ProMonitor Limited Sources Justification_redacted.pdf

UNCLASSIFIED

FEDERAL ACQUISITION REGULATION (FAR) PART 8

LIMITED SOURCE JUSTIFICATION (LSJ)

Procurement Title: Public Record Data – LexisNexis ProMonitor Alert Contract Number:

Estimated Value:

Limited Source Authority: FAR 8.405-6(a)(1)(i)(B)

LIMITED SOURCE JUSTIFICATION

1. Identification of the agency and contracting activity.

The United States (US) Department of War (DoW) Defense Counterintelligence and Security Agency (DCSA) Procurement Solutions (PRS) proposes to enter a contract on a basis of other than full and open competition for the Personnel Vetting (PV) Directorate.

a. Requiring Activity/Program Office:

DCSA – Personnel Vetting 27130 Telegraph Road Quantico, VA 22134

b. Contracting Activity:

DCSA – Procurement Solutions 27130 Telegraph Road Quantico, VA 22134

2. The nature and/or description of the action being approved.

The purpose of this document is to obtain the necessary approvals for a limited source acquisition in accordance with FAR 8.405-6(a)(1)(i)(B) – Only one source can provide the supplies required at the level of quality required because the supplies are unique or highly specialized.

DCSA PV has a requirement for consolidated and extensive criminal, financial, and public record information to help DCSA more effectively use data to satisfy its personnel vetting mission. Specifically, PV requires the LexisNexis ProMonitor Alert Service and its associated Accurint Trusted Intelligence Portal (A-TIP) for a comprehensive public record monitoring tool. PV requires access to public records via automated record checks and the LexisNexis database for the purpose of monitoring trusted individuals enrolled in DCSA’s Continuous Vetting (CV) program. The information contained in the LexisNexis database is necessary to facilitate end-to-end continuous vetting of cleared DoW and Federal Government personnel and contractors.

The automated record check datasets provided are received for ingestion into the National Background Investigation Services (NBIS) system and Mirador sub-system. Mirador is the CV’s system for personnel security and uses public record information to detect security issues among the trusted Federal workforce.

Mirador uses multiple automated approaches to assess eligibility during the career of a cleared employee.

The ProMonitor Alert Service will continue to allow the DCSA CV program to perform continuous monitoring of the current and future CV population base. Maintaining a constant source of accessible data to ensure continuous personnel security vetting for DCSA is vital to the national interest. Access to public record data through the ProMonitor Alert Service, A-TIP access, and support is necessary to continue DCSA’s mission and to achieve the Trusted Workforce (TW) framework and milestones set by current policy.

PV processes require modern transformational reform in line with today’s complex missions, societal norms, threat landscape, changing workforce, and evolving technology. The Executive Agents (EAs) have developed an iterative implementation approach that positions the enterprise to build momentum and accelerate TW 2.0 implementation timelines. Phase 1 of TW 2.0 was focused on mitigation measures for reducing the inventory and improving timeliness of background investigations. Phase 2 of TW 2.0 implementation aims to transform personnel vetting across the enterprise, of which Phase 2b focuses on implementation of the TW 2.0 transitional states. In February 2020 and January 2021, the EAs issued Executive Correspondences establishing minimum standards for transitional continuous vetting states and introduced TW 1.25 and TW 1.5, with set milestone dates for enrollment. As TW 2.0 policies are being developed, TW 1.25 offers select high value checks and deferring periodic investigations to CV, and TW

1.5 offers a full suite of high value checks and agency specific checks that replaces periodic investigation.

The mission requirement for public record data is aligned with the transformation of personnel vetting processes under TW policy. The criminal, financial, and public record data provided by LexisNexis are required for three of the seven automated record check data categories necessary to achieve an iterative implementation of the 2.0 framework. Without current access to this one data provider, the DoW and Federal Departments and Agencies subscribed to DCSA’s CV service would not be compliant with TW

1.5 policy, putting them at an increased risk of undiscovered derogatory information, which includes information that may unfavorably impact suitability adjudication because of the nexus between the issue or conduct and the core duties of the position.

PV currently obtains public record data via the LexisNexis ProMonitor Alert Service under task order (TO) HS002124F0006. The TO was placed against the LexisNexis Special Services General Servies Administration (GSA) Schedule, GS-00F-178DA. The period of performance for the TO is for a base of 12-months and one (1) 12-month option period. The current and final option of this TO ends on 27 March 2026.

This requirement will renew the LexisNexis ProMonitor Alert Service data subscription service procured under TO HS002124F0006 and integrated into DCSA’s NBIS system for use in executing the CV mission for the DoW and Federal Government stakeholders. The ProMonitor Alert Service is the only service in its existing state that is immediately compatible with NBIS. Per FAR 8.401, this acquisition is being conducted under the authority of the Multiple Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.) and Title 40 U.S.C. 501, Services for Executive Agencies.

The procurement strategy is to issue a request for proposal directly to LexisNexis Special Services, Inc.

(LNSSI) for the issuance of a TO off its existing General Services Administration’s Federal Supply Schedule (FSS) contract, GS-00F-178DA.

3. A description of the supplies or services required to meet the agency’s needs.

The purpose of this requirement is to continue providing the PV office with LexisNexis ProMonitor Alert Service and A-TIP access for public record data on the trusted workforce enrolled in CV. A-TIP access, as well as any technical analysis, and integration support provided by LNSSI is included with the LexisNexis ProMonitor Alert Service subscription.

integration with the NBIS system until the DCSA Integrated Security Data Services (ISDS) is implemented and fully operational. The ISDS is an enterprise-wide data architecture that will deliver a complete data ecosystem – ingesting, managing, analyzing, and securely sharing Defense Security Enterprise (DSE) data.

