Limited Source Justification - WA Fin Statement_FINAL_signed.pdf

LIMITED-SOURCES JUSTIFICATION

TO: Kiaira Stallworth, Contracting Officer, IG/M/AOO

FROM: Damian Wilson, Director, IG/AIE/FA

DATE: September 9, 2025

SUBJECT: Financial Statement Audit Services with Williams Adley and Company DC LLP -

Limited-Sources Justification

In accordance with FAR 8.405-6, the proposed contractual action is pursuant to the statutory authority under the Multiple Award Schedule Program.

1. This document provides the facts and rationale for using limited sources in accordance with FAR 8.405-6.

This is a limited source award justification to utilize Williams Adley’s GSA schedule GS-00F-013DA for audit support services. The requiring activity is the United States Agency for International

Development (USAID), Office of Inspector General (OIG), Audit Inspections and Evaluations (AI&E).

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

This justification for a limited-source acquisition for financial statement audit services is for the performance of an audit of USAID’s FY2025 financial statements. The action to be awarded is a new, firm-fixed price task order (TO) under Williams Adley’s GSA schedule, GS-00F-013DA, with one, five-month base period and one, one-year option period.

3. Description of the supplies or services required to meet the agency’s needs, including the estimated value:

USAID OIG requires the services of a qualified independent public accounting firm to perform the annual financial statements audit of USAID for the Fiscal Year (FY) ending September 30, 2025.

This audit is required by the Government Management and Reform Act, Public Law 103-356 (1994)

(GMRA). The audit must be completed in time to meet the Office of Management and Budget's (OMB) due date of November 15th each year (unless an OMB extension is granted).

The contractor will audit USAID’s financial statements in accordance with:

• Generally Accepted Government Auditing Standards (GAGAS) as set forth in GAO’s

Government Auditing Standards (GAO-21-368G, Technical Update April 2021) as amended.

• OMB Bulletin 24-02, Audit Requirements for Federal Financial Statements, and any updated versions of this bulletin. This bulletin governs the conduct of Federal financial statement audits.

• The Government Accountability Office (GAO) and Council of the Inspectors General on

Integrity and Efficiency (CIGIE) Financial Audit Manual, which provides a standardized approach to performing financial statement audits.

• GAO’s Federal Information System Controls Audit Manual (FISCAM).

• GAO’s Standards for Internal Control in the Federal Government, (Green Book).

• American Institute of Certified Public Accountants (AICPA) Statement on Auditing Standards, OMB Circulars A-136 & A-123.

Tasks will include a series of planning, internal control evaluation, substantive testing, compliance review events, and issuance of the Independent Auditor’s Report to OIG and GAO deliverable.

The estimated value of this audit is $3,121,617.72.

4. Authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

Urgent and Compelling Need - FAR 8.405-6(a)(1)(i)(A) - The agency’s need for the services is so urgent that following ordering procedures would result in unacceptable delays.

USAID OIG previously utilized an interagency agreement with the Department of Interior (DOI) for acquisition support services. On or around February 2025, USAID OIG was notified by DOI that it would be terminating all the contracts it awarded under the interagency agreement.

In and around March 2025, the acting USAID Administrator notified Congress of the intent to reorganize certain USAID functions under the Department of State, as well as discontinue the remaining USAID functions that do not align with Administration priorities. Over the months that followed, USAID OIG continually asked USAID if it was going to be able to provide the FY2025 statements and agency support for the audit.

On August 25, 2025, USAID informed USAID OIG that the agency will ultimately have the financial statements prepared and ready for audit; however, this only left AI&E with 1.5 months to complete the audits. The normal timeline for the completion of this audit is 11-12 months, the time from the initial activity to the final activity as outlined in the timeline of the terminated DOI contract. Though the usual deadline is November 15th, the mandated deadline for issuing the FY2025 financial statements audit report is November 17, 2025, since November 15th of 2025 is a Saturday. If possible, AI&E plans to request a 60-day extension from OMB for submitting the final audit report, making the timeline for the effort 5 months.

If this requirement is competed using routine processing time, the FY2025 mission-critical audit deadline cannot be met and would result in serious injury to the government in that noncompliance with the federal mandates creates a trickle-down effect to any government-wide reporting, such as the

Agency Financial Report (AFR) and the Financial Report of the U.S. Government. The AFR provides an overview of a specific federal agency's financial results, operations, accomplishments, and challenges, enabling Congress, the President, and the public to assess the agency's stewardship of financial resources. It also demonstrates an agency's commitment to accountability to the public and Congress.

