Statement of Work (SOW)_10212024.docx

Statement of Work

1. Title of Project Regulatory Support Services in support of the U.S. Citizenship and Immigration Services (USCIS) Office of Policy & Strategy, Regulatory Coordination Division (RCD).

2. Period of Performance This order has a base performance period of one year and two one-year option periods to be exercised at the government’s discretion.

3. Place of Performance The principal place of performance will be at the contractor’s facility.

4. Project Background USCIS administers the nation’s lawful immigration system, safeguarding its integrity and promise by effectively and fairly adjudicating requests for immigration benefits while protecting Americans, securing the homeland, and honoring our values.

The Regulatory Coordination Division (RCD), within the Office of Policy & Strategy, is responsible for managing the USCIS regulatory process and compliance with the Paperwork Reduction Act for USCIS information collections.

RCD’s mission is to develop quality regulations by providing courteous and responsive professional support in analytical research. RCD centrally manages and coordinates the development of all USCIS regulations. RCD is responsible for conducting quantitative and qualitative impact analyses of various policy options and presenting that information in a clear and concise way for senior USCIS leadership and the public.

RCD is primarily focused on ensuring rulemaking activities are performed in accordance with federal law. For instance, RCD is responsible for ensuring all USCIS regulations are in compliance with Executive Orders 12866 (Regulatory Planning and Review) and 13563 (Improving Regulation and Regulatory Review). RCD also makes sure USCIS regulations comply with the Regulatory Flexibility Act, the Small Business Regulatory Enforcement Fairness Act, the Congressional Review Act, and the Unfunded Mandates Act.

Over the last several years, the volume of public comments received on USCIS rulemaking actions has varied with a low of only a few hundred public comments on several rules, to a high of approximately 266,000 public comments received on the rule entitled “Inadmissibility on Public Charge Grounds.” While it is impossible to forecast the volume of comments for each regulatory action USCIS plans to publish over the period of the contract, based on the public interest in the regulatory plans that USCIS has published in the Unified Agenda, the Agency anticipates that a few of those actions may receive public comment volumes in the high tens of thousands or more.

5. Scope The contractor shall provide regulatory support services to USCIS in developing and promulgating regulations that implement U.S. immigration policy and programs. The contractor shall provide these services by reviewing, summarizing, and analyzing public comments received on USCIS documents that are published in the Federal Register. To this end, the contractor must possess a knowledge and understanding of U.S. immigration law, regulations, and policies as well as the federal regulatory process. The contractor shall provide all personnel, materials, supervision, other items, and services necessary to perform regulatory support services to conduct the documentation and assessments required under this contract. The contractor shall have the capacity to expeditiously review, monitor, synthesize, categorize, summarize, track, and produce a variety of reports on tens of thousands of comments on USCIS’ regulatory actions throughout the comment period, as well as provide final reports shortly after the close of the comment period. The contractor shall participate in regular meetings with the USCIS rulemaking teams to support this effort.

The contractor shall provide technical writing support for development of the rulemaking documents and publication in the Federal Register. The contractor shall participate in regular meetings with the USCIS rulemaking teams to support this effort.

6. Specific Tasks A listing of services the contractor shall provide is below:

· Monitor, review, and categorize comments received by USCIS from external stakeholders via the Federal Document Management System (FDMS). This includes comments received by Congress, state and local government officials, special interest groups and professional organizations which may be received outside of the FDMS process. The contractor must develop a system to compile, monitor, evaluate, synthesize, and report comments received over and above the tools offered by FDMS. This includes any comments received via mail and updated to FDMS. In addition, as needed by USCIS, the contractor will need to develop a system to review, analyze, and categorize comments received by internal stakeholders, such as federal agency partners during an internal federal review process of the rulemaking effort.

