Limited-Sources Justification (LSJ)_nv_ss25Nov2025.pdf

Attachment 4 U.S. Customs and Border Protection

Limited-Sources Justification (LSJ) - FAR 8.405-6 For orders or BPAs not exceeding the Simplified Acquisition Threshold (SAT)

Version 2.0 November 2020

Date: 10/27/2025 PR Number: 20153880

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C.

152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity. Identification of the agency, contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This Limited Sources Justification (LSJ) is prepared by the U.S. Customs and Border Protection (CBP), Office of Acquisition, Procurement Directorate, Mission Support Contracting Division (MSCD), on behalf of the Office of Professional Responsibility (OPR), Personnel Security Division (PSD). The justification supports the issuance of an order under the GSA Multiple Award Schedule (MAS) to LexisNexis Special Services Inc. for credit reporting services.

2. Nature and/or description of the action being approved. Describe the action being approved, and include the name and address of the proposed contractor(s).

CBP proposes to award a firm-fixed-price task order to LexisNexis Special Services Inc. under GSA MAS Schedule Contract #GS-00F-178DA for the provision of tri-merged employment credit reports, supplemental public records checks, and Social Security Number (SSN) verifications. The total estimated value of the action is $67,500.00, and the period of performance is from November 26, 2025, to December 25, 2025.

The award will be made pursuant to FAR 8.405-6(a)(1)(i)(B), which allows for limiting sources when only one source is capable of providing the required supplies or services due to unique capabilities or other factors.

The proposed contractor for this effort is:

Contractor: LexisNexis Special Services Inc.

Address: 1775 Greensboro Station Pl, Ste 4, McLean, VA 22102-3466 Contract #: GS-00F-178DA

SAM UEI: H5AKPL6N4L96

NAICS: 561450

GSA Link: https://www.gsaadvantage.gov/ref_text/GS00F178DA/0Y1V2P.3TS7XD_GS-00F-

178DA_LNSSIGSAGS00F178DAMARCH2023.PDF

Size Status: Other than Small

Total value of proposed action: $67,500.00

3. Description of Supplies/Services. Describe the supplies or services to be acquired. Provide the estimated total value (including options, if any).

http://uscode.house.gov/ https://www.gsaadvantage.gov/ref_text/GS00F178DA/0Y1V2P.3TS7XD_GS-00F-178DA_LNSSIGSAGS00F178DAMARCH2023.PDF https://www.gsaadvantage.gov/ref_text/GS00F178DA/0Y1V2P.3TS7XD_GS-00F-178DA_LNSSIGSAGS00F178DAMARCH2023.PDF https://www.gsaadvantage.gov/ref_text/GS00F178DA/0Y1V2P.3TS7XD_GS-00F-178DA_LNSSIGSAGS00F178DAMARCH2023.PDF

Limited-Sources Justification (LSJ) - FAR 8.405-6

The contractor shall provide the following services:

• Tri-Merged Employment Credit Reports: Combining data from Experian, Equifax, and TransUnion into a single, user-friendly report.

• Supplemental Public Records Checks: Identifying public records such as bankruptcies, repossessions, foreclosures, tax liens, and judgments.

• SSN Verifications: Cross-checking the subject’s SSN, name, and date of birth, with a death indicator if applicable.

• Training: Providing training to CBP personnel on interpreting credit reports, including a training plan, quick reference card, and instruction manual.

• Secure Interface: Maintaining a secure web-based application for manual and automated requests for credit reports, compliant with DHS IT security standards.

The total value of the action is $67,500.00, inclusive of all deliverables and associated costs.

4. Authority and supporting rationale.

This justification is prepared under the authority of FAR 8.405-6(a)(1)(i)(B), which permits limiting competition when only one source is capable of providing the required supplies or services due to unique capabilities.

Supporting Rationale:

LexisNexis is the only vendor capable of meeting CBP’s requirements for the following reasons:

Unique Capabilities:

LexisNexis provides tri-merged credit reports that integrate data from all three major credit bureaus (Experian, Equifax, and TransUnion) into a single report. This capability is essential for CBP’s background investigations and ensures compliance with the Fair Credit Reporting Act (FCRA), Executive Order 12968, and other federal regulations.

