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Description
This posting provides notice that the limited-sources justification (LSJ) for the Technical Support for Payment Systems and Rates procurement is being posted pursuant to GSAR 538.7104-3(b)(3)(i), which requires the ordering activity to publish a notice and post the justification within 14 days after placing an order exceeding the simplified acquisition threshold that is supported by an LSJ. The agency requires the continuation of highly specialized ratesetting and related enterprise architecture activities that have been developed, refined, and maintained by Acumen since 2010. Acumen is the only responsible source capable of providing the required services at the level of quality and technical sophistication necessary to meet agency needs at this time. With more than a decade of continuous performance, Acumen has developed substantial institutional knowledge, proprietary analytical tools, and refinements to ratesetting models that are not replicated elsewhere in the market. These capabilities are currently inseparable from the agency's operational workflows and are essential for accurate, timely data production and the execution of rulemaking schedules. The current period aligns with critical milestones in the SAS Conversion and broader enterprise architecture modernization efforts, and introducing a new vendor at this stage would create significant operational and programmatic risk. Transitioning midstream would require reconstruction and relearning of proprietary methodologies, duplication of already-funded development, and revalidation of highly technical processes—all of which would result in unacceptable delays and substantial additional costs. Because the required work is deeply integrated with ongoing modernization activities and the SAS Conversion effort, switching vendors at this time would require extensive re-familiarization, redevelopment of analytical baselines, and re-establishment of complex data linkages. Such a transition would reduce efficiency, waste previously obligated funds, and delay key milestones associated with data validation and model conversion. While the continued Federal Supply Schedule (FSS) task order independently qualifies as a logical follow-on under FAR 8.405-6, the broader justification for continuity with Acumen further reflects the sole-source considerations described above. This acquisition also qualifies as a logical follow-on to the original Federal Supply Schedule order as it was awarded competitively using the General Services Administration (GSA)’s Multiple Award Schedule (MAS) SIN 541611. Continuing the work with Acumen is essential to preserving technical and operational continuity across interconnected workstreams that cannot be separated or re-sequenced without jeopardizing mission-critical deliverables. The ratesetting models, data production schedules, and enterprise architecture components under this contract directly support multiple regulatory and rulemaking timelines. Interrupting performance or onboarding a new vendor would compromise the sequencing and validation of these processes, introducing significant risk to statutory and policy deadlines. A short-term logical follow-on ensures continuity of operations, preserves the value of prior investments, and allows adequate time for full and open competition in 2028. It also gives the agency sufficient runway to develop updated metrics, engage with industry, build internal subject-matter expertise, and design a more targeted and cost-effective competitive strategy. Continuing the work with Acumen is therefore the most efficient and economical approach, and it squarely satisfies the FAR requirement for a logical follow-on acquisition. Please see the Attachments section of this notice for a complete copy of the approved LSJ. Note - This is NOT an active procurement opportunity but is instead a required posting of an approved LSJ subsequent to task order award.
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