Justification for Exception to Fair Opportunity - RIMU A-File Mod Redacted

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3016.506-90

JUSTIFICATION FOR EXCEPTION TO FAIR OPPORTUNITY

EXCEEDING SAT: FAR 16.507-6

4. Statutory Exception and rationale for its use:
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RFO FAR 16.507-6(b)(1): The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

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RFO FAR 16.507-6(b)(2): Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

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RFO FAR 16.507-6(b)(3): The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

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RFO FAR 16.507-6(b)(4): It is necessary to place an order to satisfy a minimum guarantee.

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RFO FAR 16.507-6(b)(5): For orders exceeding the SAT, a statute expressly authorizes or requires that the purchase be made from a specified source.

Rationale:
ICE/OAQ intends to modify RIMU Task Order 70CTD024FR0000094 to add A-File integration support. ICE requires the RIMU records-management environment to be modified to integrate the Office of the Principal Legal Advisor’s (OPLA) PLAnet litigation case management system with the United States Citizenship and Immigration Service’s (USCIS) STACKS digital A-File repository through ICE's data mesh/Application Programming Interface (API) gateway architecture while preserving the accuracy, completeness, security, chain of custody, retrievability, and lawful disposition of Permanent Record A-File information. This effort constitutes a logical follow-on to the original competitive award, as the integration relies entirely on the technical architecture, security baselines, and records-management frameworks already established and maintained by the incumbent under the existing task order. The requirement is not a stand-alone software development effort; it is an extension of the active RIMU environment requiring deep, low-level access to the integrated ICE/OPLA/USCIS data ecosystem. Pursuant to RFO 16.507-6(b)(3), this modification is in the interest of economy and efficiency because it prevents duplicative dual-vendor system discovery and development efforts that would create an unacceptable schedule risk, and because it prevents the unmanageable division of accountability between multiple vendors that could compromise system