LSJ Exceeding SATredacted_Redacted.pdf

CISAM 3008.405-690(a)(2) Limited-Sources Justification (LSJ)

For orders or BPAs exceeding the Simplified Acquisition Threshold

LSJ No: FY23-0106 Page 1 of 3 Rev: 11/21/2022

LSJ Number: FY23-0106 PR Number: VER230051 and VER230061

Limited-Sources Justification

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), Office of Contracting (OCON), proposes to award an Order, on behalf of Office of Information Technology (OIT)/Identity Records and National Security Division (IRNSD), pursuant to FAR 8.405-6, Limiting Sources.

2. Nature and/or description of the action being approved.

The proposed action is for a sole source order to Slalom, Inc., 821 Second Ave., Suite 1900, Seattle, WA 98104, through General Services Administration, Multiple Award Schedule, Special Item Number, IT Schedule-70. The award will be Time and Materials (T&M) for a base period of 41 days with no option periods.

3. Description of Supplies/Services.

VISOTS (Verification Information System Ongoing Transition Support) will consist of transition teams to provide development, security, and operations (DevSecOps) services to support United States Citizenship and Immigration Services (USCIS) Information Technology (IT) system delivery primarily VIS (Verification Information System) The teams will be performing transition activities with USCIS personnel in preparation to support modernizing complex, large-scale, Internet-facing websites and IT systems in a cloud environment using forward-thinking, modern, open source technologies and managed cloud services with heavy customer engagement.

Period PoP Duration Monthly Total Base Period 41 Days Total

4. Authority and supporting rationale.

This acquisition is conducted under the authority of Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

Pursuant to FAR 8.405-6(a), the circumstance that justifies limiting sources to fewer than those required by FAR 8.405-1 and 8.405-2 is:

FAR 8.405-6 (a)(1)(i)(A) An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

Rationale:

CISAM 3008.405-690(a)(2) - Limited-Sources Justification (LSJ)

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Due to continued performance issues experienced by the program office under the Verification Information Program Engineering Resources (VIPER) task order, the program office is in need for Slalom, the previous incumbent, to continue to provide critical expertise which they’ve been providing for the past 3.5 years. The VIPER contractor is lacking in DevSecOps maturity required to maintain and develop the Verification Information System (VIS).

Without Slalom providing mature DevSecOps experience and unique technical knowledge that they have gained from their years of VIS development and operations, the program could experience severe outages and degraded services. These services include public facing impacts such as federal, state, and local benefit-granting agencies would not be able to verify a benefit applicant’s immigration status or naturalized/derived citizenship. E-Verify an internet-based system in partnership with the Social Security Administration, companies and federal contractors would not be able verify the legal status employment eligibility of an individual. The current VIPER task order is set to expire on July 11, 2023, and USCIS will not be exercising the option period due to continued poor performance. A separate twelve month sole source will bridge the gap between the end of VIPER July 11, 2023, and awarding this as a competed requirement in fiscal year 2024. Awarding this contract to another company would obviate the requirement for seasoned engineers since there would be an extensive learning curve even for a large company.

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 issuing the proposed Task Order to Slalom for the VIS transition support to be the best value considering price and administrative costs, to meet the Government’s urgent needs for support. This order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.” The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates. Discounts to these GSA schedule rates have be requested. Additionally, prior to issuance of the task order, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific task being ordered to determine that the total price is reasonable. The contractor’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate.

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 in accordance with FAR Part 10 and HSAM 3010, and the DHS Market Research Guide. USCIS reviewed applicable Best in Class (BIC), Governmentwide Acquisition Vehicles and other recently awarded USCIS agile development task orders. Due to the urgent and compelling need to support these critical public facing systems no other companies would be able to quickly takeover support without serious interruptions in services.

7. Any other facts supporting the limited-sources justification.

No additional facts.

CISAM 3008.405-690(a)(2) - Limited-Sources Justification (LSJ)

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

The government intends to procure new agile development services in the future to support IRNSD in FY24. The program and OCON have issued an sources sought notice via SAM.gov to ensure that in future acquisitions that the same type of support, thus eliminating the barriers to competition.

9. USCIS 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.

Technical Representative/COR Date

11. Contracting Officer Certification and Approval

Pursuant to FAR 8.405-6(c)(2)(ix) and (xi), I certify that the Limited-Sources Justification is accurate and complete to the best of my knowledge and belief, and I determine that the circumstance identified in Section 4 applies.

Contracting Officer Date