A05_Part 8 Over SAT JA_Final_12318726Q0195.pdf

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

Over the Simplified Acquisition Threshold Identification Number: 1175597

Rev. 2/26/26

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

(1) Mission Area and Contracting Activity.

Requisition Number: 1175597

Requesting Activity Agency: USDA Forest Service - Procurement Operations – Products & Services

Contracting Activity: USDA Forest Service - Procurement Operations – Products & Services

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

This J&A authorizes and approves the award of a sole‑source task order as a follow‑on to contract 12318721F0235 for the procurement of support services in support of Procurement Operations. This sole source effort follows a competitive award. This effort supports GAOA‑funded actions in Procurement Operations. Without this award, many current contract actions will not make it to award. The new contract will continue to provide the critical resources and expertise needed to maintain continuity of procurement operations, ensure timely execution of GAOA actions, and support Federal Acquisition functions that are closely associated with inherently governmental activities while ensuring the contractor does not perform any inherently governmental functions.

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

The suggested contractor is:

Jefferson Consulting, LLC

1666 K ST NW, STE 1110

Washington, DC 20006

SAM UEI: PS8NEAKW1MM4

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

The Forest Service Procurement Operations group requires follow-on contractor support to assist with procurement actions for the GAOA procurement group. Under this award, the contractor will be expected to perform Federal Acquisition functions which are closely associated with the performance of inherently governmental functions such as those listed in FAR Subpart 7.5— Inherently Governmental Functions but the vendor will not be performing any of the inherently governmental functions

Estimated Value: $526,525

Period Fiscal Year Total

BASE - GAOA funds FY26 $526,523

Funds used at time of award are Great American Outdoor Act (GAOA), which will limit contract support to GAOA funded contract requirements.

(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: GSAM 538.7104-3 (b)(iii) - The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.

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

This is a high priority sole source effort, intended for Jefferson Consulting, LLC. Historically, there have been two (2) active orders for contract support; one BPA Call award against a GSA contract for staff management, and one (1) BPA Call award against a GSA contract for contract workload surge support. While both calls are worked concurrently, the end date of these efforts had not been coordinated. This award will allow the surge effort completion date to align with the completion date of the staff management effort of December 24, 2026. This order will allow the Government time to properly compete the full GAOA contracting support effort under one (1) follow-on order.

A sole-source follow-on contract is uniquely justified for this effort due to the severe operational risks and unacceptable delays that a competitive procurement would introduce. With 27 projects actively in progress, introducing a new contractor would disrupt critical, ongoing technical lifecycles. A transition of this magnitude would require an estimated 60 to 90 days for a new vendor to achieve full operational proficiency. This learning curve would effectively stall the active pipeline, delay time-sensitive deliverables, and result in substantial duplication of costs that the government cannot expect to recover through competition.

Furthermore, the incumbent possesses exclusive, specialized expertise and proprietary institutional knowledge regarding the active workflows. Forcing a competitor to replicate this technical baseline midway through execution would directly threaten project integrity and milestone schedules.

Because the current effort is limited to a brief 4-month duration totaling $526,524 in base operational costs, the administrative timeline and financial overhead required to complete the contract would far exceed any potential cost savings. Therefore, awarding a sole-source follow-on to the incumbent is the only viable pathway to ensure uninterrupted continuity, protect the $7,000,000 investment in active projects, and successfully meet agency mission requirements.

It has been determined that there is a critical need for Jefferson Consulting support to align the completion dates for the effort to allow for the full effort to be properly competed under a new GSA task order. Upon release of that award, it was determined that another new award must be made to continue executive support for the surge effort. This award will be a new order placed against Jefferson Consulting’s GSA contract.

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

The Contracting Officer reviewed the proposed order pricing against the contractor’s GSA Schedule rates and confirmed that the proposed labor categories, quantities, and discounts are consistent with the requirement and do not exceed approved Schedule ceiling rates. Although GSAM 538.7102-2(d) waives a formal determination, an appropriate price evaluation was completed.

Based on this review, the anticipated cost is considered fair and reasonable.

The Contracting Officer will ensure the final price remains fair and reasonable by verifying labor category alignment, confirming any applicable discounts, and reviewing the final pricing prior to award.

(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.

No Market Research was done to consider other contractors. The effort under this order is in direct support of the GAOA contracting support effort under GSA BPA call order 12318721F0235.

This order will be awarded against GSA contract GS-00F-120DA.

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

Several additional factors support the use of this justification for a sole‑source award. The Forest Service Procurement Operations group requires uninterrupted follow‑on contractor support to ensure timely execution of GAOA procurement actions. The current contractor possesses unique, contract‑specific knowledge of ongoing GAOA requirements, established workflows, and historical acquisition context that cannot be readily transferred to a new vendor without causing significant delays.

The support services required under this effort involve performing Federal Acquisition functions that are closely associated with inherently governmental activities as described in FAR Subpart 7.5.

Although the contractor will not perform inherently governmental functions, the work requires a high degree of judgment, familiarity with agency‑specific procedures, and an understanding of sensitive procurement actions developed during performance of the existing contract. Transitioning to a new contractor would introduce operational risk, reduce efficiency, and require substantial time for onboarding, training, and re‑acclimation to GAOA priorities, all of which would impede the agency’s ability to meet critical deadlines.

Given these factors, continuation with the current contractor is essential to avoid disruption of mission‑critical procurement operations and ensure continuity of support for GAOA‑funded actions.

(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.

The agency will conduct updated market research, refine the performance work statement to remove vendor-specific elements, and engage industry through RFI. This effort will broaden vendor awareness, clarify requirements, and support a fully competitive acquisition strategy for future procurements.

Over the Simplified Acquisition Threshold Identification Number: 1175597

Rev. 2/26/26

(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.

Colleen M. Reittinger

_August 5, 2026_______ Date

PAST Chief

(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.

Tracy Doud Date Contracting Officer

(11) Contracting Officer’s Certification