Part 8 Limited Source Justification for PAS_12 03 2024 - FINAL_Redacted.pdf

Version 2.0

LIMITED SOURCE(S)

FOR AN ORDER/BPA EXCEEDING

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 8.405-6)

Purchase Request Number: EDOFSA-25-000333

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

1. Agency and contracting activity.

Department of Education, Federal Student Aid (FSA), Acquisitions Directorate.

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

Under the General Services Administration (GSA) Multiple Award Schedule (MAS), Contract Number 47QTCA20D000E, FSA is awarding Phoenix Programming Services (PPS) InfoTech, Limited Liability Company (LLC) a firm-fixed-price task order to procure operations and maintenance services for the Person Authentication Service (PAS) system.

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

The PAS system provides an enterprise-wide solution for user identity and access management for external and internal facing applications to ensure appropriate and secure access to student aid records and protect the identity of system applicants. PAS coordinates with the Department and FSA leadership to set enterprise-wide Information Technology (IT) security policies, standards, and guidelines for managing access to FSA applications, systems, and services. PAS provides an approach promoting mutual trust and interoperability between the PAS solution and integrated FSA applications, systems, services, and customers.

Objectives:

1. Strengthen FSA applications and systems security.

2. Enable information sharing and safeguarding within FSA applications and systems.

3. Securely deliver mission critical services to FSA applications, systems, and customers.

4. Support seamlessness and efficiency in the FSA IT ecosystem.

Services Provided:

1. Authentication: Verification that an entity is who/what it claims to be.

2. Authorization: Managing authorization information an entity can access.

3. Interchange: Exchange of identity information between FSA applications, systems, and

Customers. (Technologies: Open Authorization (OAuth) Open Identity Connect (OIDC), Security Assertion Markup Language (SAML), Application Programming Interface (API), Security Tokens (JavaScript Object Notation (JSON) Web Tokens and SAML Assertions), Secure Lightweight Directory Access Protocol (LDAP)).

FOR AN ORDER/BPA EXCEEDING

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 8.405-6)

The PAS system provides mission critical authentication and logon credentials for the services and support to 100+ million students, parents, and borrowers to access public-facing FSA applications.

The PAS system supports Non-Privileged External Users (Non-ED.gov) to include Student Applicants, Parents, and Borrowers applying or will apply for Financial Aid accessing their own Title IV information.

FSA must continue services for operational and maintenance support for ongoing activities for the PAS system to provide a full range of technical and project management services for integrated FSA applications with the PAS system.

The PAS system is unified with the Access and Identity Management System (AIMS), which provides user and system validation for all system-to-system interconnections/communications, ensuring the validity of the user accessing the system. The PAS support applications are also behind the AIMS Single-Sign on (SSO) Portal that authenticates users’ access. The underlying technology and infrastructure used to run the AIMS and PAS systems are the same International Business Machines (IBM) Security and Linux operating technologies, allowing the technical support team to support either system quickly. AIMS and PAS system interconnections/communications are reliant upon each other for successful operations and services.

Uninterrupted services are critical in supporting FSA’s priority for the Federal Student Aid supported Free Application for Federal Student Aid (FAFSA) 2025/2026 for 2025/2026.

The estimated value of this new task order is $4.97 million for a 12-month period of performance covering January 1, 2025 – December 31, 2025.

4. Authority and supporting rationale. The following circumstance justifies limiting the source as supported below:

Only one source under the authority of FAR 8.405-6(a)(1)(i)(B)

Currently, only one source, PPS InfoTech, LLC, can continue the current services and support without causing disruption to FSA’s PAS System. A lapse in services and support would cause an immediate disruption to all mandatory business operations across FSA systems.

In May of 2024, The Secretary of The Department of Education, mandated that the primary focus for FSA is to have a successful FAFSA 2025/2026. As a result, FSA shifted internal resources away from the PAS recompete (including Operations and Maintenance (OM), Systems Modernization and ID Proofing) to focus elsewhere.

Although the Identity and Access Management (IAM) team was given direction to prioritize the automation of the ID verification, FSA’s Technology Office was already supporting numerous high priority tasks straining the same resources. As a result, FSA concluded that executing the recompete action before the December 31, 2024, expiration of the current PAS task order was not feasible. Unless a limited source justification was approved allowing PPS InfoTech to

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 8.405-6)

continue performing, A gap in critical services would occur affecting all FSA systems and applications they support.

PPS InfoTech has in-depth and critical institutional knowledge and skills, specifically within FSA supporting the PAS system, which provides an enterprise-wide solution for user identity and access management for 100+ million external users accessing public facing FSA applications.

This ensures appropriate and secure access.

Executing this bridge task order with the current contractor avoids disruption to current efforts and maximizes the success rate of key FSA initiatives to be released into production.

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

Since (a) GSA has already determined the prices of the supplies and services under FSS contracts, including rates for services offered at fixed hourly rates to be fair and reasonable; and (b) by placing an order against a schedule contract using the procedures in FAR 8.405, the ordering activity Contracting Officer (CO) has concluded that the order represents the best value (see FAR 2.101) and results in the lowest overall cost alternative as follows:

The CO has determined that the expected outcome of this acquisition provides the greatest overall benefit in response to the requirement and therefore the best value to the Government consistent with FAR 8.404(d), based on all factors considered within this justification.

Further, the CO will determine that the prices are reasonable for this effort to ensure that discounts are solicited, while a reasonable level of effort and labor mix are evaluated under these procedures.

This approach provides the greatest overall benefit in response to the requirement and results in the lowest overall cost alternative, namely in the form of time, cost, risk, and opportunity.

6. Market research was conducted among schedule holders (or reason market research was not conducted).

Market research was started in September of 2024 and was conducted by engaging in numerous discussions with technical and subject matter experts to determine if other vendors had the capability to provide the same services for identity and access management for operations and maintenance, modernization and migration, and user verification processes to the scale required to support the scope of PAS services. FSA also surveyed various GSA sources and determined that these services are available under other GSA contract vehicles. However, the market research confirmed that PPS InfoTech, LLC is the only source capable of providing continued services under the entire scope of these highly specialized services within the time constraints, and thereby ensure mission-critical quality levels are achieved.

7. Any other facts supporting the justification.

N/A

LIMITED SOURCE($)

FOR AN ORDER/SPA EXCEEDING

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 8.405-6)

8. 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.

FSA is currently engaged in acquisition planning (AP) for the recompetition of these services during Fiscal Year 2025. It is anticipated that these activities will lead to a new task order award by first the quarter of Fiscal Year 2026. As such, industry will be provided a fair opportunity to compete for award of the services from the resulting future procurement.

9. Technical/Requirements Representative Certification.

I certify that this requirement constitutes the Government's minimum needs and the supporting data provided herein is accurate and complete to the best of my knowledge and belief.

Amy Yamashiro Date

Enterprise Technology Directorate Identity and Access Management (1AM) Division Contracting Officer Representative

10. Approving Official Determination of Circumstance Applicability.

In accordance with the requirement at FAR 8.405-6(c)(2)(xi), the undersigned approving official for this justification hereby determines the circumstance cited above at #4, Authority and supporting rationale, applies to this acquisition.

11. Contracting Officer's Certification and Approval

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

Emmanuel Wilson Contracting Officer

Date

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 8.405-6)

12. Approval for Justifications.

Approve:

Betty Hoapili Date FSA Advocate for Competition