LSJ.pdf

Office of Inspector General

LIMITED-SOURCES JUSTIFICATION

TO: Scott Ferrante, Contracting Officer, IG/M/AOO

FROM: Richard Ingram, Director, IG/M/IM

DATE: June 24, 2025

SUBJECT: AT&T Mobility Limited-Source Justification

In accordance with FAR 8.405-6, the proposed contractual action is pursuant to the statutory authority under the Multiple Award Schedule Program.

1. This document sets forth the facts and rationale justifying the use of limited sources, in accordance with FAR 8.405-6:

This is a Limited Source Justification request to utilize the AT&T mobility GSA schedule 47QTCA19D00MV. The requiring activity is USAID OIG Information Management Division (IG/M/IM).

2. The nature and/or description of the action being approved:

This is a request for a limited source award to AT&T Mobility, Inc. The estimated cost for this effort is

$429,261.00 for the current contract year beginning 7/1/2025 through 6/30/2026. The action to be awarded is a new, time and materials task order (TO) under AT&T Mobility’s GSA schedule

47QTCA19D00MV with a one-year base and four one-year option periods. AT&T mobility will provide the USAID OIG with wireless products and services such as unlimited Domestic plan (voice, data, text) +

International Day Pass, for which the cost is incurred only upon usage, as the standard plan for all users and tethering and equipment charges.

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

IG/M/IM division has a requirement for cellular and wireless devices and telecommunication plans.

USAID OIG’s mission requires travel and communication throughout the United States and across the globe, including remote locations, daily. USAID OIG needs a supplier that can provide wireless support, cell phones devices, and reliable nationwide coverage 24 hours a day, 7 days a week. The proposed

-2-acquisition is to provide wireless services to OIG personnel. It is intended to acquire wireless cellular services for domestic use and international services for a period of twelve (12) month base year with up to four (4) one-year option periods to AT&T Mobility in the total amount of $2,147,000.00. To support this effort, IG/M/IM is seeking to establish a task order utilizing GSA Schedules to provide equivalent cellular and wireless devices and plans.

4. Authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

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

The proposed acquisition is to support USAID OIG personnel and their ongoing mission of combating fraud, waste, and abuse with a continuation of wireless services performed by AT&T. AT&T Mobility is the only provider with established infrastructure within USAID OIG as well as with Department of State to provide quality wireless services. Without AT&T’s proven reliability of its international coverage and without the alignment of federal overseas operations and communication services, the organization’s mission would be at great risk.

The need for these services is so specialized that providing a fair opportunity would result in a loss in 5G

LTE coverage for some extremely remote locations as well as a loss in global connectivity required for critical operations in remote locations. AT&T provides expansive global coverage across over 230 countries, exceeding the international reach of other service providers. Its International Day Pass offers high-speed, unrestricted mobile data, voice, and SMS capabilities that are essential for mission-critical communications overseas. This global performance aligns directly with USAID OIG’s operational continuity requirements, especially in regions where AT&T is the only provider with reliable data roaming agreements in place.

Past performance and evaluations have been conducted in several countries to determine that AT&T is the only carrier that can support the wide Outside Continental United States (OCONUS) critical requirements for OIG. Although other providers are strong domestically, they offer service plans with unlimited data overseas at tiered speeds which do not consistently meet the performance standards required to support USAID OIG’s mission. AT&T Mobility has superior coverage within USAID OIG’s operating environments as they consistently offer the best available in-country network coverage speeds. They have also continuously demonstrated technological support and a willingness to commit the necessary manpower and resources in support of OIG’s unique (and challenging) work.

The cost to reprocure another service provider would not be fiscally responsible for the organization. A transition of service would result in significant costs associated with acquiring new government-furnished equipment (GFE), staff time to migrate newly acquired devices to the organization’s Mobile

Device Management (MDM) solution, staff time to re-establish endpoint security, and staff time to reload deployed phone applications. This effort would present a significant burden to staff that is already under-resourced. To avoid service disruptions, a transition of service would represent an increase in cost by running provider services simultaneously to gracefully transition to the new provider.

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The estimated cost of the reprocurement is $250,000 to include the transition to the new service provider along with the device setup and required configuration work. As stated above, a change in service providers would require significant reconfiguration of OIG’s MDM and 3rd party solutions, further increasing the risk of service disruption and potential lapses in endpoint security compliance standards.

AT&T maintains longstanding infrastructure compatibility with Foreign Affairs agencies operating in embassies and overseas posts. This alignment ensures interoperable, secure communications within diplomatic channels and security offices where other providers may lack support integration. This support is critical as many of the organization’s overseas staff function in remote locations where they face security challenges. Having a provider’s service that is consistent with other federal entities is essential to staff’s safety as well as their ability to communicate with proper authorities in cases of emergency.

