Sole Source Justification 07.31.2026.pdf

U.S. Department of Justice

U.S Trustee Program

Executive Office for U.S. Trustees

Washington, DC 20530

Personnel Security Support – Parker Tide Page 1

Sole Source Justification GSA Ordering Procedures subpart 538.71

1. Agency and Contracting Activity.

This justification is prepared by the United States Department of Justice (DOJ), United States Trustee Program (USTP), Procurement and Property Branch.

The requiring agency is the DOJ United States Trustee Program (USTP). The contracting activity is the Justice Management Division (JMD) Procurement Services Staff (PSS), Office of Acquisition Management (OAM).

2. Nature and/or description of the item/service being procured and anticipated cost.

Parker Tide Corp will provide critical Personnel Security Support services based on their knowledge and experience of USTP and DOJ systems and policies.

Parker Tide Corp will provide critical administrative and operational support, allowing USTP Security Specialists to focus on higher-level adjudicative responsibilities, while ensuring security processing functions are completed efficiently and accurately. This position would help reduce existing backlogs, improve processing times for new hires, maintain compliance with federal personnel security standards, and mitigate operational risks associated with understaffing.

Given the current staffing levels, workload volume, and mission-critical nature of personnel security operations, the Personnel Security Specialist position is essential to maintaining effective program operations and supporting the organization’s workforce and security objectives.

The total estimated value of the task order is $96,020.64.

3. Identification of the authority and rationale.

This action is authorized by Federal Acquisition Regulation subpart 8.4 – Ordering under the Federal Supply Schedule. This sole source action will comply with GSA subpart 538.71 for actions under the Simplified Acquisition Threshold (SAT).

The rationale is as follows:

Only one reasonably available source:

☒ Urgent and compelling circumstances exist. The nature of the requirement has been deemed urgent due to unusual and compelling circumstances. Following competitive procedures would result in unacceptable delays resulting in serious injury to the Government.

Rationale:

The U.S. Trustee Program – Security Management Branch currently faces a significant workload imbalance due to a reduction in staffing from a team of five (5) personnel security professionals and one (1) student volunteer to only two (2) staff members. This reduction has substantially increased the workload assigned to each remaining employee and has created as risk to the timely completion of critical personnel security functions. This reduction was caused by the resignation of two specialists and the implementation of Executive Order 14158, issued on January 20, 2025. Executive Order 14158 established the Department of Government Efficiency (DOGE) to support efforts to reduce federal spending, streamline the federal workforce, and modernize government operations. In conjunction with related administration policies, these changes also resulted in the elimination of certain diversity-related programs, including the Hispanic Association of Colleges and Universities (HACU) program. As a result, the HACU program was terminated, and our section lost its student volunteer. Further, USTP was not authorized to fill vacant positions.

Currently the office has approximately 713 pending adjudicative determinations requiring review and disposition. These cases involve the detailed analysis of background investigation ranging from 80 – 150 pages in length and require the preparation of comprehensive summaries and adjudicative recommendations. The volume and complexity of this workload necessitate additional support to prevent delays in security determinations and onboarding activities. Prior to the reduction in staffing, the Security Management Branch (SMB) maintained an average workload of approximately 33 new adjudications per month while simultaneously working to eliminate a significant backlog of more than 1,200 adjudications that existed prior to the SMB leadership transition. During this period USTP leadership directed the SMB to prioritize pre-employment waivers and onboarding activities to meet the component’s 30-day turnaround requirement, resulting in adjudication delays due to limited staffing resources. Additionally, the implementation of the Intelligence Reform and Terrorism Prevention Act’s (IRPTA) 90-day adjudication window further increased the pressure on the branch to complete adjudication within mandated timeframes.

As staffing levels declined, the remaining personnel were required to absorb both the ongoing influx of new adjudications and the existing backlog, significantly increasing individual workloads and delaying the completion of critical adjudicative functions.

Contract support is needed to provide immediate surge capacity to address the backlog and current workload

In addition to the adjudication workload, the office processes between 20 and 60 new hires at any given time. These actions require review and verification of security packages, completion or pre-employment suitability checks (including credit, fingerprint, selective service, tax, drug testing, etc.), establishment and maintenance of security files, and initiation of background investigations. Timely completion of these activities is essential to support organizational hiring goals and ensure compliance with federal security requirements.

4. The anticipated price will be determined fair and reasonable based on one or more of the price analysis techniques described below.

☐ Market Research;

☐ Comparison of the proposed price with prices found reasonable on previous purchases;

☒ Current price list;

☐ Comparison with similar items in a related industry;

☒ Comparison to Independent Government estimate;

☐ Contracting Officer’s personal knowledge; or ☒ Other reasonable basis.

In accordance with FAR 8.4 and GSA subpart 538.7102-2(d), “Ordering activities are not required to …. Make a fair and reasonable price determination for FSS products, or solutions at the order level or BPA level as FSS contract pricing has been determined fair and reasonable.” However, the Contracting Officer will seek further price discounts or other concessions before placing the order.

5. A description of the market research conducted among schedule holders, and the results or a statement of the reason market research was not conducted.

Market research was conducted to review an existing GSA task order performing similar services for USTP. Task order 15JUST25F0000007 demonstrated Parker Tide Corp has the required expertise and personnel to meet USTP’s need in an expedited fashion.

Parker Tide Corp. has previously provided qualified Personnel Security professionals to the U.S. Trustee Program and is an established, vetted vendor familiar with the agency’s personnel security operations, policies, and adjudicative processes. Utilizing a previously vetted contractor enables USTP to obtain qualified personnel on an expedited timeline, eliminating the delays associated with identifying, vetting, and onboarding a new vendor.

6. Other facts supporting the justification.

The office is also responsible for numerous ongoing administrative and operational security functions, including:

• Managing and responding to security mailbox inquiries.

• Providing customer service and applicant support.

• Processing and adjudicating HSPD-12 Personal Identity Verification (PIV) credentials.

• Maintaining employee records within security management systems.

• Inventorying and maintaining a file room containing more than 1000 security case files.

• Preparing legacy files for digitization and uploading them into security systems.

• Managing records retention and destruction requirements.

The addition of Personnel Security Support Specialist will balance workload assignments to each remaining employee and mitigate the current risk of timely completion of critical personnel security functions. Expedited contractor support is critical to ensure the USTP can meet its personnel security mission and remain compliant with Executive Order 13467, as amended, which established government-wide requirements for continuous vetting and ongoing personnel security oversight of covered individuals. Additionally, OPM SuitEA Notice 2026-01, Streamlining Vetting Processes in Support of the Merit Hiring Plan (issued March 17, 2026), direct agencies to accelerate and modernize personnel vetting processes by fully leveraging existing vetting capabilities to improve timeliness and reduce delays. The DOJ-JMD has requested this mandate to be met by July 10, 2026.

Given the current staffing shortages, increased adjudicative workload, and ongoing continuous vetting requirements, utilizing an established and vetted contractor provides the immediate operational capability necessary to maintain compliance with federal personnel security requirements while supporting mission-critical adjudication and onboarding functions.

7. Certifications, Concurrences and Approval.

Technical/Requirements Personnel Certification:

I certify that the information contained in this document for which I am responsible, is accurate and complete to the best of my knowledge and belief.

Hyacinth Carter

EOUST – US DOJ

Chief, Facilities & Security Management Branch Security Program Manager

Date

Contracting Officer Approval:

I certify that this justification is accurate and complete.

Allen A. Tillman II Contracting Officer Chief of Procurement and Property U.S Trustee Program (USTP)

Date

Sole Source Justification