Part 8 Over SAT JA FNA Account Management Agent (AMA) 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) in support of the Food and Nutrition Administration (FNA) proposes to issue a sole source order on a firm-fixed-price basis for technical enhancement services in support of stabilizing the Account Management Agent (AMA) application. This action will result in a contract modification against an existing an Blanket Purchase Agreement (BPA) Call order, 12314425F0369.

Requisition Number: 1176061

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

This Justification and Approval (J&A) is to authorize and approve an in-scope modification to Blanket Purchase Agreement (BPA) Call Order 12314425F0369. This modification is specifically designed to optimize the technical enhancement services currently deployed in support of the ongoing stabilization of the Account Management Agent (AMA) application.

A contract modification is required to meet a new legislative mandate as defined in Public Law 119- 21, the One Big Beautiful Bill Act of 2025 (OBBB). The law requires the AMA to create a mechanism for States to provide their share of SNAP benefits (i.e. AMA State Cost Share Enhancement) based on their annual quality control error rate. The cost share is variable and can not only change annually but can also change based on State appeals. The Cost Share enhancements must be in place no later than October 1, 2027. The enhancements must occur in parallel with the AMA stabilization which addresses known challenges and risks related to compliance with current technical, security, and program standards.

The current system is built on a legacy (and distributed) technology stack. In its current operational state, the system poses multiple risks to business continuity, security, compliance, and overall user experience. A recent FNA Office of Information Technology (OIT) assessment revealed the following negative Business impacts:

Security: High likelihood of exploitation due to known critical vulnerabilities in unsupported Java versions.

Compliance: Risk of federal compliance audits, fines, and/or possible lawsuits due to Section 508 non-compliance.

Operations: Escalating costs of maintenance with diminishing returns.

User Experience: Significant usability and accessibility gaps that reduces the service quality and customer satisfaction.

The simultaneous demands upon the AMA, provide a strong justification for the Food and Nutrition Administration (FNA) to claim only one source is capable caused by OBBB’s October 1, 2027, deadline to update the AMA with a State Cost Share while FNA is still in the process of stabilizing the application. In addition, the best technical course of action and the one with the least risk is to allow the current vendor to conduct the State Cost Share Enhancement. Technically, the current team is aware of and has experience with the issues the AMA currently faces and possesses critical, in-depth institutional knowledge of the application, its historical context, and current operational requirements. This established expertise and immediate familiarity with the system's unique intricacies are essential for seamless project execution. A new contractor would lack this specialized understanding and skill set, necessitating a substantial and potentially disruptive learning curve to achieve a comparable level of proficiency and operational efficiency. In addition, since stabilization and enhancement must occur simultaneously, risks are minimized when there is one team working on the application. One contract team allows for improved communication between all stakeholders and within the development team. The contractor will be able to schedule the stabilization and enhancements to work seamlessly together with a higher likelihood of reaching a minimally viable product (MVP) that can be tested and approved with sufficient time for end user training by the mandated deadline of October 1, 2027.

These commercial services will be secured through a modification to the existing BPA Call order, which was originally placed under FAR Part 8 and GSAM 538.71.

Ventera LLC Dba The Cadmus Group, LLC 1875 Campus Commons DR STE 304 Reston, VA 20191-1533

UEI: SJ85D6W4BDQ4

USDA Sustainment Blanket Purchase Agreement (BPA): 12314422A0015

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

This contract is for the acquisition of specialized technical services critical to the successful implementation and operationalization of the Agricultural Management Assistance (AMA) State Cost Share Program. These services will focus on the design, development, and integration of essential technical enhancements within the existing system. The primary objective of these enhancements is to fully enable the programmatic functionalities required for the AMA State Cost Share, ensuring efficient and compliant administration of funds. Specifically, the services will include, but may not be limited to:

1. Development of State-Specific Modules: Creation of new software modules or significant modifications to existing ones to facilitate state-level data input, management, and reporting for cost-share agreements.

2. Automated Calculation and Allocation Logic: Implementation of robust algorithms and business rules to accurately calculate cost-share allocations, track expenditures, and manage disbursement processes in accordance with program guidelines.

3. User Interface (UI) and User Experience (UX) Improvements: Enhancements to ensure an intuitive and efficient experience for state administrators and other program stakeholders, streamlining data entry and access.

