JOFOC-CO Signed (CLD signed) mas.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

Business Applications Solution (BAS) Contract for Financial Management System Modernization

Identification Number: 1331L520C13OS0005

1. Identification of the agency and contracting activity.

The Shared Services Procurement Office (SSPO) within the Office of Acquisition Management in the Department of Commerce (the Department) proposes to modify contract number 1331L520C13OS0005 (the “Contract”), commonly referred to as the Department’s existing Business Applications Solution (BAS) contract, on the basis of other than full and open competition.

2. The nature and/or description of the action being approved.

The Department requires modernization of financial systems and development and maintenance of an Enterprise Data Warehouse (EDW) for the entire Department of Commerce, excluding only the Patent and Trademark Office. The period of performance of the Contract consists of a base year and 19 option years, for a total cumulative period of performance if all options are exercised of 20 years. The Contract was competed on a full and open, unrestricted basis, and awarded to Accenture Federal Services LLC (AFS) on April 24, 2020. The total value of the Contract at the time of award was $340,914,621.69.

The period of performance began on April 24, 2020, and the Contract is currently in the middle of option year six. This document justifies a modification that increases the total value of the Contract above which was originally contemplated.

3. A description of the supplies or services required to meet the agency’s needs

(including the estimated value).

The BAS program is a Department information technology modernization initiative to deploy an integrated suite of financial and business management applications in support of the Department's mission using a Software-as-a-Service (SaaS), cloud-computing environment. The Department requires comprehensive enterprise services for the BAS ecosystem including a phased implementation, solution advancement, stabilization, operations, maintenance, and hosting support to integrate, optimize, and advance the BAS platform as a mature Department-level shared service.

This program is currently in the final phase of a three-stage implementation that included transitioning BAS-related systems for the National Oceanic and Atmospheric Administration, then the U.S. Census Bureau, and currently the National Institute of

Standards and Technology1. Based on key findings from the previous implementations, additional support following the launch of the new BAS-related systems for a bureau is critical to its success. This support includes enhanced post-launch Hypercare, embedded transactional resource support, transactional backlog resolution, formal Hypercare certification, as well as organizational change management activities to facilitate adoption and sustainability.

In addition, as part of implementation activities, the Government identified additional license needs for the integrated BAS programs including Sunflower, PRISM, and the Oracle E-Business Suite, as well as the associated operations and maintenance services and hosting servers required for them. The increase in user population averaged over 80% across the programs and was due to the following:

• Use of the Projects module in EBS and more budget end users having access to those functions (separate from the general ledger)

• Users in Accounts Receivable and Accounts Payable inquiries roles updated from base contract award numbers to support end users inquiring and monitoring EBS system transactions

• Use of the PRISM requirements workspace which allows program end users to collaborate on procurement documents, increasing the end user population of PRISM beyond just the acquisitions community

• Reviewer functionality in the enterprise data warehouse allowing more end users to have direct access to running dashboards and accessing information

As part of implementation and production the Government also identified needed customizations to the programs for bureau or department-unique requirements including but not limited to cost allocation, labor projections, internal fund, unbilled collections, loan processing, accounts payable integration, financial treatments, and depreciation.

These customizations were implemented and now require additional operations and maintenance services above the base software configurations to ensure that end users can continue to use the functions that were customized.

As a result of these items, this modification would increase the total value of the Contract by $35,440,397.14.

4. An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. 3304 (a)(1), as implemented by the Revolutionary FAR Overhaul (RFO) Federal Acquisition

1 Bureaus and offices without their own financial systems were included in their servicing bureaus’ implementation.

Regulation (FAR) Subpart 6.103-1(b): Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. A statement demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring the use of the authority.

The additional implementation support items can only be performed by the existing contractor as they have the knowledge and expertise obtained through the implementation process and launch activities to support them in the immediate period following. Since this contractor has specifically configured the system, no other contractor has the required knowledge of, or access to, their system in the immediate post-launch timeframe needed to provide the support.

The provision of additional licenses and accompanying hosting and operations and maintenance is integrally related to the initial system. These licenses are for additional end users for programs within the same system, therefore no other contractor can provide this for the same instance(s) to provide seamless configuration, access, and support for all end users, as required. If these licenses and the corresponding hosting and operations and maintenance services were provided by another contractor the systems would not be integrated, which could cause mission failure and duplication of overall costs.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as possible, including whether a notice was or will be publicized as required by RFO FAR Part 5 and, if not, which exception under RFO FAR Part 5 applies.

The original BAS contract was awarded competitively, where all competing vendors were given an opportunity to be considered. On September 17, 2026, the Government posted a notice of intent to modify the total contract value on the basis of other than full and open competition in accordance with 41 U.S.C. 3304 (a)(1), implemented in FAR 6.103-1: “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements”. See section 8 for further sourcing details.

7. Determination by the contracting officer that the anticipated cost to the

Government will be fair and reasonable.

The Contracting Officer will ensure the prices for the modification are evaluated and negotiated in accordance the terms and conditions of the Contract and RFO FAR 15.4 to obtain fair and reasonable pricing for the Government. The Government will perform in-house technical and price evaluation to ensure that all prices are reasonable when applied to technical requirements and the Independent Government Cost Estimates. Therefore, the contracting officer determines that the anticipated cost to the Government will be fair and reasonable.

8. The market research conducted (see RFO FAR Part 10) and the results or a statement of the reason market research was not conducted.

A review of the market revealed that the software and corresponding hosting and operations and maintenance are widely available. However, the BAS program is an integrated effort that was configured and customized specifically for the Department as a holistic solution. The Government will continue to perform market research to determine if future requirements may be integrated from external sources to enable future competitions.

9. Any other facts supporting the use of other than full and open competition.

All facts have been documented in section 5. There are no additional facts to be reported in this section.

10. A listing of any sources that expressed a written interest in the acquisition.

A notice of intent to sole source was issued on September 17, 2026, with a submission deadline of October 2, 2026. No companies responded.

11. A statement of any actions the agency may take to remove or overcome any barriers to competition, if subsequent acquisitions are anticipated.

The Government will continue to conduct thorough market research to gauge the marketplace capabilities for future requirements.

12. CERTIFICATION

The JOFOC has been prepared and certified by:

Technical/Requirements Personnel:

I certify that the above narrative is accurate and contains complete data necessary to support the recommendation for other than full and open competition. I further certify that the narrative verifies the Government's minimum needs or schedule requirements and any rationale used to justify other than full and open competition procedures.

Michelle Grow Date Contracting Officer Representative

Marcelle Loveday Date Contracting Officer

13. REVIEW

Review

Office of General Counsel

Chris Walton Date Attorney, Contract Law Division Office of General Counsel

14. APPROVAL

DOC Competition Advocate

Molly Shea Date Deputy for Procurement Management and Deputy Senior Procurement Executive