PASS JA_Redacted.pdf

Professional Accounting Services Support for Financial Services Center PR #: 51800PR260000126

Last Updated 07/23/26 1

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

10 U.S.C. § 3205

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by Revolutionary FAR Overhaul (RFO 16.507-6(b)(3) (FAR Class Deviation 26-04 Rev. 11), this justification for an exception to fair opportunity is supported as follows:

1. Agency and Contracting Activity.

Department of Homeland Security, United States Coast Guard (USCG), Headquarters COCO Office 13.

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

(a) Nature of the action: USCG intends to procure on a sole source basis Professional

Accounting Support Services (PASS) for USCG Financial Services Center (FSC).

(b) Name and address of the contractor:

Information Technology Coalition, Inc, Doing Business As (DBA): ITC Federal 4114 Legato Rd, Ste 850, Fairfax, VA 22033

(c) Contract Type: Firm Fixed-Price Contract

(d) Estimated total value (including options):

Period Duration Unit Price Total Base Period 1 September 2026 – 28 February 2027 6 Months $234,730.08 $1,408,380.48

Option Period 1 1 March 2027 – 31 March 2027

1 Month $234,730.08 $234,730.08

Option Period 2 1 April 2027 – 30 April 2027

1 Month $234,730.08 $234,730.08

Option Period 3 1 May 2027 – 31 May 2027

1 Month $234,730.08 $234,730.08

Total $2,112,570.72

(e) Type of funding: Operations and support funds

1 In this document, citations to RFO Parts 6, 10, 15, 16, and 25 are citations specifically to FAR Class Deviation 25- 11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 Rev. 1 for FAR Part 15, FAR Class Deviation 26-04 Rev. 1 for FAR Part 16, and FAR Class Deviation 25-09 Rev.1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

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(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: 70Z02326Q80000005

(h) Background information about the requirement: The current contract for PASS was awarded under HSHQDC-16-D-P2017 Order 70Z09023F80000001 and is a firm fixed price task order that expires on 31 August 2026. It competed using FAR 16.505 (RFO 16.507) procedures and awarded under the PACTS II vehicle (Functional Category 2), Service-Disabled Veteran-Owned Small Business (SDVOSB) set-aside.

3. Description of Supplies/Services.

The requirement is to obtain hands-on accounting and financial transaction support necessary to operate and sustain FSC’s core business lines, reinforcing financial accountability and operational readiness across multiple DHS components. This includes executing and validating financial transactions; processing and reconciling accounts payable actions; end-to-end payment processing; critical transaction reclassifications but does not include FSMS helpdesk support.

PASS is essential services to be acquired in support of the USCG’s FSC, the Transportation Safety Administration (TSA), and the Countering Weapons of Mass Destruction (CWMD) Office. FSC supports the DHS Financial Systems Modernization Solution (FSMS) within an Oracle Federal Financials E-Business Suite (EBS) environment.

4. Exception to Fair Opportunity.

The exception to fair opportunity is RFO 16.507-6(b)(3) – The new work is a logical follow-on to an original order, and the order was placed in accordance with the fair opportunity process and was not issued under sole-source or limited-sources procedures.

5. Identification of Exception to the Buy American Statute.

N/A

6. Supporting Rationale of the Exception.

(a) The limited duration action is needed to maintain essential accounting operations while the Government completes a long-term competitive follow-on acquisition. In alignment with RFO 16.507-6(b)(3), ITC Federal is the incumbent contractor performing these services and the only source that can continue performance under a limited duration follow-on without an unacceptable delay, disruption, or loss of continuity. A change in contractor support would require a substantial transition period to gain the necessary understanding of FSC’s systems, processes, controls, reporting cycles, and open audit remediation activities. Based on the complexity of the environment and the breadth of

Last Updated 07/23/26 3 service lines supported, a new contractor would require an estimated 90-to-120-day knowledge transfer and onboarding period before reaching comparable operational effectiveness.

(b) The events leading to this logical follow-on action are driven by an unavoidable convergence of external disruptions: a major organizational restructuring compounded by unprecedented legislative and budgetary volatility.

Organizational Complexity: The recent transition from the Finance Center (FINCEN) to the FSC significantly expanded the organization's scope of technical authority. This restructuring created six distinct service lines with greater interdependencies, requiring additional time to define requirements, align stakeholders, and develop a competitive procurement strategy for the follow-on contract.

