Sole Source Justification.pdf

Justification for Other than Full and Open Competition

Documented in Accordance with FAR 6.104-1

(1) Agency and Contracting Activity:

Requiring Activity:

Acquisitions Divisions, United States Census Bureau (USCB) Associate Directorate for Economic Programs

(ECON)

(2) Nature/Description of Action being Approved:

In accordance with Revolutionary FAR Overhaul (RFO) 12.102, Restricting Competition, and RFO 6.103-2 - Unusual and compelling urgency and statutory authority of 41 U.S.C. 1901, the agency’s need for the required Places and Spend Commercial Data is of an unusual and compelling urgency that justifies an award on a sole source basis to SafeGraph.

The applicable procedures are in RFO 12.201- 1 Simplified Procedures, as implemented by Department of Commerce through FAR Class Deviation for FAR Parts 1 through 53 (PM 2026-06).

(3) Description of Supply/Service Places and Spend Commercial Data. The U.S. Census Bureau (USCB) is the Federal Government’s largest statistical agency dedicated to providing current statistical data about America’s people, places, and economy. This data assists Congress, the executive branch of the Federal Government, state, and local Governments, the general-public, and the private sector in the development and evaluation of social and economic activities and drive the decision-making of critical public-policy and private sector business decisions. Reliable collection, preparation, tabulation, and dissemination of demographic and economic statistics are vital to the USCB’s overall mission and strategic goals and objectives. The Economic Directorate (ECON) uses transparent, scientific methods to provide broad and impartial information on the changing U.S.

economy for use in public and private sector decision-making. Within these data products are the Economic Census, 17 Principle Economic Indicators, and over 100 separate survey areas/data products. ECON relies on timely high-value alternative data in the production of key economic indicators—including the Advanced Monthly Retail Sales Reports, the Monthly State Retail Sales Reports, the Annual Integrated Economic Surveys, and the Economic Census. The estimated value is $442,900.00 and the Period of Performance is 01/02/2026 – 12/31/2026.

(4) Identification of the Statutory Authority permitting Other than Full and Open Competition.

Pursuant to FAR 6.103-2(b) Urgency, Agencies may contract without providing for full and open competition when the agency's need for the supplies or services is of such an unusual and compelling urgency that the Government would be seriously injured, financially or otherwise, unless the agency is permitted to limit the number of sources from which it solicits bids or proposals. The applicable statutory authority is 41 U.S.C. 3304(a)(2).

(5) A demonstration that the proposed Contractor’s unique qualifications or the nature of the Acquisition requires the Authority cited.

Currently, ECON acquires the necessary Places and Spend Commercial establishment-level data from SafeGraph which directly supports the Principle Economic Indicators. This data identifies all business locations nationwide, tracks openings and closures in near-real-time and includes credit-card–based spend information for a subset of locations. Places and Spend Commercial data directly support the USCB’s ability to detect business churn quickly, reduce the lag in incorporating new establishments, and identify closures with precision. This data enables the most accurate and efficient sampling frames, reduces survey collection costs by minimizing contacts to closed or nonexistent businesses, and ensures that the agency’s flagship economic indicators reflect current economic realities rather than outdated frames. Sustained utilization of Places and Spend data ensures a strategic, cost-effective enhancement to the nation’s economic measurement infrastructure. It strengthens statistical quality, improves operational efficiency, and safeguards our ability to meet urgent national information needs with relevance, accuracy, and speed.

On October 01, 2025, the Federal Government experienced a lapse in appropriations and entered a Government Shutdown. During this Shutdown, most activities for the USCB ceased. The agency continued with minimally necessary operations and activities which ensured the safety and security of data, IT resources, and property. Rapid reestablishment of accurate business frames, to which Safegraph Places and Spend is a key input, was essential to support the timely release of nationally significant economic indicators. Upon the reopening of the Government on November 13, 2025, the need for immediate access to current Places and Spend data became urgent due to the unusual timing, duration, and economic disruption associated with the shutdown.

Given these exceptional circumstances, SafeGraph’s historical coverage, consistency, and proven ability to deliver timely data uniquely position it to meet the Census Bureau’s requirements.

Without continued access to Places and Spend data, the Bureau would lose its comprehensive, economy-wide view of business activity at a critical moment—precisely when structural changes driven by shifts in consumer behavior, technology adoption, and regional economic realignments demand more frequent, granular, and responsive measurement.

