Limited Source Justification_Modification PARDON Call Order P00001_Redacted.pdf

U.S. Department of Justice Justice Management Division Procurement Services Staff Washington, D.C. 20530

Limited Sources Justification – Page 1

Limited Sources Justification

1. Identification of the agency and the contracting activity.

The requiring organization is the United States Department of Justice (DOJ), Justice Management Division (JMD), Office of the Pardon Attorney (PARDON). The contracting activity is the JMD Procurement Services Staff (PSS).

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

PSS proposes to issue a modification on BPA Call No. 15JPSS25F00000334 with expected modification number P00001, on behalf of PARDON, pursuant to FAR 8.405-6, Limiting Sources. This document outlines the rationale for executing a modification to include digitization services to sole source BPA Call 15JPSS25F00000334. Follow-on call order No. 15JPSS25F00000334 was awarded to CADENCE GROUP on March 4, 2025.

3. Description of the supplies or services required to meet the agency’s needs, including the estimated value.

proposed modification adds new work for digitization services under call order

For this modification, CADENCE will be required to digitize paper documents/records using PARDON’s established processes.

4. Authority and supporting rationale including, if applicable, demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(a)(1)(i)B - Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

PARDON has recently experienced an unprecedented volume of hard copy records due in large part to atypical early-Administration grants of clemency by the current Administration. The unanticipated increase is estimated to be at least 400% more than that recorded for the same six-month timeframe in 2024. If the call order is not modified to include the digitization of these records, the impact will be as follows:

• Inability to maintain a sufficient response rate to records received.

• Inability to complete clemency cases and negative impact on recommendations made to the Office of the Deputy Attorney General

Limited Sources Justification – Page 2 and the White House, which are formulated based on incomplete information.

• Incorrect or untimely response to congressional and other monitored correspondence.

As the incumbent, CADENCE is intimately familiar with the support required and is uniquely qualified to support PARDON with the digitization of the early-Administration grants of clemency records. CADENCE is currently performing the Records and Information Management (RIM) work until March 3, 2026. CADENCE’s performance under the sole source call order has been satisfactory. By successfully Supporting the intricacies of PARDON’s RIM work, CADENCE has the capability and expertise to continue to support this requirement with minimal interruption or schedule impact. Issuing a sole source contract to a different contractor for this additional requirement is not in the Government's best interest as a new contractor would need time to familiarize themselves with the requirement. Since CADENCE’s personnel are already onboarded and supporting PARDON, having CADENCE continue performance will avoid unacceptable delays that bringing in a new contractor would present and is the only vendor with the capability and experience needed to meet the Government requirements for such a short timeframe.

Obtaining competition for this modification is impracticable under the circumstances described herein as it requires considerable lead time to compete the requirement amongst the RIM BPAs holders, receive quotes, conduct a source selection, and process appropriate award documentation. Selecting any other source would also require a significant transition-in/ramp up period to get a new contractor up to speed on the complex services provided, including transfer of documentation, and obtaining access to controlled Government systems.

The execution of this modification to the existing CADENCE call order is most advantageous and in the best interest of the Government in meeting critical PARDON’s mission requirements.

5. Determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

Although GSA-FSS has already determined prices under its Multiple Award Schedule (MAS) contracts to be fair and reasonable, the Contracting Officer has determined that modifying the proposed call order for PARDON’s Digitization work represents the best value and results in the lowest overall cost, considering price and administrative costs to meet the Government’s needs. This order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.” The General Services Administration (GSA) has already negotiated fair and prices. Also, the underlying BPA rates were further negotiated. We expect the proposed rates to be consistent with the existing rates of the call order IAW FAR 8.405-4 discounts will be requested. Additionally, prior to the issuance of the modification, the ordering activity will consider the level of effort, and

Limited Sources Justification – Page 3 the mix of labor proposed to perform the new task being ordered to determine that the total price is reasonable. The contractor’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate.

6. Description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

Market Research is required by FAR Part 10. Market research was not conducted since this modification will be issued to the incumbent for the reasons cited in sections 3 and 4 above.

7. Any other facts supporting the justification.

In accordance with FAR 8.405-6(a)(2)(i), within 14 days after executing the modification to extend services, a redacted version of this justification will be posted on SAM.gov for a minimum of 30 days.

8. Statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

Subsequent actions are not anticipated by PARDON. PSS anticipates utilizing this sole source award to provide for the digitization services through the end of the current period of performance.

9. Certifications, Concurrences and Approval.

Technical/Requirements Personnel Certification:

I certify that the information contained in this document for which I am responsible is accurate and complete to the best of my knowledge and belief.

Limited Sources Justification – Page 4

Contracting Officer Certification:

I certify that this justification is accurate and complete to the best of my knowledge and belief.