SAS To FY24 LSJ Exceeding SAT rev_Redacted.pdf

www.uscis.gov

Rev: 10/13/2023

Limited-Sources Justification, Exceeding the Simplified Acquisition Threshold, (Statistical Analysis Software) SAS license maintenance.

REFERENCE: Justification Log Number: FY24-0059 and PR Number:

1. Agency and Contracting Activity.

The Department of Homeland Security, U.S. Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to award an order on behalf of the Office of Information Technology (OIT), Resources Management Division (RMD), pursuant to FAR 8.405-6, Limiting Sources.

2. Nature and/or description of the action being approved.

The proposed action will provide USCIS with commercial services for the maintenance of existing USCIS-owned (Statistical Analysis Software) SAS licenses. The software and hardware maintenance provides product upgrades, releases, patches, and technical support.

USCIS intends to limit the number of sources solicited, pursuant to FAR Part 8.405-6(a)(1)(i)(B), for the procurement of SAS licenses and maintenance for licenses currently owned by USCIS from Executive Information Systems, LLC (EIS), 6901 Rockledge Drive, Suite 600, Bethesda, MD 20817, as a sole source one (1) year task order under their General Services Administration’s (GSA) IT Schedule 70, Contract Number 47QTCA18D0081, SIN 511210 –Software Publishers.

USCIS currently owns SAS licenses which require maintenance through this prospective task order.

SAS is a software suite that can mine, alter, manage, and retrieve data from a variety of data sources and perform statistical analysis. SAS provides a graphical point-and-click user interface for non-technical users and additional capabilities based on the end-user’s ability to program the tool using the SAS language. SAS software is utilized within USCIS to analyze data that is critical to the agency for immigration data, adjudicative decisions, and many other case related queries.

Maintenance licenses are critical to provide access to security updates/hot fixes/software enhancements to remain compliant, secure, and updated.

3. Description of Supplies/Services.

The prospective requirement will result in USCIS acquiring maintenance of licenses on 809 existing SAS perpetual software licenses owned by USCIS. The year of maintenance will run from 04/30/2024 – 04/29/2025. Delivery of the license maintenance must occur no later than 04/30/2024 to avoid a lapse in service.

The OIT Data and Business Intelligence Services (DBIS) Program Office currently offers SAS PME to USCIS end-users who have a need for data analytics and statistical modeling software to meet requirements for agency and department level reporting. The SAS-PME was implemented in 2014 to conduct data management, pattern and trend analysis, and statistical and historical reporting. The

Limited-Sources Justification, Exceeding the SAT, (Statistical Analysis Software) SAS license maintenance.

Justification Log Number: FY24-0059

SAS licenses currently owned by USCIS organize data and identify relationships between data quickly. Using machine learning and dynamic visuals, the software allows end users to identify relationships and outliers, create reports and dashboards, summarize key metrics, and build reports with data-based suggestions. Data report recipients include the DHS Office of the Inspector General, Department of Transportation, Field Reports with Government Performance and Report Act (GPRA) reports, and OIT Verification Division. DBIS has applied resources to successfully deploy and get accredited SAS-PME at the USCIS Enterprise Level in the AWS Cloud. SAS-PME users conduct statistical modeling and analytics against eCISCOR stored data.

The Independent Government Estimate (IGE) for this award This estimate is based on current market research and a review of the procurement history.

4. Authority and supporting rationale.

This acquisition is conducted under the authority of Multiple-Award Schedule Program, 41 U.S.C.

152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies. Pursuant to FAR 8.405-6(a), the circumstance that justifies limiting sources to fewer than those required by FAR 8.405-1 and 8.405-2 is:

☒ FAR 8.405-6 (a)(1)(i)(B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

Rationale:

SAS is an Enterprise Software that is utilized within USCIS to analyze data that is critical to the agency for immigration data, adjudicative decisions, and many other case related queries.

The software has previously been procured on a perpetual license basis. Even though the licenses have already been purchased USCIS is required to procure annual maintenance support services. The licenses include the software product and comprehensive technical support services. For example, Critical CVE remediations are typically delivered within days of their discovery. Bug fixes, patches, and upgrades to functionality are also included, and allow USCIS to maintain our analytical platforms based on SAS software with modern CI/CD processes to remain compliant, secure, and updated. These features of the SAS Software License are critical to resolve any outages, based on the 809 core licenses we have previous procured, the impact of outages could affect over 1500 end users. SAS is the sole producer of SAS Software in the United States. It is available to the Government through only one authorized reseller, EIS.

SAS provides a single platform for having an intuitive user interface for the automation of many analytic-lifecycle segments. SAS produces a product which is highly transparent and auditable with respect to the data access and delivery in the form of analytical models. Translation and interpretation of models by citizen data scientist, allows for models to become more accurate.

Through the use of text analytics, SAS can aggregate data to provide analytics of real tangible value to the intelligence process, without the need to introduce risk by onboarding mandatory vendor staff.

