A05_Part 8 Over SAT JA_12SAD126Q0008_Redacted.pdf

United States Department of Agriculture Justification to Restrict Competition under FAR Part 8

Over the Simplified Acquisition Threshold Identification Number: 12SAD126Q0008

Rev. 2/26/26

In accordance with the Federal Acquisition Regulation (FAR) 8.4 and General Services Administration Acquisition Regulation (GSAR) 538.7104-3 (b), the following justification documents the decision to restrict competition for this acquisition.

(1) Mission Area and Contracting Activity.

Requisition Number: TBD

Requesting Activity Agency: Rural Development Technology Office (RDTO)

Contracting Activity: Rural Development Procurement Management Office (RD PMO)

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

This justification authorizes and approves the award of a sole source, firm-fixed price, short-term task order to ensure the continued performance of services currently provided under the Cybersecurity contract 12SAD124F0015. The current contract was originally awarded as a competitive 8(a) procurement. However, the incumbent contractor, Arlluk Technology Solutions, LLC, is no longer in the 8(a) program. To avoid a lapse in critical services when the current contract expires, a sole source task order will be issued to Koniag IT Systems, LLC, a wholly owned subsidiary of the same parent organization. Koniag IT Systems, LLC possesses the required capabilities to provide uninterrupted contractor support necessary to maintain the On-Prem and Salesforce environments for Cybersecurity, Compliance, and Quality Assurance Services. This requirement is essential for the continuous delivery of critical cybersecurity, information assurance, compliance, testing, and modernization services that safeguard RD’s information systems and support the agency’s statutory obligations. The sole-source task order will ensure continued access to the specialized resources and expertise required to sustain these cybersecurity, compliance, testing, and modernization activities while the USDA Departmental Administration (DA), Office of Contracting and Procurement (OCP), Procurement Operations Division (POD) and the Office of the Chief Information Officer continues the procurement process for an enterprise-level Cybersecurity contract.

These services are commercial in nature and will be procured utilizing the procedures listed in FAR Part 8 and GSAR 538.71.

The suggested contractor is:

Koniag IT Systems, LLC 3800 Centerpoint Dr STE 700 Anchorage, Ak 99503-5801

UEI: YH7RBH5GJYJ8

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

This task order will provide comprehensive Cybersecurity, Compliance, and Quality Assurance (QA) services to support USDA Rural Development’s (RD) on-premises and Salesforce environments. The primary objective of this task order is to strengthen Rural Development’s cybersecurity posture and ensure compliance with federal security and privacy requirements while also improving the quality and reliability of RD’s IT systems through structured quality assurance and testing.

It is anticipated that one (1) task order with a period of performance consisting of a 10-month task order will be awarded for the estimated total of

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

The statutory authority supporting the placement of an order or establishment of a Federal Supply Schedule Blanket Purchase Agreement (BPA) that exceeds the Simplified Acquisition Threshold (SAT) on a sole source basis is: GSAR 538.7104-3 (b)(i) - The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need.

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

The current contract expires on 09/03/2026. Due to the severely limited procurement lead time available, RD does not have sufficient time to conduct a new competitive procurement without causing a break in critical cybersecurity and information‑assurance services. Initiating a new full and open competition at this stage would result in an unavoidable lapse in coverage of these mission‑critical services. The contractor’s expected proposed team will be largely the same as those currently performing the work. The original contract which was awarded through a competitive process, demonstrated the contractor’s capability and efficiency in meeting the complex requirements which will largely remain unchanged under the new proposed contractor.

If the task order was not awarded, a break in services would significantly heighten cybersecurity exposure, degrade system integrity and availability, delay system releases, and increase the likelihood of unauthorized access or data compromise. Additionally, a service lapse would place RD at risk of noncompliance with federal requirements including FISMA, the Privacy Act, OMB Circular A-130, NIST Special Publications, and DHS/USDA directives.

(6) A determination by the Contracting Officer that the order represents a fair and reasonable price.

In accordance with GSAR 538.7102-2(d), Federal Supply Schedule contract pricing has been determined fair and reasonable. The Contracting Officer will compare the proposed order pricing against the contractor’s GSA Schedule rates and confirm that the proposed labor categories, and discounts do not exceed approved Schedule ceiling rates.

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

Initial market research was conducted in accordance to develop a realistic and supportable Independent Government Cost Estimate (IGCE). This research included review of the existing contract pricing, labor categories, as well as using the GSA CACL Tool. However, additional market research was not conducted for this short-term task order. These services are already included in the scope of the forthcoming mandatory use enterprise BPA, which is intended to be the competitive solution for these needs. Due to procurement delays affecting the award timeline of the enterprise BPA, the OCIO approved a delay in RD’s transition to the new BPA to ensure no lapse in mission-critical cybersecurity support. The length of this short-term task order matches the length remaining on this OCIO approval. Accordingly, the market research supports proceeding with a single source justification under the FSS program.

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

No other solution can meet the requirements and avoid a gap in service while the Department’s enterprise Blanket Purchase Agreement (BPA) is being competed. The cybersecurity, compliance, testing, and modernization activities supporting RD require continuous performance by personnel with specialized technical expertise, established privileged access, and detailed knowledge of RD’s On-Prem and Salesforce environments. These capabilities cannot be absorbed by internal Government staff due to limited workforce capacity and the highly specialized nature of the work.

A new or partial competition is not feasible within the limited time available. Conducting a new procurement, performing evaluations, issuing award, and onboarding a new contractor would inevitably result in a lapse in service. Any lapse would expose RD systems to elevated cybersecurity, operational, and compliance risks that the Government cannot accept.

Reducing the scope is also not viable. The required support functions are interdependent and collectively necessary to maintain statutory and regulatory compliance, execute mandatory security and privacy assessments, sustain Authority to Operate (ATO) requirements, and prevent degradation of system integrity and availability. Any reduction would create unacceptable mission, security, and legal risks to the Government.

(9) 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.

While PMO prepared to recompete the requirement, OCIO notified RDTO that a department level cybersecurity BPA would be awarded in April 2026, and RD’s cybersecurity requirement would be placed under that Blanket Purchase Agreement (BPA). Since the requirement was expected to transition to the new BPA, PMO did not exercise the option on its IDIQ. However, due to delays in awarding the department-level Cybersecurity BPA, OCIO recommended that RD issue a 10-month short-term task order to ensure that there was no lapse in critical cybersecurity services, as RD did not have a viable contract vehicle available to support these essential services since the current TO expires on September 3, 2026.

(10) 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

(11) 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

(12) 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