JA Limited-Sources GDIS 03.13.2025 CA Signed.pdf

Template for a Federal Supply Schedule (FSS) Limited-Sources Justification

Completion Instructions: HHS has established a standard template for the preparation of a Limited-Sources Justification (LSJ) pursuant to FAR Subpart 8.4. This template is for use with orders issued under the Federal Supply Schedule (FSS) program where the value exceeds simplified acquisition threshold and competition is restricted: (1) to fewer schedule contractors than required in FAR 8.405-1, 8.405-2, or 8.405-3, or (2) to an item peculiar to one manufacturer. See FAR Subpart 8.4 for additional guidance. This template is not for use with acquisitions other than those under FAR Subpart 8.4.

Tailor all aspects of this template to the individual acquisition. Consult FAR 8.405-6 for guidance. An addendum may be added in case additional space is needed.

When this document is printed, the blue italic instructions are automatically deleted on the printed version.

FEDERAL SUPPLY SCHEDULE

LIMITED-SOURCES JUSTIFICATION

Acquisition Title: OHS General Digital Infrastructure Services (GDIS)

Agency: PSC

PSC Divisions: Other - HHS

PSC Other Divisions: Administration for Children and Families (ACF)

Acquisition Year (FY): 25

Author: Brandon Atchison

2. Description of Action:

Nature: New Requirement Follow-on Requirement

Modification to Existing Purchase Order/Contract Number:

Pricing: Firm-Fixed Price Time & Materials Cost

Other:

Funds: OMA Other Funds:

<For each proposed contractor if more than one (e.g., brand name):>

Name of Proposed Contractor(s): Trussworks, Inc.

Street Address: FOUR EMBARCADERO CENTER STE 1400

City, State, Zip: SAN FRANCISCO, CA 94111-4164

Remove ContractorAdd Contractor

3. Description of Supplies and Services to Include Contract Vehicle/Number Utilized:

The Office of Head Start (OHS) with the Administration for Children and Families (ACF) is seeking to leverage technological efficiencies and decrease the Agency's disparate IT footprint for improved DevSecOps and security protocols.

The logical follow-on will provide continued hosting, management and configuration services and modernization of OHS' critical digital services infrastructure which includes five (5) systems and reaches 3 million annually.

The estimated value of the proposed action, including all options, is $ 10,134,864.00

Briefly describe the supplies or services to be provided, including make & model number where appropriate. Indicate whether the item to be procured is peculiar to one manufacturer (e.g., a particular brand name, product, or a feature of a product, peculiar to one manufacturer). If applicable, include quantities of supplies or period of performance for services.

Provide information for any options included in the order. If the action is a modification to an existing order, distinguish clearly between the work covered by the basic order and the work to be obtained by the proposed modification.

4. Authority:

ORDER AGAINST FSS: Authority of the Multiple Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501, Services for Executive Agencies; and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6. Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405-6(c)(2)(iv).

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

Only one source is capable of providing the supplies or services required at the level or quality required because the supplies or services are unique or highly specialized (FAR 8.405-6(a)(1)(i)(B));

In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited sources procedures (FAR 8.405-6(a)(1)(i)(C)); or

Initially, the Office of Head Start planned to solicit the recompete for digital infrastructure services as a competitive award via the General Services Administration (GSA) Multiple Award Schedule (MAS). GCS and OHS conducted comprehensive market research and developed an initial acquisition strategy to compete on the GSA MAS where many qualified vendors were available. Following the previously approved strategy, an Request for Quote (RFQ) was issued on GSA eBuy on January 7, 2025, and closed on January 14, 2025. The RFQ included two phases and received quotes for the first phase. The Office of Head Start (OHS) technical evaluation team were in the process of evaluating the Phase 1 submissions as part of an advisory down-select process. At this stage, the initial acquisition strategy remained viable, and the Agency proceeded with a competitive procurement.

Once the new administration transitioned into office a policy shift was implemented increasing emphasis on modernizing government operations and enhancing efficiency. In line with this initiative, a determination was made that it was in the best interest of the government for OHS to transition its digital infrastructure to ACF's existing infrastructure. OHS subsequently conducted additional market research to determine the timeline for this migration, concluding that a three-year transition period was necessary. This directive rendered the initial acquisition strategy impractical, necessitating a revised approach to ensure alignment with the current strategic priorities.

