Sole Source JA_eFILE Module_Redacted.pdf

SOLE SOURCE JUSTIFICATION

GSAM/R 538.7104-3(b)(ii), Unique Source

National Archives and Records Administration 8601 Adelphi Road

College Park, MD 20740-6001

Additional Work Modification for Tyler Technologies eFILE Module

Technical or Requirements Personnel Certification:

I hereby certify that this sole source justification is made in good faith, that the supporting data and information are accurate and complete to the best of my knowledge and belief, and that I would not be making this request if it were feasible to fully compete this requirement. I further certify this request is not the result of a desire to expend funds while those funds are still available.

General Counsel Concurrence:

I have reviewed this justification and consider it legally sufficient.

Contracting Officer Approval:

I have reviewed this justification and conclude that it is accurate and complete to the best of my knowledge and belief. In accordance with GSAM/R 538.7104-3(b) and NARA 501, I approve this justification.

I. IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY, AND

SPECIFIC IDENTIFICATION OF THE DOCUMENT AS A “SOLE SOURCE

JUSTIFICATION”.

See page 1.

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED.

The proposed action is for a sole source, additional work modification to be issued to Tyler

Federal, LLC under the General Services Administration’s (GSA) Multiple Award Schedule

(MAS) Task Order 88310326F00140 to add licensing and configuration services for the Tyler

Technologies eFile / Application Platform Access Module.

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

AGENCY’S NEEDS (INCLUDING THE ESTIMATED VALUE).

The National Archives and Records Administration (NARA) requires an integrated solution to collect sensitive Personally Identifiable Information (PII)—including Social Security Numbers and dates of birth—for candidate onboarding, specifically covering Optional Form 306 (OF-

306) submissions. NARA recently issued a competitive GSA MAS solicitation for a Security

Clearance and Tracking System (SCTS) resulting in an award to Tyler on June 26, 2026 for its

Application Platform – a secure, configurable, COTS SaaS case management platform designed to support personnel security operations. During implementation, NARA became aware of additional capabilities offered within the Tyler Platform, and specifically its eFile module, that would extend the capabilities of the newly procured SCTS platform by automating

OF-306 data collection, handling user registration, and providing direct Login.gov integration.

While some of these capabilities were identified as optional requirements in the SCTS solicitation, the full scope of capabilities offered by Tyler’s eFile module were not included in the SCTS scope of work. However, these additional capabilities will satisfy and streamline separate agency needs within one, integrated SCTS platform. This proposed additional work modification will add licensing for Tyler’s eFile module along with professional services to configure and implement the software as part of NARA’s ongoing SCTS implementation.

IV. IDENTIFICATION OF THE STATUTORY EXCEPTION AND SUPPORTING

RATIONALE

In accordance with General Services Acquisition Manual / Regulation (GSAM/R) 538.7104-

3(b)(ii), the unique solution exception is being used to execute an out-of-scope, additional work modification to GSA MAS Task Order 88310326F00140 with Tyler Technologies, LLC. As detailed in Section III, Tyler’s eFile module seamlessly extends the capabilities of the newly competitively procured SCTS platform by automating OF-306 data collection, handling user registration, and providing direct Login.gov integration. Procuring this add-on eFile module through Tyler as an additional work modification to the existing task order will establish a unified architecture by combining SCTS, Form 6006, and OF-306 workflows into a single system, thereby centralizing sensitive PII data collection. Specifically, the Tyler eFile module provides native platform integration dependencies that cannot be replicated by third-party tools.

Implementing an alternative commercial-off-the-shelf (COTS) solution would require building custom application programming interfaces (APIs) and middleware layers. Furthermore, deploying a disparate, external software tool severely compromises agency security governance and compliance posture. Transmitting highly sensitive PII—including Social Security Numbers and birth dates—across external interfaces introduces unnecessary data-in-transit exposure and security risks. Disparate systems create fragmented audit logging, disparate access control policies, and gaps in end-to-end encryption, directly undermining NARA's continuous monitoring capabilities and Federal Information Security Modernization Act (FISMA) authorization boundaries. In contrast, native integration within the Tyler platform ensures seamless end-to-end security governance, centralized audit capabilities, strict role-based access control (RBAC), and full alignment with NARA's FedRAMP-accredited SCTS environment.

Ultimately, leveraging the unique source authority to expand the established Tyler Tech ecosystem represents the only technically viable and secure path forward. By utilizing native platform dependencies and integrated COTS capabilities, NARA mitigates critical cybersecurity vulnerabilities, eliminates complex middleware failure points, and enforces robust security governance across its personnel security infrastructure.

V. A DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND

REASONABLE.

Given this modification will be issued under the existing GSA MAS task order, the vendor’s quoted licensing costs and labor rates must be at or below its GSA MAS contract rates which were determined fair and reasonable by GSA.

VI. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION.

Prior to proceeding with this sole source action, NARA assessed whether the inclusion of these capabilities in the SCTS solicitation would have impacted the original field of competition or award selection. That assessment revealed that the competing COTS solutions were primarily personnel security management platforms without native capabilities to intake or automate OF-

306 data collection. Market research confirmed that no other standard COTS secure forms platform can integrate directly into NARA's established SCTS architecture without custom

APIs, proprietary interface engineering, and ongoing integration support. Consequently, including these requirements in the initial solicitation would not have altered the competitive outcome, as no rival COTS solution natively offers the required unified architecture.

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

REMOVE OR OVERCOME ANY BARRIERS THAT LED TO THE SOLE SOURCE

JUSTIFICATION BEFORE ANY SUBSEQUENT ACQUISITION FOR THE

SUPPLIES OR SERVICES IS MADE.

The agency will continue to monitor the commercial market for emerging software technologies.

VIII. THE CONTRACTING OFFICER’S CERTIFICATION THAT THE JUSTIFICATION

IS ACCURATE AND COMPLETE TO THE BEST OF THE CONTRACTING

OFFICER’S KNOWLEDGE AND BELIEF.

IX. 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 A SOLE SOURCE JUSTIFICATION) AND WHICH FORM A

BASIS FOR THE JUSTIFICATION HAVE BEEN CERTIFIED AS COMPLETE AND

ACCURATE BY THE TECHNICAL OR REQUIREMENTS PERSONNEL.

X. A WRITTEN DETERMINATION BY THE APPROVING OFFICIAL THAT ONE OF

THE CIRCUMSTANCES IN GSAM/R 538.7104-3(b) APPLIES TO THE ORDER.