4. Data Integration and Reporting Capabilities: Development of secure interfaces for seamless data exchange between state systems and the central [Existing System Name/Platform], along with advanced reporting tools to monitor program performance, financial transparency, and compliance.

5. Security and Compliance Features: Integration of necessary security protocols and features to protect sensitive data and ensure adherence to federal data privacy and security mandates.

This aggressive timeline is essential to provide ample opportunity for comprehensive end-user testing, validation, and the development of robust training programs for all affected stakeholders, including state agency personnel and federal administrators. The timely delivery and successful deployment of this MVP are paramount. It will ensure that both the enhanced system and its end-users are fully prepared to commence the implementation of the AMA State Cost Share Program by the Congressionally mandated date of October 1, 2027. Failure to meet this deadline would result in significant non-compliance issues, potential disruption to critical agricultural assistance programs, and an inability to disburse vital funds to eligible recipients as directed by Congress.

A modification will be issued against the existing BPA call order to incorporate a new Contract Line Item Number (CLIN) with a twelve (12)-month Period of Performance (POP) valued at $3,000,000. Additionally, a six (6)-month extension, valued at $1,500,000, will be included. The estimated total value of this modification, encompassing the new CLIN and the extension, is $4,500,000:

Period Fiscal Year Estimated Total

BASE FY26 $ 3,000,000

6-month extension FY27 $ 1,500,000

Subtotal $4,500,000 Evaluation of FAR 52.217-8

Grand Total $4,500,000

(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.

This acquisition is justified as 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 l, pursuant to GSAM 538.7104-3(b)(ii).

A. Incumbent's Unique Qualifications Derived from a Competitively Awarded Contract and Intimate System Knowledge:

Ventera LLC currently provides critical services under BPA Call order12314425F0369, focused on the ongoing stabilization of the Agricultural Management Assistance (AMA) environment and its core application. This foundational contract was awarded through a full and open competitive process, which rigorously established Ventera LLC's superior capability, technical proficiency, and efficiency in meeting FNA’s stringent requirements for this specific system.

Due to their continuous and competitively validated engagement, Ventera LLC possesses an unparalleled and intimate understanding of the AMA system's complex architecture, dependencies, and the inherent risks associated with making modifications. Their team is actively involved in stabilizing the current operational state, which provides them with:

Real-time insight: Direct, hands-on knowledge of the system's current state, known vulnerabilities, and ongoing issues, gained through their active role in system stabilization.

Deep historical context: A comprehensive understanding of past modifications, design decisions, and their implications, built over the course of their competitively won engagement.

Risk mitigation expertise: The unique ability to anticipate and mitigate potential negative impacts of enhancements on a system currently undergoing stabilization, leveraging their established expertise.

This specialized and current knowledge, developed and proven through a prior competitive award, is critical for the proposed AMA State Cost Share technical enhancements. The enhancement work is a logical extension of the stabilization effort, representing a planned evolution within the system's lifecycle and consistent with the original scope's intent. It builds upon the foundation being secured by the incumbent, and directly benefits from the vendor's established and competitively validated understanding of the system.

B. Significant Delays and Increased Costs Associated with Competition:

Requiring FNA to pursue a new competition for these services, rather than continuing with the current vendor, would introduce substantial and unacceptable delays, significantly increase costs, and elevate technical and programmatic risks. Therefore, a sole source approach with the incumbent vendor is essential to mitigate these adverse impacts and ensure successful program execution:

1. Project Start Delay: A competitive procurement process is projected to delay the project's commencement. While a sole-source award could initiate work by August 30, 2026, a competitive award is not anticipated until September 30, 2026, resulting in an immediate one-month loss of critical project time.

2. Coordination Complexity and Risk: Introducing a new vendor would necessitate the complex alignment of their enhancement work with the incumbent's ongoing stabilization efforts. This scenario presents significant risks:

Accountability Ambiguity: Difficulties in assigning responsibility for issues arising from simultaneous modifications by two separate entities on the same codebase.

Increased Technical Debt: Potential for conflicting code changes, integration challenges, and increased technical debt.

Operational Inefficiency: The need for extensive coordination meetings, interface definitions, and dispute resolution between two distinct vendor teams, diverting resources and increasing overhead.

System Inoperability Risk: A heightened risk of introducing instability or inoperability to a system that is currently being stabilized.

