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

Over the Simplified Acquisition Threshold Identification Number: 12314426Q0077

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:

Office of the Chief Information Officer (OCIO), Client Technology Services (CTS)

Contracting Activity:

United States Department of Agriculture (USDA), Departmental Administration (DA) Office of Contracting and Procurement (OCP) Procurement Operations Division (POD) 301 S. Howes Street - Suite 321 Fort Collins, CO 80521

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

This Justification & Approval authorizes and approves the award of a Firm Fixed Price (FFP) commercial single-source Federal Supply Schedule (FSS) as a Blank Purchase Agreement (BPA) with Carahsoft Technology Corp for Granicus Communications formally GovDelivery Digital Communication Platform to support a department-wide Enterprise License Agreement (ELA) for the Granicus Communications Cloud. The United States Department of Agriculture (USDA) Office of the Chief Information Officer (OCIO), Client Technology Services (CTS) is leading a department-wide initiative to establish an enterprise agreement for a cloud based Digital Communication solution, including software, maintenance, and support. This Enterprise License Agreement (ELA) will allow USDA to standardize pricing across all agencies, streamline procurement for new orders and annual software renewals, and ensure consistent access to a secure scalable Federal Risk and Authorization Management Program (FedRAMP) authorized environment, and compliant digital communications platform

Under this agreement, USDA agencies or Mission Areas will have access to the Granicus Communications Cloud. USDA seeks to continue leveraging its existing Software-as-a-Service (SaaS) solution to effectively communicate with diverse internal and external audiences. These services are commercial in nature and will be procured utilizing the procedures listed in FAR Part 8 and GSAM 538.71. This solution supports USDA’s mission to deliver timely, accurate, and accessible information to stakeholders while maintaining compliance with federal security and accessibility standards. The current platform enables agencies to expand outreach through multiple channels, including:

Email marketing and notifications Short Message Service (SMS)/text messaging Really Simple Syndication (RSS) feeds Social media integration Mobile Messaging

The suggested contractor is:

Carahsoft Technology Corporation 11493 Sunset Hills Road Reston, VA 20190-5328

(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.

The statutory authority permitting other than full and open competition for this procurement applies due to the unique qualifications of the proposed contractor and the nature of the requirement. The Granicus Communications platform, provided exclusively through Carahsoft, is the only SaaS digital communications solution that satisfies USDA’s mandatory needs without requiring substantial modification. The Original Equipment Manufacturer (OEM) and reseller Carahsoft possess proprietary technologies, specialized expertise, and an established understanding of USDA systems, while also meeting all required federal compliance standards, including FedRAMP, Section 508, GDPR, and CAN‑SPAM. Granicus Communications top competitors in the communications cloud space include Salesforce Government Cloud, Accela, and CivicPlus.

Based on the agency’s requirements, the alternative products do not provide the necessary functionality without substantial modification. Such modifications would introduce unacceptable cost, delay, and risk.

Granicus Communications procured through Carahsoft is the only solution that meets the agency’s needs with proven capability and without requiring custom development. Granicus Communications platform is built specifically for the public sector, providing public alerts, emergency messaging and large-scale citizen updates.

Suitable mainstream alternatives do not exist and would need to be developed. Currently alternatives to this solution only offer the ability to provide partial support. Granicus Communications formally GovDelivery maintains a shared network of millions of citizen subscribers across federal agencies. GovDelivery is optimized for very high-volume, high-delivery email, whereas most other platforms struggle with this.

Market research confirmed that alternative solutions do not meet the full set of Government specific communication requirements. Competing platforms either lack essential public sector workflows, cannot support high volume deliverability, or require significant integration and customization, introducing unacceptable cost, delay, and performance risk. In contrast, the Granicus platform provides capabilities not matched by other schedule holders, including the GovDelivery Network, high‑volume/high‑deliverability infrastructure, unlimited usage scalability, and advanced automation and segmentation tools essential for enterprise‑wide communication. Because the product is purpose built for Government communications and includes proprietary components that cannot be replicated without extensive redevelopment, transitioning to another vendor would require new system build‑out, integration, developmental sprints, data migration, and user retraining. This would result in an aggressive estimated 9 to12 months of delay and duplication of cost, creating substantial operational risk and mission disruption.

