USITC Form 053 JA - TCG HTS dev project.pdf

U.S. International Trade Commission 500 E Street, SW Washington, DC 20436 United States 202-205-3098 www.usitc.gov

Justification & Approval Limited Sources/Brand Name for Federal Supply Schedule

USITC - 053 (Rev. 6/2016)

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REQUISITION NUMBER: 6100-OCIO-25-0137

1. CONTRACTING OFFICE

U.S. International Trade Commission Office of Procurement 500 E Street, SW Washington, DC 20436

REQUIRING OFFICE

Washington, DC 20436

Office of Chief Information Officer

2. NATURE/DESCRIPTION OF ACTION(S)

Sole Source

3. DESCRIPTION OF SUPPLIES/SERVICES (Check box below:)

Support services (non-R&D)

Supplies/equipment

Information technology (IT)

Other (specify):

4. ESTIMATED CONTRACT VALUE i

5. ANTICIPATED PERIOD OF PERFORMANCE/ DELIVERY DATE i

Choose Option:

This requirement is to purchase:

This requirement is to modify the existing Task Order # 34300022F0021 with TCG to add eight additional software development resources to expedite the schedule from 24 to 12 months for implementing the USITC's new re-engineered Harmonized Tariff Schedule application. All work to be performed is within the scope of the current contract.

i

Choose Option: Period of Performance

Washington, DC 20436 United States 202-205-3098 www.usitc.gov

Justification & Approval Limited Sources/Brand Name for Federal Supply Schedule

USITC - 053 (Rev. 6/2016)

Print Form

In accordance with FAR Subpart 8.404(d), services offered on Federal Supply Schedules are priced either at hourly rates, or at a fixed price for performance of a specific task. The awarding agency has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable.

The determination of best value was made upon award of the current contract # 34300022F0021 with TCG, Inc. to provide IT software development and maintenance services through the CIO-SP3 contract vehicle.

6. AUTHORITY AND RATIONALE i

FAR Subpart 8.405-6(a)(1)(i)(A) An urgent and compelling need exists, and following the procedures would result in unacceptable delays;

FAR Subpart 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; or

FAR Subpart 8.405-6(a)(1)(i)(C) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

FAR Subpart 8.405-6(b) An item peculiar to one manufacturer (Example: particular brand name, product, or a feature of a product, peculiar to one manufacturer.)

The USITC has chosen to expedite the timeline for implementing a re-engineered version of the custom software application to maintain the Harmonized Tariff Schedule (HTS) of the United States and to provide search and access capabilities to it by the public. This project was planned to be conducted within the scope of the current IT Software Development and Maintenance contract (34300022F0021 ) over an 18-24 month period spanning two option years on the contract, but due to the high rate of tariff changes occurring under the current Administration, it was determined to expedite the implementation of this project to 12 months to be able to maintain the HTS more effectively and to better serve the U.S. public.

Because of TCG, Inc.'s knowledge and technical skill with implementing the current version of the HTS application, they are uniquely qualified within the scope of their current contract as the sole source to support the USITC with this expedited project. To accommodate the shortened timeline for this project, additional funding must be added to the contract for the necessary, but temporary, increase in staff resources.

Allowing any other vendor to perform the services would cause such undue delay that the project would be a risk of not meeting our requirement for providing an up to date and accurate HTS.

7. DETERMINATION OF BEST VALUE

This acquisition is being conducted under the authority of the Multiple-Award Schedule Program. The proposed action may be awarded on a limited sources basis under the following authority: Check box below and provide supporting rationale.

Washington, DC 20436 United States 202-205-3098 www.usitc.gov

Justification & Approval Limited Sources/Brand Name for Federal Supply Schedule

USITC - 053 (Rev. 6/2016)

Print Form

Market research was not conducted because the work to be performed is within the scope of the current IT software development and maintenance contract in 2022, which was a re-compete of the preceding contract awarded to TCG in 2017. As the incumbent, TCG is uniquely qualified to meet the USITC's need to expedite the HTS application re-engineering project because of their existing knowledge of the HTS and the current software application that is used to maintain and access it.

