A05_Part 12 Over SAT JA_ANET_1171658.pdf

United States Department of Agriculture Justification to Restrict Competition

Identification Number: 1171658

Rev. 11/6/2025

In accordance with the Revolutionary Federal Acquisition Regulation (FAR) 12.102 (b), the following justification documents the decision to restrict competition for this acquisition.

(1) Mission Area and Contracting Activity.

The United States Department of Agriculture (USDA), Food Safety and Inspection Service (FSIS), Procurement Branch, proposes to enter into a contract on a sole source basis for the AssuranceNet (ANET) Integration Modernization project. This document serves as the Justification for Other Than Full and Open Competition.

(2) Nature and/or description of the action being approved.

This J&A authorizes and approves the award of a sole-source, firm-fixed price delivery/task order under GSA Contract # 47QTCA23D00BU to VCH Partners LLC (UEI: GL94VFFVFSG4) for the modernization and integration of the AssuranceNet (ANET) system into the Public Health Information System (PHIS). PHIS is the central, mission-critical information system for FSIS, supporting all core food safety inspection, enforcement, and regulatory activities. PHIS enables FSIS to collect, analyze, and act on data related to the safety of the nation’s commercial supply of meat, poultry, and egg products. It is essential to the agency’s ability to prevent foodborne illness, respond to outbreaks, and ensure compliance with federal law. The Administrative Enforcement Report (AER) module within ANET is a vital enforcement tool, allowing FSIS to document, track, and manage enforcement actions against regulated establishments. Integrating AER/ANET into PHIS is critical to consolidating enforcement workflows, improving data integrity, and ensuring that enforcement actions are timely, accurate, and accessible to all relevant FSIS personnel.

The services are commercial in nature and will be procured utilizing the procedures listed in FAR Part 12 and FAR Part 8.4.

The suggested contractor is:

VCH Partners LLC 8840 Stanford Blvd, Ste 4450 Columbia, MD 21045-5837

UEI: GL94VFFVFSG4

GSA Contract #: 47QTCA23D00BU

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

The AssuranceNet (ANET) Integration Modernization effort will modernize and consolidate the legacy ANET application by integrating its core functionality, reporting capabilities, and management-control workflows into the FSIS PHIS platform as a fully integrated module. This includes migration of data, development of new enforcement case management features, and alignment with FSIS Agile and security standards.

It is anticipated that one (1) task order contract consisting of one (1) one-year base period and four

(4) one-year option periods will be awarded. The estimated total for the base year plus all options is $9,200,000.00 as shown below:

Period Fiscal Year Total

BASE FY26 $2,724,712.17

Option 1 FY27 $2,249,114.50 Option 2 FY28 $1,787,186.99 Option 3 FY29 $1,399,546.86 Option 4 FY30 $1,101,362.97 Subtotal $9,261,923.49

Evaluation of FAR 52.217-8 $550,000.00 Grand Total $9,750,000.00

(4) Identify the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is FAR 6.103-1, Only One Responsible Source.

(5) Demonstrate that the proposed contractor's unique qualifications or the nature of the acquisition requires using the authority cited.

VCH Partners LLC is uniquely qualified to perform the ANET integration into PHIS due to its proprietary knowledge of the PHIS platform, its established track record of successful PHIS modernization, and its deep familiarity with FSIS’s mission, data, and security requirements. VCH Partners LLC expanded and currently maintains the PHIS platform, including its architecture, security, and integration points. The ANET integration requires not only technical expertise in software development and data migration, but also an intimate understanding of PHIS’s codebase, APIs, and security protocols. The contractor’s established security posture and compliance with USDA, Federal Information Security Modernization Act (FISMA), and FedRAMP requirements are essential, as the integration involves sensitive enforcement data and must meet stringent federal standards.

Continuity of operations is paramount for FSIS and the public. PHIS is the backbone of FSIS’s regulatory oversight, and any disruption in its enforcement modules could have immediate and severe consequences for public health and the food supply industry. The AER module in ANET is used to document and manage enforcement actions against establishments that may pose a risk to the food supply. If there is a break in continuity, such as a failed or delayed integration, or a loss of institutional knowledge, FSIS’s ability to respond to violations, enforce regulations, and protect the public from unsafe food products would be compromised. This could result in delayed enforcement actions, increased risk of foodborne illness outbreaks, and a loss of public confidence in the safety of the nation’s food supply. The food industry relies on FSIS’s timely and accurate enforcement actions to maintain compliance and ensure the integrity of the supply chain. Any lapse in enforcement capability would not only endanger public health but could also disrupt commerce, lead to recalls, and have significant economic impacts.