Based on these findings, only the Granicus Communications solution available through Carahsoft can meet USDA’s requirements at the necessary level of performance, security, and compliance, supporting the use of the authority cited. The requirements compliance matrix below outlines the market research results as it pertains to the following Government communications functional areas:

1. The GovDelivery Network: This feature allows Government organizations to cross-promote their content on each other's websites, similar to how Amazon recommends related products. This network facilitates

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

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. In addition, establishing a BPA would create a single, streamlined contracting source that ensures the most competitive pricing for all Government agencies.

(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 conducted among GSA schedule holders and confirmed that only the proposed source can meet the requirement. Reviews of the Top 10 Email Marketing Tools and 14 Best Email Marketing Platforms also affirmed that migrating to another service would impose a significant burden in terms of time, resources, and cost. Additionally, GSA’s Market Research as a Service (MRAS) review noted that Granicus Communications formally GovDelivery software for Government customers is only available through Carahsoft Technology Corporation under Multiple Award Schedule (MAS) Special Item Number (SIN) 54151ECOM Electronic Commerce and Subscription Services.

Comprehensive market research was also conducted using multiple federal sources, including: Category Management buying guides GSA Advantage, GSA eLibrary, and MAS SIN 54151ECOM listings NASA SEWP, SAM.gov vendor searches Small Business Dynamic Search Tool. These techniques consistently confirmed that the Granicus Communications platform offered exclusively through Carahsoft is the only SaaS Government specific communications solution meeting USDA’s requirements for FedRAMP security, Section 508 compliance, multichannel messaging, API based integration, audience segmentation, and enterprise level scalability.

This research confirmed that the required supplies/services are available under the Federal Supply Schedule;

however, only one Schedule contractor was identified as capable of meeting the specific technical requirements of this acquisition. No other Schedule holders provided comparable capabilities or solutions that satisfied the Government’s minimum needs. Accordingly, the market research supports proceeding with a single source justification under the FSS program.

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

While commercial digital marketing software is widely available, Government agencies have unique requirements that demand a specialized solution. Several additional factors support the use of other than full and open competition for this requirement. Digital Communication Services for the public sector rely on proprietary technologies and processes developed specifically for Government use . These capabilities are not readily available in commercial off-the-shelf marketing platforms, which generally lack the federal compliance, security, and integration features required by USDA.

Government agencies must meet stringent standards, including FedRAMP, Federal Information Security Modernization (FISMA), Section 508 accessibility, records management, and integration with existing Government systems that are fully supported by the Granicus platform but not by mainstream alternatives. The solution also provides audit features, public-accountability functions, and data-governance alignment essential for federal operations. Granicus, through Carahsoft, retains proprietary rights to key components of the platform, which prevents other vendors from replicating required functionality without infringing on protected technologies. Transitioning to a different provider would necessitate extensive engineering to recreate these capabilities, resulting in significant cost duplication, high operational risk, and unacceptable delays to mission-critical communications. Commercial alternatives would require major customization to approximate these features, further increasing risk and cost. As a result, a highly specialized, Government-focused solution is necessary to ensure compliance, continuity, and mission effectiveness.

(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.

To promote future competition and reduce barriers in subsequent acquisitions, OCIO will continue to conduct comprehensive market research, issue Requests for Information (RFIs), engage with industry through vendor outreach sessions, and review emerging technologies through demonstrations and capability briefings. These activities will help identify potential new entrants and assess whether evolving market offerings can meet USDA’s technical, security, and operational requirements.

This requirement is limited to Granicus Communications software solution due to the product functionality not offered by other software within this spectrum of email solutions. If USDA were to switch to a new application, a severe reduction in the high level of customer service and disruption to the mission would occur. This application has advanced functionality that allows USDA to provide exemplary service to the subscribers and allows users to develop customized mailings to the wide range of user base. Competition will be limited to Granicus Communications resellers through GSA.

At present, the effort is limited to the Granicus Communications solution because comparable products do not provide the requited Government specific functionality without significant customization. Transitioning to alternative platforms would reduce service quality and disrupt mission-critical communications due to the advanced unique features and workflows USDA relies upon. For the duration of this requirement, competition will therefore be limited to authorized Granicus Communications resellers under GSA. OCIO will reassess the market prior to any subsequent acquisition to determine whether viable competitive alternatives have emerged.