Operationalizing this strategic shift while ensuring continuity of service requires a revised strategy which is determined to be a logical follow-on award to the current vendor Trussworks, Inc. (Truss) under GSA MAS 541541S. This three-year task order will consolidate Head Start public digital infrastructure services to the ACF digital infrastructure, ensuring uninterrupted service, cybersecurity compliance, and support for essential programs until migration is complete. This infrastructure currently supports the HeadStart.gov website, Individualized Professional Development Portfolio, Coaching Companion, and Head Start mobile applications. This task order must be awarded by March 22, 2025, to prevent a lapse in service that would severely impact OHS operations and the Head Start community. Truss is the only vendor with the established technical capabilities and institutional knowledge to effectively support this transition without operational disruptions, making them the only viable source to fulfill the program's immediate and long term objectives.

A lapse in service would hinder OHS's ability to provide critical policies, training resources, and program information to the Head Start and Early Head Start communities; support the professional development of Head Start grantee staff;

and increase public awareness of the Head Start program, targeting parents, prospective staff, and organizations serving low-income families.

Truss is uniquely positioned to provide the transition requirement without unacceptable schedule and technical risks due to their extensive experience, deep institutional knowledge, and ability to meet OHS' immediate and long-term needs without disruption. Under the current task order (expiring March 21, 2025), Truss has gained in-depth expertise in managing and maintaining the Head Start digital ecosystem, including HeadStart.gov and its associated applications.

Their performance has encompassed specialized services such as cloud infrastructure management, DevOps deployment, shared services management, and operational support for OHS product teams. Their established knowledge base will ensure a seamless transition to ACF's infrastructure while mitigating risks of downtime, data integrity issues, and service delays. This logical follow-on task order is essential to consolidate Head Start public digital infrastructure services to the ACF digital infrastructure, ensuring uninterrupted service, cybersecurity compliance, and support for essential programs until migration is complete while aligning with the changing priorities and directives of the program.

Trussworks is a certified 8(a) vendor listed on GSA MAS until January 31, 2029. Awarding this three-year logical follow-on task order to Truss aligns with the strategic priorities of modernizing government operations and enhancing efficiency. This bridge facilitates OHS’s migration to ACF Tech's digital infrastructure, NGSC, aligning with the Administration’s goal of advancing technological capabilities, improving service delivery, and ensuring a seamless transition to a more efficient and effective system.

An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. (FAR 8.405-6(b)).

When competition is limited to items peculiar to one manufacturer, this justification must explain why the particular brand name, product, or feature is essential to the Government's requirements, and that market research indicates other companies' similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency's needs in accordance with FAR 11.105.

5. Market Research:

Describe the extent of the market research conducted among the schedule holders and the results, or a statement of the reason that market research was not conducted. Brand name specifications shall not be used unless the particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s need.

Market research was conducted to identify potential vendors capable of meeting the immediate need for digital infrastructure services during the period between the expiration of the current task order, March 21, 2025, and the award of the competitive task order (intial procurement strategy). Research included a review of available vendors on GSA Advantage, as well as a review of contractors holding relevant GSA MAS 8(a) schedule contracts.

While several companies possess general capabilities in digital infrastructure management, it was determined that no other vendor could effectively and efficiently provide the services required given the updated acquisition strategy to align with strategic priorities necessitating this logical follow on task order. Truss, as the incumbent contractor, has established extensive institutional knowledge and technical expertise critical to the uninterrupted operation of the Head Start digital ecosystem. There would be increased risks to a delay and/or lapse in service to the community served by OHS along with the technical capabilities and additional cost to transition to another vendor. A new vendor would require a learning curve to learn the system, maintain the recently modernized environment and then migrate to the Government's existing infrastructure. This would be a duplication of efforts. Therefore the option of awarding a competitive order with a new contractor would not align with the cost efficiency initiatives.

Bringing in a new vendor for a task order that must be awarded no later than March 22, 2025 would be inefficient and impractical. The onboarding and knowledge transfer process would significantly exceed the time available, introducing unacceptable delays and risks to the continuity of essential services.

As a result, Truss is the only acceptable vendor capable of fulfilling the Government's requirements for this logical follow-on task order without compromising service quality or operational continuity. This determination is based on both the specialized nature of the services and the immediate timeframe of performance.

6. Actions to Increase Competition:

Describe the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration prior to any subsequent acquisition for the supplies or services is made. If no such actions have been taken, explain why.