Legislative Delays: The re-procurement timeline was also affected by significant lapses in appropriations. A 43-day full government shutdown in late 2025 and a 76-day partial DHS shutdown in early 2026 resulted in 119 total days of delay. During these periods, all non-exempt procurement activities were suspended, including requirements development and acquisition planning for the follow-on contract.

Although FSC personnel continued supporting ongoing daily operations, forward-looking procurement work could not proceed until appropriations were restored.

(c) The Government considered the following alternatives:

i. Full and Open or Competitive Ordering for the follow-on Requirement

This alternative is neither operationally viable nor fiscally responsible. A competitive procurement (solicitation, evaluation, award) followed by the mandatory mobilization, security clearance processing, and training of a new workforce would take several months. This timeline guarantees a systemic lapse in service. Furthermore, it is highly uneconomical for the Government to pay duplicative start-up, onboarding, and knowledge-transfer costs for a temporary contractor who would only perform for a matter of months before the long-term contract is awarded.

ii. Use of Internal Government Resources

The Government considered using internal personnel to perform the work during the interim period. The USCG lacks sufficient Government personnel with the specialized Oracle EBS subject matter expertise to assume these high-volume accounting functions. Diverting existing Government personnel would create unacceptable risks to other financial management, accounting, and oversight functions. This approach is not sustainable or technically viable.

iii. Short-Term Transition to Another Contractor The Government considered awarding this requirement to another contractor. This alternative is highly uneconomical and would create unnecessary transition risk. The

Last Updated 07/23/26 4 limited duration contract is intended to sustain services while a long-term, competitive procurement is awarded. Duplicative start-up, onboarding, and knowledge-transfer costs would be required to transition to a new, short-term contractor. This transition effort would likely consume a meaningful portion of the performance period and could increase, rather than reduce, risk to the mission.

iv. Allowing Current Services to Expire

The Government considered allowing the current order to expire without replacement. This alternative is unacceptable because it would cause an immediate lapse in support for critical accounting operations.

(d) If this justification is not approved, the Government faces a break in critical accounting support services to include an immediate and significant risk to the missions of the USCG, TSA, and CWMD effective 1 September 2026. The short-term follow-on action is necessary to prevent these impacts and to maintain continuity while the Government completes the competitive acquisition.

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

These prices were compared to the extension prices provided by the incumbent, ITC Federal, and found to be consistent with market rates. The contracting officer determines that the anticipated price(s) will be fair and reasonable based on reviewed price lists from GSA schedules of vendors providing similar services.

8. Description of Market Research.

The Government has knowledge of the marketplace for professional accounting support services and recognizes that multiple vendors may be capable of competing for the long-term requirement. Request for Information (RFI) indicates that at least six (6) vendors are capable of competing for this requirement, supporting the expectation of robust competition for the consolidated procurement. For this short-term action, the key consideration is not whether other vendors can perform the work. Rather, it is whether another vendor could assume responsibility without disrupting services and in a manner that supports economy and efficiency as a logical follow-on. Given the limited duration of the follow-on requirement, the current contract expiration date, the complexity of the accounting support functions, and the need to maintain continuity of operations, ITC Federal is the only practical source for the immediate follow-on period.

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

N/A

10. Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

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The FSC is finalizing its requirements in support of the acquisition strategy for the future competitive procurement. The competitive solicitation is on track for release to industry on or about November 28, 2026, and there are no known barriers or concerns that would prevent timely release.

11. 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.

Todd Gerick Date Technical Representative

12. 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.

Carrie Lopez Date Contracting Officer

13. Approval

Shreena L. Morris Date Procuring Activity Advocate for Competition (PAAC)

GERICK.TODD.M.12

73016402

Digitally signed by

GERICK.TODD.M.1273016402

Date: 2026.08.24 14:20:19 -04'00'

LOPEZ.CARRIE.MARIE

.1366321060

Digitally signed by

LOPEZ.CARRIE.MARIE.1366321060

Date: 2026.08.24 14:25:35 -04'00'

Digitally signed by MORRIS.SHREENA.LYONS.1144950301 Date: 2026.08.25 15:28:36 -04'00'

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