A05_Part 8 Over SAT JA_posting2_Redacted.pdf

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

Over the Simplified Acquisition Threshold Identification Number: 12314426Q0302

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:

Requesting Activity Agency: USDA/DA/OCP

Contracting Activity: USDA/DA/OCP

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

This justification authorizes and approves the award of a new commercial, sole-source, firm-fixed-price (FFP) contract for procurement of quality data and validation services for the U.S.

Department of Agriculture (USDA).

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:

PotomacWave, Inc.

1725 Duke Street Ste 320 Alexandria, VA 22314-3472

UEI: S5ZCFWYN4KK3

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

validation, and compliance support services required under the Federal Acquisition Regulation (FAR), Office of Federal Procurement Policy (OFPP) guidance, and OMB procure mandates.

Verification and Validation (V&V) workflow services.

capable of identifying FPDS data anomalies, issuing automated alerts, supporting timely corrections, and enabling USDA to maintain accurate, complete, and reliable procurement data across FPDS and related federal reporting systems.

services may be exercised when USDA requires deeper analysis of specific FPDS elements. The development/maintenance of FPDS user guides and desk references.

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.

USDA conducted detailed market research among Schedule holders to determine whether more than one vendor could meet the agency’s minimum requirements. The research began with a thorough review of GSA Schedule offerings using GSA eLibrary and GSA Advantage, where USDA examined Schedule contractors under North American Industry Classification System (NAICS) code 54161. A review was completed of their published capability statements, service descriptions, and available solutions. This review focused on identifying turnkey contractor-managed services capable of supporting FPDS data validation, automated V&V workflow, and enterprise procurement data quality analytics. USDA then reviewed individual contractor websites associated with the relevant NAICS code to confirm whether any vendors marketed FPDS-specific validation tools, automated V&V capabilities, or procurement data quality platforms. None were found that meet the USDA’s requirements.

Open market internet searches were also conducted using terms related to FPDS validation, V&V automation, and procurement data quality analytics. These searches did not identify any vendors offering an equivalent automated or turnkey solution that could meet USDA’s technical and operational needs. USDA reviewed all mandatory and priority sources, confirming that AbilityOne does not offer FPDS validation or V&V services and that no USDA-wide contract vehicles include these services. Finally, USDA consulted internal subject matter experts familiar with FPDS reporting and procurement data quality requirements to validate whether any known industry providers offer comparable automated FPDS-aligned tools. The research confirmed that only one Schedule contractor provides the specific automated FPDS validation, V&V workflow support, and enterprise-level data quality capabilities required. Accordingly, the results support proceeding with a sole source award under the Federal Supply Schedule because only one responsible source can satisfy USDA’s minimum requirements without imposing additional Government burden.

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

The USDA has not developed technical data packages, engineering descriptions, or specifications suitable for full and open competition because the services required rely on the contractor’s models, and workflow automation tools.

been uniquely developed and refined by the incumbent provider, making it impossible for USDA to create a government algorithms or system architecture.

Developing such documentation would require substantial engineering effort, extensive internal considerable time to replicate, validate, and operationalize proprietary capabilities, resources USDA does not possess.

(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 USDA will continue conducting routine, targeted market research to monitor emerging actively engage broaden vendor awareness of the requirement and encourage development of competing solutions.

flexibility in proposing innovative, commercially available approaches. USDA will also evaluate whether portions of the requirement, such as training, analytica services, can be modularized or competed separately if the market matures. These actions improve the potential for competition in future acquisition cycles.