Lastly AT&T’s public-sector rates per line are competitive with other providers. However, AT&T’s level of service such as its broader international reach, high speed service, and seamless integration with the organization's current infrastructure offer greater value and lower total cost of ownership for the organization. The direct award of a GSA task order will provide flexibility, reduce expenses associated with third party management, and provide direct support for USAID OIG. Without proper infrastructure or roaming agreements in place, it is difficult for other providers to achieve the level of service currently provided by AT&T Mobility.

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

Under the Federal Supply Schedule (FSS) program, the General Services Administration (GSA) meticulously establishes prices for supplies, fixed-price services, and hourly-rate services. This rigorous process ensures that the prices offered through its schedule contracts are, by definition, fair and reasonable. Consequently, ordering activities are generally relieved of the burden of conducting an independent fair and reasonable price determination. The GSA's pre-negotiated pricing inherently satisfies this requirement, with the singular exception of the price evaluation mandated by FAR 8.405-

2(d), which does not apply to the purchase requested herein.

By adhering to the procedures outlined in FAR 8.405 for placing an order against an FSS contract, an ordering activity affirmatively concludes that the order represents the best value—as precisely defined in FAR 2.101—and constitutes the lowest overall cost alternative to fulfill the government's requirements.

While the GSA's comprehensive negotiation process already guarantees fair and reasonable pricing, ordering activities may pursue further discounts prior to placing an order, as articulated in FAR 8.405-4.

The contracting team has confirmed with AT&T Mobility that it has applied a discount and pricing is under list price.

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.

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Extensive market research conducted within the year using 2024 and 2025 data from GSA Advantage, GSA eLibrary, contract vehicles, domestic and abroad coverage data, and vendor pricing. Additionally, research from other agencies was reviewed (Dept. of State, Dept. of Homeland Security, and Dept. of

Defense) to assess service options. Additionally, prior past performance reviews and evaluations were conducted by the requiring activity and the contracting activity across various multiple-award contractors with service in several countries. The findings indicate that although this critical requirement can be met by a commercial item, AT&T Mobility is currently the sole provider capable of fulfilling the

USAID OIG’s critical OCONUS requirements. While other providers are strong domestically, they offer service plans with unlimited data overseas at tiered speeds which do not consistently meet the performance standards required to support USAID OIG’s mission.

AT&T Mobility's unique ability to ensure continuous and uninterrupted coverage in extremely remote

OCONUS (Outside Continental United States) locations, coupled with its global connectivity in other remote areas, is paramount to meeting the Government's needs without risk of service interruption.

7. Any other facts supporting the justification:

Utilizing the GSA schedule for AT&T Mobility will provide flexibility to change devices and plans as needed. The decision to procure domestic and international cellular service together under the GSA

Schedule is driven by operational efficiency, cost-effectiveness, and continuity of service. The agency’s mission requires CONUS and OCONUS capabilities. Procuring these services from a single supplier under an existing GSA Schedule contract eliminates service fragmentation and ensures unified management of voice, data, and roaming capabilities across multiple regions. The agency’s needs for CONUS and

OCONUS cellular service are inherently interdependent in the context of its operations given its positions of staff located in missions overseas or those who frequently travel. Separation of the requirements between suppliers would introduce unnecessary logistical complexity, increase administrative overhead, and create potential interoperability issued between service platforms. It could also result in inconsistent user experiences, incompatible device provisioning, and redundant billing structures. AT&T Mobility demonstrated the ability to provide bundled CONUS and OCONUS cellular coverage with a single billing account, consolidated reporting, and standardized support services, capabilities not equally offered across multiple suppliers. This approach allows leveraging economies of scale and simplifying of contract oversight and invoice reconciliation under FAR Subpart

8.4. Thus, acquiring these services as a bundled requirement under a GSA Schedule contract represents best value to the government aligns with mission-critical needs, and avoids the risks and inefficiencies associated with managing separate service providers for overlapping functions.

8. A 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.

As part of its procurement planning process, USAID/OIG may periodically assess its requirements, limitations, and the vendor market for cellular and wireless services. Although the organization has recently reduced its overseas footprint, highly transient staff continue to work within 3rd world nations where affordable and high-quality coverage limitations exist. IG/M/IM will continue to survey the market in conjunction with federal overseas operations to promote competition.

9. Technical or Requirement Personnel Certification:

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In accordance with FAR 8.405-6(c)(2)(x), I hereby certify that the technical statements included above, which form a basis for the justification, are complete and accurate.

Richard Ingram Date Contracting Officer’s Representative

10. Contracting Officer’s Certification:

In accordance with FAR 8.405-6(c)(2)(ix), the justification is accurate and complete to the best of my knowledge and belief.

Scott Ferrante Date Contracting Officer

11. Justification Approval:

Based on the limited source circumstance described above, and in accordance with FAR 8.405-6(d)(2), I hereby approve the justification.

Lauren Sylvester Date Director, Administrative & Overseas Operations

Reviewed By:

Kelsie Cooley Date Attorney, Office of General Council