LSJ FY24_00229_70RDAD22FR00000055_One23Group_Final_Signed.pdf

OPOAM 3008.405-6(a)(2) Limited-Sources Justification (LSJ)

For orders or BPAs exceeding the Simplified Acquisition Threshold

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LSJ No.: FY24-00229

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.

The Department of Homeland Security (DHS), Office of Procurement Operations (OPO), Departmental Operations Acquisition Division II (DOAD II), in conjunction with the DHS Office of Policy (PLCY), Office of Homeland Security Statistics (OHSS) proposes to exercise FAR 52.217-8 Option to Extend Services for Task Order No.

70RDAD22FR0000055 with The One 23 Group pursuant to FAR 8.405-6, Limiting Sources.

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

DHS intends to exercise FAR 52.217-8 Option to Extend Services from 07/12/2024 until 01/11/25 for Task Order No. 70RDAD22FR0000055 with The One 23 Group which was placed under the General Services Administration (GSA) Multiple Award Schedule (MAS) Contract No. 47QTCA19D0092 in accordance with FAR 8.405 to provide OHSS with Data Governance Support Services.

3. Description of Supplies/Services.

The One 23 Group is currently providing Data Governance Support Services to the DHS/PLCY/OHSS including:

Assisting the Immigration Data Integration Initiative’s (IDII) Data Governance Working Group (DGWG) and Policy and Oversight Working Group (POWG) in project management, requirements gathering, technical writing, and software development related to documenting, implementing, and managing reference data standards and data sharing policies and procedures.

The data governance support and services include producing documentation for the publication of data standards; change and configuration management of published reference data standards and glossary terms; baselining and monitoring the implementation of the reference data standards throughout the Department’s immigration data systems; and developing workflows in SharePoint and Matrix, the Department’s data governance platform. DHS/PLCY/OHSS has migrated to Microsoft Office 365 and utilizes the 365 Apps for many activities.

http://uscode.house.gov/

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Total value of this exercise action is $720,666.30 as detailed below:

Period Period Total Base (07/12/24 - 01/11/25) $720,666.30

Total: $720,666.30

4. Authority and supporting rationale.

This action is being taken under statutory authority permitting limited-sources IAW FAR 8.405-6(a)(1)(i)(A) An urgent and compelling need exists, and following the procedures would result in unacceptable delay.

This action is to exercise FAR 52.217-8 Option to Extend Services for Task Order No.

70RDAD22FR0000055 with The One 23 Group expiring on 07/11/2024 which was placed under the GSA MAS Contract No. 47QTCA19D0092 in accordance with FAR

8.405. The Department started planning efforts and market research to recompete the new task order in March 2024, well in advance of the task order expiration date of July 2024.

Request for Quotation (RFQ) No. 70RDA224Q00000056 for the new task order was released on GSA MAS SIN 54151S on May 23, 2024, and the solicitation closed on June 12, 2024.

However, on June 18, 2024, DHS decided the requirements for standardizing reference data for immigration data stored in the DHS’s various immigration data systems will be transitioned from OHSS to the oversight of the DHS Office of the Chief Information Officer (OCIO) by January 2025.

The scope of work being procured under RFQ No. 70RDA224Q00000056 is to provide vendor support with OHSS for Immigration Data Integration Initiative (IDII) Data Governance (DG). The statement of work (SOW) speaks to a senior-level Executive Steering Committee (ESC) that leads the IDII. The SOW states that the IDII Data Governance Working Group (DGWG) standardizes reference data and has established a repeatable process to baseline and publish reference data standards. Tasks within the SOW include providing project management support to the DGWG as well as producing technical documentation and system development supporting reference data standard.

The existence of the IDII ESC has been sunset with the creation of the Statistical Official (SO) Council and Chief Data Officer (CDO) Council with full transition effective January 2025.

Additionally, current tasks within the SOW require the vendor to research relevant compliance requirements related to sharing federal data for each immigration data system of record and assisting in drafting data sharing/governance policies and agreements for each federal agency or office with immigration responsibilities. One of the core functions of the DHS OCIO established by the Evidence Act is to manage the sharing of data assets

LSJ No: FY24-00229 - 3 -in accordance with applicable law. Therefore, the research and assistance services of the current RFQ are no longer needed by OHSS.

