PS0017_47QTCB21F0037_LSJ_REDACTED 2025-5-30.pdf

3. A DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS (INCLUDING THE ESTIMATED VALUE):

The modification will increase the level-of-effort (LOE) for the time-and-material contract line-item numbers (CLINs) 3001, 3002, 3004, and 3005 for the current Option Period 3, as summarized below:

CLIN DESCRIPTION CURRENT LOE PROPOSED CHANGES DIFFERENCE

Hours Funding Hours Funding Hours Funding

3001 Integration Support (T&M) 1,680 $234,744.00 1,876 $279,034.00 196 $44,290.00

3002 Operations Support (T&M) 3,960 $383,220.00 4,473.5 $402,883.95 513.50 $19,663.95

3004 Communication and Outreach Support (T&M)

1,320 $127,980.00 4,831.8 $358,032.68 3511.75 $230,052.68

3005 Program Administration Support (T&M)

720 $70,860.00 1,081 $137,169.90 361 $66,309.90

TOTAL: $360,316.53

Integration Support provides integration of disparate parts of a portfolio (consisting of varied contracts) to ensure continuity of service at all times per an IT strategic plan consisting of core and non-core services that supports a turn-key Personal Identity Verification (PIV) issuance service.

Operations Support provides an end-to-end federal identity credentialing service, combining enrollment, hosted operations, card production and issuance, and card activation that may require periodic government inputs such as sponsorship, adjudication, agency preparation and work approval and performance analysis.

Communications and Outreach Support provides open and transparent communications with the user community that is vital to ensuring the success of the USAccess program (e.g., maintaining a public facing website at www.fedidcard.gov; developing and maintaining a robust and effective communication, marketing and outreach program ensuring that the Government has effective communication vehicles that appropriately address its distinct stakeholder's needs).

Program Administration Support provides activity tracking to maintain customer lists and databases to facilitate notifications, marketing, and business development activities; and updates to the Project Management Plan that describes in detail a breakdown of individual projects including milestones, tasks, and subtasks.

4. THE AUTHORITY AND SUPPORTING RATIONALE AND, IF APPLICABLE, A

DEMONSTRATION OF THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS TO PROVIDE THE REQUIRED SUPPLY OR SERVICE:

Orders placed or BPAs established under Federal Supply Schedules are exempt from the requirements in Part 6. However, an ordering activity must justify its action when restricting consideration in accordance with paragraphs (a) or (b) of FAR 8.405-6:

This action is issued in accordance with FAR 8.405-6(a)(1)(i)(A); an urgent and compelling need exists and following the procedures would result in unacceptable delays due to the length of time necessary to reprocure the level of support. Since JPI is currently supporting the required services and possesses the corporate knowledge to perform at an acceptable level, they are uniquely positioned to fulfill this urgent need without onboarding delays, duplicative ramp-up costs, or risk to system integrity. JPI provides: a) Knowledge of the program’s operations to support integration with the next-generation architecture; b) Established relationships and coordination protocols with more than 130 agencies and key federal stakeholders; c) A proven track record of rapidly deploying resources in response to shifting program priorities. Replacing the incumbent at this stage, even via competition among other MAS contract holders, would require a minimum 60–90 day onboarding period, during which USAccess program performance would degrade, placing agency mission operations and compliance at risk. These critical support services enable the USAccess program to remain in compliance with Federal Information Processing Standards (FIPS) 201-3 and additional Presidential directives, including the RealID initiative and allows continued support through the remainder of this option period.

5. A DETERMINATION BY THE ORDERING ACTIVITY CONTRACTING OFFICER

THAT THE ORDER REPRESENTS THE BEST VALUE CONSISTENT WITH 8.404(d):

A multiple-award BPA was awarded competitively under the GSA MAS and several vendors were solicited in accordance with FAR 8.405-1. Adequate price competition was received and evaluated, resulting in the selection of JPI and six (6) other schedule holders. Per FAR Part 8.404(d), GSA has already determined the rates for services offered at hourly rates under schedule contracts to be fair and reasonable. In addition, the Contracting Officer reviewed the pricing submitted by JPI at the time of award and conducted a price analysis in accordance with FAR Part 15.404-1(b)(2)(i), using price comparison among competing vendors. The labor rates awarded in the order are lower than JPI’s GSA MAS rates and BPA rates, further supporting the price as fair and reasonable. These same rates will be used for the proposed increase in level of effort. At this time, re-competing this requirement or soliciting additional quotations would not yield more advantageous pricing and would introduce unacceptable delays. Based on the urgent need, the subject BPA order being competitively awarded, and the discounted pricing provided by JPI, this action represents the best value to the Government.

