GS-10F-0372_68HERC22F0512ASL_LSJ_FINAL__3-21-2025_Redacted_1.pdf

Limited-Sources Justification 2

• Basic and scientific interpreter services, including American Sign Language (ASL)

• Cued Language Transliterator (CLT)

• Communication Access Real-time Translation (CART) captioning for deaf and hard of hearing (D/HH) employees at EPA agency-wide events, whether remote or on-site

These services cover various technical subjects, including environmental science, legal matters, enforcement material, information technology, and general professional workplace discussions.

This ensures EPA's commitment to maintaining continuity of services for D/HH employees, enabling them to fulfill their professional responsibilities and obligations in a hybrid workforce environment. Refer to the attached Performance Work Statement for the complete scope of services.

Estimated Value of Extension Period:

The total maximum estimated value for the increase in ceiling capacity is to maintain continuity of interpreter services for the duration of the 6-month extension period to September 30, 2025.

4. The authority and supporting rationale, and, if applicable, a demonstration of the proposed contractor's unique qualifications to provide the required supply or service:

In accordance with FAR 8.405-6(a)(1)(i)(B), only one source is capable of providing these unique and highly specialized services at the level of quality required to support the immediate needs of the deaf and hard of hearing employees across the Agency at this time. The current contractor, Access, has performed at a satisfactory level under the existing task order and is familiar with the service requirements. Furthermore, the current vendor is already equipped, integrated into the Agency’s IT infrastructure, and postured to comply with all applicable Agency policies and the federal statutes that mandate these services to be made available to the deaf and hard of hearing employees. The interpreting services currently provided by Access are critical to support the functional capabilities of EPA staff who use these services to perform their essential job functions seamlessly across different Agency platforms both virtually and in-person. Extending the task order with the current contractor will ensure no interruption in services while the follow-on task order is being reprocured. Disrupting these critical services will result in the Agency’s non-compliance with the statutory mandates prescribed in Sections 501 and 508 of the Rehabilitation Act of 1973 (29 U.S.C § 794 (d)) which requires EPA to afford disabled employees and member of the public the right to access Federal electronic and information technologies.

Continuation of services with the current vendor is in the best interest of the Government to maintain seamless operations and fulfill legal obligations. Competing a six-month contract prior to the expiration of the current task order is not feasible, would prove administratively inefficient, and ultimately increase the risk of statutory non-compliance due to the time it would take another contractor to ramp-up to fulfill the Agency’s needs. Another vendor would need to become familiar with the scope of services, stand up a compatible IT and scheduling system, and train employees on the use of the new system.