FAR 8.4_Limited Sources Justification Exceeding SAT - IAS IT Services Bridge Contract v3_Redacted.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

1. Identification of the agency and the contracting activity.

United States Department of Agriculture (USDA), Departmental Administration (DA), Office of Contracting and Procurement (OCP), Procurement Operations Division (POD), 1400 Independence Ave SW, Suite 124-W. Washington, D.C. 20250 in support of USDA, Procurement Systems Division

(PSD).

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

Procurement Systems Division (PSD) has a requirement for IT support services for the Integrated Acquisition System (IAS) Program. PSD owns and manages all aspects of the IAS program for which it uses contractors to perform the activities required to maintain the system and carryout program functions for this major information technology (IT) investment. PSD is proposing a bridge contract with Spry Methods, Inc., following expiration of the current contract on August 30, 2024.

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

IAS serves as the enterprise-wide, end-to-end procurement system for USDA accounting for over $6.3 billion in obligations annually. It is a commercial off-the-shelf (COTS), web-based integrated procurement solution that includes Unison’s PRISM for requisitioning, soliciting, and awarding contracts, Oracle Application Express (APEX) for procurement forecasting, reporting, user registration and other utilities not met by the COTS product, and U.S. Treasury’s Invoice Processing Platform (IPP) for invoicing functionality. It has custom interfaces with IPP, USDA’s financial system – Financial Management Modernization Initiative (FMMI), and USDA’s single sign-on utility as well as a COTS interface with Federal Procurement Data System – Next Generation

(FPDS-NG).

Beyond continuing to provide a reliable, secure, and high performing system that adheres to regulations, PSD is focused on maximizing COTS product functionality, configurations to meet USDA needs, enabling task automations, and simplifying the technical architecture. PSD’s goals for IAS are to:

Ensure reliable and accurate USDA-wide procurement-related information.

Reduce program office and administrative burden in the acquisition management process.

Ensure efficient IAS program operations and management as it pertains to IT investments, electronic commerce directives, and digital Department initiatives.

Ensure compliance with Federal Acquisition Regulation and USDA procurement and acquisition policy within the system.

Ensure system compliance with the Office of Management and Budget OMB Circular (A-

123) internal controls and USDA’s Office of the Chief Information Officer (OCIO) Cyber Security Policy and Guidance Access Protection standards.

USDA PSD and POD anticipate awarding an eight (8) month base period and adding two, 2-month option periods. The breakdown of the period of performance (POP) is listed below. The contract will be Firm Fixed Price (FFP).

Base Period: August 31, 2024 – April 30, 2025 (8 months): $4,730,491.00 Option Period 1: May 1, 2025 – June 30, 2025 (2 months): $1,182,623.00 Option Period 2: July 1, 2025 – August 31, 2025 (2 months): $1,182,623.00

4. Identification of the authority for limiting sources.

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.

5. Supporting rationale demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring the use of the authority.

Due to the GSA notification, received by USDA on August 2, 2024, contract number 12314419F0728 shall end and be brought into compliance with the 8(a) STARS II GWAC (STARS II) ordering procedures. The bridge contract will allow USDA/PSD to continue to operate during FY24, while getting prepared to issue a request for proposal to provide services after the expiration of the bridge contract. The incumbent contract represents the only solution which offers Integrated Acquisition System (IAS) / Invoice Process Platform (IPP) integration and executes the operations of a contract writing system for the USDA mission areas to submit requisitions and procurement officials to execute those dollars within the time remaining.

Spry Methods is uniquely qualified to operate IAS as it requires:

continuity of complex processes (e.g., fiscal year-end processing, help desk operations, training operations, 30+ batch processes, recurring data fixes, recurring external data ingest processing, management of over ten complex interfaces, management of custom applications, robotics process automation (RPA) bot processing, new development in progress to support three new USDA major interfacing systems);

extensive technical experience (e.g., UIPath, Unison PRISM backend, Oracle Application Express (APEX), Oracle database management, IBM Message Queuing (MQ), Tableau; and extensive functional experience (e.g., Unison PRISM, federal procurement, SAP, USDA and mission area-specific procurement processing).

No other contractor could operate IAS without a long period of transition. Any disruption to the team would have a profound impact on services which ultimately would lead to inability to issue contracts, avoid anti-deficiency, comply with Federal Acquisition Regulation (FAR), and pay vendors.

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

Previous evaluation of existing contract provides a basis for fair and reasonable price determination.

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 recently conducted was for the originally planned recompete. The recompete is still on, it was just momentarily derailed due to the GSA notification. A bridge is being put into place to keep critical services going. A recompete is still planned following completion of this 8-month bridge contract.

The contracting officer posted a Microsoft Forms Request for Information (RFI) link on GSA Stars III, GSA MAS NAICS code 541519 – Information Technology Professional Services and SAM.gov.

responses were received during the market research exercise. PSD and POD will use the information received from the RFI to establish the requirements and scope of the Request for Quote (RFQ) for the recompete of the PSD IAS IT requirements contract.

To clarify, this market research was conducted in advance of the GSA notification and is only being provided in this section to provide data that USDA intends to solicit from as many sources as possible.

8. Any other facts supporting the justification.

Contractor is a small business in the designated NAICS 541512. Additional socio-economic representations include self-certified small disadvantaged business. Contracting with Spry Methods, Inc., supports small business and small disadvantaged business goaling. The anticipated bridge contract value is $7,103,428. As mentioned in section 5, this bridge contract is being issued using the authority cited by FAR 8.405-6(a)(1)(i)(B), Only one source is capable of providing the supplies required at the level of quality required.

Contractor is a small business in the designated NAICS 541512. Additional socio-economic representations include self-certified small disadvantaged business. Contracting with Spry Methods, Inc., supports small business and small disadvantaged business goaling.

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

USDA is actively engaged in market research for a request for quotation (RFQ) that is anticipated to be issued in early fiscal year 2025. We received responses from the RFI which will used to assist in drafting the RFQ. It’s our goal to be completed with the RFQ process in February 2025 to allow a potential data transfer to take place that is estimated to last 30 days and be completed no later than May 1, 2025.

Certifications & Approval

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

Rick Toothman

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

Sean Jordan Contracting Officer

Additional Reviews & Approvals

Signatures are required at each threshold up to the total estimated dollar value of the acquisition

Advocate for competition for the procuring activity (if over $750,000, but not exceeding $15 million). 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/MASCO, I hereby approve this justification. If required, my approval constitutes clearance for submission to the Head of the Procuring Activity.

Richard Jiron Title: Chief, Procurement Operations Division (POD) Procuring Activity Advocate for Competition

Head of the Procuring Activity (if over $15 million, but not exceeding $75 million). 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 Mission Area- Senior Contracting Official, I hereby approve this justification. If required, my approval constitutes clearance for submission to the Senior Procurement Executive.

Hilary (Cole) Erickson Head of the Procuring Activity United States Department of Agriculture