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AO 370C (12/18)

JUDICIARY PROCUREMENT PROGRAM

LIMITED SOURCES JUSTIFICATION (LSJ)

This acquisition is being conducted under the GSA Multiple Award Schedule Program (See FAR 8.401)

1. Agency name, contracting activity and requesting office (provide identification of judiciary organization requesting the 

procurement, i.e., Administrative Office of the US Courts, department, office OR court unit or federal public defender organization)

 Administrative Office of the US Courts, Procurement Management Division (PMD) in support of the 

Department of Technology Services (DTS), Information Technology Security Office (ITSO). 

 

2. Nature and description of the action and the estimated dollar value of proposed procurement

 ITSO requires Systems Security Testing Services for up to an additional one year period. This 

year of services is estimated at . 

This requirement will be a modification (mod) to Axxum's current order (USCA15BPAC1020) 

under Axxum's Security Penetration and Validation Testing Blanket Purchase Agreement 

(BPA), USCA15B0007. USCA15BPAC1020 expires on 08/16/2020 and this mod will add two 

6-month options to that order, potentially extending the period of performance to 08/16/2021. 

3. Description of supplies/services required to meet judiciary needs 

 ITSO requires contract labor for up to 1 year for System Security Testing in support of the Judiciary 

Systems Security Testing (JSST) and National Systems Security Assessments (NSSA) branches within 

the Security Policy and Assessments (SPA) division of ITSO. These branches within ITSO-SPA 

provide continuous assessment services for a wide variety of applications and systems in use throughout 

the Judiciary. The services these branches provide is critical to making sure that vulnerabilities and 

security issues are identified in a timely manner before these systems and applications go into the 

production environment. A failure or lapse in these assessments may result in various systems and 

applications going into the Judiciary's production environment with vulnerabilities and security risks 

that may be exploited by bad actors. To mitigate this risk, ITSO-SPA requires contractor support for up 

to one additional year to carry out the actual testing and assessment services to support this critical 

assessment service. 

4. Basis for limiting sources/Authority 

 Brand Name/Items peculiar to one manufacturer - FAR 8.405-6(b) and Guide Vol. 14 § 310.50.66 

 An urgent and compelling need exists and following competition procedures would result in 

 unacceptable delays - FAR 8.405-6(a)(1)(i)(A) and Guide Vol. 14 § 310.50.63(a)(1) 

 Only one source can provide the supplies or services required at the level of quality 

 required because the supplies or services are unique or highly specialized - FAR 8.405-

6(a)(1)(i)(B) and Guide Vol. 14 § 310.50.63(a)(2)) 

 In the interest of economy and efficiency, the new work is a logical follow-on to an original FSS 

 order provided that the original order was placed in accordance with the applicable FSS ordering 

procedures. The original order or BPA must not have been previously issued under sole-source or 

limited-sources procedures - FAR 8.405-6(a)(1)(i)(C) and Guide Vol. 14 § 310.50.63(a)(3) 
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AO 370C (12/18)

JUDICIARY PROCUREMENT PROGRAM

LIMITED SOURCES JUSTIFICATION (LSJ)

This acquisition is being conducted under the GSA Multiple Award Schedule Program (See FAR 8.401)

5. Supporting rationale (explanation of the unique nature of products/services being procured, contractor's unique qualifications, or 

other factors supporting use of the authority cited)

 Please see the LSJ Addendum for the supporting rationale. 

6. Description of market research conducted among schedule holders and the results, or explanation why market 

research was not conducted 

 Market research was not conducted for this specific mod as the mod is a logical follow on to an order 

that was placed off a BPA created from Axxum's GSA schedule. There is no other vendor that can 

provide this logical follow on service. 

 With the above said, the AO is currently conducting extensive market research as it relates to the 

upcoming recompete for the services Axxum is currently providing so as to maximize competition. 

7. Actions, if any, the judiciary may take to remove or overcome any barriers that led to restricted consideration 

before any subsequent acquisition for the supplies and services is made 

 As mentioned above, the AO is currently carrying out market research and taking action to remove any 

barriers or incumbent advantage for the re-compete so that all vendors have a level playing field to 

compete for the new contract at the end of this logical follow-on work. The AO is also structuring the 

follow-on mod with a more limited time period with two 6-month options. In the event the testing issues 

regarding and the increased volume of testing are addressed in the first 6-month period, the 

AO may not exercise the additional 6-month option period and shall transition the work to the winner of 

the re-compete of these services. 

8. Confirm that the Contracting Officer has sought a price reduction consistent with Guide Vol. 14 § 

 310.50.40(c) (Required for purchases exceeding the GSA Simplified Acquisition Threshold ($150,000)

 The Contracting Officer shall seek a price reduction during negotiations of the follow-on modification. 

