BDAS ED FSS SSJ Above SAT RFO 9 2026

CONTROLLED UNCLASSIFIED INFORMATION

WHEN FILLED IN

U.S. Department of Education

FEDERAL SUPPLY SCHEDULE (FSS) SOLE-SOURCE JUSTIFICATION

(SSJ) REVOLUTIONARY FAR OVERHAUL (RFO)

ORDERS PLACED OR BLANKET PURCHASE AGREEMENTS (BPAS) EXCEEDING

THE SIMPLIFIED ACQUISITION THRESHOLD (SAT)

CONTRACT INFORMATION

PROCUREMENT TITLE:

Borrower Defense Adjudication Support

ACTION ID NUMBER:

91003126F0014 & 91003126F0015

ESTIMATED VALUE:

$81,382,398.35

PRINCIPAL OPERATING COMPONENT (POC):

Federal Student Aid (FSA)

1. IDENTIFICATION OF CONTRACTING ACTIVITY.
Federal Student Aid (FSA) Contracts Operations Division (COD)

2. NATURE AND/OR DESCRIPTION OF THE ACTION INCLUDING A DESCRIPTION

OF THE SUPPLIES/SERVICES REQUIRED TO MEET THE AGENY’S NEEDS. Vendors must support the delivery of Attorney Services adjudication work to the Department of Education (The Department). The Borrower Defense Branch (BDB) of Federal Student Aid (FSA) requires assistance from contract attorneys to adjudicate applications pursuant to 34 C.F.R. § 685.222, 206(c), 206(e), and the Sweet v. McMahon settlement agreement. Adjudication consists of both fact-finding, which is done on a school level; and adjudication of individual borrower applications. Fact-finding is a regulatory required process for schools with pending borrower defense applications which includes a review of Department records,
applications,
other materials.RATIONALE.
After fact-finding is complete the associated applications

3. THEborrower

AUTHORITY

ANDand

SUPPORTING

will be adjudicated under the appropriate regulatory standard(s), subject to a 20% quality control process and The statutory exception supporting the placement of an order or an establishment of a FSS BPA that 100%
finalthe
review
process.
BDB uses
a customized
Salesforce
interface
to track, record,
exceeds
SAT on
a sole-source
basis
as implemented

by GSAM/R

538.7104-3(b)
is: and issue
decisions. Services must be provided using this tool.
538.7104-3(b)(iii) – Logical follow-on.
Provide the rationale behind the selection of the above statutory exception.

The rationale behind the selection of the exception is based on the fact that the scope of the original work has proven to be larger than initially anticipated, resulting in extended timelines for completion. Given this circumstance, it is logical and efficient to continue utilizing the current contractors who are already familiar with the project's requirements and complexities. Changing contractors would significantly impact time and