Sole Source for Contracts 360 Final_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.

Requisition Number:

Requesting Activity Agency: USDA Office of the Chief Information Officer (OCIO)

Contracting Activity: USDA Office of Contracting and Procurement (OCP), Procurement Operations Division (POD)

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

This limited source justification supports a sole source, firm fixed price (FFP) delivery order under the General Services Administration (GSA) Multiple Award Schedule (MAS), Information Technology (IT) for Palantir solutions in support of USDA’s financial review workflow.

These services are commercial in nature and will be procured utilizing the procedures listed in FAR Part 8 and the General Services Acquisition Manual (GSAM) subpart 538.71.

The suggested contractor is:

Palantir Technologies Inc.

19505 Biscayne Blvd., Ste. 2350 Aventura, FL 33180-3648

GSA #: GS-35F-0086U

UEI: FSY4LVSBGWB7

NAICS: 511210

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

The delivery order will provide specialized software licenses, configuration services, integration support and operational capabilities necessary to continue the design and full deployment of the financial review software workflow tool (known to the Dept. as Contracts360). The tool allows for proper fund allocation and oversight by rapid review, tracking and approval of budgets backed by real-time data line history and exposure adjustments. It unifies disparate data streams by integrating multiple resources into a single operating picture. The financial review software builds automated data lineages for auditability and compliance auditing, along with providing oversight into potential contract consolidation.

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.

Palantir is the only vendor capable of delivering the capabilities outlined in Section 3 without causing unacceptable delays or duplicative effort. Any alternative provider would face extensive accreditation and system-rebuild requirements, resulting in significant operational disruption and directly jeopardizing mission-critical activities.

This integration is built on a uniquely tailored framework developed through extensive collaboration with USDA mission-area personnel. Achieving the required accreditations, including FedRAMP High; DoD Impact Levels IL2, IL5, and IL6; and mission partner environment, would require any new contractor to make substantial investments in time, resources, and security engineering. Full accreditation at DoD Impact Level 5 (IL5), as defined in the Department of Defense Cloud Computing Security Requirements Guide and based on NIST 800-53, represents a particularly significant hurdle for a replacement provider.

By proceeding with this Palantir order, the Government avoids fragmented contracting efforts and gains efficiencies in transparency, cost management, scalability, and the rapid delivery of Palantir’s capabilities.

Palantir satisfies the following compliance frameworks which are part of the overall Palantir platform solution:

Service Organization Control (SOC):

SOC 1

SOC 2

SOC 3

Cybersecurity Maturity Model Certification (CMMC) Level 2 Federal Information Security Management Act (FISMA) High FedRAMP High DoD IL2, IL5, IL6 Certifications in the following:

ISO/IEC 27001:2022

ISO/IEC 27017:2015

ISO/IEC 27018:2019

ISO 9001:2015

Palantir Technologies has consistently delivered the extensive volume and scope of work required, along with the interoperability essential for both existing and future systems that support USDA’s critical agricultural infrastructure. Its agile development approach enables rapid adaptation to evolving requirements—a level of responsiveness not demonstrated by other developers. This speed, flexibility, and proven performance are vital to meeting the dynamic needs of USDA OCIO, ensuring the platform continues to advance in step with organizational demands.

Comparisons with similar applications have not identified any product offering advanced data-integration capabilities or the agility needed to respond to rapidly evolving requirements.

Palantir stands alone in providing the full set of features required by OCIO, making it the only solution capable of effectively supporting USDA’s contractual reviews and budget management needs.

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

Pricing is based on the GSA contract pricing which has been pre-negotiated and deemed fair and reasonable. The estimated prices include an additional discount off the GSA contract pricing from Palantir.

(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.

Based upon market research, while there are several comparable companies that provide data analytics and integration platforms (i.e., SAP S/4HANA &SAC, CGI Momentum, Oracle Cloud Government), none offer the combination of capabilities, enterprise scale data fusion, real-time analytics, compliance monitoring and integration with existing USDA systems that Palantir provides, nor hold the required level of FedRAMP authorization (NOTE: Because the current product vendor, Palantir, maintains a native FedRAMP High authorization, moving the Dept.’s workflows to another “out-of-the-box” vendor could possibly alter USDA’s security boundary definitions). Palantir is the only vendor capable of breaking down silos by integrating USDA’s diverse data sources and disparate networks/systems into a unified platform, providing real-time analytics for the Dept. to utilize the workflow to audit and streamline procurement pipelines (contract consolidation oversight) as well as ensuring that federal spending aligns with statutory appropriations, all while maintaining existing security controls across all integrated tools and upholding the highly specialized workflows within the USDA’s systems. Because these exclusive qualifications are essential to meeting USDA’s mission critical requirements, the capabilities and solutions offered by Palantir represent the most viable option for achieving USDA objectives.

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

While other MAS vendors offer analytic or integration services, none provide a unique platform or suite of capabilities that can deliver the mission-critical, real-time system integration and the interoperability required with existing USDA Palantir components.

(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.

USDA will maintain unlimited rights and ownership to all Government data, documents, and computed data properties, which will enable future competition when market research identifies competitors able to meet the necessary requirements.

Additionally, USDA will continue to proactively identify and reduce barriers to competition. Before issuing subsequent requirements for the same or similar products and services, OCIO will conduct renewed market research to assess the availability and capabilities of alternative sources. This ongoing review will help determine whether changes in the marketplace could allow current or future needs to be met through additional competitive options