As the seven-year incumbent on the current contract, TCG has demonstrated that they are highly capable in performing the required work for this project by having been consistently provided exceptional software development work throughout the periods of performance on both the original and follow-on contracts.

8. MARKET RESEARCH

9. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION

10. FUTURE PLANS TO PROMOTE COMPETITION

As the Agency retires existing networking components due to age or serviceability, an analysis is performed to find the best value technically suitable solution. This is not restricted to any one vendors products. The Agency weighs several measures when selecting the appropriate solution. Including technical capabilities, staff training requirements, initial product cost, and on-going maintenance. When TCG's current order expires on 09/28/2027, a full competition will be held to find our next provider of these services.

Washington, DC 20436 United States 202-205-3098 www.usitc.gov

Justification & Approval Limited Sources/Brand Name for Federal Supply Schedule

USITC - 053 (Rev. 6/2016)

Print Form

11. TECHINICAL PERSONNEL/REQUIRING OFFICE CERTIFICATION

Date: May 13, 2025

Requestor/COR

Signature:

Print Name: Joel Moeller, CORPrepared By:

Date: May 14, 2025

Office Director/Cost Center Manager

Signature:

Print Name: Keith Vaughn, CIO/CCMApproved By:

12. CONTRACTING OFFICER CERTIFICATION

I have received this justification and find it to be accurate and complete to the best of my knowledge and belief.

Date: May 14, 2025

Contracting Officer

Signature:

Print Name: Ian Quillman, COApproved By:

I certify that the facts and representations in this justification, included herein, meet the Government's need and that the supporting data which forms the basis for this justification is complete and accurate

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500 E Street, SW Washington, DC 20436 United States 202-205-3098 www.usitc.gov Justification & ApprovalLimited Sources/Brand Name for Federal Supply Schedule Page of USITC - 053 (Rev. 6/2016)

1. CONTRACTING OFFICE

U.S. International Trade Commission Office of Procurement 500 E Street, SW Washington, DC 20436

REQUIRING OFFICE

U.S. International Trade Commission

500 E Street, SW Washington, DC 20436

2. NATURE/DESCRIPTION OF ACTION(S)

3. DESCRIPTION OF SUPPLIES/SERVICES (Check box below:)

4. ESTIMATED CONTRACT VALUE

i Insert independent government estimate of value, which must include all option years if applicable.

Type numbers only

5. ANTICIPATED PERIOD OF PERFORMANCE/ DELIVERY DATE

i Insert the anticipated period of performance or delivery time frame.

In accordance with FAR Subpart 8.405-6, this limited sources justification for other than full and open competition will result in award of a Federal Supply Schedule order for the brand name .

Choose Option:

to This requirement is to purchase:

In accordance with FAR Subpart 8.405-6, this limited sources justification for other than full and open competition will result in award of a Federal Supply Schedule order for the brand name .

In accordance with FAR Subpart 8.405-6, this limited sources justification for other than full and open competition will result in award of a Federal Supply Schedule order to .

i Insert requirement and purpose of requirement.

Choose Option:

Options Through:

Contact Information Adobe LiveCycle Designer Template 9.0.0.2.20101008.1.734229

6. AUTHORITY AND RATIONALE

i [Insert limited sources Justification Rationale here]

[In supporting the sole source or brand name for supplies and equipment, provide a description of unique capabilities of equipment and/or software and the performance requirement that mandates such a feature.]

[In supporting the sole source or brand name for services, describe the unique qualifications, and/or facilities available from only the proposed source. It is not sufficient to demonstrate that a firm is exceptionally well qualified, or even the best qualified. The justification must demonstrate that no one else can satisfactorily perform the required service or study.]

