Outbound Mail Ops Sole Source JA Redacted.pdf

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

(41 U.S.C. 3304(a)(7))

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103, FAR Class Deviation 25-11 and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:1

1) Agency and Contracting Activity.

The Federal Emergency Management Agency (FEMA), Office of the Chief Procurement Officer, proposes to enter into a purchase order contract on a basis other than full and open competition.

2) Nature and/or Description of the Action being Approved.

FEMA has a requirement to provide outbound mail services for disaster survivors. Outbound mail operations include printing, inserting, applying postage, and pre-sorting correspondence addressed to disaster victims. Due to current disaster activity, the Agency is currently on a path to exceed existing outbound mail baseline requirements by mid-May 2026. There is no existing contract vehicle to award new surge task orders for outbound mail operations, and due to new disaster surge activities (specifically related to DR4898-TN and DR4899-MS), an urgent and compelling need has arisen to provide immediate outbound mail surge support for these disasters. This requested purchase order award falls under FAR 6.302-2 unusual and compelling urgency, and is the only method of fulfilling the Government’s need without serious injury to the Government (see paragraph (b) of section 6.302-2).

(a) Nature of action: FEMA intends to procure outbound mail surge services on a sole source basis with a purchase order

(b) Name and address of contractor: Allison Payment Systems / Doxim, LLC; 2200 Production Dr., Indianapolis, IN 46241

(c) Contract type: Firm Fixed Price

(d) Estimated total value: (one year period of performance from date of award)

Period Unit Price Total

Base Year 12 mo. $225,000 $225,000 Total $225,000

1 In this document, citations to RFO Part 5, RFO Part 6, RFO Part 8, RFO Part 10, RFO Part 15, RFO Part 25, and HSAR Part 3006 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-17 for FAR Part 5, FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-20 for FAR Part 8, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08, Revision 1, for FAR Part 15, FAR Class Deviation 26-09, Revision 1, for FAR Part 25, and Homeland Security Acquisition Regulation (HSAR) Class Deviation 25-01 for HSAR Part 3006, which were issued as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

Control # 26-083

Note: The outbound mail services were previously awarded to Allison Payment Systems / Doxim, LLC under a competitively awarded Indefinite Delivery/Indefinite Quantity (IDIQ) contract in March 2021. This IDIQ contract expired in April 2026 without a new IDIQ contract in place yet, therefore surge task orders can no longer be awarded until a new IDIQ is in place. A new IDIQ is planned and in process but will not be in place until December 2026 or later due to approval delays at no fault of the Program or Contracting Offices.

(e) Type of funding: Fund Code 6 funds approved and certified by disasters.

(f) Year of funding: Disaster funds are no-year funds; however the funds were certified in

FY26.

(g) Solicitation number: TBD

(h) Background information about the requirement.

The Federal Emergency Management Agency (FEMA), a component of the U.S.

Department of Homeland Security, is authorized pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act, as amended (42 U.S.C. Chapter 68), to assist individuals and households following Presidentially-declared disasters and emergencies. In cooperation with state governments, FEMA provides grant assistance to disaster victims in accordance with the Act. These programs receive extensive visibility from the highest levels of federal, state, and local governments and are continually reported on in the public media.

Disaster declarations and resulting assistance applications create a need to process large quantities of outbound applicant correspondence in a short timeframe. Privacy, accuracy, and timely delivery of services are required to ensure the needs of the disaster applicant are met through the most expedient means possible.

FEMA has determined the most efficient way to manage an outbound mail operation is through contractor support. FEMA does not have the internal capability (equipment, personnel, space, etc.) to provide the necessary outbound mail services.

3) Description of Supplies/Services.

The requirement is to provide surge outbound mail operations including printing, inserting, applying postage, and pre-sorting outbound correspondence addressed to disaster victims.

Mailings will include correspondence to applicants using FEMA-provided envelopes which will contain both sensitive personally identifiable information (PII) and public information.