Transitioning this work to another contractor would require extensive ramp-up time, knowledge transfer, and reengineering, introducing significant risk of operational disruption. The effort to duplicate the contractor’s proprietary knowledge and onboarding a new vendor is estimated at a high cost, and the transition would likely result in an extreme delay. Such a delay is unacceptable given the critical nature of the enforcement functions and the potential impact on public health and safety.

(6) Provide 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 Part 5 and, if not, which exception under Part 5 applies.

FSIS conducted comprehensive market research to identify potential sources capable of performing the ANET integration. The agency reviewed GSA Schedules, USDA-wide contracts, and open market sources, and analyzed the capabilities of current FSIS contractors as well as other vendors identified through internet research and industry outreach. Vendors such as Digital Infuzion, Weems Design Studio, Saritasa, Cognizant, Capgemini, and CGI were evaluated informally for their technical qualifications, past performance, and ability to meet the full scope of the requirement. Despite this broad market research, only VCH Partners LLC demonstrated the necessary combination of PHIS platform expertise, security credentials, and proven performance on similar FSIS modernization efforts. No other vendor was found capable of meeting the technical, security, and schedule requirements without introducing significant risk and cost to the Government.

A Sources Sought or RFI was not issued for this Task Order, as the market research confirmed only one responsible source.

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

The anticipated cost to the Government is considered fair and reasonable. This determination is based on a thorough comparison of historical pricing for similar PHIS modernization work performed by VCH Partners LLC, the development of an Independent Government Cost Estimate (IGCE) using current market rates, and the review of GSA Schedule rates for comparable labor categories. The GSA contract was competitively awarded, and the labor rates have been negotiated to ensure best value for the Government.

(8) A description of the market research conducted, and the results or a statement of the reason Market Research was not conducted.

FSIS undertook a multi-faceted market research effort to ensure that all potential sources were considered. The agency reviewed the capabilities of current and past FSIS contractors, including those already providing IT modernization and integration services. The market research included a review of GSA’s Governmentwide Acquisition Contracts (GWACs), USDA-wide contracts, and open market sources, as well as an analysis of vendor websites, published capability statements, and past performance information. FSIS also reviewed the results of previous acquisitions for similar work, consulted with technical subject matter experts, and analyzed the requirements for security, data migration, and enforcement workflow integration.

The market research revealed that while several vendors possess general IT modernization capabilities, none except VCH Partners LLC have the specific, in-depth knowledge of the PHIS platform, its architecture, and its security environment. The integration of ANET’s AER module into PHIS is a highly specialized task that requires not only technical skill but also a deep understanding of FSIS’s regulatory mission, enforcement processes, and data security requirements.

The agency determined that onboarding a new vendor would require significant time and resources to achieve the necessary level of understanding and compliance, resulting in unacceptable risk to continuity of operations and public health. The market research concluded that VCH Partners LLC is the only responsible source capable of meeting the Government’s requirements for this critical integration effort.

(9) Any other facts supporting use of other than full and open competition, such as:

The ANET integration requires proprietary knowledge of PHIS’s architecture and codebase, as well as established processes for security and privacy compliance. The integration is time-sensitive and critical to FSIS’s enforcement modernization goals. Security and privacy requirements preclude onboarding a new vendor without significant risk, and the transition to a new contractor would introduce unacceptable delays and costs. The agency’s market research and acquisition planning confirm that only VCH Partners LLC can provide the required services at the necessary level of quality and timeliness.

(10) A listing of the sources, if any, that expressed an interest in the acquisition in writing.

During the market research process, FSIS identified and reviewed several vendors, including Digital Infuzion, Weems Design Studio, Saritasa, Cognizant, Capgemini, and CGI. However, none of these vendors were found capable of meeting the full scope of the requirement for ANET integration into PHIS. No other sources expressed written interest or demonstrated the ability to perform the work at the required level of quality and security.

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition of the supplies or services required.

FSIS is committed to fostering competition for future acquisitions. The agency will continue to document technical requirements, update system documentation, and modularize system components where feasible to reduce vendor lock-in. Lessons learned from this integration will inform future efforts to facilitate competition and broaden the pool of qualified vendors for similar work.

(12) Certifications & Approvals

Technical / Requirements Personnel Certification I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Name Date Title

Contracting Officer’s Certification I certify that the data supporting the recommended use of other than full and open competition accurate and complete to the best of my knowledge and belief.

Name Date Contracting Officer

Additional Reviews & Approvals

Competition Advocate (greater than $900,000 but not exceeding $20M).

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, I hereby approve this justification. If required, my approval constitutes clearance for submission to the Head of the Contracting Activity (HCA).

Name of Chief of the Contracting Office (COCO) Date Competition Advocate

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