The Census Bureau would be seriously injured—financially and operationally—if it were not permitted to limit this procurement to SafeGraph. The near–real-time inventory of businesses and their operating status is the cornerstone of ECON’s survey operations. Without it, the Bureau would lose the ability to accurately monitor economic dynamics at both national and sub-national levels, impairing its capacity to assess emerging trends, technological impacts, and the economic effects of disruptive events such as the Government Shutdown. Failure to acquire Places and Spend data would directly degrade the accuracy of survey samples that depend on the reliable identification of active establishments. These samples underpin multiple recurring statistical releases and economic indicators produced by the Census Bureau. Without this data, the Bureau’s ability to maintain continuity, credibility, and relevance in its economic statistics would be materially compromised.

Without this data, the USCB would experience a lag in production of approximately 6 months, resulting in a serious financial and operational impact.

(6) A description of efforts made to ensure that offers are solicited from as many potential sources as possible, including Whether a Notice was or will be publicized as required by FAR Part 5 and, if not, which exception under FAR Part 5 applies.

Given the urgency of this action, as described in detail in Section 5 of this Justification, efforts were not made to solicit offers from as many potential sources as possible. Pursuant to FAR subpart 5.101(b)(2), the Contracting Officer is not required to post a pre-solicitation notice to Government Point of Entry (GPE) when using other than full and open competition.

(7) A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

As required for the purchase under this Justification, the Contracting Officer issued a request for proposal to SafeGraph, LLC. The Contracting Officer determined the cost to the Government would be fair and reasonable through a variety of methods, including comparisons to prices of similar services in a related industry, to the Independent Government Cost Estimate, and to price paid under previous contracts for the same or similar purchases. It was anticipated that the total price of the 12-month contract will not exceed $442,900.00.

(8) The market research conducted and the results or a statement of the reason market research was not conducted.

Market Research was conducted and documented in accordance with FAR Part 10 in support of this procurement. Market Research for this procurement consisted of a review of historical acquisition information, knowledge in procuring services of this type, review of internet resources, and contacts with other federal government program representatives. Based on the market research, the Government determined that SafeGraph, LLC, has a valid entity registration in the System for Award Management (SAM), was not on the excluded parties list and no other businesses were identified as capable of supporting the requirement at this time.

(9) Any other facts supporting using other than full and open competition.

The USCB has a long history of leveraging administrative and other non-survey data to create new products or enhance current programs. By integrating high-quality third-party data sets from SafeGraph, particularly in key sectors such as retail, the USCB reduces the impact of declining survey response rates, enhances coverage, and allows for the stable and timely production of estimates, thus strengthening the resilience, reliability, and timeliness of the Principal Federal Economic Indicators (PFEIs) and other key economic indicators.

Non-survey-based data sources, such as the commercial places and spend data, for statistical production are critical to maintaining existing products, while reducing the burden on respondents – all of which reflects the alignment with EO 14303: Restoring Gold Standard Science.

(10) A listing of the sources, if any, that expressed an interest in the acquisition in writing.

Not applicable.

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The unprecedented volume of data and rapid proliferation of commercial data sources present both significant opportunities and complex challenges for the USCB as it carries out its mission to be the Nation’s leading provider of reliable, objective, and accurate statistical information for Government, industry, and the public. While the growing abundance of data expands analytical possibilities, the distributed, disparate, and heterogeneous nature of these sources increases the complexity and time required for effective analytics and decision-making. As the USCB reinvents how it conducts business, it is deliberately broadening its perspective through expanded use of alternative data sources, modernized analytical methods, advanced processing techniques, and state-of-the-art dissemination and visualization capabilities. These efforts are essential to ensure that the USCB’s statistics remain relevant, timely, and responsive to ever evolving economic and social conditions. Through this modernization, the USCB strengthens its https://www.federalregister.gov/documents/2025/05/29/2025-09802/restoring-gold-standard-science https://www.federalregister.gov/documents/2025/05/29/2025-09802/restoring-gold-standard-science role as a trusted data leader in the Information Age, better serving its stakeholders while adopting the innovative approaches and technologies necessary for the continued success of censuses, surveys, and economic programs. Simultaneously, the USCB is continuously evaluating the use of commercially available data across new and existing programs and operational processes. To keep pace with rapid programmatic modernization and advances in the commercial data marketplace, the USCB has established an enterprise-level team dedicated to coordinating the acquisition, market research, governance, and strategic use of commercial datasets across the agency. This contract serves as a critical bridge, ensuring uninterrupted access to urgent, mission-essential data while the enterprise-team conducts a comprehensive evaluation of its long-term commercial data needs and integration strategies and performs market research on sources that would overcome or remove barriers to competition in future procurements.

(12) Contracting Officer Certification As the Contracting Officer, I certify that this justification is accurate and complete to the best of my knowledge and belief.

Kristina D. Hartman - Contracting Officer