West TX_South TX_New Mexico_Contract Consolidation Determination and Findings Redacted.pdf

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Notice of Consolidation Determination for Protective Security Officer (PSO) Services for West Texas, South Texas and New Mexico
Solicitation number
70RFP426QE7000007
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This is a Determination and Findings document for contract consolidation issued by the Department of Homeland Security Federal Protective Service (FPS). The determination authorizes consolidating three existing Protective Security Officer (PSO) service contracts covering West Texas, South Texas, and New Mexico into a single contract valued at $368 million including all options. The consolidation is made pursuant to FAR 7.107-2 Class Deviation 25-32, R2 and applies to the NAICS code 561612 (Security Guards and Patrol Services), with APFS number F2026072551 published on November 21, 2025.

The three incumbent contracts being consolidated are: 70FRP420DE7000001 awarded to Paragon Systems, Inc. on July 21, 2020 ($132,616,218.79) for South Texas PSO services; 70FRP421DE7000003 awarded to Paragon Systems, Inc. on June 14, 2021 ($50,950,330.00) for West Texas PSO services; and 70FRP421DE7000001 awarded to Diversified Protection Corporation on July 1, 2021 ($60,444,960.00) for New Mexico PSO services. Market research conducted on October 3, 2025 via RFI to Track #1 large business Multiple Award Contract (MAC) holders identified seven MAC holders willing to bid and two declining due to competing priorities. The consolidation will eliminate redundant administrative efforts, reduce overhead costs, streamline contract management, improve resource allocation, enhance vendor accountability, and ensure consistent service delivery across the southern border region identified as a mission-critical national security priority. Small business participation will not be adversely affected as incumbents are large businesses and will be required to maintain small business subcontracting plans.

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2) Market Research

On October 3, 2025, FPS AD issued a Request for Information (RFI) to Track #1 (large business) Multiple Award Contract (MAC) holders to assess the potential for adequate competition for the award of a single contract encompassing the South Texas, West Texas, and New Mexico areas of responsibility. Of the responses received, seven (7) MAC holders expressed their intent to submit a quote, while two

(2) MAC holders stated they would not participate, citing competing priorities as the primary reason. The Market Research did not reveal any small businesses with contracts at or approaching the magnitude of the instant requirement.

Review of historical procurements indicates that the recurring requirement for services has proven difficult for vendors to sustain personnel under the smaller, location-based efforts, especially across South Texas. Further, the market research also provided insight into the historical operations involved with the location-based efforts, demonstrating redundant task order administration efforts due to the large number of orders, such as the processing of invoices.

(See attached Market Research Report)

3) Contracting Alternatives

The alternative to consolidating three efforts into one larger task order includes awarding three separate ID/IQ type contracts or three separate MAC task orders.

Consolidating the three location-based (West Texas, South Texas and New Mexico) requirements into a larger requirement will address inefficiencies in monitoring and administration efforts, reduction in overhead which may reduce overall costs, and increase quality of services by allowing a stabilized approach to retaining personnel. The alternative of continuing with the location-based requirements would retain a high administrative burden to initiate and monitor multiple efforts versus a single vehicle, including the corresponding costs associated, and would not allow for the anticipated performance improvements.

While awarding three individual contracts or task orders may offer flexibility to address the unique requirements for each area of responsibility, this acquisition strategy increases the administrative burden and complexity of the procurement process, increases cost, diverts resources from other mission critical requirements and diminishes overall efficiency.

4) Small Business Participation

The Federal Protective Service Acquisition Division, through its Office of Procurement Operations Small Business Specialist, coordinated this Determination and Findings with the Office of Small and Disadvantaged Business Utilization (OSDBU).

The consolidation of South Texas, West Texas and New Mexico contracts will not adversely affect small business participation, as the incumbent contracts are all currently performed by large businesses and were solicited unrestricted. The consolidation will not displace or exclude small businesses from existing opportunities and conversely aims to enhance efficiency and streamline the procurement processes without altering the competitive landscape for small businesses. All of the Multiple Award Contracts include a small business subcontracting plan. Additionally, it may create new opportunities for small businesses to participate as subcontractors or free them to compete in future solicitations for requirements that better align with their capabilities.

5) Benefits

The benefits of consolidating these efforts under one contract include reduction in overhead which may reduce overall costs, simplified contract management, improved resource allocation, and more efficient strategic planning.

Reduction inOverhead: Consolidation may reduce overall procurement costs and streamline operations by avoiding duplication of effort from the pre-solicitation phase through contract closeout. Consolidation will also eliminate the need to prepare multiple solicitations, convene multiple technical evaluation panels, and administer three separate contracts.

Simplified Contract Management: Consolidation will streamline the contract management process, enhance operational efficiency and eliminate redundancies, which would be unavoidable with the award of three separate contracts. One vendor can provide standardized services across all locations, ensuring consistent quality and a reduction in the time and effort required for contract administration. This streamlined approach improves operational effectiveness by enabling faster decision-making, reducing delays, and improving resource allocation.

o Consolidating the contracts into a larger area of responsibility will increase efficiency in monitoring and administering the services. Redundant actions across multiple contracts/ task orders will be streamlined into one action.

Examples of streamlining to increase administrative efficiencies are invoice processing, issuance of FAR Class Deviation 25-32, R2 notices, modifications to exercise option periods, etc.).

Resource Allocation: Consolidating these efforts under a single contract will allow

Enhanced Vendor Accountability – Simplifies performance monitoring, making it easier to ensure compliance with the SOW and hold the vendor accountable for instances of non-compliance Administrative Efficiency – Reduction in the time and effort required for the procurement process and contract management, allowing contracting personnel to focus on other priorities

6) Critical to Agency’s Mission Success:

While the quantifiable expected benefits under this consolidation do not meet the threshold for a substantial benefit, the benefits identified herein are critical to the Federal Protective Service’s mission success. The strategic geographic alignment under one contract at the southern border ensures consistency in performance thereby enhancing the overall quality of contract management and performance.

Administering one contract will lead to improved communication between FPS and the awardee’s management team, resulting in a faster response time to issues and contractual concerns.

Streamlining the procurement process will significantly reduce administrative time and overhead, enabling FPS to reallocate valuable resources toward other mission-critical initiatives. This approach enhances operational efficiency, allowing the agency to focus on activities that directly support its objectives and strengthen its ability to fulfill its mission.

The Southern border of the United States is a mission critical national security priority and the most significant vulnerable area within Region 7. By consolidating three requirements into a single contract, FPS can ensure comprehensive service coverage across all points of entry in the region. This consolidation will simplify communication by creating a single point of contact, enhancing operational coordination, improving efficiency, and ensuring consistent implementation of the policies and procedures in the SOW.

Contract consolidation enhances efficiency, strengthens vendor accountability, and improves service quality which are key factors in achieving operational goals and maintaining critical mission readiness. Additionally, this procurement strategy promotes maximum practicable participation by small business subcontractors, ensuring their continued contribution to the FPS’s needs while fostering innovation and competition.

DETERMINATION

I hereby determine that the benefits identified herein are critical to the Department of Homeland Security/ Federal Protective Service’s mission success even though the benefits of this consolidated acquisition are not substantial. Also, this procurement strategy provides for maximum practicable participation by small business.

Component Small Business Specialist Office of Small Disadvantage Business Utilization

Contracting Officer Federal Protective Service Acquisitions Division

Head of the Contracting Activity Office of the Chief Procurement Officer

APPROVAL:

Chief Procurement Officer Department of Homeland Security

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