LMS Bridge Support_Federal Supply Schedule LSJ-signed_20260324.pdf

Federal Supply Schedule Limited-Sources Justification

Acquisition Title: Learning Management System (LMS) Licenses Bridge - Content Support Agency: Administration for Children and Families (ACF) Acquisition Year (FY): 2026 Author: Shadonna Minnis, Contract Officer Representative

2. Description of Action

Modification to Existing Order/Contract Number: GS-00F-002BA_75P00125F80104 Pricing: Firm Fixed Price Funds: Other

Name of Proposed Contractor(s): METCOR, Ltd., dba Learning Systems International (LSI) Street Address: 1501 M ST NW ST 340 City, State, Zip: Washington, DC, 20005

3. Description of Supplies or Services:

The estimated value of the proposed action, including all options, is $490,788

The Unaccompanied Alien Children Bureau (UACB), within the Office of Refugee Resettlement (ORR), requires continued services to support the operation, maintenance, and administration of its Learning Management System (LMS), a mission-critical platform used to deliver, track, and manage required training for Federal staff and external care providers supporting the Unaccompanied Alien Children (UAC) program.

The LMS currently supports approximately 25,000 users and includes the provision and management of Systems, Applications, and Products (SAP) user licenses. Required services include ongoing technical support, system configuration, website administration, and performance management to ensure system availability, security, and reliability.

This requirement also includes instructional design and content development services to update 39 required e-learning training modules across six topic areas. The contractor shall assess modules for accuracy and compliance, convert legacy content into fully editable formats, and collaborate with ORR subject matter experts to revise and develop content aligned with current policy, guidance, and regulatory requirements. All deliverables must comply with Section 508 accessibility standards, remain fully compatible with the LMS, and be delivered in both English and Spanish.

Performance of this requirement must ensure uninterrupted LMS operations. Any disruption would adversely impact training delivery, completion tracking, and compliance oversight for approximately 25,000 users.

4. Authority:

This acquisition is conducted under the authority of the Multiple Award Schedule (MAS) Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501; and Section 803 of the National Defense Authorization Act of 2002 (Pub. L. 107-107), as implemented by the Federal Acquisition Regulation (FAR) 8.401(b) and the General Services Administration Acquisition Regulation (GSAR) Subpart 538.71.

The LMS supports approximately 25,000 Federal and external users and serves as the primary system for delivering, tracking, and managing required training for the UAC program. The LMS and its supporting infrastructure—including system configurations, integrations, and SAP user licensing—are currently operated and maintained by Metcor, Ltd. under an existing General Services Administration (GSA) MAS task order. The scope of this modification is within the scope of the existing task order and does not constitute a new requirement.

Due to policy changes and evolving program requirements, 39 required training modules must be updated to ensure accuracy and compliance. ORR does not have sufficient internal staffing resources or specialized instructional design expertise to complete these updates within the required timeframe. Internal estimates indicate that Government performance would take approximately 4.5 years.

Continued reliance on outdated training materials presents compliance, operational, and safety risks, including the potential for care providers to rely on incorrect guidance and a reduced ability for ORR to monitor and enforce compliance. Accordingly, updates must be completed expeditiously while maintaining uninterrupted LMS operations.

Courses of Action Considered

(1) Provide fair opportunity to all MAS contractors.

Providing fair opportunity would require transition activities, including system familiarization, knowledge transfer, and validation prior to full performance. Given the LMS supports approximately 25,000 active users and is integral to ongoing operations, this approach would introduce a high risk of service disruption, delays in training delivery, and continued reliance on outdated content. This option was determined to present unacceptable performance and schedule risk.

(2) Separate LMS operations from instructional design services.

Separating these functions would introduce integration challenges between LMS functionality and training content, increase the risk of incompatibility, and require additional Government oversight. This approach would not ensure coordinated performance and was determined to be impracticable.

(3) Perform the requirement using Government personnel.

This option was determined to be infeasible due to limited staffing resources and lack of specialized technical and instructional design expertise. The estimated completion timeline of approximately 4.5 years does not meet mission requirements and would result in prolonged reliance on outdated training materials.

(4) Transition LMS operations to a new contractor.

Transitioning LMS operations, including management of approximately 25,000 SAP user licenses, would require extensive onboarding, knowledge transfer, and system validation. Given the complexity of the LMS and its active use, this approach would introduce a high likelihood of service disruption, delays in training delivery, and degraded system performance. This option was determined to pose unacceptable operational risk and would result in duplication of cost associated with transition activities that would not provide commensurate value to the Government.

(5) Modify the existing GSA MAS task order with Metcor, Ltd. (Chosen Course of Action).

Modification of the existing task order with Metcor, Ltd. ensures continuity of LMS operations and enables timely updates to training content without disruption. This approach avoids transition risks, delays, and potential performance degradation associated with onboarding a new contractor. As the incumbent contractor, Metcor, Ltd. possesses detailed operational knowledge of the LMS environment—including system configurations, integrations, and user management processes—enabling efficient performance within the required timeframe.

Limiting sources is justified, in accordance with GSAR 538.7104-3(b)(2)(ii), because only Metcor, Ltd. can meet the Government’s requirement within the required timeframe and without unacceptable risk to mission performance. No other contractor is capable of performing this requirement without a transition period that would result in unacceptable delays and a significant risk of disruption to ongoing LMS operations. Accordingly, modification of the existing task order is the only viable approach to ensure continuity of operations, maintain uninterrupted support for approximately 25,000 users, minimize performance risk, and enable the timely correction of critical training deficiencies.

