACT system before planned decommissioning and data migration activities could be completed.

Logical Follow-On Justification:

Justification for Exception to Fair Opportunity (JEFO) February 2026

JEFO > SAT

JEFO No. 26-082

Issuing this order as a sole-source logical follow-on to the incumbent contractor is necessary in the interest of economy and efficiency for the following reasons:

Scope Continuity: The requirement to restore the FACT system, migrate production data to the Response Geospatial Mapping and Analysis Center (MAC), and decommission the system is directly related to the scope of the original contract. The incumbent is uniquely positioned to complete these tasks, having designed, operated, and maintained the system and possessing exclusive access to the environment snapshots and proprietary configurations.

Period of Performance: The follow-on work must be completed within a limited timeframe (by September 30, 2026) to comply with federal records management and IT security requirements. The incumbent’s familiarity with the system and prior performance ensures timely and efficient completion, minimizing risk of delay or data loss.

Value and Efficiency: Engaging the incumbent avoids duplicative onboarding, technical ramp-up, and security vetting that would be required for a new contractor. This approach preserves the value of prior investments and ensures seamless transition from shutdown to decommissioning, maximizing efficiency and minimizing cost.

Mission Criticality: The abrupt contract lapse prevented the Government from executing planned decommissioning and data migration. Only the incumbent can logically and efficiently restore the system and extract essential data, ensuring FEMA’s mission continuity and compliance with federal regulations.

Fair Opportunity:

Vendors were given a fair opportunity to be considered for the original order. The need for this logical follow-on arises solely from circumstances beyond FEMA’s control, and the current work on this order is directly tied to the original scope and performance and is the last phase of the operating cycle of a system, completing the decommission process.

Conclusion:

This sole-source order is a logical follow-on to the original contract, necessary for economy and efficiency, and directly related to the prior order in scope, period of performance, and value. The incumbent contractor is uniquely qualified to complete the decommissioning and data migration activities, ensuring FEMA’s mission requirements are met without unnecessary risk or cost.

5. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable. This paragraph should always begin with a sentence similar to: “The contracting officer determines that the anticipated price(s) will be fair and reasonable based on….” The section should include information such as commercial pricelists or prior acquisition history that will help the contracting officer determine that the anticipated cost is fair and reasonable (see RFO Subpart 15.4 and HSAM 3015.4 for contract pricing).

Justification for Exception to Fair Opportunity (JEFO) February 2026

JEFO > SAT

JEFO No. 26-082

6. Any other facts supporting the justification.

The internet was searched for a list of contractors on GSA and CIO SP3 that would be able to provide the decommissioning for the Field Assessment Technical Tool Services. The market research showed that only these two sites can provide the necessary process for decommissioning the system. Price lists for Ardent Management Consulting on both of the strategic source website providing comparable services were reviewed to assist with making the price reasonableness determination.

The DHS Geospatial Technical Support Services (GTSS) 3.0 Blanket Purchase Agreement (BPA) was originally scheduled for re-competition in September FY2024. However, due to a reasonable extension, the re-competition schedule was delayed, and the DHS GTSS BPA 3.0 was ultimately awarded in February 2025. The performance period for the BPA ended on March 12, 2025, necessitating the issuance of a FAR 8 action to ensure continuity of services.

The DHS GTSS BPA was designed to provide geospatial technical services at fair and reasonable prices. However, the FACT recompete action could not be executed in time to continue services after its performance period ended on September 12, 2025. As a result, stakeholders for this system decided to decommission the system.

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.

FEMA conducted market research on the GSA and CIP SP3 to established contract vehicles to validate which vehicle provides the best value for geospatial technical support services to meet the decommissioning. FEMA will build out a comprehensive acquisition package to allow sole source award contract to Ardent Management Consulting.

8. 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.

Digitally signed by JILLITA J BULLUCK Date: 2026.05.19 07:56:08 -04'00'

Contracting Officer Jillita Bulluck

Date

9. Evidence that all supporting data, which is the responsibility of technical or requirements personnel, has been reviewed and verified by the personnel responsible for the FACT system.

This data, used to establish the Government’s minimum needs and requirements and any rationale for exceptions to fair opportunity, has been certified as complete and accurate by the technical or requirements personnel.

JILLITA J BULLUCK

Justification for Exception to Fair Opportunity (JEFO) February 2026

JEFO > SAT

JEFO No. 26-082

10. A written determination by the approving official that one of the circumstances in Section 4 of this justification applies to the order.

Pursuant to FAR 16.505(B)(8), I certify that this justification is accurate and complete to the best of my knowledge and belief and hereby determine that the circumstances for an exception to fair opportunity exist:

11. 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.

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/COR Date Gracie Brown

12. Contracting Officer Certification and Approval *

Pursuant to RFO 16.507-6(e)(1), I certify that this justification is accurate and complete to the best of my knowledge and belief and hereby determine that the circumstances for an exception to fair opportunity exist:

Not exceeding $900,000 Date Contracting Officer Jillita Bulluck

5/19/2026