Redacted_Part 6 JA for Other Than Full and Open Competition_Secure_Stamps_FINAL_20260730.pdf

Justification & Approval for Other Than Full and Open Competition Template (Rev. 2/10/2026)

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Revolutionary Federal Acquisition Regulation Overhaul (RFO) 6.103 and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO

6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:1

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to award a purchase order on behalf of USCIS Office of Intake and Document Production (OIDP), Document Management Division (DMD), resulting from a solicitation containing a brand-name specification.

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

Procurement of 9,000 Numbered Secure “Approved” Stamps, 9,000 Numbered “Denied” Stamps, 250 Asylum Grant stamps, and 2,000 Temporary I-551 stamps for the Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), and the Office of Intake and Document Production (OIDP).

3. Description of Supplies/Services.

DMD intends to procure, on a sole-sourced basis, and provide 9,000 numbered secure approve stamps, 9,000 numbered denied stamps, 250 Asylum Grant stamps, and 2,000 Temporary I-551 stamps for Immigration Services Officers, Asylum Officers, and Refugee Officers to officially signify appropriate conclusive action regarding applications and petitions for benefits under the current laws and regulations.

The secure stamps shall incorporate security features and must be produced in a secure manner. Specific security features will be shared with the Contractor after contract award.

Secure stamps are used to imprint documents with identifying marks that record or give visible expression to official decisions that have been made, usually on applications and petitions submitted by persons seeking immigration services or benefits. They are usually made of rubber with plastic, wood or metal handles. Each secure stamp is individually serial numbered and assigned to a specific individual. Secure stamps are unique to USCIS and incorporate security features.

1 In this document, citations to RFO Part 5, RFO Part 6, RFO Part 10, RFO Part 15 and RFO Part 25 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-17, for FAR Part 5, FAR Class Deviation 25-11, for FAR Part 6, FAR Class Deviation 26-06, for FAR Part 10, FAR Class Deviation 26-08, Rev. 1 for FAR Part 15, FAR Class Deviation 26-09, Rev. 1 for FAR Part 25, and HSAR 3006 Class Deviation 25-01, for HSAR 3006, which was issued as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

The total estimated amount of the proposed action is: $802,775.00. The resultant order shall be a one-time delivery within 90 days of contract award.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

RFO 6.103-1 only one responsible source and no other supplies or services will satisfy agency requirements.

5. Identification of Exception to the Buy American Statute.

Buy American statute exceptions not applicable to this request.

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The specific authority for this request is RFO 6.103-1, only one responsible source and no other supplies or services will satisfy agency requirements. The Government requires procurement of numbered secure approved/denied stamps. New York Marking Devices Corp.

(NYMD) is the original contractor and retains exclusive control over the design files and production templates for these secure stamps, ensuring that no unauthorized duplication or third-party manufacturing is possible.

NYMD is the only contractor capable of meeting the full spectrum of technical, security, and operational requirements for secure stamps, as detailed below:

a) Proprietary Security Features: NYMD holds patents on their secure stamp construction, including proprietary tamper-evident ink formulas and micro-engraving techniques that are not available through any other manufacturer. Their stamps incorporate multi-layered security features—such as embedded microtext, UV-reactive ink, and custom holographic seals—that have been independently validated by DHS Security Assessment teams.

b) Compliance with USCIS Security Standards: NYMD secure stamps have been tested and approved for use in environments handling Controlled Unclassified Information (CUI), Law Enforcement Sensitive (LES), and For Official Use Only (FOUO) documents. Their facility is the only one with an active DHS-approved security plan for the handling, storage, and destruction of sensitive stamp components.

c) Chain of Custody and Traceability: Each stamp produced by NYMD is assigned a unique serial number, and the company maintains a secure chain-of-custody log from production through delivery. The company’s tracking system allows the agency to verify the origin, authenticity, and status of each stamp, supporting internal audits and investigations as required by DHS policy.

d) Risk Mitigation: Procuring from any other source would introduce unacceptable risks of stamp forgery, document fraud, and non-compliance with federal security mandates. The use of non-certified stamps could compromise the integrity of official documents, leading to potential legal and operational consequences for the agency.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential

Sources as is Practicable.

In accordance with FAR 6.301(b), an announcement will be posted to SAM within 14 days of contract award.

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

The Contracting Officer determines that the anticipated price(s) will be fair and reasonable based on analysis of historical prices paid by the Government for this requirement under USCIS contract HSSCCG-15-F-00597. The Contracting Officer will utilize one or more of the available proposal analysis techniques as required in FAR 15.404-1 to determine the price as fair and reasonable.

9. Description of Market Research.

Market research conducted by DMD, OIDP April 2026 included review of the NYMD secure stamps contract, inquiries with potential third-party service providers, and examination of Government wide contract vehicles. No other vendor demonstrated the ability to meet all technical specifications, security requirements, or delivery timelines.

The results of the market research indicate other companies’ similar products/services lack the feature(s) required and do not meet, or cannot be modified to meet, the needs of USCIS.

Therefore, competition is not practicable because only NYMD can meet the Government’s minimum requirements for secure stamps.

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

OIDP, DMD and NYMD have a longstanding relationship, providing secure stamps for over six (6) years. They are familiar with DHS-specific requirements, workflows, and document types ensure seamless integration and reduce the risk of errors or delays. NYMD is the only vendor with access to agency-specific stamp designs, templates, and security overlays. These assets are stored and managed under strict confidentiality agreements and DHS-approved protocols, preventing unauthorized use or disclosure.

Transitioning to another vendor would require extensive revalidation of security features, retraining of staff, and updates to internal procedures, resulting in significant additional costs and operational disruption.

11. A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

Currently, no sources have expressed interest in the acquisition. Market Research conducted did not identify any additional vendors capable of meeting the requirement.

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

Barriers to competition will be removed when the program goes through the process of full procurement in the future of new systems. The program continues to conduct market research and meets with vendors in the industry to stay abreast of the latest technologies and capabilities.

13. 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.

Rachel Turner Date Contracting Officer

14. 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.

Technical Representative

APPROVAL:

Rachel Turner Date Contracting Officer

RACHEL M TURNER

Digitally signed by RACHEL M

TURNER

Date: 2026.07.29 11:23:43 -04'00'

RACHEL M TURNER Digitally signed by RACHEL M TURNER Date: 2026.07.30 11:49:12 -04'00'