LSJ Template CfA PMSS Deloitte_Redacted.pdf

SOLE SOURCE JUSTIFICATION UNDER FEDERAL SUPPLY SCHEDULE

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING

ACTIVITY

Department of State Contracting Activity

Acquisition Management Foreign Service Institute Office of Foreign Missions U.S. Mission to the United Nations Overseas Post

Requiring Activity

Diplomatic Technology, Center for Analytics (CfA) and the Division for Counter Threat Finance and Sanctions (TFS)

SECTION 2: NATURE AND/OR DESCRIPTION OF THE ACTION BEING

APPROVED

The U.S. Department of State (DoS) Bureau of Global Acquisitions (GA) proposes to issue a cost extension of mission critical services under the Program Management Support Services Blanket Purchase Agreement (PMSS BPA, agreement no.: 19AQMM19A0280) with Deloitte Consulting, on behalf of the Center for Analytics (CfA) and the Division for Counter Threat Finance and Sanctions (TFS). The approximate total value of the extension is for an additional one year and two six-month option periods to the current performance period of the BPA Call with Deloitte Consulting (call No.:

19AQMM21F7091) under the PMSS BPA. The additional year with two six-month option periods, if exercised, will extend the period of performance of the BPA Call with Deloitte under the PMSS BPA from September 30, 2026, until September 29, 2028. If the two six-month option periods are not exercised, the period of performance will extend by one year only, to September 29, 2027.

The action being approved is a one-year extension with an additional two, six months option period extension of Deloitte Consulting LLP’s BPA call, 19AQMM21F7091, issued under the PMSS BPA 19AQMM19A0280. The BPA call will continue essential technical and program management services, including artificial intelligence development and adoption, data engineering and testing, and sanctions and investigation support that are performed under the current call. The BPA and the BPA call had no maximum ceiling established.

SECTION 3: DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET

THE AGENCY’S NEEDS

The DoS requires the continuation of technical and program management services to CfA, TFS, and their partner bureaus to meet the Department’s analytics, artificial intelligence, and national security requirements, and provide the desired performance and value to the Department.

CfA is responsible for delivering the Department’s enterprise data and analytics platforms and the capabilities critical for ensuring the agency’s alignment with the President’s AI Action Plan, particularly in accelerating adoption across government and driving American leadership in AI innovation for national security and diplomacy. CfA is also responsible for operating Data.State, an enterprise data platform available to all bureaus that includes 400+ data pipelines and the data analytics mission needs across 30+ bureaus. CfA is currently in the midst of the enterprise deployment of StateChat and App Factory tools serving more than 50,000 users worldwide.

The CfA has multiple, high priority AI initiatives in flight addressing Administration priorities such as the processing and analysis of USAID data and system integration and standup of AI tools, agentic workflows, and platform solutions in ClassNet.

TFS leads the Department’s efforts to develop and implement security-related economic actions to address threats to national security posed by specific activities, terrorist groups, and countries. The Department uses sanctions to counter national security threats from hostile governments, to include Russia, Iran, the Democratic People's Republic of Korea, and Venezuela; defend against human rights abuse and threats to U.S. sovereignty from the International Criminal Court; address corruption; and deprive terrorist groups of funding. TFS relies on specialized support to meet this responsibility and execute Administration policy priorities, including multiple National Security Presidential Memorandums and Executive Orders, and Congressional mandates. TFS has active requirements that need continuity of service and knowledge from the current contractor. Specifically, this involves the use of sanctions in ongoing peace negotiations involving Russia and Ukraine, as well as requirements to impose robust sanctions on Iran as outlined in National Security Presidential Memorandum 2. Given the recent Department reorganization and current staffing levels, a change in contract at this point would be highly disruptive to TFS core efforts.

This costed extension will continue to enable the Department to meet the following critical mission and high priority service areas related to CfA and TFS:

Implement the Department’s sanctions authorities through expert knowledge and interpretation of those authorities, extensive research and analysis of both classified and open-source information, identification of entities of interest and their complex networks, drafting of high-quality evidentiary memorandums serving as the legal basis for the sanctions actions, and coordination of those actions throughout the Department and interagency.

Review and process sanctions petitions and provide litigation support in cases where sanctioned entities are requesting removal from the sanctioned list or bringing legal cases against the Government on their sanction. Prompt support is required to mitigate risk of further escalation, burden, and costs to the Government.

Provide insights to inform ongoing peace and trade negotiations, including evidence-based options for actions available to implement as needed. These actions are often required to be done in a matter of days, not weeks or months.

Deploy advanced analytics solutions and AI/ML based on statistical modeling approaches to produce insights across a variety of foreign policy and management strategic questions including countering Chinese influence.

Support the Agency’s Chief AI Official in complying with several statutory requirements (OMB M-25-21 Accelerating Federal Use of AI through Innovation, Governance, and Public Trust) and including AI impact assessments, producing the Departments AI use case inventory that includes identification of high-risk use cases, and the ongoing monitoring of AI systems to detect performance issues and risks.

