SAM -Part 8 Over SAT JA Travel Relocation Management.pdf

United States Department of Agriculture

Justification to Restrict Competition under FAR Part 8

Over the Simplified Acquisition Threshold

Identification Number:12314426Q0184

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.

Requesting Activity Agency: Office of Chief Financial Officer (OCFO)

Contracting Activity: Departmental Administration, Office of Contracting and Procurement

Operations Division (POD)

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

The Department of Agriculture (USDA) Office of Chief Financial Officer proposes to issue a sole source, Firm-Fixed Price (FFP), logical follow-on to an FSS order 12314421F0469 already issued on a competitive basis for the procurement of the Travel Relocation Management Service

Support to assist USDA with its processing, expense, recording, and reporting travel relocation expenditures for USDA employees. This follow-on contract will continue to provide the critical government relocation management Software as a Service (SAAS) solution integrated into both the USDA Financial Management Modernization Initiative System (FMMI) and the Integrated

Acquisition System (IAS).

These services are commercial in nature and will be procured utilizing the procedures listed in

FAR Part 8 and GSAM 538.71.

The suggested contractor is:

MLINQS, LLC

8203 Roseland Dr.

Fairfax Station, VA

22039-2535

SAM UEI: FYXQSLS7MH63

The expected renewal period of performance is 09/01/2026 to 08/31/2027.

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

The follow-on to MLINQS contract 12314421F0469 will continue to provide Travel Relocation

Management Service Support to USDA Office of the Chief Financial Officer (OCFO) Mission

Areas with the necessary system enhancements to ensure proper accounting of relocation expenditures. The Travel Relocation Management Service Support system is an integrated SaaS solution with the USDA Financial Management Modernization Initiative System (FMMI) that allows Mision Areas to assist their employees with home sales, home purchases, moving services, and other items associated with relocating from one city to another.

It is anticipated that one (1) task order consisting of one (1) one-year base period and four (4) one-year option periods will be awarded. The estimated total for the base year plus all options is

$5,907,549.00.

(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)(iii) - The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.

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

The incumbent contractor’s team possesses unique institutional knowledge which is critical to ensuring USDA is able to continue to meet Executive Order 14222 related to implementing

Department of Government Efficiency (DOGE) Cost Efficiency Initiative and the USDA

Secretary’s Mandate to relocate USDA Mission Areas to HUB Locations across the United States from the Washington D.C. Metropolitan Area. The system and associated support will meet all regulatory guidelines and assist with the ongoing initiative to relocate USDA employes out of the

Washington D.C area to USDA Hub locations by the end of the fiscal year. This follow-on contract will continue to provide the critical government relocation management Software as a Service

(SAAS) solution integrated into both the USDA Financial Management Modernization Initiative

System (FMMI) and the Integrated Acquisition System (IAS).

The implementation of SaaS solution with both FMMI and IAS took 7 months, as the system was able to go into production in April of 2022. One reason the follow-on contract is required is to ensure there is not a break in service due to the ongoing need to relocate USDA Mission Areas to

HUB Locations needed for USDA employees. Given the time required to integrate a new system with USDA—including integration with FMMI (the enterprise Financial System) and obtaining

Authority-to-Operate from OCIO, which takes 5–9 months—there is insufficient time to launch another solution before relocation needs arise in 2026 and 2027. Therefore, continued use is necessary for efficiency of delivery for the government.

In addition, due to prior investments in the solution. The current contract 12314421F0469 included

$70k for implementation and $230k for consulting. Switching vendors would at least require these costs again, plus inflation, with no way to recover sunk expenses. Therefore, the follow-on award is the most economical and efficient option for the government. The current Travel Relocation

Management Services Support contract 12314421F0469 was competed under Federal Supply

Schedules (FSS) 541511T (Employee Relocation Management Software) and 561599 (Travel –

Travel Agent and Misc. Services) in accordance with the applicable FSS procedures. The solicitation resulted in award of task order number 12314421F0469 against MLINQS GSA contract

GS-35F-0007U for a 12-month base plus 4 12-month options currently ending on August 31, 2026.

There would be substantial duplication of cost to recompete this requirement, and those costs are not expected to be recovered through competition. Additionally, the risks associated with recompeting this requirement outweigh any potential benefits of renewed competition. A new competition would require transition of services to a different vendor, which introduces risks.

