LSJ FY26-0210 Final_Redacted.pdf

Limited Source Justification 41 U.S.C. 152(3) and 40 U.S.C. 501

LSJ No.: FY26-0210

Description of Supplies/Services.

The Department of Homeland Security (DHS) Office of the Chief Financial Officer (OCFO) requires continued contractor support to sustain and enhance its financial management operations, drive process optimization, and address evolving Departmental priorities. The Contractor will provide technical financial management support, quality management system (QMS) maintenance and enhancement, process improvement, and automation solutions.

Additionally, the Contractor will deliver organizational communications, performance optimization frameworks, and structured program management to strengthen OCFO’s operational effectiveness, accountability, and transparency.

Specifically, the Contractor shall provide services to:

• Ensure complete and accurate delivery of deliverables critical to DHS and other reporting requirements, as applicable, to sustain the Department’s unqualified audit opinion issued by the Independent Public Accountant (IPA) for the fiscal year ending September 30, 2026, including support for the Annual Financial Report due by November 15, 2026.

• Support risk and financial management activities related to the Financial Systems Modernization Solution (FSMS), including external audit support (e.g., U.S. Government Accountability Office (GAO)) and internal assessment, oversight, and maintenance activities.

• Mitigate audit, Information Technology General Control (ITGC), and accounting-related risks impacting FSMS and the broader DHS Financial Systems Modernization (FSM) program.

• Provide adequate coverage during the transition period to any follow-on contract, as applicable, including Quality Control/Quality Assurance (QC/QA), project status reporting, milestone management, and execution briefing support.

• Support DHS OCFO’s annual planning process to define the scope of DHS financial management initiatives necessary to sustain a clean financial statement audit opinion, with the objective of achieving a clean internal control audit opinion.

• Assist DHS OCFO and DHS Components in preparing the Agency Financial Report (AFR), including audited financial statements and other information required by OMB.

• Prepare and review documentation and generate reports for Government review and approval to support compliance with the DHS Financial Accountability Act (FAA), OMB Circulars A-123 and A-136, and other financial reporting requirements identified by management.

3. Identification of Statutory Authority Permitting Other Than Full and Open

Competition.

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 implemented by GSAR 538.7104-3(b)(1)(ii), “Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.”

4. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The scope of this proposed short-term extension will remain consistent with the services and deliverables outlined in the original Statement of Work (SOW). The current Task Order No.

70RDA225FR0000010 expires during a critical period of ongoing work, including in-scope audit support, process improvements, automation initiatives, and organizational realignment actions for the DHS Office of the Chief Financial Officer (OCFO). Multiple government shutdowns in FY 2026 (42-day lapse in Q1; 80-day lapse in Q2) delayed the recompete for the follow-on requirement. The government shutdowns delayed completion and submission of the Procurement Request (PR) package. As a result, the current task order ends on August 17, 2026, and there is insufficient time to conduct a full and open competition, complete transition-in, and achieve operational readiness with a new contractor without causing significant mission impact. This extension through September 30, 2026, will provide the necessary time for award and transition to the follow-on task order.

The incumbent contractor is currently providing essential support for OCFO’s audit activities, process optimization, automation development, Quality Management System (QMS) maintenance, and organizational realignment efforts. These activities are time-sensitive and require continuity of support to ensure successful completion and adoption. The incumbent possesses detailed, current knowledge of OCFO’s business processes, ongoing improvement initiatives, audit requirements and findings, automation frameworks, and organizational structure changes. Replacing the incumbent at this stage would introduce a steep learning curve, increase the risk of delays, incomplete or inaccurate deliverables, and potentially jeopardize OCFO’s ability to achieve its operational and strategic objectives, including timely and accurate audit support.

This sole-source extension is strictly limited in scope and duration to the minimum period necessary to maintain continuity of services through completion of key audit, process improvement, automation, and organizational realignment activities, while the Government completes a competitive acquisition for the long-term requirement. The extension will not prejudice or preclude full and open competition for the follow-on requirement; rather, it is intended to stabilize operations during an extraordinary period of schedule compression and mitigate significant risk to OCFO’s financial management mission.

5. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The Contracting Officer has determined that the anticipated cost to the Government for the proposed task order modification to Guidehouse, Inc. will be fair and reasonable and represents the best value to meet the Government’s needs.

This procurement will be conducted in accordance with FAR 8.405-2, utilizing the General

Services Administration (GSA) Multiple Award Schedule (MAS) contract GS-00F-045DA.

DHS/OPO has previously determined that the MAS labor rates are fair and reasonable based on competition at the schedule level and analysis of underlying GSA Schedule pricing. For this modification, the Government will encourage additional discounts from Guidehouse’s MAS rates, further enhancing price reasonableness.

Prior to award, the ordering activity will evaluate the contractor’s proposed level of effort and labor mix for the specific tasks to be performed and compare them to the Independent Government Cost Estimate (IGCE). This comparison will include a review of historical usage under the current task order and alignment with the defined scope of work. The combination of pre-competed MAS rates, any additional discounts obtained, and confirmation that the proposed labor mix and hours are consistent with the IGCE and historical experience provides a sufficient basis for the Contracting Officer to conclude that the total proposed price is fair and reasonable to the Government.

6. Description of Market Research.

The Program Management Office (PMO), in coordination with the Contracting Officer, reviewed the current requirement, historical performance under Task Order No. 70RDA225FR0000010, and the acquisition timeline for the competitive follow-on requirement. No formal market research was conducted for this short-term action because the purpose of the extension is limited to maintaining continuity of existing services while the Government completes the follow-on acquisition.

The PMO reviewed the incumbent contractor’s current level of effort, labor mix, performance, and alignment with the Independent Government Cost Estimate (IGCE). Due to multiple FY 2026 government shutdowns and resulting delays to the competitive follow-on acquisition, there is insufficient time to conduct a new competition, transition to another contractor, and achieve operational readiness before the current task order expires on August 17, 2026, without disrupting critical OCFO support services.

Based on this review, the Contracting Officer determined that continued use of Guidehouse, Inc.’s existing GSA Multiple Award Schedule (MAS) contract for this short-term, limited-source action is appropriate. The Government will evaluate the proposed labor mix, level of effort, and total price against the IGCE, historical usage, and applicable GSA MAS rates to support a determination that the price is fair and reasonable.

7. Any Other Facts Supporting the Limited Source Justification.

This short-term, non-competitive extension is necessary to prevent gaps in critical services and allows OCFO additional time to finalize and recompete the follow-on requirement. The task order extension will only include a period of performance sufficient to maintain continuity of audit support, financial management, process improvement, automation, and organizational realignment activities until the follow-on task order is awarded. The schedule for the competitive recompete was significantly impacted by multiple government shutdowns totaling over 120 days.