The Financial Report of the U.S. Government, jointly authored by both the Department of the

Treasury and OMB, is based on the agency’s audited financial statements and provides a comprehensive annual overview of the U.S. government's financial position, revenues, costs, assets, and liabilities, including key financial issues and long-term sustainability factors. Without meeting the deadline, not only would the agency not meet its own reporting obligation, but such an unacceptable delay means critical information for making informed fiscal and policy decisions regarding the agency will not be presented and accountability for departmental spending at the agency cannot be held.

Additionally, transparency to the agency’s finances for the President, Congress, and the American public will become opaque at such a critical time.

Prior to the termination of the DOI contract, Williams Adley successfully completed the audit of

USAID’s financial statements for FY2024 and started preparations for the audit of the FY2025 financial statements. Given their prior experience, Williams Adley’s direct familiarity with financial systems, processes, and corrective action plans and its unique recent familiarity and expertise with USAID’s financial systems, processes, and corrective action plans reduces audit risk, ensures efficiency, and shortens the lead time on beginning the work to meet the mission critical deadline.

Lastly, a lapse in audit coverage would impair USAID OIG’s ability to meet its statutory obligations to

OMB, the Treasury, and Congress. As an annual statutory requirement pursuant to the GMRA, USAID

OIG must secure audit services immediately to comply with the law requirements. Thus, it is in the best interest of the government to source this audit from Williams Adley since they previously started preparations for the FY2025 financial statement audit and are familiar with USAID’s financial systems.

Williams Adley’s prior USAID auditing experience and prior FY2025 financial statement preparation best postures Williams Adley to meet the USAID OIG’s need to conduct 11-12 months of work within the truncated timeline of 5 months.

5. Determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d).

Under the Federal Supply Schedule (FSS) program, the General Services Administration (GSA) meticulously establishes prices for supplies, fixed-price services, and hourly-rate services. This rigorous process ensures that the prices offered through its schedule contracts are, by definition, fair and reasonable. Consequently, ordering activities are generally relieved of the burden of conducting an independent fair and reasonable price determination. The GSA's pre-negotiated pricing inherently satisfies this requirement, with the singular exception of the price evaluation mandated by FAR 8.405-

2(d), which does not apply to the purchase requested herein.

By adhering to the procedures outlined in FAR 8.405 for placing an order against an FSS contract, an ordering activity affirmatively concludes that the order represents the best value, as precisely defined in

FAR 2.101, and constitutes the lowest overall cost alternative to fulfill the government's requirements.

While the GSA's comprehensive negotiation process already guarantees fair and reasonable pricing, ordering activities shall pursue further discounts prior to placing an order, as articulated in FAR 8.405-

4. The contracting team shall seek a price reduction from Williams Adley.

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

While market research identified multiple CPA firms on the GSA Schedule, only Williams Adley can perform the work and meet the mission critical deadline of OMB’s due date for the final audit report since they previously started preparations for the FY2025 financial statement audit and are familiar with USAID’s financial systems. Willaims Adley’s prior USAID auditing experience and prior FY2025 financial statement preparation provides USAID OIG the best chance of conducting 11-12 months of work within the truncated timeline of 5 months.

7. Any other facts supporting the justification:

If this requirement is competed using routine procurement processing time, the FY2025 mission-critical audit deadline cannot be met in that normal procedures would take an estimated 45-60 days to solicit, evaluate proposals, and award.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

USAID OIG will continue to actively stay abreast of agency restructuring and coordination to ensure the government’s needs are timely fulfilled and competition is maximized to the furthest possible extent.

9. Technical or Requirement Personnel Certification:

In accordance with FAR 8.405-6(c)(2)(x), I hereby certify the technical statements included above, forming the basis for this justification, are complete and accurate.

Damian Wilson Date

Director, IG/AIE/FA

10. Contracting Officer’s Certification:

In accordance with FAR 8.405-6(c)(2)(ix), the justification is accurate and complete to the best of my knowledge and belief.

Kiaira Stallworth Date

Contracting Officer

11. Justification Approval:

Based on the limited source circumstance described above, and in accordance with FAR 8.405-6(d)(2), I hereby approve the justification.

Lauren Sylvester Date

Director, Administrative & Overseas Operations

Reviewed By:

Kelsie Cooley Date

Attorney, Office of General Council

Kelsie Cooley

September 15, 2025