Justification for an Exception to Fair Opportunity Redacted

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

10 U.S.C. § 3205

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by Federal Acquisition Regulation (FAR) 16.507-6(d)(2) (FAR Class Deviation 26-04 Rev. 1 1), this justification for an exception to fair opportunity is supported as follows:

1. Agency and Contracting Activity.
Department of Homeland Security, United States Coast Guard (USCG), Office of Contracting & Procurement (C&P) Air Acquisitions (CG-AIR-C12)

2. Nature and/or Description of the Action being Approved. (a) Nature of the action: The Coast Guard plans to award a non-competitive sole source contract for project management and implementation support for essential healthcare IT services.
(b) Name and address of the contractor:
Ellumen, Inc.
8403 Colesville Rd, STE 340
Silver Spring, MD 20910

(c) Contract Type: Firm Fixed-Price Task Order.
(d) Estimated total value (including options): $1,867,913 Period

Period of Performance (POP)

Total

Base Year

09/30/2026 - 09/29/2027

$1,867,913

(e) Type of funding: Operations and Support (O&S) Funds.

(f) Year of funding: Fiscal Year 2026.
(g) Solicitation number: 70Z02326R93330003

In this document, citations to RFO Parts 6, 10, 15, 16, and 25 are citations specifically to FAR Class Deviation 2511 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 Rev. 1 for FAR Part 15, FAR Class Deviation 26-04 Rev. 1 for FAR Part 16, and FAR Class Deviation 25-09 Rev.1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

Last Updated 07/23/26

(h) Background information about the requirement: This requirement was previously competitively procured and awarded on 30 September 2022, as firm-fixed price Task Order # 70Z02322F93330002, in the amount of $2,863,770.18 for the Base year. The Task Order was competed under the NITAAC CIO-SP3 Small Business GWAC vehicle HHSN316201200132W and established for a One (1) 12-month Base Period and Three (3) 12-month Option Periods. The following table provides an overview of Task Order 70Z02322F93330002 detailing the Periods of Performance and the Total Obligated Amounts per period:
Period

Period of Performance
(POP)

Base Period
Option Period 1
Option Period 2
Option Period 3

09/30/2022 to 09/29/2023
09/30/2023 to 09/29/2024
09/30/2024 to 09/29/2025