Furthermore, DHS OCIO is evaluating approaches for a streamlined operating model moving forward. Because this shift to DHS OCIO represents a significant material change to the OHSS requirements moving forward, this requirement under RFQ No.70RDA224Q00000056 is no longer needed. Therefore, this six-month temporary extension of the current task order allows OHSS to temporarily continue this critical work to provide enough time to successfully transition this oversight to DHS OCIO by January 2025.

Because of this change, there is now an urgent and compelling need for One 23 Group to continue these services under Task Order No. 70RDAD22FR0000055 IAW FAR 8.405- 6(a)(1)(i)(A). Without this short-term extension period, the mission risk and excessive cost that would be inherent in a short-term competitive bridge award to cover the six-month gap in service. If a competition were held to bridge the gap period, DHS would be required to plan for an additional transition from One 23 Group to bridge awardee until transition to DHS OCIO in January 2025. The potential for service disruption would pose risk to the mission. In addition, it would not be cost-effective in time and resources for the agency to plan for and execute a competitive bridge award for the gap in service. It would be not only imprudent for the brief exercise period but also impossible to issue another new, competitive task order for OHSS to bridge the transition gap for DHS OCIO under the GSA MAS prior to the current order’s expiration on 07/11/2024.

Therefore, in order to prevent any gaps in these critical services this order will continue until 01/11/2025 per FAR 52.217-8, which was included in the original contract (however not evaluated at award). Therefore, a limited sources justification (LSJ) under FAR 8.405-6 is being issued and approved prior to the exercise of 52.217-8.

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

The Contractor’s FAR 52.217-8 exercise pricing is on based on current Base Period firm fixed pricing which was determined to be fair and reasonable at time of award. The Contracting Officer will ensure the extension pricing remain consistent with the awarded base period monthly fixed pricing to ensure the overall FAR 52.217-8 exercise pricing remain fair and reasonable.

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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Market research was conducted in as part of the acquisition process for awarding original Task Order No. 70RDAD23FR0000055 as well as the follow-on requirement under RFQ No. 70RDA224Q00000056 before the transition from this requirement from OHSS to DHS OCIO. Market research showed that issuing both the previous and current, follow-on solicitation as a small-business set aside under the GSA MAS SIN 54151S in accordance with FAR 8.405 was the best acquisition strategy to procure these Data Governance Support Services for OHSS. The rationale was that GSA MAS SIN 54151S included an adequate amount of small-business vendors capable of performing this requirement to achieve a high degree of competition all the while providing the Government the best value.

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

OHSS requires the exercise of FAR 52.217-8 for these critical services given that OHSS is responsible for immigration domain operational data governance. Task Order 70RDAD22FR0000055 with The One 23 Group supports this mission which is critical to DHS immigration component operations. It supports the management of operational standards for key immigration domain data elements including maintaining DHS data standard tables, change management of codes, operational and tactical support and the facilitation of Data Stewardship Tactical Working Group (DSTWG) and Communities of Interest (COI)

Any lapse in this contract support would result in disruption to DHS immigration component operations, interoperability and alignment to standards across DHS, especially with the crisis at the southern border. It‘s imperative that DHS maintain continuity and stability in our data governance, statistical analysis, and data management systems within DHS. OHSS needs to retain these services for continuity of operations and potential transition to a new vendor depending on the results of the selection process.

Any disruption poses significant risks to our immigration and national security efforts with disruption of immigration operations at the Southern border, loss of institutional knowledge, data security issues, negative impact on statistical data analysis and capabilities as well as further degradation of trust in DHS data.

The additional time given with this exercise option allows DHS sufficient time to plan for the long-term strategy and effect of its shifting data governance requirements plans from OHSS to DHS OCIO to temporary continue these critical services until January 2025.

Thus, is the reason for the request to exercise FAR 52.217-8 for these critical services being provided to OHSS under Task Order 70RDAD22FR0000055 with The One 23 Group.

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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.

Task Order 70RDAD23FR0000055 with The One 23 Group was originally competed as a small business set-aside under the GSA MAS with sufficient competition.

9. DHS intends to post this requirement on System for Award Management (SAM.gov) pursuant to FAR 8.405-6(a)(2)(i).

10. Technical/Requirements Personnel Certification.

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.

Thomas Woermer Date Technical Representative

DHS/PLCY/OHSS

11. Contracting Officer Certification and Approval

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

Matthew Wetzel Date Contracting Officer

DHS/OPO/DOAD II