Part 6 JOFOC Public.pdf

[1] In this document, citations to RFO Part 15 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 26-08, for FAR Part 15, 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.

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

(Cite authority, e.g., 10 U.S.C. 3204(a)(7) or 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 FAR 6.104 (FAR Class Deviation 25-11), the justification for the use of the statutory authority under FAR 6.103 (FAR Class Deviation 25-11) is justified by the following facts and rationale required under FAR 6.104-1 (FAR Class Deviation 25-11) as follows:

REFERENCE: Justification Log Number: FY26-0049 and 70SBUR26Q00000016

1. Agency and Contracting Activity. U.S. Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to enter into a contract using other than full and open competition.

2. Nature and/or Description of the Action being Approved. This document is a revision to a previously approved justification after receipt of an initial and revised proposal. USCIS intends to award a firm fixed price sole source bridge contract to provide Field Operations Support Services (FOSS). The identified contractor is Sciolex Corporation, located at 4511 Singer CT, Ste 100, Chantilly, Virginia, 20151. The total award amount is estimated at

. The original justification was for a three-month period of performance. The revised justification is for a six-month period of performance from 3/23/2026 to 9/22/2026.

3. Description of Supplies/Services. The Contractor shall provide records management and administrative support to 16 of the 86 USCIS field office locations throughout the U.S. to support adjudication efforts of Immigration Service Officers in order to affect the performance of naturalization and citizenship ceremonies nationwide, the issuance of naturalization and citizenship certificates, and in-person interviews for immigration benefits

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition. Identify the most applicable statutory authority that will be used to justify other than full and open competition from the seven listed under FAR 6.103 (FAR Class Deviation 25-11).

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

3304(a)(1) implemented by the FAR Subpart 6.103-1 (FAR Class Deviation 25-11) entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Identification of Exception to the Buy American Statute N/A.

Justification & Approval for Other Than Full and Open Competition Template v3.7 (Oct 2025)

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

Sciolex Corporation is the only responsible contractor that can currently provide the services under the circumstances surrounding this procurement. If there was a lapse in service, the agency would be negatively impacted in its ability to adjudicate immigration benefits accurately and effectively. This would directly harm the mission of Field Office Directorate, the USCIS Director’s priorities and the overall mission of USCIS.

This is a sole source bridge action to maintain services so that a longer-term competitive contract can be executed through the normal acquisition process. There were several circumstances that led to the need for an interim contract, outside the control of the contracting office. The services are currently provided under 70SBUR23F00000009, which was awarded against the Program Management, Administrative, Clerical, and Technical Services II (PACTS II) strategic source contract. The PACTS II contract expired in February 2025 and performance under task orders can occur for a maximum of 1 year past the expiration of the Indefinite-Delivery/Indefinite-Quantity contract. The period of performance under 70SBUR23F00000009 already goes the maximum duration, so no further extensions are available. The initial acquisition strategy for the recompete was to use the PACTS III contract vehicle, but that contract vehicle was canceled in Fiscal Year 2025, which negatively impacted the acquisition strategy for the recompete efforts. Due to the cancellation, there is not enough time remaining to follow the normal competitive procedures to award a contract estimated at over $100 million with an estimated start date of 3/23/2026.

As a result, the only reasonable acquisition strategy under the circumstances is a sole source bridge contract allowing for enough time to follow the normal competitive procedures for the recompete.

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

Due to the circumstances in Section 6, the only practicable solution is to solicit a quotation from the incumbent contractor for the bridge contract. The proposed sole source acquisition strategy was posted to SAM.gov. No responses were received related to the proposed strategy.

In an effort to ensure adequate competition, the Contracting Officer considered issuing a solicitation on a competitive basis for the bridge contract but determined that it was unfeasible to pursue that acquisition strategy for the interim period. There are approximately 400 contractor staff working on the current contract. If a new contractor receives the award for the bridge contract, all contractor employees would need to be transitioned through the USCIS security office. The period of performance start date for bridge contract does not allow sufficient for a new contractor to complete the transition. At least half or more of the performance period would be encumbered by onboarding the number of individuals required to reach the optimal replacement staffing level.

8. 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 bridge contract award will be fair and reasonable following the techniques and procedures to analyze the contractor’s quotation. Examples include comparison of the quoted price to a sufficient price history for the same requirements adjusted for industry standard escalation, competitive published prices such as the General Services Administration (GSA) eLibrary, independent Government cost and market research estimates.

9. Description of Market Research.

Market research has demonstrated that administrative and clerical services are widely available through GSA Multiple Award Schedule (MAS) and are commercially available.

There are over 30 Service-Disabled Veteran Owned Small Businesses (SDVOSB) under GSA MAS category 561110 with established prices within the GSA contract. The competitive solicitation to replace the bridge contract will be an SDVOSB set aside through GSA MAS. There are not any other Department of Homeland Security (DHS) strategic sourcing vehicles that provide these services. The Contracting Officer has spoken to six of the SDVOSBs in category 561110 by telephone and they have stated that they are interested in competing for this solicitation and that they have a successful track record of providing staffing support contracts. Many of the contractors have experience with the DHS and Department of Defense (DOD) credentialing process. A contractor with experience in the credentialing process provides a higher level of confidence that the contractor will be able to onboard new staff efficiently

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

The contractor that received the award for the bridge contract is not guaranteed to receive the award for the five-year contract. If a new contractor received the five-year contract, then the Government would have transition a massive number of contractor employees from the incumbent to the awardee of the bridge contract, and then again to the awardee of the five-year contractor. Such a large-scale transition is completely unreasonable and carries a high risk of negatively impacting performance at the field offices. The most practical and reasonable approach allowing for continued performance of essential duties is for the bridge contract to be awarded to the incumbent to maintain services, allowing enough time for the solicitation to go through the normal competitive procedures.

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

There are over 30 SDVOSBs under GSA MAS category 561110. The Contracting Officer has spoken to 6 of the SDVOSBs and they have stated that they are interested in competing for this solicitation and that they have a successful track record of providing staffing support contracts. Many of the contractors have experience with the DHS and Department of Defense (DOD) credentialing process. The 6 companies contacted are listed below.

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

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

APPROVAL:

Procuring Activity Advocate for Competition, or Alternate

SANDIE S

KAPOOR

Digitally signed by

SANDIE S KAPOOR

Date: 2026.02.25 10:52:53 -05'00'

KAREN J

SIMONS

Digitally signed by KAREN

J SIMONS

Date: 2026.02.24 16:24:26 -05'00'

MICHAEL P

HODAHKWEN

Digitally signed by

MICHAEL P HODAHKWEN

Date: 2026.02.23 13:28:32 -08'00'