Limited Sources Justification.pdf

U.S. DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY (OST)

OFFICE OF THE SENIOR PROCUREMENT EXECUTIVE (OSPE)

SOLE SOURCE JUSTIFICATION- GSA

This Limited Sources Justification is prepared in accordance with RFO FAR 43.302- and complies with the requirements of GSAM - procedures and approval requirements for Sole Source Justifications GSAM 538.7104-3(b)(2).

1. IDENTIFICATION OF AGENCY AND CONTRACTING ACTIVITY

Office of the Secretary (OST) Acquisitions Services Division 1200 New Jersey Avenue, SE Washington, DC 20590

2. DESCRIPTION OF ACTION BEING APPROVED

Justification and approval to limit sources to execute a bilateral authorization under GSA

Multiple Award Schedule; Contract Number/FRA BPA/OST ORDER - GS-00F- 045DA/693JJ625A000001/693JK425F55007N with Guidehouse Inc.

The authorization is for a contract modification to extend for a term of approximately 6 months.

Period of Performance: from September 26, 2026, to March 25, 2027.

3. DESCRIPTION OF SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

This authorization will provide the Department of Transportation/Office of Secretary (OST) with Internal Control services to address the Office of Management and Budgets (OMB) Circular A-123 and the Federal Managers Financial Integrity Act (FMFIA) requirements.

In FY 2026, OST must expand the Appendix A assessment procedures under the DATA act to include Subrecipient Reporting activities. The modification also supports execution of required Appendix C Improper Payment and Fraud Risk Assessments. Pursuant to the Payment Integrity Information Act of 2019 (PIIA), Public Law 116-117, federal agencies are required to conduct risk assessments for all programs with outlays exceeding $10 million at least once every three years. The Department’s next assessment cycle is scheduled for FY 2026. Additionally, the contract modification will enable completion of required annual A-123 tasks for the FY 2027 reporting cycle.

The amount to be funded at this time is $723,086. The modification is estimated to provide an additional $717,810. The total estimated value of the award is $1,440,896 for the entire period of performance (09/26/2025-3/25/2027).

4. IDENTIFICATION OF THE STATUTORY AUTHORITY PERMITTING A LIMITATION

OF SOURCES

GSAM 538.7104-3(b)(1)(iii)- in consideration to FAR 52.217-8 OPTION TO EXTEND

SERVICES (NOV 1999)

The Government may require continued performance of any services within the limits and at the rates specified in the contract. These rates may be adjusted only as a result of revisions to prevailing labor rates provided by the Secretary of Labor. The option provision may be exercised more than once, but the total extension of performance hereunder shall not exceed 6 months. The Contracting Officer may exercise the option by written notice to the Contractor prior to the expiration of the current performance period.

5. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE

AUTHORITY CITED

Performing end-to-end vendor competition in Q4 of FY 2026 would result in unacceptable delays of required tasks before fiscal year end in time for the Statement of Assurance letter to verify compliance with legal requirements. OST is satisfied with Guidehouse’ s performance and extending the period of performance for a maximum of 6 months is the most effective method.

6. EFFORTS MADE TO OBTAIN COMPETITION

Vendor competition under the FRA A-123 BPA will be required when the 6-month extension expires. With the majority of FY 2027 A-123 tasks also included in the extension, the team can shift additional focus on end-to-end procurement activities for the next A-123 cycle.

7. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED

COST TO THE GOVERNMENT IS FAIR AND REASONABLE

The independent government cost estimate (IGCE) is based on rates provided by the vendor multiplied by estimated hours based on level of effort for each task area. The rates also include annual increases based on vendor documentation in the FRA A-123 BPA.

The Contracting Officer determines that the overall anticipated cost to the Government for this modification is fair and reasonable based on negotiated BPA rates and validated labor hours.

8. A DESCRIPTION OF MARKET RESEARCH CONDUCTED

Market research was conducted within the GSA MAS and FRA BPA holder pool. Due to immediate FY26 compliance deadlines, bringing on a new vendor to perform the required scope will cause unacceptable delay and duplicate costs

9. ACTIONS TO REMOVE BARRIERS TO COMPETITION

See the previous response.

REPARED BY:

10. CERTIFICATIONS AND APPROVALS

In accordance with GSAM 538.7104-3(2)(b)(2)-content requirements-I certify that this justification provides sufficient detail and supporting rationale to support this exception to competition.

P

Jay Monitz Contracting Officer’s Representative

APPROVED BY:

Based on the foregoing justification, the limitation of sources is hereby approved for the proposed authorization under GSA Schedule Contract GS-00F-045DA / FRA BPA 693JJ625A000001 / Task Order 693JK425F55007N, pursuant to the authority of GSAM 538.7104-3(b)(1)(ii), "Only One Source.”

Robin D. Golden Chief of the Contracting Office, Acting Associate Director/Contracting Officer M-63, Acquisition Services Division