The contractor shall provide all management, personnel, services, supplies, equipment (except for Government Furnished Equipment), and facilities necessary to operate an outbound mail processing operation in accordance with the requirements of the Statement of Work (SOW).

4) Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 41 U.S.C.

3304(a)(1) implemented by the RFO Subpart 6.103-2 entitled “Unusual and compelling urgency.”

5) Identification of Exception to the Buy American Statute.

N/A.

6) Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited. The previous outbound mail operations IDIQ contract was competitively awarded in Mar 2021 to Allison Payment Systems / Doxim, LLC and was structured to provide annual baseline task orders which would service a monthly volume of up to 500,000 outbound mail images printed per month. During the event of high disaster surge activity, monthly volume would exceed this monthly baseline amount and would require the award of surge task orders which would have their own surge CLINs and would cover additional work beyond the baseline amounts. The final outbound mail baseline task order was awarded on Apr 28, 2026 with a period of performance through Nov 30, 2026, and the IDIQ contract expired on Apr 30, 2026.

Beginning in May 2024, the Contracting Officer Representative (COR) team and the Program Office began a series of planning meetings to prepare for an IDIQ re-compete. Requirements were identified and validated, lessons learned were discussed, and an acquisition timeline was created. Subsequently, acquisition documents were created and routed for approval, and funding was budgeted. In May 2025, the Department of Homeland Security (DHS), Secretary (S1) memo process for procurements over $100K was active, and concurrent to building the IDIQ acquisition package, the COR team routed the necessary S1 memo for approval. After several months of requested revisions, the outbound S1 memo came back as disapproved, however no other solution was offered for meeting this statutorily-mandated requirement.

Because of the necessity of the requirement and the fact that FEMA would not be able to perform this requirement internally due to lack of equipment, personnel, and space, another S1 memo was created in January 2026 to try to extend the current outbound services while the COR team and Program Office devised some way of meeting the requirement. This later S1 memo identified and addressed the issues associated with the initially rejected S1 memo. This second S1 memo was routed to the DHS Secretary, but was neither approved nor disapproved; during the duration of the second DHS shutdown, which finally ended in April 2026. A final baseline task order was awarded on April 28, 2026 with a Period of Performance (PoP) through November 30, 2026. However, no surge task order was in place at the end of the IDIQ PoP on April 30, 2026.

A revised fully automated S1 memo process was enacted in April 2026, the outbound mail re-compete IDIQ is back on and moving forward again. However, there is still a large backlog of memos that still need to be reviewed and approved or rejected. Once approved that IDIQ procurement will require a full acquisition and source selection process, and the earliest it is projected to be in place is December 1, 2026 under the best case scenario. Unfortunately, FEMA has now had several disaster declarations, and as of May 2026, we are on track to exceed our monthly outbound baseline mail cap of 500,000 images. This would mean that since we do not have a surge task order in place, once we reach the monthly baseline cap, no additional work could be performed until the following month. This would create an unacceptable gap in coverage and would prevent FEMA from proper registration, communication, and case processing for disaster survivors. It would also leave FEMA unacceptably unprepared for the upcoming hurricane season which begins June 1, 2026— historically the highest volume time of the year. Since the re-compete IDIQ will not be in place for 7-12 months, we must have some way of servicing the surge requirement, both now and through the remainder of the hurricane season. Therefore we are requesting a period of performance beyond 150 days on this purchase order (see HSAR 3006.103-2(c)(70) (HSAR Class Deviation 25-01)) in order to meet this requirement.

Based on current outbound mail volume, we anticipate the monthly baseline amount for May 2026 will be exhausted by approximately May 18, 2026 which leaves us with no viable way to complete the IDIQ re-compete in time, nor do we have a current IDIQ to award a task order from, and we also do not have time to do a competitive purchase order. Therefore, the only viable option to meet the current surge requirement is to award a purchase order through other than full and open competition to the current outbound mail operations contractor, Allison Payment Systems / Doxim, LLC. The contractor is already performing baseline services and they will require no new security clearances, no ramp-up time, and no time for shipment of GFE (laptops, envelopes, etc). Subsequently, they will be able to begin surge work immediately upon receipt of award. This is the only solution which will allow FEMA to continue operations without an unacceptable gap in service which would prevent disaster survivors from receiving the assistance to which they are due and greatly in need of for their recovery.

7) Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

The contracting officer is planning to post an announcement in SAM.gov, within two weeks of purchase order award, so the estimated date of publication is May 25, 2026.

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

The contracting officer determines that the anticipated price will be fair and reasonable based on the fact that this purchase order will use the pre-negotiated Option Year 4 surge CLIN rates from the previous IDIQ awarded in 2021. These rates were already determined to be fair and reasonable prior to exercising each option period, including option period 4, and market research has shown these rates to be the least expensive and best value rates available at this time for the required services.

9) Description of Market Research.

a) Thorough Market Research was performed from April 25, 2026 through May 8, 2026 by reviewing the following web pages:

i) DHS and FEMA strategic sourcing contracts:

https://usfema.sharepoint.com/teams/FEMAET/ocpo_tools/fssp/SitePages/FEMA%2 0Strategic%20Sourcing%20Program.aspx

ii) Interagency Contract Directory, https://www.contractdirectory.gov/contractdirectory.

Because of an absence of information, the researchers determined that this requirement could not be satisfied by entering into an InterAgency Agreement.

iii) General Services Administration, Buyers Guidance and Resources | GSA:

https://www.gsa.gov/buy-through-us/products-and-services/professional-services/buy-services/oasis-and-oasis-small-business/buyers-guidance-and-resources

iv) After reviewing several contract vehicles such as FSSI Domestic Delivery Services Blanket Purchase Agreement (BPA), FSSI Office Supply BPA II, and the FSSI Print Management BPA, the researchers found that the requirement is not within scope of a strategic sourcing contract vehicle.

v) Based on the length of time to procure as well as the length of the security clearance process, this requirement could not be met through a GSA contract such as OASIS.

vi) Based on the Market Research techniques, sources, and findings, there are a variety of products/services, and sources available from GSA that could provide some of the required services, however, not all products/services were available from the same vendor. In addition none of the vendors could sufficiently meet the timeline associated with the current requirement.

vii) Due to the extreme urgency of this surge requirement which would not allow for a lengthy acquisition process and contractor ramp up, as well as the better pricing that is available under the existing rates from the previous IDIQ compared to other sources, and also the fact that other potential sources do not offer all the needed services, the recommendation is to proceed with awarding a purchase order for this surge requirement.

b) Describe the market research results that support the determination that the items are nonavailable (Section is required to be completed when the J&A includes the exception listed under RFO 25.103(b)(2) or RFO 25.202(a)(2)).

N/A; items are available.

c) If market research was not conducted, a reason for its absence must be cited here.

N/A; market research was conducted.

d) If patents, copyrights, and/or intellectual property are applicable to the acquisition, describe the circumstances for acquiring a patented or copyrighted product on the representation of the intellectual property holder that has not been licensed for resale.

10) Any Other Facts Supporting the Use of Other Than Full and Open Competition.

11) A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

N/A.

12) A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

FEMA is conducting a re-compete of the outbound mail IDIQ which will be subject to full and open competition. Awarding a sole source purchase order will allow the Agency time to conduct the full acquisition process and ensure that the maximum amount of competition can offer proposals for the follow-on IDIQ as soon as practicable. Time was lost to a S1 approval process, which has continually changed since its implementation. Now the process has been fully automated, reviews are coming more regularly. However, there is still a large backlog of memo reviews that still need to take place and it is impossible to tell where in the queue our current S1 memo is.

13) Contracting Officer’s Certification. I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Contracting Officer Date

14) Technical/Requirements Personnel Certification. I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Technical Representative Date

Contracting Officer Date