A05_Part 8 Over SAT JA OCFO AG-3144-D-17-0052 - AFS - FMMI OM_Redacted.pdf

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

Over the Simplified Acquisition Threshold Identification Number:

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.

The United States Department of Agriculture (USDA), Departmental Administration (DA), Office of Contracting and Procurement (OCP), Procurement Operations Division (POD) in support of the Office of the Chief Financial Officer (OCFO) proposes to issue a contract modification on a firm-fixed-price basis for Operations and Maintenance Support services in support of Support services in support of the following OCFO-FMS Financial Systems: FMMI the Enterprise Financial System application, the Corporate Mixed Systems (MINC, CPAIS, ACRWS, & FSDW), SAP S4HANA 2023, SAP Analytics Cloud (SAC), Cbeyond Budget Solution, and G-Invoicing. This action will result in a contract modification against an existing an Delivery Order, AG-3144-D-17-0052.

Requisition Number: 1176661

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

This Justification and Approval (J&A) is to authorize and approve an in-scope modification to a Delivery Order AG-3144-D-17-0052. This modification is specifically designed to maximize the functional and technical operations of the OCFO-FMS Enterprise Financial Support Services for USDA Mission Areas and Staff Offices.

This contract modification is essential to enable the USDA Office of the Chief Financial Officer (OCFO) to meet its statutory obligations under the CFO Act of 1990 and to uphold the principles of Executive Order 14249, "Protecting America’s Bank Account Against Fraud, Waste, and Abuse." The incumbent's specialized support services are critical for maintaining financial system integrity, ensuring compliance, and supporting key modernization initiatives.

The ongoing support provided by this contractor encompasses several mission-critical functions:

Treasury G-Invoicing System Compliance: These services are responsible for ensuring USDA's continuous compliance with the implementation of Treasury’s G-Invoicing System, which is mandated for all federal agency government-to-government transactions. While USDA has achieved base functionality, the contractor's support is vital for addressing additional functionalities, such as EZ and Intra-Governmental Payment and Collections, in upcoming releases.

S4HANA Modernization and Compliance: The contractor provides continuous support for the critical upgrade of the SAP S4HANA system from version 2022 to version 2023. This upgrade is paramount, as federal law requires USDA to operate within three years of the most recent S4HANA version. Failure to complete this migration would render USDA non-compliant, posing significant contractual and systemic risks.

Advanced Financial Reporting and Analytics: The contractor is responsible for generating and refining complex financial reporting information related to various spending, receivables, and ledgers within SAP Analytics Cloud. This raw financial data is then translated into clear, actionable dashboard insights for the non-financial executive community, facilitating informed decision-making.

Budget Formulation and Execution Support: The contractor supports Mission Areas in building their annual budget formulation and execution processes. This includes providing essential training and mentoring to Mission Area Points of Contact (POCs) on the new Cbeyond Budget tool, crucial for developing a consolidated and accurate budget.

Tier 2 and 3 Helpdesk & Incident Management: These services include dedicated functional and technical Tier 2 and 3 helpdesk resolution for complex accounting and financial reporting issues. This support is also critical for ensuring USDA Mission Areas and Staff Office financial incident management is resolved in a timely manner, preventing impacts to time-sensitive outgoing payments or obligations.

Critical Risks of Disruption (if these services are not continued):

Disruption to these services would pose immediate and severe risks across USDA's financial operations:

Regulatory Non-Compliance:

S4HANA: Inability to complete the S4HANA 2023 migration would result in USDA failing to meet the legal requirement of operating within three years of the most recent S4HANA version.

G-Invoicing: Delays in implementing full G-Invoicing functionality could lead to non-compliance with Treasury mandates for inter-governmental transactions.

Operational Instability and Failure:

Loss of Critical Knowledge: The immediate loss of the contractor's specialized knowledge of USDA's highly customized SAP financial systems cannot be rapidly replaced, leading to significant operational paralysis.

Payment & Obligation Delays: Unresolved financial incidents would directly impact time-sensitive outgoing payments and obligations, potentially causing legal and reputational damage.

Defect Resolution: Significant issues would arise in system defect resolution, financial adjustments, and reconciliations, compromising data integrity.

