1-15-1_Consolidation Determination for Zone 5 SLI_Non Substantial Quantifiable Benefits_20251028_Redacted.pdf

Acquisition Alert 24-13 Attachment 2

DETERMINATION TO CONSOLIDATE REQUIREMENTS INTO A SINGLE

CONTRACT

(NON SUBSTANTIAL QUANTIFIABLE BENEFITS)

Determination for U.S. Citizenship and Immigration Services (USCIS) to Consolidate Sign Language Interpretation Services for USCIS Offices in Zone 5 (MT, ID, WA, OR, CA, AZ, Guam, AK, MP, HI) into a Single Contract.

This determination is made pursuant to FAR 7.107-2.

The total value of all actions covered by this determination is estimated to be

FINDINGS

1) Description/Background

USCIS has historically acquired Sign Language Interpretation (SLI) services for federal employees through location-based procurements, resulting in various redundancies and inefficiencies (as discussed in section 6 below). USCIS is now pursuing a zone-based approach for the procurement of SLI services, which will involve the consolidation of multiple location-based requirements into singular zone-based requirements for five geographic-based zones, resulting in significant benefits (as discussed at section 6 below). The instant determination is to address the consolidation of requirements to satisfy SLI service requirements within Zone 5.

USCIS Zone 5, which is comprised of 36 offices, has multiple employees who are deaf and hard of hearing. These Federal employees attend and conduct various in-person and virtual meetings, trainings, town halls, interviews and other work-related functions and will need sign to voice, voice to sign and other available SLI services. The USCIS Office of Civil Rights and Equal Employment Opportunity (CREEO), Accommodation & Access Division requires these SLI services to allow the employees to fully participate in all work-related functions.

The following five requirements for SLI services for USCIS employees who are deaf and hard of hearing were procured previously as individual orders to satisfy the requirements for SLI services within the above-described Zone 5 region. The services were procured either off of the General Services Administration (GSA) Multiple Award Schedule (MAS) 541930, Translation and Interpretation Services or the Department of Homeland Security (DHS) Strategic Sourcing Vehicle (SSV) for Communications Access Services (CAS) Blanket Purchase Agreement (BPA) consisting of five Small Business Holders.

Current Orders being Consolidated

Platform/ Vehicle #/ Vendor

Order # / Type of Set Aside

Description Date Procured

Dollar Value

DHS CAS BPA/

70FA4022A00000011

(Deaf Access Solutions

70SBUR22F00000178

SLI services for the San Diego Field

08/12/2022 $1,730,994.72

Current Orders being Consolidated

Platform/ Vehicle #/ Vendor

Order # / Type of Set Aside

Description Date Procured

Dollar Value

Inc.) (Set Aside: Small Business)

Office (SND)

DHS CAS BPA/

70FA4022A00000011

(Deaf Access Solutions, Inc.)

70SBUR22F00000189

(Set Aside: Small Business)

SLI services for the Los Angeles Field Office (LOS)

08/12/2022 $1,539,486.00

GSA Schedule/

47QTCA21D009H

(TCS Interpreting, Inc)

70SBUR23F00000029

Business)

SLI services for the Santa Ana Field Office (SAA)

01/18/2023 $53,824.72

GSA Schedule/

47QRAA22D004R

(Stuart B. Consultants, Inc)

70SBUR24F00000159

Business)

SLI services for USCIS Sacramento Field Office

(SAC)

07/03/2024 $794,990.72

GSA Schedule/ GS- 10F-0168X (Deaf Access Solutions, Inc.)

70SBUR24F00000210

Business)

SLI services for the Los Angeles Field Office (LOS)

08/29/2024 $2,130,900.40

The North American Industry Classification System (NAICS) code for each of the above stated Small Businesses is 541930. The Acquisition Planning Forecast System (APFS) number for the expected award for the Zone 5 SLI requirements is F2025072226, which was published on 09/26/2025. The Independent Government Cost Estimate (IGCE) of accounts for additional locations and the flexibility to bring new USCIS employees, specifically those in support of the law enforcement and immigration benefits functions (i.e., Immigration Service Officers, Fraud Detection and National Security (FDNS) Immigration Officers, etc.), as the training for these categories includes 6-9 weeks of in-person training per employee.