These risks, combined with the significant duplication of cost, would outweigh any potential savings achieved through competition. Accordingly, the Government has determined that proceeding with this logical follow-on action ensures continuity of operations, maintains compliance with security and technical requirements, and represents the most prudent and cost-effective course of action.

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

Although GSAM 538.71022(d) waives a formal determination, the Contracting Officer has determined this contract action represents the best value as defined in FAR 2.101 to the government in accordance with GSAM 538.71022(b)(4). The Contracting Officer (CO) has evaluated the proposed pricing by reviewing the contractor’s Federal Supply Schedule (FSS) rates, which have already been determined fair and reasonable by GSA at the master contract level.

In addition to relying on the established FSS pricing, the CO has:

• Reviewed historical pricing data from the incumbent contract to ensure consistency and to validate that the proposed rates align with prior Government purchases for the same or similar services.

• Compared proposed labor categories and rates to the GSA Schedule contract rates and confirmed that they do not exceed those ceiling rates.

• Considered market conditions and any available independent Government estimates (IGCE) or benchmarking data to further support the reasonableness determination.

This determination of best value considers not only the price but also the contractor’s unique technical qualifications, incumbent knowledge, and proven ability to maintain continuity of operations and compliance with agency-specific requirements. Accordingly, the combination of pre-negotiated FSS pricing, discounts, validation against historical data, and avoidance of duplicative costs provides the Government with assurance that the awarded prices are fair and reasonable and represent the best value to the Government.

(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 by reviewing SIN 541511T

Employee Relocation Management Software to include Mlinqs, Relocation Management

Worldwide, and Runzheimer International as the only available vendors. This review confirmed that the required services were, in fact, available under the Federal Supply Schedule from all three vendors. However, based on the government total cost of ownership (TCO), the effort and efficiency of the government, and potential impacts to service a logical follow-on is in the best interest of the government. The government has already spent over a million dollars on the development and implementation of solution. Additionally, these services are Software as-a-Service and must be integrated with both FMMI, Treasury, and in some situations USDA’s Integrated

Acquisition System (IAS). Based on the expense and efficiency of the existing product it would not be in USDA’s interest to duplicate costs and implement another solution at this time. Should the government procure a different alternative, we would need to bridge or extend the existing systems contract while making the determination on a new system so that services could continue and not impact Executive Order 14222 which is aimed at consolidating the Federal footprint as much as possible. Based on the above, a logical follow-on is in the best interest of the government.

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

As previously mentioned, transitioning to a new system would require design, engineering, development and implementation efforts by the government, would impact the delivery of services as the implementation would take time beyond the end of contract period of performance; and would increase cost in new investment for the government unnecessarily.

(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.

If subsequent acquisitions for these services are anticipated, USDA/FNS will take proactive measures to broaden the competitive base among HUBZone small businesses and reduce reliance on a single source. These measures will include:

• Enhanced Market Research: Expanding outreach through SBA’s Dynamic Small Business

Search (DSBS), industry days, and HUBZone-focused vendor engagement events to identify additional qualified sources.

• Advance Planning and Notices: Publishing Requests for Information (RFIs) and Sources

Sought notices on SAM.gov well in advance of future requirements to provide industry adequate time to prepare.

• Vendor Development and Outreach: Coordinating with SBA’s HUBZone Program Office and Procurement Technical Assistance Centers (PTACs) to encourage additional HUBZone firms to pursue certification and position themselves for similar work.

• Acquisition Strategy Review: Considering partial set-asides, reserves under multiple-award contracts, or on-ramp provisions to increase the number of qualified HUBZone vendors available for future competitions.

• Feedback Mechanisms: Providing debriefings and technical feedback to non-HUBZone vendors to increase their awareness of HUBZone certification benefits and encourage participation in future HUBZone competitions.

Through these efforts, the Agency will work to mitigate barriers to competition and foster a more robust HUBZone vendor or open competition to the entire USDA/FNS Sustainment pool for subsequent acquisitions, thereby ensuring maximum practicable competition consistent with statutory requirements.

(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.

Contracting Officer’s Representative Date

(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.

Contracting Officer Date

Additional Reviews & Approvals

Signatures are required at each threshold up to the total estimated dollar value of the acquisition, including all possible options. Delete reviews/approvals that are not needed.

(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).

Josh Tafoya Date

Chief of the Contracting Office (COCO)

Competition Advocate