This new data ecosystem will allow DCSA to bring on a new company and switch companies in less time and with vastly less effort than it would today, resulting in cost savings for the government. The ISDS system is anticipated to be fully functional in calendar year 2026.

LexisNexis ProMonitor is the only comprehensive public record data source currently integrated into NBIS and, with ISDS becoming operational in the near term, competing this requirement and potentially going through the process of connecting a new contractor would take an estimated nine to twelve months to complete. The extensive time and resource cost to this process would result in mission degradation and potentially halt essential vetting processes, which would significantly impact national security. With the creation of the ISDS, it is not advisable to bring in new companies at this time.

The proprietary database access and monitoring tool provided by the ProMonitor Alert Service and A-TIP is one of a kind and provides more data access than other data providers in the marketplace. The LexisNexis database is proprietary and LNSSI is the only authorized seller of the required ProMonitor Alert Service, as no companies are authorized to resell its data and the subscription service. Specifically, LexisNexis uses its proprietary LexID unique person identifier with multi-patented linking technology for entity resolution.

LexisNexis has a complete aggregate of data sources and partnerships with the social intelligence communities that provide the ability to evaluate the most data sources and compare them to the CV database. LexisNexis comprehensive data includes public and proprietary records, with 10,000+ sources; a comprehensive commercial database of 2.5+ million risk entities, from global sanctions and watch lists; as well as vast social media, law enforcement records management systems, and other data sets.

5. A determination by the Contracting Officer that the order represents the best value (FAR 8.404(d)).

The Contracting Officer has determined that awarding a TO against the GSA Federal Supply Schedule represents the best value to the government, offering the lowest overall price while meeting the government’s requirements. This decision is based on the availability of the required product via GSA FSS, which reduces administrative burden and time compared to awarding a new contract. Additionally, the Contractor’s proposed pricing has already been deemed fair and reasonable by GSA, though the government will seek further discounts.

Although GSA has determined FSS prices to be fair and reasonable, per FAR Subpart 8.4, the Contracting Officer will conduct additional price analysis using methods such as comparing historical prices paid and competitive published price lists. A separate fair and reasonable determination will be made, and further discounts will be requested in accordance with FAR 8.405-2, DFARS 208.404, and Department of Defense Class Deviation 2014-O0011, dated March 13, 2014.

Considering the justification for continuing the LexisNexis ProMonitor Alert Service, the market research conducted, anticipated volume discounts, and the streamlined procedures under FAR Part 8, DCSA has determined that issuing a single award task order to LNSSI, a GSA FSS holder, represents the best value to the government at the lowest potential price.

7. Any other facts supporting this justification.

The ISDS is an enterprise-wide data architecture that will deliver a complete data ecosystem becoming operational in the near term to ingest, manage, analyze and securely share Defense Security Enterprise (DSE) data. It will establish the foundation required to leverage artificial intelligence (AI) and reduce startup time and costs to onboard new technologies and data sources. The ISDS will provide visibility, traceability and accountability for DSE data. It will also make DCSA data Visible, Accessible, Understandable, Linked, Trustworthy, Interoperable, Secure (VAULTIS).

The ISDS improves data quality and accessibility by enforcing data standards, governance, operations, and business rules, keeping data ready for use. It will save the government costs by reducing duplicate investments in data acquisition, storage, legacy back-end system maintenance, and back-end systems development. The ISDS will streamline agency efforts to improve efficiency of workflows and reduce the manual lift in data collection, preparation, sharing and use.

Procurement History:

Contractor: Contract Number: Period of Performance

$ Value Competition

LexisNexis Special Services (RELX Inc is parent company)

HS002124F0006 28 Mar 24 – 27 Mar 26

$24,437,977 Sole Source

RELX Inc HS002119F0009 28 Mar 19 – 27 Mar 24

$41,846,079 Sole Source

RELX Inc GSQ0317DS0023 28 Mar 17 – 27 Mar 19

$11,905,000 Sole Source

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition of the supplies or services required.

In the next several months, DCSA intends to conduct additional market research and a capabilities assessment of all public record data tools that meet the minimum functional requirements. DCSA anticipates any barriers to competition related to system interface and connections to be mitigated once ISDS is deemed fully operational. ISDS and the NBIS system architecture will allow for additional source connections.

DCSA will also continue to regularly assess the market by contacting knowledgeable individuals in government and industry including DCSA partners and other US Government agencies to identify any additional products that may have the necessary capabilities to meet DCSA’s minimum requirements.

Additionally, DCSA continually reviews online catalogs and other generally available product literature published by manufacturers, distributors, and dealers. DCSA will continue to conduct market research to ascertain if changes occur in the marketplace that would enable future actions to be competed.

Certification:

Program Official:

I certify that the facts and representations under my cognizance, which are included in this justification, and which form the basis for this justification, are complete and accurate.

Program Analyst Personnel Vetting

Contracting Officer:

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

Contracting Officer Procurement Solutions, Mission

Reviews and Approvals:

Competition Advocate:

This review serves as concurrence and my written determination that the circumstances apply in accordance with 8.405-6(a)(1)(i)(B), subject to the availability of funds, and provided the services described herein have otherwise been authorized for acquisition.

Competition Advocate

Senior Procurement Executive:

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. This review serves as approval and my written determination that the circumstances apply in accordance with FAR 8.405-6(a)(1)(i)(B), 8.405-6(d)(3), and DFARS PGI 208.405-6.

Senior Procurement Executive