5. Market Research:

ORR has conducted ongoing market research since 2021 to inform the acquisition strategy for LMS support services, including Training and Technical Assistance (TTA). This research included evaluation of industry capabilities, available contract vehicles, and potential vendor sources within the marketplace.

Consistent with FAR 10.001, market research was conducted to determine the availability of commercial products and services and to assess the capability of small businesses and other vendors to meet the Government’s requirements. The results confirmed that the requirement constitutes a commercial service available through existing Governmentwide contract vehicles, including the GSA MAS, and that multiple capable vendors, including small businesses, exist within the marketplace.

Market research confirmed the availability of multiple capable vendors; however, none can meet the requirement within the required timeframe without introducing unacceptable performance risk associated with transition and system familiarization.

Although capable vendors have been identified, the Government determined that additional market research specific to this action is not necessary. The previously conducted research remains current, accurate, and relevant, and there have been no material changes in market conditions, technology, or the Government’s requirements that would affect the acquisition approach.

This action is limited to a modification of the existing task order with Metcor, Ltd., a small business, to ensure continuity of LMS operations and support ongoing Monitoring and Compliance Branch (MCB) training requirements. The decision to limit sources is based not on a lack of capable vendors, but on the need to avoid unacceptable performance risk associated with transitioning a mission-critical, actively used system.

For the anticipated follow-on requirement, the Government will conduct updated market research and provide fair opportunity to all qualified MAS contractors in accordance with FAR 8.401(b) and GSAR Subpart 538.71. This will include the use of GSA eBuy to solicit and evaluate quotations from capable vendors, with the objective of promoting competition to the maximum extent practicable and maximizing small business participation.

6. Actions to Increase Competition:

ORR recognizes the importance of promoting competition for future LMS requirements. While the current action is limited to modifying the existing task order to maintain operations and update required training content, it represents a necessary step toward enabling greater competition in future acquisitions.

Performance of this effort will provide ORR with improved insight into system dependencies, content management processes, and operational requirements. This increased visibility will support the development of clearer requirements, defined performance baselines, and enhanced technical documentation necessary to facilitate future competition.

Following completion of this effort, ORR intends to evaluate and implement strategies to expand competition, improve flexibility, and reduce reliance on a single contractor. These strategies may include modularizing LMS components, standardizing system interfaces, and improving documentation of system configurations and content development processes to support onboarding of additional vendors.

Additionally, conversion of training content into accessible, fully editable formats will reduce reliance on legacy materials and lower barriers to entry for future contractors, enabling more efficient updates and enhancements.

This phased approach allows ORR to stabilize LMS operations and standardize training content in the near term, while positioning the program to increase competition over time through reduced transition complexity, improved transparency, and better-defined requirements. These actions are intended to reduce barriers to competition and enable future requirements to be competed among qualified MAS contractors.

Although this action requires limiting sources to ensure continuity and timely delivery, it directly supports ORR’s long-term objective of promoting competition by establishing the conditions necessary for more open and effective future acquisitions.

7. Any other facts supporting the justification:

Not Applicable to this procurement.

8. Technical / Requirements Certification:

By my signature below, I certify that the supporting data under my review which is included in this Limited-Sources Justification is accurate and complete.

Program Manager Name: Katie Pittman Position Title: Assistant Division Chief, Evaluation and Learning Email Address: Katie.pittman@acf.hhs.gov Telephone Number: 227-215-4246 Signature

Program Manager Supervisor (or one level above Program Manager) Name: Saunji Fyffe Position Title: Acting Division Chief, Evaluation & Learning Email Address: Saunji.fyffe@acf.hhs.gov mailto:Katie.pittman@acf.hhs.gov mailto:Saunji.fyffe@acf.hhs.gov

Telephone Number: Via Teams Signature

9. Best Value Determination:

As Contracting Officer, I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable. In accordance with FAR 8.401(b) and GSAR Subpart 538.71, I will conduct a price analysis of the contractor’s proposed pricing, including a review of applicable GSA MAS rates, to ensure that the final negotiated price is fair and reasonable.

The price analysis will consider the level of effort, scope of work, and the value associated with maintaining continuity of operations for a mission-critical system. The proposed pricing structure will be evaluated to ensure it is balanced and consistent with the requirements of the order.

As appropriate, I will apply additional price analysis techniques to support and document the determination that the final negotiated price is fair and reasonable.

Contracting Officer Name: Emily Graham Position Title: Contracting Officer Email Address: Emily.Graham@hhs.gov Telephone Number: 771-241-7890

10. Contracting Officer's Approval:

Based on the foregoing justification, I hereby approve the procurement of continued Learning Management System (LMS) operations, licensing management, and training content development services on a limited sources basis pursuant to the authority of Title 40 U.S.C. 501, Services for Executive Agencies, as implemented by FAR 8.401(b) and GSAR Subpart 538.71, specifically GSAR 538.7104-3(b)(2), subject to the availability of funds and provided that the services described herein have otherwise been authorized for acquisition.

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

mailto:Emily.Graham@hhs.gov

Emily S. Graham Contracting Officer Office of Mission Acquisition Solutions (OMAS) Office of Acquisitions (OA) | Assistant Secretary for Financial Resources (ASFR) U.S. Department of Health and Human Services