Continuity of Operations:

CBP has an existing relationship with LexisNexis under BPA #70CMSD20A00000001.

Transitioning to another vendor would result in significant operational disruptions, including reconfiguration costs, retraining personnel, and delays in meeting investigative requirements.

Compliance with Security Standards:

LexisNexis complies with DHS IT security requirements, including HTTPS/SSL protocols, and provides secure delivery of reports in both PDF and XML formats.

Limited-Sources Justification (LSJ) - FAR 8.405-6

Market Research Findings:

Market research conducted by CBP confirmed that no other vendor can provide the required data accuracy and secure transmission of reports to CBP’s network.

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

The Contracting Officer has determined that awarding this task order to LexisNexis represents the best value to the Government. The pricing is based on GSA MAS rates, which have been determined to be fair and reasonable. Additionally, the continuity of services minimizes administrative costs and operational risks. Discounts from the GSA schedule prices will be requested.

6. A 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 was conducted to identify potential vendors capable of meeting CBP’s requirements. The following methods were used:

• Review of GSA MAS Vendors: A review of GSA MAS vendors offering credit reporting services revealed that LexisNexis is the only provider capable of delivering tri-merged credit reports that meet CBP’s requirements. This contractor has an active Authority to Operate (ATO) with DHS CBP and is currently providing services under order 70B06C25F00000779 (DHS SSV

BPA 70CMSD20A00000001).

• Consultation with Technical Experts: CBP technical personnel confirmed that alternative vendors lack the necessary data integration capabilities, and compliance with federal security standards.

• Past Performance Evaluation: LexisNexis has a proven track record of successfully supporting CBP’s investigative requirements under previous contracts.

Based on these findings, LexisNexis is the only responsible source capable of meeting CBP’s needs.

7. Any other facts supporting the limited-sources justification. Additional facts may be stated in this section. If there are no additional facts, you must state that here.

A current order (70B06C25F00001251) is already in place under a competitively awarded strategic sourcing vehicle with Verato, Inc. (DHS SSV #70CMSD25A00000001); however, this order is still undergoing an Authority to Operate (ATO) approval process with the Department of Homeland Security (DHS). Until the ATO is approved and Verato can begin providing the required reports, LexisNexis Special Services Inc., the current provider, is the only source available to meet CBP’s immediate needs. LexisNexis has been providing these services under an existing contract

Limited-Sources Justification (LSJ) - FAR 8.405-6 and has the necessary infrastructure, security compliance, and operational capabilities to ensure continuity of services without disruption.

The delay in the ATO approval for Verato necessitates this limited-sources justification to ensure that CBP’s mission-critical operations, including background investigations and suitability determinations, are not adversely impacted.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made.

None.

9. CBP intends to post this requirement on SAM.gov pursuant to FAR 8.405-6(a)(2)(i).

10. Technical/Requirements Personnel Certification:

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

10/27/2025 Technical Representative/COR Date

11. Contracting Officer Certification and/or Approval: *

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and to the best of my knowledge and belief.

Contracting Officer Date

*Note: In accordance with FAR 8.405-6(d)(1) for proposed BPAs or orders with an estimated value exceeding the simplified acquisition threshold, but not exceeding $900,000, the ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the ordering activity contracting officer’s knowledge and belief will serve as approval.

► LSJ Approvals:

VALENTINE

Digitally signed by NATARSHA L

Date: 2025.10.27 14:40:02 -04'00'

Limited-Sources Justification (LSJ) - FAR 8.405-6

13. PROCURING ACTIVITY ADVOCATE FOR COMPETITION (Per FAR 8.405-6(d)(2) - Exceeding $900,000)

Approved Disapproved

Name (Print):

Competition Advocate

Signature: Date:

14. HEAD OF CONTRACTING ACTIVITY (Per FAR 8.405-6(d)(3) – Exceeding $20M to $90M)

Head of the Contracting Activity

Signature: Date:

15. DHS CHIEF PROCUREMENT OFFICER (Per FAR 8.405-6(d)(4) - Exceeding $90M)

DHS Chief Procurement Officer

Signature: Date:

Note: Each Limited-Sources Justification must be reviewed and approved by lower level approval(s).

For example, actions over $95 million requiring CPO approval must be reviewed, approved, and signed by the contracting officer, Component Competition Advocate, and HCA.