2) Market Research

Recent market research was conducted from May 2025 to July 2025 and included a review of historical procurements for similar SLI services, a review of recent market research conducted for similar historical procurements, as well as a review of available ordering vehicles (DHS CAS BPA and GSA Multiple Award Schedule (MAS) ). The market research indicates that the required SLI services are available under GSA MAS as well as under the DHS CAS BPA strategic sourcing vehicle. The DHS CAS BPA, comprised of five (5) small businesses and competitively established under the GSA Professional Services, Language Services, Translation and Interpretation Services Multiple Award Schedule, provides the ability to purchase communications access services with improved quality and responsiveness at volume discounts and pre-negotiated terms and conditions. As market research indicates that the small business CAS BPA holders are capable of providing the required services and that there is an expectation of obtaining competition amongst the CAS BPA holders, this requirement will be competed amongst the small business CAS BPA holders.

Review of historical procurements, including coordination with cognizant acquisition officials, indicates that CREEO’s recurring requirement for SLI services has proven difficult for vendors to sustain personnel under the smaller, location-based efforts. Further, the market research also provided insight into the historical operations involved with the location-based efforts across the Zone, demonstrating redundant task order administration efforts due to the large number of orders, such as the processing of invoices, and a high volume of OSI security clearance processing due to the number or orders and the order-by-order screening required.

Consolidation from a location-based approach into a zone-based approach is now being pursued, with the significant benefits of this approach detailed in section 6 below.

3) Contracting Alternatives

The alternative to consolidating into a zone-based approach includes continuing with placing task orders for small, location-based services. As detailed at section 6 below, consolidating the location-based requirements into a zone-based requirement will address inefficiencies in monitoring and administration efforts, provide for significant cost savings, and increase quality of services by allowing a stabilized approach to retaining personnel. The alternative of continuing with location-based requirements would retain the high-level administrative burden for CREEO and OCON to initiate and monitor multiple efforts versus a single vehicle, including the corresponding costs associated, and would not allow for the expected service quality improvements through more stable staffing requirements.

4) Coordination with Component Small Business Specialist and Office of Small and Disadvantaged Business Utilization (OSDBU)

The Office of Contracting (OCON), through its Small Business Specialist, coordinated this Determination and Findings with the Office of Small And Disadvantaged Business Utilization

(OSDBU).

5) Negative Impacts to Small Business Participation

Consolidating into a single zone-based requirement will mean fewer separate opportunities to compete for multiple smaller location-based efforts. However, this effort will be procured under the DHS CAS multiple award BPA and will afford competitive opportunity to the five Small Business CAS BPA holders (reflecting a small business set-aside approach similar to the to-be consolidated Zone 5 requirements.) This acquisition strategy ensures small business participation.

6) Benefits

a. Identify benefits to consolidating

(i) Consolidating the SLI task orders into a larger area of responsibility will increase efficiency in monitoring and administering the services. Redundant actions across multiple task orders will be streamlined into one action. One example of streamlining to increase administration efficiencies is invoice processing. The standard invoicing practice amongst the small businesses is to submit one invoice for these services typically every two (2) weeks. Using five (5) locations as an example, this would result in up to 10 invoices per month. A larger area of responsibility would offer the vendors a more stabilized approach to invoicing and allow the Government to meet contractual requirements under reduced manpower constraints with the processing of a single invoice versus multiple repetitive actions, decreasing from 10 invoices per month in this scenario down to two.

(ii) Cost Savings for the Government includes the Office of Security and Integrity

(OSI) clearance process in which each interpreter must be cleared on each individual task order.

Across all of the five zones, there are currently seventeen (17) location-based task orders to satisfy the SLI service needs of USCIS. Each task order must have its own Entry on Duty (EOD) determination through reciprocity and/or full background investigations, resulting in clearance adjudication for all personnel under each of the seventeen task orders. For Zone 5, having two (2) task orders results in duplication of efforts, with clearances required for the personnel under each of the two (2) orders. Moving from multiple task orders to satisfy the SLI requirements within each zone’s area to a single task order per zone will significantly reduce the number of required clearances as clearances will only be necessary for a single pool of interpreters under a single awardee for each zone.

