LSJ_Redacted_1.pdf

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C 501

SOLICITATION # 140D0425Q0574

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This document serves as a Limited-Sources Justification for the Department of Health and Human Services (HHS), Administration for Children and Families (ACF), Office of Community Services’ (OCS) Low Income Home Energy Assistance Program (LIHEAP) Support Services requirement. The contracting activity procuring this requirement is the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division 1, Branch 3 on behalf of the

HHS, ACF, OCS.

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

The purpose of this document is to outline the rationale for issuing a task order on a sole source basis to Apprise Inc against its General Services Administration Multiple Award Schedule Special Item Number 541611 contract without considering other awardees pursuant to FAR 8.405-6 (a)(1)(i)(A).

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The scope of this effort is to provide the services to maintain and enhance the LIHEAP Clearinghouse and Performance Management Website; assistance in the annual calculation of the LIHEAP 1984 funding formula allocation by using the most recent available data and methodology; manage the National Energy Assistance Referral (NEAR) Phone Hotline/call center, Interactive Voice Response (IVR) and email service; provide training and ad hoc LIHEAP related assistance to internal OCS federal staff and LIHEAP grant recipients; coordinate and provide the logistics for the bi-annual LIHEAP Performance Measures Implantation Working Group (PMIWG); preparing essential LIHEAP reports and other data; and regularly coordinate with the ACF Tech.

The services required are considered severable services as all tasks are considered continuing and recurring in nature and can be separated into components that independently meet a need of the Government.

SOLICITATION # 140D0425Q0574

which will not be awarded by August 29, 2025. The follow-on recompete is anticipated to be awarded during the second quarter of Fiscal Year 2026 (FY26) to allow for an estimated 60-day transition period for a potential new awardee due to the complexity and breadth of the work.

Per FAR 8.405-6(a)(1)(i)(A), the Contracting Officer (CO) may make an award on a limited sources basis when an urgent and compelling need exists and following procedures would result in unacceptable delays. AQD intends to issue this bridge task order to Apprise Inc, the incumbent contractor, in the interim to maintain critical support for ACF OCS until the new competitive follow-on order award is in place which is expected to occur no later than the second quarter of FY26. The interim task order is logical in that it will continue services at the same level of effort and scope as the current contract (75N92021P00340).

The delayed execution of the LIHEAP Support Services bridge contract would cause a significant disruption in the continuity of critical operations supporting the LIHEAP.

This contract encompasses a wide range of essential services, including maintenance of the LIHEAP Clearinghouse and Performance Management websites, operation of the NEAR hotline, execution of required federal data reporting functions, technical assistance to grant recipients, and performance measure analysis.

The nature of a delay would impede OCS's ability to provide uninterrupted support to LIHEAP grant recipients, to maintain 24/7 public access to energy assistance information, and to execute timely updates to federal systems that require compliance with cybersecurity, accessibility, and cloud-hosting standards. Key deliverables— including weekly call center reports, training activities, and updates to eligibility tools and performance dashboards—would either stall or be at risk of noncompliance.

The impact of this delay would undermine both federal program accountability and public access to critical information. It would hinder the ability of low-income households to locate local intake agencies for energy assistance, delay technical guidance to states and tribes, and interrupt progress on performance data analytics vital to congressional reporting and program oversight. This lapse would also introduce risks to federal IT security and jeopardizes compliance with established governance frameworks, including FedRAMP and Section 508 accessibility requirements.

As the incumbent, Apprise Inc is intimately familiar with the support required and is qualified to support ACF OCS while AQD continues with the competitive follow-on task order process. Apprise Inc’s performance under the current task order has been satisfactory. Apprise Inc has the capability and expertise to continue to support this requirement with minimal interruption or schedule impact. Awarding a task order to a different contractor for this bridge support is not in the Government’s best interest as a new contractor would need time to familiarize themselves with the requirement.

Apprise can avoid the unacceptable delays that bringing in a new contractor would require and is the only vendor with the capability and experience needed to meet the

Government requirements on this tight schedule.

Obtaining competition for this bridge is impracticable under the circumstances described herein as it would require considerable lead time to identify sources, receive quotes, conduct a source selection, and process appropriate award documentation. Selecting any other source would also require a significant transition-in/ramp up period to get a new contractor up to speed on the complex services provided, including transfer of documentation, and obtaining access to controlled Government systems.

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

The CO will determine the anticipated price will be fair and reasonable through the use of the GSA MAS program and through the program’s schedule pricing. The rates used by GSA MAS program schedule contract holders have been determined at the time of schedule contract award to be fair and reasonable. To further ensure the price is reasonable, price evaluation will be conducted in accordance with FAR 8.405-2(d). In accordance with DOI-AAAP-0024, Enhancing Competition, and due to only one quote being received, the price analysis tools and techniques at FAR 15.404-1(b)(2) may be used to further determine the price 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.

The Government’s market research shows that there are potentially several capable vendors under GSA MAS SIN 541611. However, due to the current task order expiring on August 29, 2025, there is not adequate time to follow competitive procedures to ensure a timely award such that there will not be a break in services. Thus, a bridge task order will be award under FAR 8.405-6 (a)(1)(i)(A) as there is an urgent and compelling need to ensure that there is no break in services and to bridge the gap between the existing order and the competitive follow-on order.

7. Any other facts supporting the justification.

A Request for Quotation (RFQ) will not be released on GSA eBuy as it has been determined that there is only one source, Apprise Inc, capable of providing the services for LIHEAP Support Services requirement due to an urgent and compelling need. After the placement of the task order, a notice will be posted on SAM.gov along with a redacted copy of the approved Limited-Sources Justification in accordance with the requirements at FAR 8.405-6(a)(2).

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 supplies and services is made.

The need for a subsequent sole source task order will be mitigated in the future through the award of a competitive follow-on task order anticipated to be awarded by the second quarter of FY26 to allow for an adequate transition period.

9. The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

I certify this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer

10.Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify the technical data which forms a basis for this justification is complete and accurate and meet the Government’s minimum needs.

11.For justifications under 8.405-6(a)(1), a written determination by the approving official identifying the circumstance that applies.

Under the authority of FAR 8.405-6(a)(1)(i)(A), only one source is capable of providing the services required due to the urgent and compelling nature of the Government’s needs to ensure continuity of services for the LIHEAP support services requirement;

therefore, the approving official hereby determines the circumstances of this action can only be provided by Apprise Inc.

12.Reviews and Approvals

Concur

Branch Chief

Concur

Division Chief

Approve

Bureau Competition Advocate