The agency attempted to overcome competition barriers by soliciting competitively on the GSA MAS amongst 8(a) vendors;

however, the Agency has determined strategic priority alignment represents the most efficient path forward. Therefore, the focus of this effort has shifted to facilitate OHS' migration to ACF Tech’s digital infrastructure, NGSC. It is anticipated that a subsequent award after migration activities will be competitive for the ACF Tech digital infrastructure.

7. Any other facts supporting the justification:

N/A

8. Technical / Requirements Certification: By my signature below, I certify that the supporting data under my review which is included in this Limited-Sources Justification is accurate and complete.

Program Manager

Name: Alana Buroff

Position Title: Supervisory Public Affairs Specialist

Email address: alana.buroff@acf.hhs.gov

Phone: (202) 205-7873

Program Manager Supervisor (or one level above Program Manager)

Name: Shawna Pinckney

Position Title: OHS Associate Deputy Director

Email address: Shawna.Pinckney@ACF.hhs.gov

Signature:

Date: Mar 4, 2025

9. Best Value Determination: By my signature below, after review of the relevant documents, I have determined that the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d), and constitutes a fair and reasonable price. The basis for my determination is as follows:

Describe in detail the basis for the determination that this order provides the best value, and that the price is fair and reasonable. Attach and/or summarize applicable market research, commercial prices lists, comparable GSA schedule pricing or other markers that were used in this determination.

The Contracting Officer will determine that the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d), and constitutes a fair and reasonable price. The Contracting Officer will compare Truss Works' proposed pricing to at least three other GSA Schedule 8(a) vendors and the Independent Government Cost Estimate (IGCE) to determine it is fair and reasonable. The analysis will include labor categories, hourly rates, and total costs in alignment with task requirements.

10. Contracting Officer's Approval (Required for proposed contract not to exceed $700,000 (value calculated including all options)): I hereby certify that this justification is accurate and complete to the best of my knowledge. I approve this justification subject to the availability of funds, and provided that the services and supplies herein described have otherwise been approved for acquisition.

Name: Brandon Atchison Phone: 202-897-6678

Signature: Date: 03/4/2025

11. Legal Review:

All J&As greater than $68 million must have a legal review from the General Law Division of the Office of the General Counsel prior to sending it to the Department.

12. OPDIV Competition Advocate Approval (Required for proposed contract over $700,000 but not exceeding $13.5 million (value calculated including all options)):

I have reviewed this justification and find that it adequately supports limiting sources.

Name: Evelyn S. Tyndell Phone: 202-604-8234

Signature: Date: Mar 14, 2025

13. Office of Small and Disadvantaged Business Utilization:

I have reviewed this justification and find that it adequately supports limiting sources.

Name: Christine Haber Phone: 202-853-1616

Signature: Date: March 19, 2025

14. OPDIV HCA Approval (Required for proposed contract over $13.5 million but not exceeding $68 million (value calculated including all options)):

Name: Phone:

Signature: Date:

15. Department Competition Advocate:

Concur: Non-Concur:

Name: Phone:

Signature: Date:

(The below approval paragraph is required if the cumulative contract value, including all options, exceeds $68 million.)

16. HHS Senior Procurement Executive (SPE) Approval:

Based on the foregoing justification, I hereby approve limiting sources for the above stated procurement, subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

State supplies/services being procured:

The Office of Head Start (OHS) with the Administration for Children and Families (ACF) is seeking to leverage technological efficiencies and decrease the Agency's disparate IT footprint for improved DevSecOps and security protocols.

The logical follow-on will provide continued hosting, management and configuration services and modernization of OHS' critical digital services infrastructure which includes five (5) systems and reaches 3 million annually.

State the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304:

Name: Phone:

Signature: Date:

Template for a Federal Supply Schedule (FSS) Limited-Sources Justification

Completion Instructions: HHS has established a standard template for the preparation of a Limited-Sources Justification (LSJ) pursuant to FAR Subpart 8.4. This template is for use with orders issued under the Federal Supply Schedule (FSS) program where the value exceeds simplified acquisition threshold and competition is restricted: (1) to fewer schedule contractors than required in FAR 8.405-1, 8.405-2, or 8.405-3, or (2) to an item peculiar to one manufacturer. See FAR Subpart 8.4 for additional guidance. This template is not for use with acquisitions other than those under FAR Subpart 8.4.

Tailor all aspects of this template to the individual acquisition. Consult FAR 8.405-6 for guidance. An addendum may be added in case additional space is needed.