(iii) Quality improvements – a requirement covering a larger area of responsibility offers the vendor a more stabilized approach to retain personnel as the interpreters may be afforded opportunities to support additional schedules throughout the locations identified within the Zone. With a more stabilized workforce, the Vendor’s probability to meet the demands for interpreters, including hard-to-fill cities, increases the overall quality of the services (schedule and performance).

(iv) Consolidation of requirements into a larger area of responsibility will provide for a reduction in acquisition cycle times. Exercising optional tasks or option years will be reduced to a single task order; whereas, if the consolidation did not occur, there would be multiple packages for several task orders. With reduced manpower in CREEO and OCON, the risk of a break in service increases significantly due to multiple actions and redundancy of workload actions required to support individual task orders per location.

b. Compare anticipated benefits

(based on GS13 average base salary). Furthermore, the OCON administrators could be reduced by an additional $205,000 (based on GS13 average base salary for 2 positions) as the reduced number of task orders will minimize the required amount of support. With the estimated cost savings of $512,000 resulting from level of effort decreases due to the elimination of redundancies in these administrative areas across all five zones of the SLI consolidation effort, consolidation within each respective zone, including Zone 5, represents significant cost savings.

In addition to the contractual administration, the task orders per location require a security clearance to be processed for each individual interpreter for each task order, resulting in multiple security clearance packages being processed. As shown in the chart above, a zone-based effort will eliminate this redundancy, reducing the number of required clearances by approximately 71% across all five zones, from an estimated 255 clearances required to support the CREEO SLI portfolio to 75 (using an average pool of 15 interpreters per zone), and yielding an estimated cost savings of $270,000 (reduction of 180 clearances at an estimated cost of $1,500 per clearance). The current location-based task orders are awarded to multiple vendors;

therefore, requiring clearances for an increased number of interpreters. Additionally, while an interpreter may be cleared under one location-based task order, the OSI process requires the same interpreter to also be cleared under any other location-based task order whether it runs concurrently or subsequently to the task order under which the interpreter was initially cleared.

Utilizing the zone-based approach with a single vendor, the pool of resources would be significantly reduced and a single OSI clearance granted per interpreter as those resources would be available to support multiple locations with varying schedules under one task order. For the instant consolidated requirement, Zone 5 as shown in chart 2 above, this means a significant reduction in the number of clearances required, from 75 down to 15 (using an average pool of 15 interpreters per zone). With the estimated cost savings of $270,000 resulting from decreases in the amount of clearances across all five zones of the SLI consolidation effort, consolidation within each respective zone, including Zone 5, represents significant cost savings.

c. Apply the threshold test for the quantifiable benefits

The benefits quantifiable in dollar amounts do not meet the FAR 7.107-2(d) definition of substantial in that the quantifiable cost savings do not meet the threshold of ten percent of the estimated order value (with the total order value estimated below $94 million). However, as discussed in detail above, the consolidation effort will result in considerable cost and performance benefits.

7) Critical to Agency’s Mission Success:

While the quantifiable expected benefits under this consolidation do not meet the threshold for a substantial benefit, these benefits and others identified herein are critical to USCIS’s mission success because they represent the correction of multiple operational inefficiencies (e.g., invoice processing, contract award/administration efforts, clearance processing), quality improvements through more stabilized workforce demand, and reduction in acquisition cycle times. Also, this procurement strategy provides for maximum practicable participation by small business.

DETERMINATION

I hereby determine that this procurement meets the requirements of FAR 7.107-2. While the quantifiable benefits are not substantial, the benefits identified herein are critical to USCIS’s mission success, and this procurement strategy provides for maximum practicable participation by small business.

Alternate Small Business Specialist Office of Contracting U.S. Citizenship and Immigration Services

Angela Hodges Date Contracting Officer Office of Contracting U.S. Citizenship and Immigration Services

Head of the Contracting Activity Office of Contracting US. Citizenship and Immigration Services

APPROVAL:

Chief Procurement Officer, or designee Date Department of Homeland Security