Best value for the logical follow-on work shall be determined in accordance with FAR 8.404(b). The 

BPA's pricing was established in accordance with FAR 8.404(b) and the CO has verified that the BPA 

pricing is less than Axxum's GSA FSS rates, and the current order that will be modded has pricing that 

is equal to or less than Axxum's BPA pricing. The modification to USCA15BPAC1020 for the logical 

follow-on work shall only include pricing that is less than or equal to Axxum's BPA rates and any 

pricing added to the order shall be evaluated to make sure the pricing is fair and reasonable and the 

pricing is in accordance with FAR 8.404(b). 

Certifications and Signatures:

To the best of my knowledge and belief, I hereby certify that the technical information provided in the above 

justification is accurate and complete. 

Judiciary Procurement Program 

Limited Sources Justification (LSJ) 

Addendum 

Section 5 – Supporting Rationale: 

In the interest of economy and efficiency, the work under this modification would be a logical 

follow-on to the work already being performed under USCA15BPAC1020, that was awarded off 

of Axxum’s BPA, USCA15B0007, that was awarded off their GSA Federal Supply Schedule 

(FSS), GS-35F-0189V. Axxum’s GSA FSS contract is currently active until January 25, 2024. 

Axxum’s BPA was not sole sourced nor was it competed under limited source procedures. 

Axxum’s BPA and current order were placed in accordance with the applicable FSS ordering 

procedures. For the following reasons, a logical follow on order per FAR 8.405-6(a)(1)(C) would 

be justified. 

ITSO-SPA provides security testing and assessment services to all of the court units and national 

program offices (NPOs) in the federal judiciary. Contract labor provides security testing of 

systems in a pre-production and production environments. The results of these tests identify 

levels of security risk to systems, program offices, court units, and the Judicary as a whole. 

The current vendor providing these services, Axxum, has a unique understanding of national and 

court developed applications. The current contract USCA15BPAC1020 expires on 08/16/2020. 

Before Axxum's current order expires, the JSST branch will be engaged in ongoing preproduction testing of the system 

that is scheduled to begin on 07/29/2020 and the assessment will not be completed before 

Axxum's current contract ends. 

 is one of the most widely used and relied upon applications throughout the Judiciary 

and is used by most if not all court units in the Federal Judiciary. Being able to seamlessly work 

with the program office to get new versions of approved and available is critical to the 

Judiciary's day-to-day operations and the mission of this branch of government. During the 

period of the logical follow-on work, the NSSA branch will also be in the middle of 3 NPO 

assessments: . 

The AO is currently working on a re-compete for the services currently provided by Axxum but 

it does not make sense to replace Axxum mid-assessment. A change in vendor during an 

assessment would require a complete restart of the assessment. Nor does it make sense for a new 

vendor to be thrown into assessing one of the Judiciary's most critical systems after onboarding. 

For and other court unit and NPO systems, delays to the pre-production testing would 

have a negative effect on the go-live and promised go-live dates as the testing dates are 

scheduled well in advance due to the number of factors that need to be aligned to allow for such 

testing. Such delays would result in the system owners having to make a choice between 

delaying release and incurring schedule and other performance costs or releasing the system into 

production without knowledge of any vulnerabilities and security risks they need to address. Due 

to the critical nature of and other systems currently planned for assessment, the 

Judiciary cannot take the risk of allowing these critical systems to enter production with potential 

security risks, nor can they push off the assessment process and delay the projects. 
Judiciary Procurement Program 

Limited Sources Justification (LSJ) 

Addendum 

The logical solution is to mod the current order to allow for the logical follow on work so that 

Axxum may carry out the current assessments that are planned without any delay, disruption or 

lapse of services so that and other NPO systems may be properly assessed and tested. 

There is also another reason that a logical follow-on mod makes sense. While testing and 

assessments for the various SPA offices has continued during the current pandemic situation, the 

volume of requests for testing has dropped and there has been a request to push back testing 

schedules as various court units and NPOs adjusted to the current situation. Based on current 

timelines for when things may go back to a more normal level of operations, the SPA branch is 

anticipating an increase in new testing requests along with an increase in the backlog of work 

that was pushed off previously. This work is expected over the coming months into the end of 

the year. SPA typically operates on a 14-business day queue and the flow of work is continuous, 

though the overall volume of work is expected to increase. 

SPA’s concern is similar to the issue with the system issues discussed above, as it is 

likely the work volume may increase under Axxum's current contract in late July and early 

August but then if Axxum were to be replaced by a new vendor all of the assessments would 

need to be restarted once the new vendor onboarded. System owners would again be left with 

difficult decisions in determining whether to delay production releases or take security risks by 

foregoing assessments. In addition, some of the systems coming up for testing require these 

security assessments before the organizations can transfer ownership of systems to other 

organizations. This would result in additional impacts to various organizations as they would be 

left with systems that they had not anticipated owning or controlling while entering a new fiscal 

year. 

In the interest of efficiency and economy, not to mention the best interest and security posture of 

the Judiciary, a logical follow on mod to Axxum’s current order makes the most sense.