6. A DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG

SCHEDULE HOLDERS AND THE RESULTS OR A STATEMENT OF THE REASON

MARKET RESEARCH WAS NOT CONDUCTED:

No additional market research was conducted for this action, as the requirement is to increase the ceiling of an existing order awarded under a prior competitive process. JPI was determined to be responsible and technically capable during that evaluation and they continue to successfully perform under the current order. The proposed action does not change the scope, labor categories, or pricing terms of the existing order. It only increases the level of effort under previously awarded CLINs to meet an urgent and compelling need. Given the original competition, current performance, and immediate mission requirements, conducting new market research at this time would provide no additional value and would delay the agency’s ability to respond to time-sensitive priorities.

7. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION:

This increase in level of effort is time-sensitive and directly tied to the transition and integration activities required for the deployment of USAccess 2.0. Delays or gaps in this support would disrupt credential issuance, degrade service to agency customers, and hinder the implementation of governmentwide identity management policies. Executing this ceiling increase under the existing order avoids unnecessary administrative costs and delays that would be incurred through a new solicitation for duplicative services. JPI has consistently demonstrated high-quality performance under the existing order and possesses institutional knowledge that is critical to maintaining uninterrupted support to the USAccess program.

The need for increased levels of effort under this BPA Order has evolved over multiple performance periods. Although previous ceiling increases should have been accompanied by a LSJ once the cumulative value exceeded the SAT, those justifications were not completed. The current justification is being prepared to support the most recent ceiling increase and to retroactively support the continued use of the incumbent contractor under prior modifications.

JPI has consistently delivered services at competitively awarded rates, without changes to scope or labor categories, and has supported mission-critical efforts under urgent circumstances. This LSJ provides the required rationale and ensures the acquisition file is brought into alignment with FAR 8.405-6 requirements.

8. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS THAT LED TO THE RESTRICTED

CONSIDERATION BEFORE ANY SUBSEQUENT ACQUISITION FOR THE

SUPPLIES OR SERVICES IS MADE:

For any re-compete effort, the requiring agency intends to re-evaluate the Government’s needs;

specifically, what is the appropriate level of effort required to support this requirement in the future to mitigate increases to the contract ceiling price. Actuals (i.e., labor hours and material costs) from the subject order will be leveraged to estimate accurately the extent or duration of the work or to anticipate costs with a reasonable degree of confidence.

9. EVIDENCE THAT ANY SUPPORTING DATA THAT IS THE RESPONSIBILITY OF

TECHNICAL OR REQUIREMENTS PERSONNEL (E.G., VERIFYING THE

GOVERNMENT’S MINIMUM NEEDS OR REQUIREMENTS OR OTHER

RATIONALE FOR LIMITED SOURCES) AND WHICH FORM A BASIS FOR THE

JUSTIFICATION HAVE BEEN CERTIFIED AS COMPLETE AND ACCURATE BY

THE TECHNICAL OR REQUIREMENTS PERSONNEL:

I certify that the supporting data under my cognizance which form the basis for this justification are accurate and complete to the best of my knowledge and belief.

_________ ____________________ Date:______________ Technical or Requirements Personnel

Contracting Officer’s Representative

10. THE ORDERING ACTIVITY CONTRACTING OFFICER’S CERTIFICATION

THAT THE JUSTIFICATION IS ACCURATE AND COMPLETE TO THE BEST OF

THE CONTRACTING OFFICER’S KNOWLEDGE AND BELIEF:

The Contracting Officer has concluded that the proposed BPA Order modification represents the best value (as defined in FAR 2.101) to meet the Government’s needs in accordance with FAR 8.404(d). Further, I certify that this justification is accurate and complete to the best of my knowledge and belief.

_ ____________________________ Date:______________ Contracting Officer

11. APPROVING OFFICIAL CERTIFICATION:

_ ___________________________ Date:______________ Competition Advocate for FAS, ITC

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