Impaired Financial Reporting and Decision-Making:

Without the contractor's expertise, the generation of critical financial reports and the translation into executive dashboards would cease, hindering strategic oversight and accountability.

Budgetary Disruption and User Impact:

Failed or delayed implementation of new systems (S4HANA, G-Invoicing, Cbeyond

Budget) would severely impact user training, adoption, and the overall effectiveness of budget formulation and execution across Mission Areas.

These commercial services will be secured through a modification to the existing BPA Call order, which was originally placed under FAR Part 8 and GSAM 538.71.

Accenture Federal Services LLC 800 North Glebe Road Suite 300 Arlington, VA 22203

UEI: C47BNA8GM833

Contract Number: HHSN316201200002W/Delivery Order Number: AG-3144-D-0052

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

The USDA Office of the Chief Financial Officer (OCFO) requires the continuation of highly specialized and integrated professional services to maintain financial system integrity, ensure regulatory compliance, and support critical modernization initiatives. These services are essential for OCFO to meet its statutory obligations under the CFO Act of 1990 and Executive Order 14249, "Protecting America’s Bank Account Against Fraud, Waste, and Abuse."

The required services encompass the following mission-critical functions:

1. Treasury G-Invoicing System Support and Compliance:

Providing ongoing support for USDA's implementation of Treasury’s G-Invoicing

System, which is mandated for all federal agency government-to-government transactions.

Developing and integrating additional G-Invoicing functionalities, including EZ and Intra-Governmental Payment and Collections, in upcoming system releases to ensure full compliance.

2. SAP S4HANA Modernization and Regulatory Adherence:

Delivering continuous support for the critical upgrade and migration of the SAP S4HANA system from version 2022 to version 2023. This is vital to ensure USDA remains compliant with federal law requiring operation within three years of the most recent S4HANA version.

3. Advanced Financial Reporting and Business Intelligence:

Creating, refining, and validating complex financial reporting information related to various spending, receivables, and ledgers within SAP Analytics Cloud.

Transforming raw financial data into clear, actionable dashboard insights tailored for the non-financial executive community, facilitating informed decision-making and strategic oversight.

4. Budget Formulation and Execution Tool Support:

Supporting Mission Areas in the build-out and refinement of their annual budget formulation and execution processes.

Providing essential training and mentoring to Mission Area Points of Contact (POCs) on the new Cbeyond Budget tool, which is crucial for developing consolidated and accurate budget plans.

5. Tier 2 and 3 Financial System Helpdesk & Incident Management:

Offering dedicated functional and technical Tier 2 and 3 helpdesk resolution for complex accounting and financial reporting issues.

Ensuring timely resolution of financial incidents impacting USDA Mission Areas and Staff Offices to prevent disruption to time-sensitive outgoing payments or obligations.

These services are not merely supplementary; they are integral to the daily operations, compliance posture, and strategic modernization efforts of USDA OCFO. Their continuation is critical to prevent regulatory non-compliance, operational instability, and significant delays in financial processes.

A modification will be issued against the existing order to extend the period of performance (POP) for four (4) months valued at $2,000,000.00.

Period Fiscal Year Estimated Total

09/01/26 – 12/31/26 FY26 $2,000,000.00

Grand Total $2,000,000.00

(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)(ii) - Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.

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

This acquisition is justified as Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized l, pursuant to GSAM 538.7104-3(b)(ii).

(1) Demonstration of Proposed Contractor's Unique Qualifications and Necessity for Cited Authority

The proposed incumbent contractor possesses unparalleled and indispensable expertise directly aligned with the highly specialized and integrated financial systems and regulatory compliance requirements of the USDA Office of the Chief Financial Officer (OCFO). This unique depth of knowledge, accumulated through continuous support, is absolutely essential for maintaining operational continuity, ensuring compliance with federal mandates, and mitigating significant risks to the USDA's financial operations. This directly justifies the use of the cited authority.

A. Unrivaled Expertise in Highly Complex and Integrated Financial Systems:

The services required are not generic IT support but demand profound, specialized knowledge of USDA's intricate financial ecosystem, including:

SAP S4HANA Modernization: The contractor possesses critical, long-standing expertise in USDA's highly customized SAP S4HANA environment. Their team has been integral to its development, maintenance, and the ongoing, time-sensitive migration from version 2022 to 2023. This involves intimate knowledge of custom configurations, data structures, and business processes, which is irreplaceable. A new vendor would lack the institutional memory and technical understanding required to manage this complex upgrade without severe delays and compliance risks.