Execute the Secretary’s Enterprise and AI Data strategy by informing business challenges, extract value, assess organizational pain points and evaluating the maturity of an effective, data-driven culture. This includes developing and updating enterprise data strategy and roadmaps and advising on the prioritization and implementation of data-centric business goals, scaling innovative tools, tracking AI investments for the department, and driving design and adoption of AI solutions that directly impact mission-critical operations.

Perform data management and governance processes for internal analytical efforts and for the Department’s enterprise requirements, supporting features include data discovery, access, usage, sharing and security. Key data management efforts include enhancing data infrastructure and pipeline reliability, modernizing and supporting data platforms, establishing and maintaining data quality and metadata standards, improving data interoperability and integration, and reducing manual data handling. Additionally, the activities support implementing robust frameworks for data management, security, and information sharing, as well as fostering a data-informed culture through communication, policy, and user empowerment.

Maintain a cross-domain technical infrastructure across multiple tech stacks including Microsoft Azure Government Cloud and Palantir and build a pioneering API-first architecture to maintain agility and flexibility in a rapidly evolving technology revolution. Key activities include maintaining and enhancing infrastructure, testing/experimenting new technologies and tools, advising on technology options for cross-domain, cloud and/or on-prem capabilities, and conducting support in compliance with information technology and cybersecurity policies.

Stand-up large technical teams as required, staffed with cleared resources possessing deep technical experience, mission knowledge, and the ability to successfully collaborate across the Department and the interagency. With the contingency nature of the Department’s mission, CfA actions may require 24/7 support, with teams on multiple work shifts supporting user requirements across the globe. Activities include ad hoc or surge and/or crisis efforts, applying deep knowledgeable of foreign affairs missions, cleared staff, and effective use of on-premise capabilities; rapid solution creation using array of software including Foundry, Azure AI, Databricks, Elastic, Python, Power Platform, Copilot Studio, R, Tableau, SQL and web-based development language.

Technical support to design and apply testing approaches for AI use cases, experiment and identify risks related to implementation of new and emerging technologies, and red teaming.

SECTION 4: AUTHORITY AND SUPPORTING RATIONALE

This acquisition is conducted under the authority of the Multiple-Award Federal Supply Schedule Program as implemented in FAR 8.401 using procedures set forth in GSAR 538.71.

According to GSAR 538.7104-3 Sole source justifications, paragraph (b) (iii): The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.

This order will promote substantial efficiencies and avert serious disruption to major in-flight programs across multiple interrelated programs, including the 30+ bureaus that CfA and TFS support.

In the face of unpredictable geopolitical events and rapid technological advancements, it is imperative that the Department retains uninterrupted access to critical support services to ensure immediate responses to global crises and compliance with urgent directives from the White House, National Security Council, and Congress. The contractor’s ongoing work is vital to sustaining mission-critical programs that underpin the Department's safety, economic prosperity, and essential infrastructure. Any disruption or transition poses a significant risk of operational failure, delays, and increased costs that cannot be recovered through competition.

The ongoing service delivery for CfA and TFS enables the Department to counter far-reaching national security threats through subject matter expertise, commercial data and tools, advanced analytics, and AI. The program requires cleared (top secret security clearance) personnel with the requisite knowledge and understanding of sanctions policies, which spans across nearly 40 programs, and their implementation, including the investigation, crafting of the necessary records, and coordination and processing of the sanctions actions. This accumulated knowledge can only come from direct sanctions implementation support to the Government. Further, the contractor is utilizing technology, advanced analytics, and AI to support sanctions by enabling the Department to more quickly and efficiently identify information about entities of interest and develop the requisite records. More broadly, the contractor is leading the way for the Department to build and deploy emerging technology applications critical to implementing the agency’s AI-first posture, as championed by the President, and enabling America’s decision advantage in global diplomacy and national security, a cornerstone of the AI Action Plan's vision for global AI dominance.

Shifting the in-flight delivery of several enterprise systems and foreign policy actions to a new contractor would cause substantial delay and mission disruption. It would require significant ramp-up time for new personnel to acquire the requisite understanding of data, systems and platform configuration, programmatic knowledge and high-level security clearances essential to deliver on the complex requirements of this BPA call. Transitioning to a new contractor at this critical juncture would bring the following challenges and risks:

Impact to National Security and Increased Mission Risk: The current services are closely integrated with multiple mission-critical initiatives—including national security and public safety operations, sanctions designation implementations, advanced analytics initiatives on a range of high priority foreign policy efforts including countering Chinese influence and securing resilient supply chains, cyber response platforms, AI infrastructure design, and enterprise AI deployments. The maintenance of enterprise platforms such as Data.State and StateChat and compliance on Executive Orders for AI and cybersecurity would be impacted if existing workstreams are disrupted. Each involves deep understanding of Department-specific systems, data, intra- and interagency stakeholders, and evolving program requirements accumulated through years of direct engagement.

Complexity of Transferring Technical Ecosystems: The ongoing efforts span complex technical environments, including data pipelines, analytics solutions, and AI-enabled tools—where knowledge of existing integrations, workflows, and custom-built solutions is essential to sustain progress and respond to urgent pipeline and maintenance needs from business users. Additionally, the Department has access to commercial tools that enable the Department to obtain critical information efficiently and effectively. With a transition, access to these tools would be disrupted, causing delays to ongoing national security-related investigations.

