Employee Benefits Security Administration (EBSA) Employee Retirement Income Security Act of 1974 (ERISA) Filing Acceptance System II (EFAST2) - Justification
Overview
Buyer
Place of Performance
NAICS
PSC
Set Aside
Original Source
Timeline
Qualification Details
Fit reasons
- NAICS alignment with historical contract wins in similar service areas.
- Scope strongly matches core technical capabilities and delivery model.
Risks
- Past performance thresholds may require one additional teaming partner.
- Potential clarification needed on staffing minimums before bid/no-bid.
Next steps
Validate eligibility requirements, assign capture owner, and schedule partner outreach to confirm teaming strategy before submission planning.
Quick Summary
The Department of Labor's Employee Benefits Security Administration (EBSA) has issued a Sole Source Justification for a bridge contract to ensure continuity of operations for the Employee Retirement Income Security Act of 1974 (ERISA) Filing Acceptance System II (EFAST2). This action is necessary to sustain critical filing capabilities for EBSA, IRS, and PBGC while a competitive modernization acquisition is planned. The incumbent, GDIT, will continue to operate the system due to exclusive control of operational artifacts and credentials.
Scope of Work
The EFAST2 system provides core capabilities for the receipt, validation, storage, and distribution of Form 5500 series and Form 5558 filings. The required services for this bridge contract, covering filing years 2026-2028, include:
- Sustainment of production operations.
- Delivery of annual rollover updates.
- Daily data distributions to IRS, PBGC, and EBSA as defined in the Interface Requirements Document (IRD).
- Operation and maintenance of the EFAST2 system, which supports approximately 1.2 million annual submissions.
- Contact center/help-desk support.
- Implementation of additional form requirements from IRS, PBGC, and EBSA.
- All security and compliance documentation required for FedRAMP Moderate, CUI/FTI processing, and Section 508 compliance.
- Execution of a Transition/Knowledge Transfer Plan to enable a future competitive modernization award.
Contract & Timeline
- Type: Sole-source order against GSA FSS MAS Contract Number GS-35F-393CA.
- Period of Performance: Base period of twelve (12) months with two (2) six (6) month option periods.
- Estimated Value: $15,454,665.50 (includes infrastructure and software licensing).
- Incumbent: GDIT.
- Published Date: April 20, 2026.
Set-Aside
This is a sole-source action justified under FAR 8.401 and GSAM 538.7104-3(b)(1)(ii). No set-aside applies.
Evaluation
This is a justification for a sole-source award, not a solicitation for proposals. The Contracting Officer will determine that the order represents the best value, considering price and administrative costs.
Additional Notes
The justification highlights the incumbent's exclusive control of critical operational artifacts and credentials, making them the only vendor capable of immediately assuming operations without disruption. Market research indicated no other vendor could meet this requirement. A transition/knowledge transfer plan will be implemented to facilitate a future competitive procurement for modernization.