Part 8 Over SAT JA DISC Carahsoft ServiceNow 12314426F0121 Redacted.pdf

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

Over the Simplified Acquisition Threshold Identification Number:

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.

The United States Department of Agriculture (USDA), Departmental Administration (DA), Office of Contracting and Procurement (OCP), Procurement Operations Division (POD) proposes to issue a brand name task/sole source order on a firm-fixed-price basis for software subscription.

This order will be as a result of a brand name/sole source RFQ issued via GSA MAS.

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

The United States Department of Agriculture (USDA), Office of the Chief Information Officer (OCIO), Digital Infrastructure Service Center (DISC), Digital Services Center Division (DSCD) proposes to issue a sole source/brand name task order on a firm-fixed-price basis for ServiceNow enterprise software subscriptions for the replacement of an existing contract set to expire in March 2026. This order will result from a sole source/brand name Request for Quote (RFQ) via FAR Part 8 and GSAM 538.71. Per GSAM538.7104-3(b) (i) – The need is such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need.

The suggested contractor is:

Carahsoft Technologies Corp 11493 Sunset Hills RD

STE 100

Reston, VA 20190-5230

UEI: DT8KJHZXVJH5

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

The requirement is for the USDA/OCIO/DISC/DSCD enterprise-wide ServiceNow Cloud subscriptions, and the ancillary products as noted in the attached product list, on behalf of USDA and all its Mission Areas.

The ServiceNow Platform provides critical support to multiple USDA agencies and program areas.

The ServiceNow Platform, which has been in production in the USDA for over 10 years, has expanded from a single application to various robust business platforms across several USDA agencies from hosting more than 50 mission critical applications. Current USDA applications developed and maintained by ServiceNow in support of critical mission areas.

This acquisition requires the ServiceNow brand name software solution that is compatible with the existing infrastructure and deployed on Certified FedRAMP Moderate environment. The ServiceNow brand name software functions as the USDA’s Enterprise Software System used for security incident response capabilities would significantly weaken the Department’s ability to respond effectively to cyber threats and maintain a secure environment on USDA networks.

(6) A determination by the Contracting Officer that the order represents a fair and reasonable price.

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.

The market research effort assessed available industry partners across the USDA enterprise and the broader GSA acquisition environment to determine the availability, capability, and capacity of vendors able to support enterprise-wide cloud, cybersecurity, and IT modernization services. This research included evaluating the structure, scope, and technical domains associated with the relevant vendor pools, along with an assessment of contractor qualifications, past performance, and small-business participation levels.

In addition to reviewing internal contract structures, the team conducted a comprehensive product search on GSA Advantage by validating each required SKU to confirm availability through GSA.

Comparative research was also performed to examine alternative acquisition strategies, including options such as CIO-SP4, GSA MAS IT, and agency-specific BPA vehicles.

The results of this research concluded that GSA offers a technically qualified and acquisition-efficient solution for meeting the Government’s requirements.

Consistent with FAR Part 8 and GSAM 538.71, and specifically GSAM 538.7104-3(b)(i), the need warrants an approach that avoids delays associated with extended competitive posting requirements.

Conducting market research on GSA demonstrated that, due to the 30-day posting requirement applicable to alternative internal vehicles, GSA provides the most timely and effective acquisition method for this requirement.

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

ServiceNow is the only option that can meet and exceed all the projected USDA business application requirements. The USDA has significant deployment of existing applications built on the ServiceNow platform. The ServiceNow platform contains proprietary source code only authorized by ServiceNow and their authorized resellers. Therefore, no other brand name solution can provide the necessary ServiceNow patches, updates and software and platform support. Adding a non- ServiceNow software platform to the infrastructure will require new architecture, integration and deployment of operations support development. This would lead to a significant cost increase generated by the implementation of a new and complex software application in which agencies will encounter a steep learning curve ultimately creating extensive delays.

The ServiceNow brand name footprint within USDA has expanded from supporting one application and one agency to now supporting multiple agencies and line offices across the USDA. Dozens of customized ServiceNow applications have been built and deployed in support of the USDA mission areas with many more currently being developed.

(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 brand name justification allows for competition among multiple resellers. Future competitions may also define salient characteristics, if possible, to allow for a brand name or equal competition.