LIMITED SOURCES JUSTIFICATION 9.10.pdf

LIMITED SOURCES

Agency: United States Census Bureau

Contracting Office: Acquisitions Division

Requiring Activity (Program Office): Office of the Chief Financial Officer

Nature/Description of Action being

Approved:

Limited Sources – only one source is capable of providing the required supplies or services

Description of Supply/Service: ORACLE EPM ACCOUNT

RECONCILIATION – IMPLEMENTATION

& GTAS EDIT CHECK CONFIGURATION

Estimated Value: $2,487,855.39

Period of Performance: 09/14/2026 – 09/13/2027

Authority

RFO FAR 8.401(b), GSAR 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 and highly specialized.

Accenture is the only source capable of providing the required services at the level of quality necessary due to their uniquely specialized and longstanding technical expertise in the

Department’s Financial System.

Rationale

a. The particular brand-name, product, or feature is essential to the Government’s requirements:

The Office of the Chief Financial Officer is seeking support services for additional functionality to their Consolidated Budget & Reporting Application (COBRA) Oracle Enterprise Performance

Management (EPM) platform to strengthen audit readiness, leverage AI, remediate existing audit findings, and relieve operational strain due to reductions. The Contractor owns and operates and

Oracle EPM enhanced AI Natural Language Query tool, not available through any other vendor. The tool is technically dependent on the Oracle Cloud Infrastructure Environment managed exclusively by Accenture, making both the capability and its delivery model unavailable from any other source.

The objective is to support compliant financial reporting, improve reconciliation accuracy, strengthen internal controls, and enable automated Governmentwide Treasury Account Symbol

(GTAS) validation prior to Treasury submission. Accenture currently possesses the following:

Specialized Experience and Unique Capability: Accenture possesses a unique combination of proprietary technology, specialized Oracle EPM expertise, and Federal

Financial management knowledge that no other source can replicate. The Contractor owns and operates an Oracle EPM enhanced AI Natural Language Query tool, not available through any other vendor. The Tool is technically dependent on the Oracle Cloud

Infrastructure environment managed exclusively by Accenture, making both the capability and its delivery model unavailable from any other source.

System Ownership and Institutional Knowledge: Accenture defined the accounting treatment and standardized business processes with the Department of Commerce

Enterprise Resource Planning (ERP) modernization initiative known as the Business

Applications Solution (BAS) program. This provides unmatched knowledge of data structures, classifications, and transaction flows. This expertise is essential to execute subledger to general ledger reconciliation and remediate prior audit findings, particularly within Oracle Account Reconciliation Cloud Services (ARCS).

First of a kind Federal Capability: The ARCS based reconciliation capability represents a first of a kind implementation in the Federal environment. Accenture uniquely applies commercial derived ARCS expertise combined with Federal accounting expertise to configure EPM and its Federal Reporting requirements, including GTAS.

The USBC plans to enter into a task order in a manner of a limited sources with Accenture

Federal Services LLC, (“Accenture”) on the basis that it is the only source capable of providing these services under GSA Contract GS-35F-540GA

b. The market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s needs:

Historical information demonstrated that no other contractor could provide the level of detail and technical capabilities needed to continue with this requirement.

Award to any other source would result in substantial duplication of cost that would not be recovered through competition.

Accenture is the only source capable of providing the required services at the level of quality necessary due to its uniquely specialized and longstanding technical expertise with the

Department’s CBS Core Financial System (CFS), Accenture has support the CFS for more than a decade and possesses unmatched, in-depth knowledge of the system’s highly customized code base, integrations, interfaces, workflows and operational environment. This deep familiarity enables Accenture to implement configuration changes, troubleshooting issues, and optimize system performance with a level of precision and efficiency that no other vendor can match.

Market Research confirmed that no alternative sources are available. No vendors were identified with the technical understanding necessary to support this environment. Prior market research conducted by the Department of Commerce, March 2026, demonstrated that

Accenture is the only contractor with the specialized knowledge, proprietary insights, and sustained hands-on experience required to maintain and enhance the Core Financial

System without introducing significant operation risk.

Absent Accenture, Census would be required to independently procure, stand up, and manage a separate Oracle Cloud Infrastructure (OCI) environment to support the required AI and data capabilities. This approach would introduce significant duplicative infrastructure and operational costs driven by required labor across cloud architecture, engineering and security roles; licensing for OCI and AI platforms; compute capacity, including graphics processing unit (GPU) intensive workloads and ongoing security and compliance needs, including independent third party assessment and authorization required for a federal environment costing millions annually to operate and maintain the environment, with no offsetting value.

Acquisition Strategy Considerations

The Government will award a task order under GSA Schedule GS-35F-540GA to Accenture in a limited sources basis pursuant with GSAR 538.7104-3(b)(ii) and this justification will be posted in accordance with GSAR 538.7104(b)(3)(i)-(iii) .

Fair and Reasonable Price Determination

Pursuant to GSAR 538.7102-2(d)(2), Ordering activities are not required to make a fair and reasonable price determination for Federal Supply Schedule (FSS) products, services, or solutions at the order level or BPA level as FSS contract pricing has been determined fair and reasonable.

Other Facts Supporting the Justification

Based on the document technical dependencies, proprietary EPM capabilities, Accenture-developed federalized accounting configurations, and the time critical nature of USCB’s quarterly and year-end financial reporting cycles, competition would result in (1) loss of mission essential capabilities not replicable by any other vendor within the required timeframe; (2) substantial duplication of prior Government investment that would not be recoverable through competition; and (3) unacceptable delays that would jeopardize the timeliness, accuracy, and overall integrity of Census statutory mandated financial reporting.

For these reasons, Accenture is the only responsible source capable of meeting the agency’s immediate and mission critical requirements.

Transitioning reconciliation and financial reporting support to another vendor would require rebuilding the Federal specific accounting logic that Accenture has already established. The cost and time required to replicate this foundation would represent a substantial duplication of prior Government investment.

Given the highly specialized nature of the requirement, the absence of viable alternative sources, and the operational risk associated with introducing a new vendor at this stage in the system lifecycle, Accenture is the only contractor capable of delivering the required services at the necessary level of quality.

Actions to Remove Barriers to Competition in the Future

As the underlying IT infrastructure modernizes, critical cloud migration efforts are initiated, programs adapt to the change, and technology offerings evolve, the USCB is actively and continuously assessing the enterprise needs and organizational directives to determine the best compute solutions to meet the changing needs of the organization and its unique programs.

The USCB will continue weighing the benefits of alternative offerings to ensure the investment of taxpayer resources at the best value. As such research and assessments are conducted, a determination can be made on the best solution to support the objectives of the program into the future subsequently removing or overcoming any barriers to competition.

Technical Certification

I certify that the supporting data and information forming the basis for this justification are accurate and complete.

Contracting Officer Certification

As the Contracting Officer, I certify that this justification is accurate and complete to the best of my knowledge and belief

Larrieka Knox- Contracting Officer

Competition Advocate Approval

Samantha Brady - Competition Advocate, United States Census Bureau