PIV Card Support_JEFO FY22-0174_Final Conformed_20211214_Signed_Redacted.pdf

CISAM 3016.505-90(b)(4) Justification for Exception to Fair Opportunity

Exceeding the SAT pursuant to FAR 16.505(b)(2)(ii)(B)

JEFO No: FY22-0174 Page 1 of 4 Rev: 05/06/2021

JEFO Number: FY22-0174 PR Number:

Justification for Exception to Fair Opportunity

1. Agency and Contracting Activity.

The Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to modify an existing task order on behalf of the Office of Security and Integrity, pursuant to Federal Acquisition Regulation (FAR) 16.505(b)(2), Exceptions to the fair opportunity process.

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

USCIS intends to procure Personal Identity Verification (PIV) Card Support services for the Office of Security and Integrity (OSI) on a noncompetitive basis through extending 70SBUR19F00000522 with the incumbent contractor:

Redzone, LLC 221 Midden Way Holly Springs, NC 27540

This task order was placed against a DHS Program Management, Administrative, Operations (Clerical), and Technical Services II (PACTS II) Indefinitely Delivery Indefinite Quantity (IDIQ) contract which has a contract ordering period of 03/01/2017 – 02/28/2022. PACTS II allows for task orders to extend up to 12 months beyond the contract ordering period. Therefore, the period of performance of this extension would be allowable under the existing order and parent IDIQ.

3. Description of Supplies/Services.

This requirement is for continuation of Personal Identity Verification (PIV) Card Support services on an interim basis for the Office of Security and Integrity. The Independent Government Cost Estimate (IGCE) for this effort is $ . The period of performance is 12/16/2021 – 06/15/2022 with three (3) months being funded initially, and three (3) one (1) month option periods. The current period of performance on 70SBUR19F00000522 is 12/16/2019 – 12/15/2021; this modification would extend the period of performance by six (6) months, through 06/15/2022.

4. Statutory exception and supporting rationale.

The applicable statutory FAR citation and basis for using an exception to fair opportunity process is:

CISAM 3016.505-90(b)(4) - Justification for Exception to Fair Opportunity

JEFO No: FY22-0174 Page 2 of 4

FAR 16.505(b)(2)(i)(B). Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

At this juncture, the current awardee, Redzone, LLC, is the only awardee capable of providing PIV card support services at the level of quality required. Redzone, LLC’s current staff is fully cleared, qualified and trained to provide the PIV card support service requirements specific to the various USCIS locations. No other awardee is capable of onboarding and maintaining the current level of quality with the limited current timeline required for continuation of services.

Additionally, this extension would prevent jeopardizing an impact to the mission of USCIS. The services performed under this order are necessary to help offices cover the tasks of a daily PIV Card Issuance Facility (PCIF) and other security related responsibilities to ensure all employees have the proper identification that is required to perform their duties.

Rationale:

Redzone, LLC, is the only awardee capable of providing PIV card support services at the level of quality required. USCIS OSI requires continued PIV card support services at the current quality level without a lapse in service since these services are critical to the overall mission of OSI and USCIS as a whole. Redzone LLC’s contractor staff under this existing task order are fully cleared through the USCIS Entry on Duty (EOD) process. This allows a seamless extension of services with existing staff. Additionally, the Redzone LLC staff are fully trained on the processes and procedures of DHS and specifically USCIS’ PIV card support. Redzone LLC’s staff all possess the required USCIS PCIF Enrollment Officer training, further ensuring that a high level of quality will be maintained during the extension period at all required USCIS office locations. Based on the current limited timeline for continuation of services under the existing task order, 70SBUR19F00000522, Redzone, LLC is the only awardee capable of providing PIV card support services to USCIS at the required level of quality for this extension period.

Market research was conducted spring 2018 through April 2019 for 70SBUR19F00000522. The market research report was reviewed and confirmed that the market research is still appropriate.

Since this action will result in the extension of an existing order, and not a new task order, no new market research was conducted. FAR 8.002 and 8.003 were reviewed to ensure the priorities for use of mandatory Government sources could not meet the needs for this requirement. In accordance with DHS Directive 060-01 – Development and Use of Strategic Sourcing Contract Vehicles, DHS components are required to use strategic sourcing vehicles for designated commodities, supplies and services. 70SBUR19F00000522 is currently placed against DHS PACTS II IDIQ, a DHS Strategic Sourcing Contract Vehicle, which has a contract ordering period of 03/01/2017 – 02/28/2022. PACTS II allows for task orders to extend up to 12 months beyond the contract ordering period. Therefore, as previously mentioned, the period of performance of this extension would be allowable under the existing order and parent IDIQ.

5. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

CISAM 3016.505-90(b)(4) - Justification for Exception to Fair Opportunity

JEFO No: FY22-0174 Page 4 of 4

10. Contracting Officer Certification

Pursuant to FAR 16.505(b)(2)(ii)(B)(8), I certify that this justification is accurate and complete to the best of my knowledge and belief.

______________________________ 12/14/2021_ Jason Hawkins Date Contracting Officer

APPROVAL: Pursuant to FAR 16.505(b)(2)(ii)(B)(10), I hereby determine the circumstance identified in Section 4 applies to the order.

______________________________ 12/14/2021_ Sandie Kapoor Date Alternate Procuring Activity Advocate for Competition

JASON S

HAWKINS

Digitally signed by JASON S

HAWKINS

Date: 2021.12.14 15:57:58 -05'00'

SANDIE

S

KAPOOR

Digital y signed by SANDIE S

KAPOOR

Date: 2021 12 14 16 12:34 05 00