LSJ - EIS Bridge - SAM Posting.pdf

JUSTIFICATION AND APPROVAL FOR OTHER-THAN FULL-AND-OPEN COMPETITION

and external disruptions that directly impacted the acquisition planning timeline, and the clarity of future EIS needs. Ongoing litigation regarding agency funding, employee departures and retirements, restructuring of the organization, closure of field offices, changes to operational capacity, continued to obscure CFPB' s future EIS needs and created difficulty in creating an accurate Independent Government Cost Estimate (IGCE).

These disruptions and uncertainties hampered the teams' ability to:

• Finalize the EIS SOW with appropriate performance standards, service levels, and system requirements

• Project accurate cost estimates and funding requirements in development of the

IGCE

• Conduct a timely, fair, and open procurement with meaningful competition

(existential threat, uncertainties in court decisions and CFP B's strategic direction)

This logical follow-on allows the procurement team to continue to execute on an acquisition package that more closely aligns with the Bureau's expected future state. It provides additional time to definitize the EIS requirements, finalize a more accurate IGCE, and conduct a full and open competition that more closely reflect CFPB' s anticipated infrastructure needs while maintaining continuity of operations.

This logical follow-on will consists of:

• One, (3) three-month base period: March 23, 2026-June 22, 2026

• Three, (1) one-month option periods o Option Period 1: June 23, 2026 -July 22, 2026 o Option Period 1: July 23, 2026 -August 22, 2026 o Option Period 2: August 23, 2026-September 22, 2026

Total Potential Amount $1,236,302.73

3. 0 Authority for other-thanfull-and-opencompetition(proposed contractor 'sunique quals, etc.)

The current 6-month extension for EIS services is scheduled to expire on March 22, 2026. With less than one month remaining, there is insufficient time to finalize the requirements, release a solicitation, evaluate proposals, and if necessary, execute a 60-day transition to a new provider. A short-term logical follow-on contract, in accordance with FAR 16.505(b)(2)(i)(C) to continue with the current EIS provider is the only viable approach to mitigate risks associated with the Bureau losing all of its telecommunications services and CFPB' s infrastructure support and operations. Specifically, this logical follow on contract with Lumen enables the Bureau to:

• Maintain continuity of operations and protect critical infrastructure services (network, voice, phone lines, managed security services, MTIPS, and data center hosting) from interruptions while the Bureau completes its acquisition effort.

• Stabilize long-term requirements, revise the SOW and complete a scope review with

CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552

JUSTIFICATION AND APPROVAL FOR OTHER-THAN FULL-AND-OPEN COMPETITION

6. 0

7. 0

8.0

9. 0 time for the CFPB to award a long-term EIS contract that is stable, cost effective, and best aligned with CFPB' s anticipated future state.

A description of efforts made to ensure that offers are solicited from as many potential sources as practicable, includingwhether a notice was, or will be, publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies. Include a listing of sources, if any, that expressed a written interest in the acquisition as a result of the FBO posting.

A notice of intent to issue or a notice of award will be publicized after award at the Governmentwide Point of Entry (GPE) website https://sam.gov/ in accordance with FAR 16.505(b )(2)(ii)(D(1).

A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services is made.

Services performed under this logical follow-on Task Order will be recompeted in the next 3 to 6 months under full and open competition against GSA's EIS IDIQ. This logical follow on order will be structured with a base of 3 months and three, (1) one-month option periods, to allow the Bureau to transition to a new fully competed contract as soon as possible.

A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The pricing proposed by the Contractor will be verified to ensure that the awarded follow-on order's fixed prices are consistent with the current EIS Task Order 9531CB20F0132 rates or Lumen Technologies current GSA EIS IDIQ prices. At the time of the Task Order award, the Contractor's pricing will be deemed to be fair and reasonable based on 15 .404-1 (b )( 1) and data related to prices (such as comparison of the proposed price with prices previously found reasonable, and comparison to the Independent Government Cost Estimate (IGCE)).

An IGCE has also been created for comparison before award of this Task Order. The CO has determined that these estimated prices, and the resulting estimated cost, represents the best value to the Government.

Approvals.

9.1 TECHNICALIREOUIREMENTSPERSONNEL. All supporting data that is the responsibility of technical or requirements personnel, and which form a basis for the justification, are hereby certified as complete and accurate by the technical or requirements personnel.

PETER WILSON

Name: Peter Wilson

Digitally signed by PETER WILSON

Date: 2026.03.18 13:44:03 -04'00'

Date:

Title: Supervisory Program Analyst (Procurement & Budget) - T &I

CONSUMER FINANCIAL PROTECTION BUREAU (CFPB), 1700 G STREET, NW WASHINGTON, DC 20552