Treasury G-Invoicing System Implementation: The contractor has been central to the initial implementation of USDA's G-Invoicing base functionality. Their team holds the specific knowledge required to develop and integrate the remaining critical functionalities, such as EZ and Intra-Governmental Payment and Collections, ensuring USDA's adherence to a mandatory federal system. This specialized G-Invoicing integration expertise is not widely available in the market for USDA's specific environment.

SAP Analytics Cloud & Executive Reporting: The contractor's personnel are uniquely skilled in extracting, analyzing, and transforming complex financial data from FMMI into actionable insights and executive dashboards within SAP Analytics Cloud. This requires not only technical proficiency but also a deep understanding of USDA's financial reporting requirements, business logic, and the specific needs of the non-financial executive community.

Cbeyond Budget Tool Implementation & Support: The contractor has been directly involved in the implementation and ongoing support of the new Cbeyond Budget tool. Their expertise is crucial for training and mentoring Mission Area POCs, facilitating the consolidation of budgetary information, and ensuring the successful adoption and utilization of this new system across the agency.

B. Indispensable Institutional Knowledge and Risk Mitigation:

The incumbent contractor's subject matter experts have accumulated extensive years of experience in supporting these interconnected, mission-critical systems. This depth of experience represents an irreplaceable institutional memory that cannot be replicated by another vendor in a timely or cost-effective manner.

Preventing Regulatory Non-Compliance: Without the incumbent's specialized S4HANA expertise, the USDA faces an imminent risk of failing to meet the legal requirement of operating within three years of the most recent S4HANA version, leading to significant non-compliance. Similarly, delays in G-Invoicing functionality due to a new vendor would violate Treasury mandates.

Avoiding Operational Paralysis: The loss of the contractor's critical knowledge of USDA's customized SAP financial systems would immediately lead to operational paralysis, causing delays in financial incident management, outgoing payments, and obligations, potentially impacting USDA's mission delivery.

Mitigating High Transition Risk: The introduction of a new vendor would necessitate an extensive, high-risk knowledge transfer period. Given the complexity, customization, and critical role of these systems in USDA's financial operations and regulatory compliance, such a transition would pose unacceptable risks of:

Prolonged system outages and financial processing delays.

Errors in financial reporting and data integrity issues.

Failure to meet federal mandates (S4HANA, G-Invoicing).

Significant cost overruns due to the need for extensive training, rework, and potential penalties for non-compliance.

Severe disruption to user training, defect resolution, and financial adjustments/reconciliations.

Therefore, the incumbent contractor's unique, long-standing, and highly specialized qualifications, particularly their proprietary knowledge of USDA's customized SAP S4HANA, G-Invoicing, SAP Analytics Cloud, and Cbeyond Budget implementations, make them the only source capable of meeting the agency's urgent and continuing needs without incurring unacceptable risk, regulatory non-compliance, and severe operational disruption.

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

Pursuant to GSAM 538.7102-2(d), a formal determination of fair and reasonable pricing is waived for orders placed against Federal Supply Schedules. However, the Contracting Officer (CO) has conducted a comprehensive and fact-based price analysis to ensure the proposed pricing for this sole source requirement, with an estimated total of $2,000,000.00, remains fair and reasonable to the Government.

This evaluation included the following specific actions:

1. GSA ScheduleVerification: The CO thoroughly reviewed the contractor's proposed labor rates against both their established GSA Federal Supply Schedule contract and the negotiated rates within the existing contract under which the current OCFO support is provided. This review confirmed that all proposed rates for the identified labor categories are consistent with the BPA's negotiated pricing and do not exceed the approved GSA Schedule ceiling rates.

2. Labor Category Alignment: A detailed comparison was performed between the proposed labor categories and the technical requirements outlined in the Statement of Work (SOW) for critical OCFO support, including G-Invoicing implementation, SAP S4HANA 2023 migration, SAP Analytics Cloud reporting, and Cbeyond Budget tool support. The CO confirmed that the proposed labor mix and skill sets are appropriate and directly aligned with the required specialized services.

