Redacted Sole Source Justification_Redacted.pdf

SOLE SOURCE JUSTIFICATION FOR COMMERCIAL PRODUCTS AND

COMMERCIAL SERVICES USING SIMPLIFIED PROCEDURES

1. The Federal Housing Finance Agency (FHFA) proposes to restrict competition, as authorized by Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) 12.102(b), for the commercial acquisition of the usage of the Washington Metro Area Transit Authority (WMATA) SmartBenefits transit system to enroll, withdraw, and change employee transit benefits. The estimated price, including any options is

2. Nature and/or description of the action being approved. FHFA seeks to award a follow-on contract to maintain a WMATA SmartBenefits Commuter Benefits Program account on a sole-source basis through a firm fixed price contract with a base year plus four optional years.

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

FHFA’s Office of the Chief Operating Officer’s Agency Operations Branch (AOB) manages FHFA’s transit benefit program and requires the use of WMATA’s SmartBenefits program. The SmartBenefits program allows AOB to manage and fund transit benefits for eligible employees. FHFA transit benefit participants can use their individual SmarTrip cards to commute to and from work using different modes of public transit, including Metrorail, Metrobus, regional commuter buses, and local commuter trains. The SmartBenefits program allows FHFA to independently manage the funded values of all SmartTrip cards assigned to FHFA employees. WMATA does not charge a fee for the use of its SmartBenefits program allowing FHFA to pay only the actual cost of the transit benefits.

AOB seeks to award a sole-source contract to WMATA for the purpose of continuing access to the SmartBenefits Commuter Benefits Program system and to support providing transit benefit subsidies to FHFA employees using the WMATA transit system. The estimated value for a five-year contract based on historical billings is $2,250,000.00.

4. An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition for this requirement is 41 U.S.C. 3304(a)(1), RFO 6.103-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

5. A demonstration that the proposed Contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

WMATA manages the only subway system in the Greater Washington DC area (Metrorail) and as such provides the only fee-free access to a system allowing FHFA to manage portions of its transit benefits program. Additionally, the WMATA SmartBenefits program is the only program in the region that offers seamless transition between multiple modes of transportation across multiple jurisdictions while allowing FHFA to independently manage its budget and funding for individual commuter employees.

Accordingly, WMATA is the only responsible source capable of fulfilling this need.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is possible.

There are no other sources that can provide FHFA access to a SmartBenefits Commuter Benefits Program account or other fee-free system that allows FHFA to provide employees with a transit subsidy for the Metrorail or Metrobus system. WMATA is the sole proprietor and operator of the SmarTrip and SmartBenefits architecture. No other commercial or public vendor can directly credit or manage mass transit benefits on the physical or digital transit media required by FHFA personnel in the D.C. area. FHFA’s requirement relies strictly WMATA’s proprietary SmartBenefits electronic transit benefit distribution system, which allocates subsidies directly onto employee SmarTrip fare media.

In accordance with RFO publicizing requirements for commercial services, interested parties may submit a capability statement demonstrating their technical ability to satisfy this requirement.

All capability statements must be submitted via email to the Contracting Officer at no later than 11:00 AM EST on October 26, 2026.

7. A determination by the Contracting Officer that the anticipated cost to the

Government will be fair and reasonable.

FHFA anticipates receiving WMATA’s standard offered commercial pricing. FHFA also anticipates no fee for the use of WMATA’s SmartBenefits system. Therefore, the Contracting Officer anticipates that the pricing submitted by WMATA will be fair and reasonable.

8. A description of the market research conducted and the results or a statement of the reason market research was not conducted.

AOB conducted market research and determined that WMATA remains the only entity capable of providing transit services via Metrorail and Metrobus, and the only entity capable of benefit transferal between Metrorail/Metrobus and other local transit systems.