A06 - Updated FAR 8.4_Limited Sources Justification Exceeding SAT.pdf

United States Department of Agriculture Limited Sources Justification

For an Order/BPA Exceeding the Simplified Acquisition Threshold

FAR 8.405 Federal Supply Schedules (FSS) Multiple Award Schedule Program

Control No. (if applicable)

1. Identification of the agency and the contracting activity.

United States Department of Agriculture, Departmental Administration, Office of Contracting and Procurement, Procurement Operations Division, 301 S. Howes Street, Suite 321, Fort Collins, CO 80521.

2. The nature and/or description of the action being approved.

The United States Department of Agriculture (USDA) Office of Contracting, and Procurement proposes to issue a sole source, short-term task order to General Dynamics Information Technology (GDIT), 3150 Fairview Park Drive, Suite 100, Falls Church, VA 22042 on a labor hour basis for USDA Farm Service Agency (FSA) Acreage Reporting Systems and Customer Portal Support. The 6-month task order will continue FSA Acreage Reporting Systems support services currently performed under task order AG-3144-D-17-0276 of NITAAC’s CIO-SP3 contract HHSN316201200050W and will be awarded against GDIT’s General Services Administration (GSA) Schedule GS-00F-057CA.

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

This acquisition will provide FSA Acreage Reporting Systems support services from March 12, 2023 – September 11, 2023. Services include requirements definition and analysis, systems development, production, maintenance, application assessment & authorization (A&A), disaster recovery, and knowledge transfer, and transition-out planning support for an estimated cost of $339,434.00.

Services will begin the day after task order AG-3144-D-17-0276 expires on March 11, 2023. FPAC plans to award a task order for FPAC Farm Programs Software Delivery Services (Beech) competitively by July 12, 2023. This acquisition will support knowledge transfer and transition to the FPAC Farm Programs Software Delivery Services task order during the final two months of performance.

4. The authority and supporting rationale.

The following circumstance justifies limiting the source under FAR 8.405-6:

FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of providing the supplies or services requried at the level of quality required.

Pursuant to FAR 8.405-6(a)(1)(i)(B), GDIT can provide the necessary services at this time to avoid substantial duplication of cost to the Government that is not expected to be recovered through competition.

The FPAC Business Center (FPAC-BC) Information Solutions Division (ISD) realigned the information technology delivery functions from FSA, NRCS, and RMA to a single organization on

October 14, 2018. The Government will procure services for FPAC Farm Programs Software Delivery services, which will subsume Acreage Reporting Systems Services, no later than September 12, 2023 through an underway acquisition nicknamed “Beech”. The Government will incur start-up costs associated with the FPAC Farm Programs Software Delivery services task order in July 2023. It would be both costly and potentially detrimental to the Government to procure Acreage Reporting Systems services with another vendor less than 12 months prior to the procurement of integrated Farm Programs Software Delivery services. The original source can provide the services without a duplication of start-up cost that will not be recovered through competition. The following factors cause a competition to not be in the government’s best interest:

• Security Adjudication

• Badging

• Laptops

• Knowledge Transfer

The time required to complete onboarding with USDA currently is greater than 49 business days, creating an estimated start-up time of six to eight weeks for a fully onboarded team with Government furnished laptops and badges. The new vendor would then require overlap with the incumbent for two to three weeks for knowledge transfer.

5. A statement demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring the use of the authority.

Pursuant to FAR 8.405-6(a)(1)(i)(B), GDIT has the unique capability to be able to provide the required services as they are the only contractor that has immediate access to Government systems to continue providing mission critical support services. The services themselves are not unique to GDIT but they are situationally unique to the requirement, however, due to the nature of the bridge requirement it is critical that the services continue while the agency complete a competitive acquisition for a long-term requirement. Any attempt to utilize other than the identified contractor will create substantial duplication of cost to the Government that is not expected to be recovered through competition or otherwise.

The current time required to complete onboarding with USDA is between 30 - 90 business days and the end of performance on the existing order is March 11, 2023. It is not possible to onboard another vendor in this amount of time which further supports the situationally unique qualification of GDIT in that they are the only contractor that has immediate access to provide the required and critical support.

Any new vendor would not have sufficient time to complete onboarding, receive knowledge transfer and successfully provide the services. This would result in a break in service and would be detrimental to the Government.

The only solution ensuring the overall integrity and quality FPAC business processes, and their timely and effective adoption by the organization is to award a bridge delivery order to GDIT. Not awarding a bridge to GDIT would result in an immediate loss of critical support, institutional knowledge and create duplicate start-up costs that the Government would not recoup. No other vendor has the capability to have immediate access to Government systems to provide the required support needed at the quality level required as well as does not have the institutional knowledge nor environmental knowledge to support the requirement at the quality level required.

6. A determination by the ordering activity Contracting Officer (CO) that the order represents the best value consistent with FAR 8.404(d).

Placing this order presents the best value to the government. Award will be made based on the receipt of a technically acceptable quote containing a fair and reasonable price. USDA will review the contractor’s proposed technical solution in response to the performance work statement and review the pricing quote taking the level of effort and mix of skills available into consideration. The resulting order will be labor hour. USDA will conduct a price analysis as required.

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 continually performs market research for the related services. The Government did not do any specialized market research for this acquisition because it is solely intended to provide services to Farm Service Agency until the Beech services are awarded. As stated previously the unique qualification is GDIT has immediate access which is required to meet the Government need.

Market research is ongoing for the follow-on competitive acquisition.

8. Any other facts supporting the justification.

9. A statement of actions the agency may take to remove or overcome any barriers to competition if subsequent acquisitions are anticipated.

The Government is concurrently seeking a fully competitive award to be in place upon expiration of this temporary bridge task order. An acquisition is in process to complete the new compliance support services requirement in Fiscal Year 2023 via a competitive Small Business set-aside acquisition.

There are no anticipated barriers to competition for the follow-on competitive procurement.

JEREMY ZELMAN Digitally signed by JEREMY ZELMAN Date: 2023.03.07 10:01:09 -05'00'

Digitally signed by ELEANOR

ELEANOR PONTORIERO PONTORIERO

Date: 2023.03.07 08:37:55 -07'00'

Certifications & Approval

Supporting data which form the basis for and included in this justification are certified accurate and complete.

Jeremy Zelman, Contracting Officer’s Representative (COR) Information Services Division, Farm Production and Conservation Business Center

The information contained in this Limited Sources Justification is certified accurate and complete to the best of my knowledge and belief.

Eleanor Pontoriero Contracting Officer