RedactedJA_00005.pdf

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

Over the Simplified Acquisition Threshold Identification Number: 12318725F0181 P00005

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: 1177012

Requesting Activity Agency: USDA, FS, WO – Human Resources Management (HRM)

Contracting Activity: USDA, FS, WO – PPS – National Procurement Office, National Contracts Branch

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

This action is a modification to contract 12318725F0181 exercising FAR Clause 52.217-8 Option to Extend Services.

The suggested contractor is:

GovStrive, LLC 100 W Jackson St. Unit D Dublin, GA31021-6116

UEI: UKXQJYEKUN34

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

Ongoing HRM Personnel Support Services are required for an additional 14 weeks and three days.

The services received for this modification will include initiation procedures and applicant follow-up for background investigations related to new and existing Forest Service employees, enabling compliance with the mandatory requirement Homeland Security Presidential Directive 12 (HSPD-

12) – “Policy for a Common Identification Standard for Federal Employees and Contractors”, dated August 27, 2004. Contractors will initiate, follow-up, monitor progress, review investigative packages, manage and process all levels of background investigations in e-APP, prepare and work with Defense Counterintelligence Security Agency (DCSA) Special Agency Checks (SAC), and ensure timeline compliance.

The extension is for 14 weeks and 3 days, extending the contract from September 30, 2026 through January 09, 2027. The estimated value of this extension is The total contract value is increased from .

(4) Identify the statutory authority permitting other than full and open competition.

The statutory authority supporting the extension of this order is authorized by FAR clause 52.217-8, Extension of Services.

The statutory authority supporting the establishment of the Federal Supply Schedule Blanket Purchase Agreement (BPA) that exceeds the Simplified Acquisition Threshold (SAT) on a sole source basis is FAR 8.405-6(a)(1)(C) – In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule. The FAR reference is the applicable FAR at the time the order was issued.

(5) Demonstrate that the proposed contractor's unique qualifications or the nature of acquisition requires using the authority cited.

Although FAR Clause 52.217-8 was included in the contract, the value of the option was not included in the price evaluation conducted prior to contract award. In a GAO ruling dated 14 September 2009, if the value of the option was not included in the price evaluation, a J&A is required before the option can be exercised.

Exercising the option clause stated above will provide continued contractual coverage of HRM personnel security services. The incumbent contractor has the requisite qualified personnel in place to continue uninterrupted services beyond the current end date of 29 September 2026. It would not be possible for any other contractor to mobilize qualified personnel by the required date.

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

The anticipated labor categories were determined fair and reasonable under the base BPA. The original requirement was competed against all multiple award contract (MAC) BPA holders prior to award of the call order 12318721F0120 and GovStrive’s proposal provided the best value to the Government. The current labor rates utilized to determine the firm-fixed price were compared to the current labor rates in GovStrive’s price list for their GSA contract and the labor rates used to establish the firm fixed price in this order are below the rates under their current GSA price list. The Contracting Officer determines the price fair and reasonable and the extension of services continues to represent the best value to the Government given the constraints associated with this critical service.

(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 originally conducted among GSA Schedule holders by reviewing the available contractors and capabilities prior to base BPA Award. The quote for 12318726Q0048, provided by the incumbent, was determined to be the most advantageous solution to the government’s needs at time of award. Additional market research was not performed upon determination to exercise FAR

52.217-8 as no other BPA Awardees provide comparable solutions that satisfy the Government’s minimum needs.

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

The continued performance of this service is critical and necessitates the need for a sole source order in an effort to provide sufficient time to compete a long-term vehicle without a significant lapse in service. The service provided is critical to USDA’s reorganization effort and will be leaned on heavily to achieve those reorganization goals.

(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 Government will overcome future barriers to competition by providing fair opportunities or open competition for the next contract action.

(10) Certifications & Approvals

Technical / Requirements Personnel Certification I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

(11) Contracting Officer’s Certification I certify that the data supporting the recommended use of other than full and open competition accurate and complete to the best of my knowledge and belief.

(12) Competition Advocate (greater than $900,000 but not exceeding $20M).

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, I hereby approve this justification. If required, my approval constitutes clearance for submission to the Head of the Contracting Activity (HCA).