1F 16.505-Justification-for-Exception-to-Fair-Opportunity- IAS Redacted.pdf

United States Department of Agriculture Justification for Exception to Fair Opportunity

FAR 16.505

1. Identification of the agency and the contracting activity.

1a. Requesting Activity Agency: Procurement Systems Division (PSD) 1b. Contracting Activity: Procurement Operation Division (POD)

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

USDA proposes to issue a sole source order on a firm fixed-price basis to Buchanan & Edwards, Inc., DBA: Buchanan and Edwards, GSA OASIS+UR Contract 47QRCA25DU513, for commercial information technology (IT) support services.

3. A description of the supplies or services required to meet the agency’s needs (including estimated value).

The requirement is for continuity of IAS IT support services following a bridge contract. Services include:

IAS System Operations (monitoring, administration, database support) IAS/IPP Help Desk Support IAS Releases, Upgrades, and Enhancements IAS Security and Program Management

Estimated (Base: 6 months + Option: 6 months)

4. Identification of the exception to fair opportunity.

The following circumstance justifies the exception to fair opportunity/brand name under FAR 16.505:

FAR 16.505(b)(2)(i)(A) - The agency need is so urgent that providing fair opportunity would result in unacceptable delay.

5. Supporting rationale demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring the use of the authority.

Buchanan and Edwards is uniquely qualified due to:

Continuity & Risk Mitigation: Retains critical IAS personnel (Program Manager, Functional Leads, Senior Developers) without costly and risky transition.

Specialized Expertise: Proven experience with IAS SDLC, PRISM upgrades, Oracle DB migration, and USDA-specific interfaces (FMMI, IPP).

Urgency & Mission Criticality: The current bridge contract awarded during a bid protest period is due to expire 2/28/2026. USDA and OCP have urgent requirements including but not limited to the second release and continued enhancement of the Requirements Planning Tool (RPT) 2.0, that necessitate the continuity of current IAS key personnel to ensure successful execution.

Cost Savings: The contractors rates reduces annual spend by 55% and average hourly rates by 10%, delivering best value.

Technical Complexity: Migration from AIX to Linux, PRISM upgrade to 7.6 before June 2026, and OCP consolidation and system reconfiguration requires deep IAS knowledge and significant coordination which cannot be accomplished within the required timeframe without the expertise of contract personnel.

6. A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The contracting officer determines that the anticipated price(s) will be fair and reasonable based on negotiated rates on Buchanan and Edwards’ OASIS contract. Buchanan and Edwards offers a labor mix, rates, and scope that provides:

Flexible staffing model (Functional Team approach) Agile SDLC efficiencies (Sprint-based development, automated testing) Lower overall cost than current IAS contract support rates and reduced GSA schedule rates.

The order represents the best value to the Government, considering price, technical requirements, and continuity of operations.

7. Any other facts to support the justification.

IAS support services were competed and awarded prior to the current bridge contract. The award, however, was protested and ultimately cancelled due to changes in scope of services needed as a result of new administration, USDA and OCP priorities including but not limited to the second release and continued enhancement of the Requirements Planning Tool (RPT) 2.0. The urgency of the support contract cannot be solicited, evaluated and awarded in time to ensure uninterrupted IAS support during this critical time.

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

USDA will plan and execute a competitive procurement for IAS support services during this short-term award. The new acquisition will be inclusive of a revised scope reflective of support services for the consolidation of many disparate and systems and processes not currently defined.

Certifications & Approval

Supporting data which form the basis for and included in this justification are certified accurate and complete.

Rick Toothman Division Chief, Procurement Systems Division (PSD)

The information contained in this Limited Sources Justification is certified accurate and complete to the best of my knowledge and belief.

Jenna Highfill Contracting Officer

RICHARD

TOOTHMAN

Digitally signed by RICHARD

TOOTHMAN

Date: 2026.02.10 10:01:31 -05'00'

JENNA HIGHFILL Digitally signed by JENNA HIGHFILL Date: 2026.02.10 09:32:59 -06'00'

Additional Reviews & Approvals

Signatures are required at each threshold up to the total estimated dollar value of the acquisition

Procuring Activity Competition Advocate (if over $750,000, but not exceeding $15 million).

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as advocate for competition for the procuring activity/COCO, I hereby approve this justification. If required, my approval constitutes clearance for submission to the Head of the Procuring Activity.

Josh Tafoya Title: Chief of the Contracting Office (COCO) Procuring Activity Advocate for Competition

JOSHUA TAFOYA

Digitally signed by JOSHUA

TAFOYA

Date: 2026.02.10 15:30:43 -07'00'