Delays Due to Security Clearance and Ramp-Up: Many aspects of the ongoing work require personnel with active TS/SCI clearances. The process for vetting and onboarding new, qualified personnel is lengthy, with average SCI adjudication often extending upwards of six months and in many cases taking over a year. A transition would severely delay the timely execution of current sensitive operations and further contribute to an extended transition timeline yielding inefficiencies and higher costs to the government in addition to disruptions to the mission and risking the security of the American people.

SECTION 5: DETERMINATION BY THE ORDERING ACTIVITY CONTRACTING

OFFICER THAT THE CONTRACT ACTION REPRESENTS THE BEST VALUE

CONSISTENT WITH FAR 8.305

The Contracting Officer has determined that issuing the proposed BPA Call costed extension to Deloitte Consulting LLP for support services pursuant to Section 3 and 4 above represents the best value and will result in the lowest overall cost, considering price and administrative costs, and schedule costs, to meet the Government’s needs. The Contracting Officer determines that the anticipated price(s) will be deemed fair and reasonable based on pricing proposed from Deloitte Consulting LLP during the BPA Order procurement under the DOS 19AQMM19A0280 and Call Order 19AQMM21F7091. The General Services Administration determined schedule prices to be fair and reasonable. The Contracting Officer will verify that the labor mix and number of hours proposed reflect a clear understanding of the requirements.

SECTION 6. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG

SCHEDULE HOLDERS AND THE RESULTS OR A STATEMENT OF THE REASON

MARKET RESEARCH WAS NOT CONDUCTED

Formal market research was not conducted for this action due to the nature of the requirement, the timeline of the current BPA order’s expiration, and the specialized mission-critical services involved. The Government previously competed this requirement among all awardees under the PMSS BPA via RFQ 19AQMM19Q0144, under which Deloitte Consulting LLP was selected based on a best-value determination and demonstrated subject-matter expertise in sanctions analytics and interagency evidentiary support. Labor rates were established through prior competition under the BPA and deemed fair and reasonable.

To support this justification, informal market research was performed to assess whether any other vendors could meet the Department’s highly specialized sanctions analytics requirements within the constrained performance window. This effort included a review of vendor profiles in GSA e-Library and SAM.gov, analysis of performance under related State and Treasury task orders, and an evaluation of key criteria including facility clearance levels, familiarity with CfA data environments, SME depth in the sanctions domain, and estimated time to reach full operational capability. While vendors such as Booz Allen Hamilton, Accenture (Novetta), CACI, SAIC, Leidos, and others hold active State Department IDIQs and appear technically qualified, Deloitte is the only contractor embedded within the Department’s classified sanctions analytics mission, with operational familiarity of the TFS environment, a fully cleared staff, and proprietary workflows already deployed across more than 30 Bureaus. This positions Deloitte uniquely to sustain the Department’s AI and national security initiatives without delay or disruption. Each alternative would require, at least, 4-6 months to onboard staff, secure systems access, and replicate established workflows, introducing delay and risk to ongoing operations.

Given the complexity and sensitivity of CfA’s current mission, including ongoing sanctions targeting, evidentiary development, and AI-enabled analysis, the Department determined that transitioning to a new contractor at this stage would result in a substantial duplication of costs and unacceptable delay. A recompete would also divert technical leadership bandwidth at a time when mission continuity is paramount.

In accordance with GSAR 538.7104-3 Sole source justifications, paragraph (b) (iii), which permits logical follow-ons when in the interest of economy and efficiency, the Department seeks to extend the current BPA Call. By extending the engagement with Deloitte Consulting LLP, the Department will preserve uninterrupted support for high-impact national security work while maintaining continuity of operations during the acquisition planning cycle.

This approach is consistent with the Department’s commitment to responsible acquisition strategy and ensures that future contract actions are informed by deliberate requirements analysis and market research. Deloitte’s existing personnel, tools, and institutional knowledge make them the only responsible source capable of continuing this work during this interim performance period without mission degradation or avoidable cost to the Government.

SECTION 7. 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

THE SUPPLIES OR SERVICES IS MADE

The Department will continue to examine capabilities of vendors in the future as broader requirements are clearer. The one-year extension with two, six-months option periods requested will permit Diplomatic Technology (DT), Center for Analytics (CFA), to conduct limited competition for a follow-on contract under the EVOLVE Indefinite Delivery Indefinite Quantity contract administered by DoS.

SECTIONS 8. CERTIFICATIONS

TECHNICAL AND REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

______4/17/2026__________ Date

CONTRACTING OFFICER CERTIFICATION

Based on the limited sources justification described above, I hereby certify that the justification is accurate and complete to the best of my knowledge and belief.

Date

SECTION 9. APPROVALS

e

LEGAL COUNSEL

AGENCY COMPETITION ADVOCATE

Date

HEAD OF THE CONTRACTING ACTIVITY

Date

CAI MEMORY 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