Sole Source Justification for RFO 8 1_Redacted.pdf

SOLE SOURCE JUSTIFICATION

FAR 8.401(b) (FAR Class Deviation 25-20 R1 for FAR Part 8), GSAR 538.7104-3, HSAM 3008.401-71(a)

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Headquarter Formal Contracts Division 1 (OL-CG-HCA-COCO-1) proposes to enter into an order on a basis other than full and open competition.

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

(a) Name and address of the Vendor: LRP Publications, Inc., 360 Hiatt Drive, Palm Beach Gardens, FL 33418

(b) Type of action: Firm Fixed-Price (FFP)

(c) Estimated total value (including options):

Period Unit Price Total

23 August 2026 – 22 August 2027

12 mo.

(e) Type of funding: Operations and support funds

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: 70Z0236Q12500003

(h) Background information about the requirement: This requirement is a continuation of the services provided under contract 70Z02325F12500003, which was previously sole sourced to LRP Publications. LRP Publications has been delivering these critical services under a FFP contract, ensuring consistent and reliable support for the agency’s needs. The current contract is set to expire on August 22, 2026, necessitating a follow-on solution to maintain uninterrupted access to these mission-essential resources.

3. Description of Supplies/Services. The Civilian Employee Relations and Labor Relations

(ER/LR) staff represents the agency in matters before the Federal Labor Relations Authority (FLRA) and supports our Attorneys in matters before the Merit Systems Protection Board (MSPB), the Office of Special Counsel (OSC), Department of Labor’s Office of Worker’s Compensation Program (OWCP), and the Equal Employment Opportunity Commission (EEOC). Attorneys also assist the Department of Justice and the U.S. Attorney's Office with claims filed in federal court. The Civilian Human Resources Office and Attorneys of the Coast Guard (CG) Legal Office are required to conduct research on applicable laws, rules, regulations, case decisions, arbitration awards, worker’s compensation decisions, and any reference material associated with specific employment and labor law issues and cases.

LRP Publications, Inc. is the sole developer/manufacturer/distributor of “CyberFeds on the

Web”, a proprietary searchable federal employment and labor resource computer database.

The CyberFeds subscription database provides users with access to numerous databases containing federal employment and labor resources. The USCG has an immediate requirement for 57 unlimited access user licenses with training/technical assistance for a 12-month period and a reasonable expectation of requiring use of the resources for an additional year. Access to three (3) Workers’ Compensation and four (4) eLearning on CyberFeds Subscriptions.

4. Identification of Statutory Exception and Rationale.

The statutory exception is GSAR 538.7104-3(b)(ii) Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.

5. Demonstration of the Proposed Contractor’s Unique Qualifications to Provide the Requirement.

The “CyberFeds on the Web” database, developed, manufactured, and distributed exclusively by LRP Publications, Inc., is a proprietary resource that provides comprehensive, searchable access to federal employment and labor law materials. No other product or service offers the same breadth, depth, and functionality as CyberFeds, nor is any alternative available from other Vendors. LRP Publications, Inc. is the sole source for this database and associated training/technical assistance.

The work required for this requirement is unique or highly specialized. The ER/LR Specialists as well as CG Attorneys require access to an electronic federal law employment database that meets the following requirements:

a. Provides computer access to searchable electronic versions of the following valuable employment law guides: Peter Broida’s A Guide to Federal Labor Relations Authority Law and Practice, and A Guide to Merit Systems Protection Board Law and Practice, as well Ernest Hadley’s Work, A Guide to the Federal Sector Equal Employment Law and Practice.

b. Provides user-friendly tips, best practices and practical guidance for federal employment law attorneys, human resources officials, management officials, EEO counselors, and other professionals working in the area of federal employment.

c. Provides up-to-date news alerts, updates, and commentary from employment and labor law experts regarding new developments in federal employment and labor law.

d. Provides easy and user-friendly access to federal agency regulations, decisions, and directives from federal agencies relevant to the practice of federal employment and labor law, including the OPM, MSPB, OSC, EEO, FLRA, and

OWCP.

While other research platforms exist and offer some federal employment-related content, none match the distinctive blend of resources, tools, and expert-authored treatises found in CyberFeds. These materials are mission-essential for USCG attorneys, labor relations staff, and HR specialists, who rely on them to ensure compliance with federal employment law, manage workforce policies, and support agency decision-making.

Replacing CyberFeds with another platform would:

a. Deprive USCG of access to exclusive and authoritative legal resources

b. Attorneys and ER/LR staff would have to rely on fragmented, less comprehensive, and less current free or ad hoc sources, significantly increasing the time required to research grievances, appeals, EEO complaints, and other matters and delaying case handling and decision-making

c. The risk of inconsistent, incomplete, or outdated legal research would increase, elevating the likelihood of legally deficient personnel actions, adverse findings before FLRA/MSPB/EEOC/OWCP, and potential orders for corrective action, attorney fees, or other remedies

d. The Coast Guard’s ability to timely support the Department of Justice and U.S.

Attorney’s Offices in federal court cases involving civilian employment matters would be degraded, potentially weakening the Government’s litigation posture

e. Increase risk of non-compliance with federal mandates, potentially exposing USCG to grievance or legal challenges

6. 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.

Sherylan Spears Date Contracting Officer

7. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Date

Technical Representative/COR

FINAL APPROVAL

Sherylan Spears Date Contracting Officer

5/28/2026

5/28/2026