When this document is printed, the blue italic instructions are automatically deleted on the printed version.

FEDERAL SUPPLY SCHEDULE

LIMITED-SOURCES JUSTIFICATION

2. Description of Action:

Nature:

Pricing:

Funds:

<For each proposed contractor if more than one (e.g., brand name):>

3. Description of Supplies and Services to Include Contract Vehicle/Number Utilized:

Briefly describe the supplies or services to be provided, including make & model number where appropriate. Indicate whether the item to be procured is peculiar to one manufacturer (e.g., a particular brand name, product, or a feature of a product, peculiar to one manufacturer). If applicable, include quantities of supplies or period of performance for services. Provide information for any options included in the order. If the action is a modification to an existing order, distinguish clearly between the work covered by the basic order and the work to be obtained by the proposed modification.

4. Authority:

When competition is limited to items peculiar to one manufacturer, this justification must explain why the particular brand name, product, or feature is essential to the Government's requirements, and that market research indicates other companies' similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency's needs in accordance with FAR 11.105.

5. Market Research:

Describe the extent of the market research conducted among the schedule holders and the results, or a statement of the reason that market research was not conducted. Brand name specifications shall not be used unless the particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s need.

6. Actions to Increase Competition:

Describe the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration prior to any subsequent acquisition for the supplies or services is made. If no such actions have been taken, explain why.

7. Any other facts supporting the justification:

8. Technical / Requirements Certification: By my signature below, I certify that the supporting data under my review which is included in this Limited-Sources Justification is accurate and complete.

Program Manager Name:

Position Title:

Email address:

Phone:

Program Manager Supervisor (or one level above Program Manager) Name:

Position Title:

Email address:

Signature:

Date:

9. Best Value Determination: By my signature below, after review of the relevant documents, I have determined that the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d), and constitutes a fair and reasonable price. The basis for my determination is as follows:

Describe in detail the basis for the determination that this order provides the best value, and that the price is fair and reasonable. Attach and/or summarize applicable market research, commercial prices lists, comparable GSA schedule pricing or other markers that were used in this determination.

10. Contracting Officer's Approval (Required for proposed contract not to exceed $700,000 (value calculated including all options)): I hereby certify that this justification is accurate and complete to the best of my knowledge. I approve this justification subject to the availability of funds, and provided that the services and supplies herein described have otherwise been approved for acquisition.

Name:

Phone:

Signature:

Date:

11. Legal Review:

All J&As greater than $68 million must have a legal review from the General Law Division of the Office of the General Counsel prior to sending it to the Department.

12. OPDIV Competition Advocate Approval (Required for proposed contract over $700,000 but not exceeding $13.5 million (value calculated including all options)):

I have reviewed this justification and find that it adequately supports limiting sources.

Name:

Phone:

Signature:

Date:

13. Office of Small and Disadvantaged Business Utilization:

I have reviewed this justification and find that it adequately supports limiting sources.

Name:

Phone:

Signature:

Date:

14. OPDIV HCA Approval (Required for proposed contract over $13.5 million but not exceeding $68 million (value calculated including all options)):

Name:

Phone:

Signature:

Date:

15. Department Competition Advocate:

Concur:

Non-Concur:

Name:

Phone:

Signature:

Date:

(The below approval paragraph is required if the cumulative contract value, including all options, exceeds $68 million.)

16. HHS Senior Procurement Executive (SPE) Approval:

Based on the foregoing justification, I hereby approve limiting sources for the above stated procurement, subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

State supplies/services being procured:

State the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304:

State the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304 Name:

Phone:

Signature:

Date:

11.0.0.20130303.1.892433.887364 Justification & Approval - Federal Supply Schedule Health and Human Services Justification & Approval - Federal Supply Schedule

The logical follow-on will provide continued hosting, management and configuration services and modernization of OHS' critical digital services infrastructure which includes five (5) systems and reaches 3 million annually.

State the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 3304: Initially, the Office of Head Start planned to solicit the recompete for digital infrastructure services as a competitive award via the General Services Administration (GSA) Multiple Award Schedule (MAS). GCS and OHS conducted comprehensive market research and developed an initial acquisition strategy to compete on the GSA MAS where many qualified vendors were available. Following the previously approved strategy, an Request for Quote (RFQ) was issued on GSA eBuy on January 7, 2025, and closed on January 14, 2025. The RFQ included two phases and received quotes for the first phase. The Office of Head Start (OHS) technical evaluation team were in the process of evaluating the Phase 1 submissions as part of an advisory down-select process. At this stage, the initial acquisition strategy remained viable, and the Agency proceeded with a competitive procurement.