C. Financial Impact and Jeopardized Congressionally Mandated Deadline:

The Office of Information Technology (OIT) estimates that the 60-day delay for onboarding and system familiarization alone will cost the government an estimated $499,391. These costs are derived from the project's Independent Government Cost Estimate (IGCE) and represent a direct financial loss that would not be recouped through competition.

More critically, these delays severely compromise the project's ability to meet the Congressionally mandated deadline of October 1, 2027, for the AMA State Cost Share implementation. The initial 13-month enhancement schedule would be immediately reduced to 12 months by competition. The additional 60-day vendor ramp-up would further shrink this critical development window to only 10 months. When factoring in the essential 90 days required for extensive User Acceptance Testing (UAT) and end-user training at the project's conclusion, the actual development period would be compressed to an unmanageable 8.5 months.

An 8.5-month enhancement schedule for a project of this complexity and criticality, especially on a system undergoing active stabilization, introduces an unacceptably high risk of project failure and non-compliance with legislative requirements.

D. Conclusion:

Therefore, issuing this modification basis to Ventera LLC is demonstrably in the best interest of the government's economy and efficiency. It leverages the incumbent's unique, real-time knowledge of the AMA system, avoids significant financial expenditure on redundant onboarding and familiarization, and most importantly, mitigates the severe technical and programmatic risks that would jeopardize the timely implementation of the Congressionally mandated AMA State Cost Share Program by October 1, 2027.

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

Pursuant to GSAM 538.7102-2(d), a formal determination of fair and reasonable pricing is waived for orders placed against Federal Supply Schedules. However, the Contracting Officer (CO) has conducted a comprehensive and fact-based price analysis to ensure the proposed pricing for this sole source requirement remains fair and reasonable to the Government. This evaluation included the following specific actions:

1. GSA Schedule and BPA Rate Verification: The CO thoroughly reviewed the contractor's proposed labor rates against both their established GSA Federal Supply Schedule contract and the negotiated rates within the existing Blanket Purchase Agreement (BPA) under which the current contract (12314425F0369) was issued. This review confirmed that all proposed rates for the identified labor categories are consistent with the BPA's negotiated pricing and do not exceed the approved GSA Schedule ceiling rates.

2. Labor Category Alignment: A detailed comparison was performed between the proposed labor categories and the technical requirements outlined in the Statement of Work (SOW) for the AMA State Cost Share enhancements. The CO confirmed that the proposed labor mix and skill sets are appropriate and directly aligned with the required services.

3. Quantity and Level of Effort Analysis: The proposed labor hours and quantities for each labor category were meticulously analyzed for reasonableness against the Independent Government Cost Estimate (IGCE) for this project. This analysis also considered the specific scope and complexity of the technical enhancements required.

4. Discount Confirmation: All applicable discounts available under the contractor's GSA Schedule contract and the BPA, including any volume discounts or prompt payment terms, were confirmed to have been applied to the proposed pricing.

Based on this rigorous and comprehensive price analysis, which included verification against both the GSA Schedule and BPA rates, alignment with technical requirements, comparison to the IGCE, and consideration of the unique efficiencies of a logical follow-on, the Contracting Officer hereby determines that the anticipated cost for this order is fair and reasonable.

Prior to final award, I will conduct a final review of the fully negotiated and proposed pricing to ensure continued fair and reasonableness, confirming the final labor category alignment, applied discounts, and consistency with the scope of work.

(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.

A comprehensive market research effort was conducted to identify the most effective and efficient acquisition strategy for the critical AMA State Cost Share technical enhancements. This research assessed available industry partners within the GSA acquisition environment and existing agency contract vehicles to determine the availability, capability, and capacity of vendors able to provide highly specialized IT development services for complex, mission-critical legacy systems.

The research included a review of GSA Multiple Award Schedule (MAS) Information Technology (IT) Special Item Numbers (SINs) and a comparative analysis of alternative acquisition strategies, including other GSA MAS IT vehicles, Government-Wide Acquisition Contracts (GWACs), and agency-specific BPAs. A key component of this research was evaluating vendors with proven expertise in modifying and enhancing existing software applications, particularly within a dynamic stabilization environment, and assessing the incumbent's established performance under contract 12314425F0369.

