Justification Other Than Full and Open Competition--OARS_Signed.pdf
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- Operations and Reporting System (OARS)
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This is a Justification for Other than Full and Open Competition (JOFOC) document from USDA APHIS requesting an 8-month no-cost extension of an existing GSA task order with Axiom Resource Management, Inc. for IT development services related to the Wildlife Services' Operations and Reporting System (OARS).
The extension will allow Axiom to complete final development and testing activities for an October 14, 2025 go-live date, followed by a hyper-care period for post-deployment bug fixes. The justification cites FAR 6.302-1 as authority, noting that Axiom has specialized expertise with OARS that would make switching contractors disruptive and costly at this final stage. The original contract was competitively awarded through GSA with a base year plus four option years. After this extension, APHIS will assume responsibility for operation and maintenance of the system. The document is signed by Samuel Patton (Branch Chief) and Larry Nelson (Contracting Officer) in February 2025.
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US Department of Agriculture (USDA)
Justification for Other than Full and Open Competition
Section 1: Justification for Other than Full and Open Competition
1.1 Identification of the Agency and Contracting Activity
Requesting Agency:
USDA, Animal and Plant Health Inspection Service (APHIS), Marketing & Regulatory Programs Business Services (MRPBS), Wildlife Services (WS)
Contracting Agency:
USDA, Animal and Plant Health Inspection Service (APHIS), Marketing & Regulatory Programs Business Services (MRPBS), Acquisition and Asset Management Division (AAMD) Procurement Branch 250 Marquette Ave Minneapolis, MN 55401
1.2 The Nature and/or Description of the Action Being Approved
APHIS proposes to extend a firm-fixed price GSA task order for an additional 8 months, on a basis other than full and open competition, for Axiom Resource Management, Inc. for IT services for the final development and go-live support of the Wildlife Services’ Operations and Reporting System (OARS).
The primary goal of Wildlife Services (WS) is to deliver high-quality wildlife damage management services to customers that result in the protection of agricultural products, wildlife and other natural resources, property, and human health and safety. Data management, which includes data collection, integrity, analysis, and reporting, is a critical part of the goal.
In 2002, WS invested in modernizing the electronic communication system known as Management Information System (MIS2000). This system was migrated from a distributed thick-client platform, built with Perl, and backed by an Oracle database. MIS2000 has been in production in an operational state since mid-2005. MIS2000 has reached its “product end-of-life” stage.
Wildlife Services has identified a need to re-engineer their core business user processes through a program named the Operations and Reporting System (OARS). Thus, the objective of this contract is to obtain Contractor services for the development and implementation support of the Operations and Reporting System (OARS).. This support shall include reassessment of initial system requirements and redesign validation from prior phases, system development in the targeted architecture, system integration and configuration of the chosen platform for expanded capabilities, data strategy and migration to stand up OARS in the production environment.
1.3 Description of the Supplies or Services Required to Meet the Agency’s Needs (Including the Estimated Value)
The extension award will be for a period of eight (8) months which will allow the contractor to complete final development and testing activities required for a go-live nf October 14, 2025 and a hyper-care period to support post deployment bug fixes. This will be a no-cost extension of this contract. The current firm-fix price will remain unchanged.
But, prior timeline has been extended to meet Government’s ability to support this project.
1.4 Statutory Authority Permitting Other than Full and Open Competition
1.4.1 Only one responsible source and no other supplies or services will satisfy agency requirements
41 U.S.C. 3304(a)(1) / FAR 6.302-1 and 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 order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.
APHIS originally solicited the current contract under a competitive GSA process. The current contract was for a base year and four option years. The learning curve to establish the knowledge base for this type of project is steep due to the technical nature of the subject. The contractor personnel assisting with this project have a tremendous amount of specialized expertise of the OARS system which any other contractor does not possess. Switching contactors at this final stage of the contract would be an incredibly disruptive event and undoubtedly lead to much additional cost and time. In the interest of economy and efficiency, this work is a logical follow-on to the initial GSA award.
1.5 Description of Efforts Made to Ensure Offers Are Solicitated from as Many Potential Sources as is
Practicable
The current contract for the OARS system development was the result of a competitive GSA procurement. All GSA contract holders were made aware of the opportunity via public posting on the GSA eBuy website.
1.6 Determination by Contracting Officer that the Anticipated Costs to the Government will be Fair and
Reasonable
The current contract pricing is the result of a competitive process and based on GSA contract pricing which has been deemed to be fair and reasonable. This will be a no-cost extension based on that pricing.
1.7 Description of the Market Research Conducted Among Schedule Holders and the Results or a
Statement of the Reason Market Research Was Not Conducted
Extensive market research was conducted for the award of the current contract. Only the current contractor has the expertise and resources to complete these services in the amount and the timeline required.
1.8 Facts Supporting the Justification
As mentioned earlier in the document, this will be an extension of the current contract which established the contract pricing. This will provide the extra seven months to complete the contract in lieu of switching contractors at this critical juncture.
1.9 Listing of the Sources That Expressed a Written Interest in the Acquisition List sources, if any, that expressed an interest in the acquisition.
N/A
1.10 Statement of Actions the Agency May Take to Remove or Overcome Any Barriers to Competition if Subsequent Acquisitions are Anticipated
No additional services for the OARS contract is anticipated at this time. At the conclusion of this contract, APHIS will assume responsibility for operation and maintenance of the new system.
Section 2: Certifications and Approvals
2.1 Program or Technical Personnel
Supporting data which form the basis for and included in this justification are certified accurate and complete.
Samuel Patton Branch Chief/Operations Project Management Branch
2.2 Contracting Officer
The information contained in this Limited Sources Justification is certified accurate and complete to the best of my knowledge and belief.
Larry Nelson Contracting Officer/Competition Advocate
| 1.1 Identification of the Agency and Contracting Activity |
| 1.2 The Nature and/or Description of the Action Being Approved |
| 1.3 Description of the Supplies or Services Required to Meet the Agency’s Needs (Including the Estimated Value) |
| 1.4 Statutory Authority Permitting Other than Full and Open Competition |
| 1.4.1 Only one responsible source and no other supplies or services will satisfy agency requirements 41 U.S.C. 3304(a)(1) / FAR 6.302-1 and FAR 8.405-6(a) (1) (C) In the interest of economy and efficiency, the new work is a logical follow-on to an ori... |
| 1.5 Description of Efforts Made to Ensure Offers Are Solicitated from as Many Potential Sources as is Practicable |
| 1.6 Determination by Contracting Officer that the Anticipated Costs to the Government will be Fair and Reasonable |
| 1.7 Description of the Market Research Conducted Among Schedule Holders and the Results or a Statement of the Reason Market Research Was Not Conducted |
| 1.8 Facts Supporting the Justification |
| 1.9 Listing of the Sources That Expressed a Written Interest in the Acquisition |
| 1.10 Statement of Actions the Agency May Take to Remove or Overcome Any Barriers to Competition if Subsequent Acquisitions are Anticipated |
| Section 2: Certifications and Approvals |
| 2 |
| 2.1 Program or Technical Personnel |
| 2.2 Contracting Officer |
| 2025-02-13T12:07:22-0700 | |
| SAMUEL PATTON |
| 2025-02-13T13:17:35-0600 | |
| LARRY NELSON |
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