3. Quantity and Level of Effort Analysis: The proposed labor hours and quantities for each labor category were meticulously analyzed for reasonableness against the Independent Government Cost Estimate (IGCE) for this project. This analysis also considered the specific scope, complexity, and critical nature of the required system upgrades, implementations, and ongoing support.

4. Discount Confirmation: All applicable discounts available under the contractor's GSA Schedule contract and the BPA, including any volume discounts or prompt payment terms, were confirmed to have been applied to the proposed pricing.

Based on this comprehensive price analysis, which included verification against both the GSA Schedule and contract rates, alignment with technical requirements, comparison to the IGCE, and consideration of the unique efficiencies derived from the incumbent's unparalleled institutional knowledge and logical follow-on work, the Contracting Officer hereby determines that the anticipated cost for this order is fair and reasonable.

(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.

Market research was not conducted for this contract modification due to the highly specialized, proprietary nature of the services and the incumbent contractor's unique, irreplaceable institutional knowledge of the USDA OCFO's critical financial systems and compliance initiatives.

The OCFO financial environment is an exceptionally complex, customized, and integrated ecosystem encompassing SAP S4HANA (including its time-sensitive 2022-2023 migration), federally mandated G-Invoicing (including upcoming EZ and IGC functionalities), SAP Analytics Cloud for executive reporting, and the new Cbeyond Budget tool. The incumbent contractor has been deeply embedded in the design, implementation, and modernization of these systems, possessing unparalleled understanding of their intricate customizations and requirements.

Introducing a new contractor would necessitate an extensive, high-risk, and costly knowledge transfer period , directly jeopardizing USDA's ability to meet critical regulatory compliance deadlines (e.g., S4HANA version requirements, G-Invoicing mandates), threatening operational continuity, and compromising financial integrity. The time and resources required for any new vendor to acquire comparable expertise would lead to unacceptable risks of regulatory non-compliance, system outages, processing delays, and mission failure.

Therefore, no other source is capable of meeting these critical agency needs without substantial cost duplication or unacceptable delays. Consistent with FAR Part 8 and GSAM 538.7104-3 (b)(ii) - Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized, this approach avoids the significant delays, increased costs, and heightened technical risks associated with a new competitive posting. Leveraging the incumbent's unique knowledge and proven capabilities is essential, as only this source possesses the specific expertise required.

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

The USDA OCFO's financial operations are directly tied to federal mandates and the uninterrupted execution of critical government functions. Beyond the incumbent's unique qualifications and the absence of viable market alternatives, this contract modification is essential to:

1. Prevent Imminent Regulatory Non-Compliance: The contractor's support is crucial for meeting the legally mandated SAP S4HANA 2023 migration deadline, which, if missed, would place USDA out of compliance with federal requirements. Similarly, their expertise ensures adherence to Treasury's G-Invoicing system implementation mandates.

2. Maintain Operational Stability of National Financial Systems: The highly customized and integrated nature of USDA's SAP S4HANA environment, G-Invoicing, SAP Analytics Cloud, and Cbeyond Budget tools means that any disruption would immediately jeopardize the processing of payments, obligations, financial reporting, and budget formulation across the entire agency, with severe downstream impacts on USDA's mission areas and the public it serves.

3. Avoid Unacceptable Mission Risk: The specialized knowledge held by the incumbent, refined over years of direct involvement with these systems, is not merely advantageous but indispensable. A transition to any other vendor would introduce an unmanageable level of risk, including prolonged system outages, data integrity compromises, and the inability to process critical financial transactions, thereby directly threatening USDA's ability to fulfill its core mission and fiduciary responsibilities.

(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 is committed to fostering full and open competition for future requirements. While this modification is necessitated by the incumbent's unique and irreplaceable expertise concerning USDA OCFO's critical financial systems (SAP S4HANA, G-Invoicing, SAP Analytics Cloud, Cbeyond Budget) and the immediate, time-sensitive compliance mandates, the USDA is actively developing the requirements for the subsequent acquisition.

This next requirement is specifically being structured and developed with the explicit intent to allow for robust competition. To address the current barriers, the agency is focusing on clearly defining modular components of the financial support services, thoroughly documenting system interfaces and critical processes, and developing a comprehensive knowledge transfer plan to facilitate new vendor onboarding. The recompete for these services is currently in the works, demonstrating