The results of this market research unequivocally concluded that, given the unique requirements, ongoing system stabilization, and the critically tight Congressionally mandated timeline, utilizing the existing GSA Federal Supply Schedule (FSS) order with the incumbent contractor, Ventera LLC, represents the most technically sound, acquisition-efficient, and least-risk solution.

Consistent with FAR Part 8 and 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, this approach avoids the significant delays, increased costs, and heightened technical risks associated with a new competitive posting.

Therefore, leveraging the incumbent's unique, current knowledge and proven capabilities is essential, as only this source possesses the specific expertise required to effectively meet this critical requirement.

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

Several additional critical factors strongly support the use of this justification for a modification with Ventera LLC. The highly specialized nature of the Agricultural Management Assistance (AMA) system, particularly within its current stabilization phase, relies on an intimate and real-time understanding of its complex architecture, existing codebase, and intricate interdependencies that have been uniquely acquired and refined by Ventera LLC during the tenure of their current contract (12314425F0369).

Moreover, Ventera LLC possesses an unparalleled and current operational insight into the AMA system's critical components and technical processes integral to its ongoing stability and the program’s success. This deep, real-time knowledge is not readily transferable or replicable by another vendor without significant effort and risk. Attempting to onboard a new vendor would necessitate an extensive period of knowledge transfer and system familiarization, which would be tantamount to recreating the incumbent's accumulated expertise from scratch. This would prevent the formulation of a detailed and competitive solicitation that could be effectively addressed by other vendors within the required timeframe, as no other vendor currently possesses the requisite hands-on familiarity with the system's precise state and nuances.

Furthermore, transitioning to an alternate source would require substantial engineering efforts, significant time, and financial investments to gain this specialized system knowledge and validate any modifications, leading to unacceptable delays and operational risks. As previously detailed, the estimated 60-day delay for a new contractor's onboarding and system familiarization, coupled with the complexities of coordinating with the ongoing stabilization efforts, would severely jeopardize the ability to meet the Congressionally mandated implementation deadline of October 1, 2027. This makes the incumbent's unique, current knowledge an indispensable asset for the timely and successful execution of these critical enhancements.

(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.

For this specific acquisition, the agency faced a unique situation driven by a Presidential mandate with an extremely limited timeframe for completion. This urgency, coupled with the critical need for immediate execution by the October 1, 2027 deadline, meant that there were no feasible actions that could be taken to remove or overcome competition barriers for this particular action. As shown with prior competition, the Food and Nutrition Administration (FNA) actively utilizes competitive means; however, the unique constraints of this mandate presented extremely limited to no opportunities to overcome competition barriers for this action.

Looking ahead to subsequent acquisitions of the AMA system enhancements and related services, FNA remains committed to fostering competition where and when circumstances allow. While the specific nature and urgency of future requirements will dictate the feasibility of certain approaches, FNA will continue its efforts to:

1. Enhance Documentation and Knowledge Capture: Systematically capture and formalize institutional knowledge, including system architecture, detailed code documentation, and operational procedures, to reduce reliance on single-vendor understanding and facilitate broader participation in future procurements.

2. Develop Performance-Based Requirements: Continuously refine Statements of Work (SOWs) and Performance Work Statements (PWSs) to clearly articulate required outcomes and functionalities, thereby broadening the pool of potential offerors for future needs.

3. Conduct Robust Market Research and Industry Engagement: Engage in ongoing market research and industry outreach (e.g., RFIs, industry days, technical workshops) to identify new sources, emerging technologies, and vendors capable of meeting future needs, particularly as the AMA system evolves beyond its immediate stabilization and enhancement phase.

While the agency remains fully committed to the proactive efforts outlined for future acquisitions to foster competition, it is imperative to acknowledge the unique and exigent constraints driving this current action. The critical necessity to meet the Presidential mandate's October 1, 2027 deadline, coupled with the AMA application's highly specialized nature, inherent complexity, and actively stabilizing state, means that immediate competition for this specific requirement was not feasible.

The current reliance on the incumbent's unique, real-time understanding of the system, cultivated through their ongoing stabilization efforts, is therefore essential and irreplaceable for meeting the mandated timeline. Overcoming these significant barriers and creating a genuinely competitive environment for such a specialized and continuously evolving system will be a long-term endeavor, requiring sustained effort over multiple acquisition cycles. The agency will maintain a continuous review process to assess progress and adapt strategies for maximizing competition in all future AMA-related acquisitions.