Redacted - LSJ for SAM.gov.pdf

LIMITED SOURCES JUSTIFICATION

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY

Department of State Contracting Activity

☒ Bureau of International Narcotics and Law Enforcement Affairs, Executive Office, Grants, Acquisition, Procurement and Policy (INL/EX/GAPP)

Requiring Activity Bureau of International Narcotics and Law Enforcement Affairs – Executive Office

(INL/EX)

SECTION 2: NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

Approval is requested to limit the number of sources for soliciting and awarding a Blanket Purchase Agreement (BPA) under a Federal Supply Schedule contract for the services described in Section 3 on behalf of the Requiring Activity.

INL intends to make a sole source interim award to each of the following contractors:

• XXXX

• XXXX

• XXXX

• XXXX

• XXXX

These interim awards will allow the continuation of their Professional Administrative Services provided to INL, supporting its mission to minimize the impact of international crime and illegal drugs on the United States, its citizens, and partner nations through effective foreign assistance and global cooperation, in alignment with the administration’s America First policies. The resulting awards will be a time and materials (T&M) contract.

The interim awards are necessitated by the Executive Order: Reevaluating and Realigning United States Foreign Assistance and ALDAC: 25 STATE 6828, which led to the cancellation of the competitive solicitation on XXXX. The existing contracts expired on XXXX, pending the 90-day Foreign Assistance Review. Each of the BPAs has been extended for all four option years and an additional six months per clause 52.217-8 Option to Extend the Services.

The services provided under these contracts are essential to INL’s mission, and there is a significant need for their continuation. Many of the more than 100 active BPA Calls will expire soon. Without active BPAs, INL cannot maintain mission-essential support provided by XXXX, XXXX, XXXX, XXXX, and XXXX. With no historical precedent for responding to a long-term pause on spending causing contract expirations before solutions are in place, the contracting officer requests interim awards to allow continued services at current level and quality.

Eight BPA Calls are scheduled to expire in April, with more in May. It is imperative to make the interim awards as soon as possible to prevent a loss in support.

SECTION 3: DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S

NEEDS

The resulting procurement will be awarded using NAICS 541611 – Administrative Management and General Management Consulting Services. This procurement will involve Third Party Contractors (TPCs) in Washington, DC, and other CONUS and OCONUS locations, providing services under the labor categories referenced in Attachment B. The anticipated period of performance is from XXXX, through XXXX. Each BPA Call issued will include 1-3 TPCs based on immediate need and available funding from the requesting office. While each BPA Call is not expected to exceed $ XXXX , it will have a ceiling of $ XXXX to accommodate multiple full time employees, if necessary.

SECTION 4: AUTHORITY AND SUPPORTING RATIONALE

This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C. 152(3) and 40 U.S.C. 501), as implemented in FAR 8.405.6 by the following:

☒ FAR 8.405-6(a)(1)(i)(A) - An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

The issuance of Executive Order: Reevaluating and Realigning United States Foreign Assistance and ALDAC: 25 STATE 6828 required a 90-day pause on procurements involving foreign assistance for a Foreign Assistance Review of all active contracts and pending requirements. Consequently, the solicitation for Professions and Administrative Services was removed from SAM.gov on January 28, 2025. Active BPA Calls were granted two temporary exemptions during the pause to allow continued performance by most TPCs. However, these contracts expired on March 5, 2025.

An urgent and compelling need exists because INL could not proceed with a competitive solicitation to evaluate multiple vendors for suitability. Immediate awards are necessary to prevent service lapses, as many active BPA Calls are expiring soon. The professional services provided by XXXX, XXXX, XXXX, XXXX, and XXXX are mission-critical to sustain its programs and initiatives.

Initiating a competitive solicitation and formal source selection could take 60-90 days, during which many TPCs would be lost due to expired BPA Calls. By issuing an interim award, we can ensure the same quality of performance, retain current TPC employees who are already cleared, badged, and equipped, and avoid delays in onboarding and system access.

SECTION 5: DETERMINATION BY THE ORDERING ACTIVITY CONTRACTING OFFICER THAT THE

CONTRACT ACTION REPRESENTS THE BEST VALUE CONSISTENT WITH FAR 8.404(D)

Awarding interim contracts to XXXX, XXXX, XXXX, XXXX, and XXXX ensures continued services with TPCs who are ready to perform their duties immediately without interruption. Their skills and knowledge of INL programs are essential for maintaining the bureau’s operations. The BPAs will be established against the vendor’s existing GSA contracts, which have pre-negotiated rates deemed fair and reasonable. The Contracting Officer can determine that the anticipated prices will be fair and reasonable based on established rates, historical pricing, and the IGCE. By signing the justification, the Contracting Officer confirms that the costs to the Government are expected to be fair and reasonable.

SECTION 6. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG SCHEDULE

HOLDERS AND THE RESULTS OR A STATEMENT OF THE REASON MARKET RESEARCH WAS

NOT CONDUCTED

A Request for Information (RFI) was posted on SAM.gov by Contracting Officer XXXX and closed in November 2024. Multiple companies expressed interest. The intent was to solicit this requirement competitively on GSA as a small business set aside. The following submitted responses to the RFI, and additional vendors asked questions and submitted capability statements.

• XXXXX

• XXXXX

• XXXXX

• XXXXX

• XXXXX

• XXXXX

• XXXXX

SECTION 7. 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

If INL is unable to issue interim awards to ensure continued services, the bureau will see a significant reduction in its TPC staff and there will be an impact to the successful performance of the mission essential duties in support of INL’s mission, programs and initiatives. There will also be further delays in continued services because a competitive solicitation would need to be issued, evaluated and awarded which would add 60-90 additional days for a completed award. Other delays that would impact performance would be waiting for new TPC clearances, badging, equipment and system access. It would be in the best interest of the Government to allow performance to continue with INL’s current TPC vendors XXXX, XXXX, XXXX, XXXX, and

XXXX.

Once the interim awards are issued, the Contracting Officer will focus on obtaining all necessary documentation to prepare a competitive solicitation for INL’s long-term solution.

SECTIONS 8. CERTIFICATIONS

TECHNICAL AND REQUIREMENTS CERTIFICATION (FAR 6.303-2(b)) I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

XXXX:

SIGNATURE:

XXXX Date

XXXX

Requirements Cognizance:

XXXX

LEGAL SUFFICIENCY REVIEW

This J&A is hereby determined to be legally sufficient.

XXXX

CONTRACTING OFFICER CERTIFICATION (FAR 6.303-2(a)(12)) I certify that this submission is accurate to the best of my knowledge, and that it contains complete information necessary to enable other officials to make an informed recommendation for approval or disapproval.

XXX Date

SECTION 9. APPROVALS

XXXX SIGNATURE:

Name Date