Vendor staff is not needed due to the mechanistic and ease of use approach SAS takes to software development. SAS includes comprehensive, intuitive machine learning tools, with automated feature engineering, that allows for the generation and interpretation of models to be reviewed by citizen data scientists—with expertise in the subject under study. While other products would require the end-user to be well educated in both theoretical computer science and the subject under study; as theoretical computer scientists would typically be required for the translation and interpretation of the data. The separation of subject under study and theoretical computer science is critical to the success of the USCIS mission as it enables a large population of analysts and consumers to be supported by a small, dedicated group of administrators. A product which requires the end user to possess both theoretical computer science and subject under study would not fit the needs of USCIS and would be required to be heavily modified to meet the needs of the agency.

Even if a product was able to be heavily modified to produce an end product which allows for use by users other than those who have knowledge of theoretical computer science, it would take years for the product to be used in the current USCIS architecture. Migration to a new product, other than that offered by SAS, would require USCIS to complete a platform re-architecture, re-design, re-installation, and re-configuration. What makes SAS software critical to USCIS is that USCIS has now accumulated a corpus of over 50 million lines of SAS Source code that supports critical information flows throughout component. While there are 1500 users with logins to the cluster that supports SAS Software, the generated reports and other artifacts are distributed widely to many thousands of consumers throughout USCIS and other components. These reports represent critical information being delivered daily, weekly, and monthly to decision makers. Unlike some other analysis tools, SAS does not charge a fee for the use of SAS Software products by those ultimate end-users.

The analytical functions enabled by SAS that USCIS finds critical include:

• Text Analytics, including sentiment and social network analysis.

• Interactive data exploration and visualization.

• Analysis of abstract data object such as node and edges.

• Forecasting Model generation and exploration.

• Financial Forecasting: Revenue, labor, and acquisition costs.

• Case and Outcome Quality management.

• The separation of subject under study and theoretical computer science in order for users lacking this expertise to accurately interpret the information.

• Transparency and auditability of analytical models.

• Data management which does not increase the infrastructure burden via data duplication.

• Automation of analytic-lifecycle segments.

• Data collection, analyst, and management which can operate under our current infrastructure.

• Commercial-off-the-shelf, the end-product must be able to function within the current infrastructure of USCIS, and free from any additional services needed in order to modify or alter the current infrastructure for the product to be functional.

• Standard list of editable functions which can be changed to conform to the requirements of

OIT.

• Comprehensive, intuitive machine learning tools, with automated feature engineering, that allows for the generation and interpretation of models by citizen data scientists.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

In accordance with FAR Part 8.404(d), GSA has already determined the prices of supplies, fixed-price services and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. It is the responsibility of the Contracting Officer and Specialist to always seek out the best possible offer to include requesting discounted prices.

Therefore, the Contracting Officer has determined that issuing the proposed task order to EIS for the SAS Software License, Maintenance and Tech Support represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs.

Discounts to GSA pricing schedule rates will be requested.

This task order will be established in accordance with FAR 8.405-2, “Ordering procedures for services requiring a statement of work.”

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.

OIT conducted market research during the period of November 2023 to February 2024. Market research consisted of reviewing acquisition history, interviewing knowledgeable individuals in industry and government, reviewing existing DHS-wide and multi-component contract vehicles with DHS Strategic Sourcing Program Office, and on DHS Enterprise-wide Contract Vehicle Portal, as well as reviewing other priority sources. SAS and its sole authorized reseller of Viya 3.5 and SAS version 9 licenses, EIS, continue to be the only source which meets the Government’s requirement.

Additionally, the SAS Institute Inc. was contacted to seek additional sources, however none were identified.

EIS is the only SAS-authorized reseller for Viya 3.5 and SAS version 9 software. Maintaining USCIS’s investment in SAS is required to ensure the software performs optimally and in accordance with the software publisher’s most recent improvements and patches. Without software maintenance, the agency runs the risk of deficient software, security vulnerabilities, and compatibility issues with the multitude of critical systems utilizing with SAS.

The results of the market research show that no other products available in the commercial marketplace meets the needs of USCIS. USCIS has made a significant investment in SAS and the software is required for statisticians and economists creating statistical analysis to be able to perform their job duties.

7. Any other facts supporting the limited-sources justification.

The SAS software, part of the USCIS enterprise infrastructure, supports the SAS Predictive Modeling Environment (SAS-PME). The current marketplace neither supports nor produces a product which can fulfill the Governments need—besides that of the product produced by SAS. SAS is used agency-wide, throughout the user community and on multiple operational and analytical reporting levels. Migration to another statistical tool is not feasible as no other product will meet all requirements, and doing so will require a complete platform re-architecture, redesign, re-installation, and re-configuration.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for the supplies or services is made.

There are currently no other providers that can provide the maintenance of the SAS perpetual licenses currently owned by USCIS. USCIS will continue to conduct marketplace surveillance and market research to identify other products that can meet the needs and/or be modified to meet the needs of the agency that may become available in the marketplace.

9. USCIS intends to post this requirement on SAM.gov pursuant to FAR 8.405-6(a)(2)(i).

10. Technical/Requirements Personnel Certification.

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

Technical Representative/COR Date

11. Contracting Officer Certification

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and complete to the best of my knowledge and belief.

Date

Contracting Officer

APPROVAL: Pursuant to FAR 8.405-6(c)(2)(xi), I hereby determine the circumstance identified in Section 4 applies.

Date

Procuring Activity Advocate for Competition