[If urgency requires that the FSS procurement action be sole source, address the following: What are the unexpected facts or the unpredictable events that led to this situation? When is the required delivery or performance start date? Why this date? What specific harm to the Government will occur if the delivery is not made or performance not begun as scheduled. Demonstrate that we are procuring only those items and quantities urgently needed until a competitive procurement action can be developed, or that a separate competitive follow on is not practical. (Note: For procurements under FAR 8.4 which are urgent and will be competitive under FSS, a formal J&A is not required.)]

7. DETERMINATION OF BEST VALUE

This acquisition is being conducted under the authority of the Multiple-Award Schedule Program. The proposed action may be awarded on a limited sources basis under the following authority: Check box below and provide supporting rationale.

8. MARKET RESEARCH

9. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION

10. FUTURE PLANS TO PROMOTE COMPETITION

i [For follow-on acquisitions, provide 1) an estimate of the cost to the Government that would be duplicated and how the estimate was derived, and/or 2) a discussion of unacceptable delays in fulfilling the agency's need that would be incurred if award was made to another source.]

[Discuss how control of patent or data rights precludes competition, including the feasibility of purchasing necessary rights to permit development of competitive sources.] i [Insert actions that will be taken in the future that could possibly remove or overcome barriers to competition before any subsequent acquisition for the required supplies or services. If not possibly explain why.]

11. TECHINICAL PERSONNEL/REQUIRING OFFICE CERTIFICATION

Requestor/COR Prepared By:

Office Director/Cost Center Manager Approved By:

12. CONTRACTING OFFICER CERTIFICATION

I have received this justification and find it to be accurate and complete to the best of my knowledge and belief.

Contracting Officer Approved By:

I certify that the facts and representations in this justification, included herein, meet the Government's need and that the supporting data which forms the basis for this justification is complete and accurate Information technology (IT) In accordance with FAR Subpart 8.404(d), services offered on Federal Supply Schedules are priced either at hourly rates, or at a fixed price for performance of a specific task. The awarding agency has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable.

The determination of best value was made upon award of the current contract # 34300022F0021 with TCG, Inc. to provide IT software development and maintenance services through the CIO-SP3 contract vehicle.

The USITC has chosen to expedite the timeline for implementing a re-engineered version of the custom software application to maintain the Harmonized Tariff Schedule (HTS) of the United States and to provide search and access capabilities to it by the public. This project was planned to be conducted within the scope of the current IT Software Development and Maintenance contract (34300022F0021 ) over an 18-24 month period spanning two option years on the contract, but due to the high rate of tariff changes occurring under the current Administration, it was determined to expedite the implementation of this project to 12 months to be able to maintain the HTS more effectively and to better serve the U.S. public.

Because of TCG, Inc.'s knowledge and technical skill with implementing the current version of the HTS application, they are uniquely qualified within the scope of their current contract as the sole source to support the USITC with this expedited project. To accommodate the shortened timeline for this project, additional funding must be added to the contract for the necessary, but temporary, increase in staff resources. Allowing any other vendor to perform the services would cause such undue delay that the project would be a risk of not meeting our requirement for providing an up to date and accurate HTS.

Market research was not conducted because the work to be performed is within the scope of the current IT software development and maintenance contract in 2022, which was a re-compete of the preceding contract awarded to TCG in 2017. As the incumbent, TCG is uniquely qualified to meet the USITC's need to expedite the HTS application re-engineering project because of their existing knowledge of the HTS and the current software application that is used to maintain and access it.

As the seven-year incumbent on the current contract, TCG has demonstrated that they are highly capable in performing the required work for this project by having been consistently provided exceptional software development work throughout the periods of performance on both the original and follow-on contracts.

As the Agency retires existing networking components due to age or serviceability, an analysis is performed to find the best value technically suitable solution. This is not restricted to any one vendors products. The Agency weighs several measures when selecting the appropriate solution. Including technical capabilities, staff training requirements, initial product cost, and on-going maintenance. When TCG's current order expires on 09/28/2027, a full competition will be held to find our next provider of these services.