Once the new administration transitioned into office a policy shift was implemented increasing emphasis on modernizing government operations and enhancing efficiency. In line with this initiative, a determination was made that it was in the best interest of the government for OHS to transition its digital infrastructure to ACF's existing infrastructure. OHS subsequently conducted additional market research to determine the timeline for this migration, concluding that a three-year transition period was necessary. This directive rendered the initial acquisition strategy impractical, necessitating a revised approach to ensure alignment with the current strategic priorities.

Operationalizing this strategic shift while ensuring continuity of service requires a revised strategy which is determined to be a logical follow-on award to the current vendor Trussworks, Inc. (Truss) under GSA MAS 541541S. This three-year task order will consolidate Head Start public digital infrastructure services to the ACF digital infrastructure, ensuring uninterrupted service, cybersecurity compliance, and support for essential programs until migration is complete. This infrastructure currently supports the HeadStart.gov website, Individualized Professional Development Portfolio, Coaching Companion, and Head Start mobile applications. This task order must be awarded by March 22, 2025, to prevent a lapse in service that would severely impact OHS operations and the Head Start community. Truss is the only vendor with the established technical capabilities and institutional knowledge to effectively support this transition without operational disruptions, making them the only viable source to fulfill the program's immediate and long term objectives. A lapse in service would hinder OHS's ability to provide critical policies, training resources, and program information to the Head Start and Early Head Start communities; support the professional development of Head Start grantee staff; and increase public awareness of the Head Start program, targeting parents, prospective staff, and organizations serving low-income families.

Truss is uniquely positioned to provide the transition requirement without unacceptable schedule and technical risks due to their extensive experience, deep institutional knowledge, and ability to meet OHS' immediate and long-term needs without disruption. Under the current task order (expiring March 21, 2025), Truss has gained in-depth expertise in managing and maintaining the Head Start digital ecosystem, including HeadStart.gov and its associated applications. Their performance has encompassed specialized services such as cloud infrastructure management, DevOps deployment, shared services management, and operational support for OHS product teams. Their established knowledge base will ensure a seamless transition to ACF's infrastructure while mitigating risks of downtime, data integrity issues, and service delays. This logical follow-on task order is essential to consolidate Head Start public digital infrastructure services to the ACF digital infrastructure, ensuring uninterrupted service, cybersecurity compliance, and support for essential programs until migration is complete while aligning with the changing priorities and directives of the program.

Trussworks is a certified 8(a) vendor listed on GSA MAS until January 31, 2029. Awarding this three-year logical follow-on task order to Truss aligns with the strategic priorities of modernizing government operations and enhancing efficiency. This bridge facilitates OHS’s migration to ACF Tech's digital infrastructure, NGSC, aligning with the Administration’s goal of advancing technological capabilities, improving service delivery, and ensuring a seamless transition to a more efficient and effective system.

While several companies possess general capabilities in digital infrastructure management, it was determined that no other vendor could effectively and efficiently provide the services required given the updated acquisition strategy to align with strategic priorities necessitating this logical follow on task order. Truss, as the incumbent contractor, has established extensive institutional knowledge and technical expertise critical to the uninterrupted operation of the Head Start digital ecosystem. There would be increased risks to a delay and/or lapse in service to the community served by OHS along with the technical capabilities and additional cost to transition to another vendor. A new vendor would require a learning curve to learn the system, maintain the recently modernized environment and then migrate to the Government's existing infrastructure. This would be a duplication of efforts. Therefore the option of awarding a competitive order with a new contractor would not align with the cost efficiency initiatives.

Bringing in a new vendor for a task order that must be awarded no later than March 22, 2025 would be inefficient and impractical. The onboarding and knowledge transfer process would significantly exceed the time available, introducing unacceptable delays and risks to the continuity of essential services.

As a result, Truss is the only acceptable vendor capable of fulfilling the Government's requirements for this logical follow-on task order without compromising service quality or operational continuity. This determination is based on both the specialized nature of the services and the immediate timeframe of performance.

The logical follow-on will provide continued hosting, management and configuration services and modernization of OHS' critical digital services infrastructure which includes five (5) systems and reaches 3 million annually.