· Comment Analysis: Construct written summaries and reports, as well as report matrices containing an organized and searchable compilation of all issues raised by commenters according to top-level issues/themes. The reports and summaries must conform with Administrative Procedures Act (APA) guidelines and in accordance with DHS and USCIS protocol and must be suitable for publishing in the rulemaking’s electronic docket. All reports must identify the source of comments and the basis for decisions, highlights of working sessions, methods and sources used to generate assumptions, analysis, statistics, and recommendations. In addition, the contractor must draft and submit a final report. The final report summarizes all the comments, by topic area, into one document. Comment summary reports should also include language that could also be used as draft “starter text” in final rules.

Meetings and Teleconferences The contractor shall participate in meetings either in person or teleconference. The number of hours and frequency for each meeting will be determined based on the requirements of the project.

7. Deliverables The contractor is responsible for the timely completion and submission of deliverables in accordance with standards set forth in various Executive Orders and Acts of Congress. For each project, the Contracting Officer’s Representative (COR) will provide a project overview and schedule for deliverables. Unless otherwise specified, the Government will have ten business days to review and provide comments to the contractor prior to acceptance of all deliverables.

The government has the right to reject or require corrections of any deficiencies. In the event of a rejected deliverable, the contractor will be notified in writing by the Contract Specialist, Contracting Officer (CO), or COR for the specific reasons for rejection.

The contractor shall have an opportunity to correct the rejected deliverable. The contractor must respond with the corrections within five business days after receipt of Government comments, unless otherwise specified.

If the deliverable is acceptable, the COR will send an e-mail to the contractor notifying that the deliverable has been accepted.

All other review times and schedules for deliverables not specifically addressed within the task order shall be agreed upon by the parties based on the final approved project plan at the Government’s discretion. The contractor shall be responsible for timely delivery to government personnel in the agreed upon review chain, at each stage of the review. The contractor shall work with personnel reviewing the deliverables to assure that the established schedule is maintained.

The contractor shall provide all written deliverables in electronic format with read/write capability using applications that are compatible with DHS/USCIS network access and usage requirements.

The following are the primary types of deliverables to be performed by the contractor.

Post Award Conference

A post award conference will be scheduled as soon as possible after award, usually within seven days, unless otherwise specified by USCIS. The date and time will be determined by the Contracting Officer. The purpose of the meeting will be to identify primary points of contact, discuss scope, tasks, and understanding of technical approach.

The Contractor shall prepare and submit a written report of the findings and understanding of the project.

Project Plan

The project plan should include a quality control plan (QCP) and an approach providing sufficient monitoring and oversight of contractor personnel.

Regulatory Briefing Materials

Prepare reports, materials, and presentations in electronic format with read/write capability in Microsoft Office Applications.

Meeting Minutes: The contractor shall capture and submit meeting minutes for any meeting held with USCIS to include the names, titles, and agency/office of participants, meeting date and time, meeting agenda, and notes from the discussion.

8. Key Personnel

The following contractor personnel shall be considered key personnel and shall provide the majority of project work for USCIS. In accordance with HSAM 3052.215-70, the contractor shall provide a minimum of a two-week notification prior to removal, or vacancies created by key personnel. Key personnel shall be principally responsible for regulatory support services as specified throughout this contract.

Project Manager Education: Advanced degree in social science, business, science, or similar field.

Experience: 10 years of experience in social science, business administration, or science and at least 5 years of supervisory experience in a management role, with a demonstrated ability to staff technical projects and manage staff members.

Duties: Serves as a liaison between the organizations staff members and leadership. Coordinates and directs staff members with diverse technical skills and backgrounds to ensure delivery of a high-quality product on time and within outlined project specifications. Responsible for all related aspects of a project.

Senior Staff Associate Education: Advanced degree in social science, business, science, or equivalent.

Experience: At least 10 years of experience and training in social science, business administration, statistics, or science and 5 years of supervisory experience leading technical projects and staff members.

Duties: Responsible for performing work of a technically complex nature; directing and reviewing the work of other staff and the day-to-day management of the professional activity on a project.

Technical Writer Education: Bachelor's degree in relevant technical or academic field.

Experience: 5 years of experience researching, proofreading, writing, and editing resources and materials for diverse audiences. Additionally, experience drafting or editing federal regulatory documents and materials fit for publication in the Federal Register, preferable.

Duties: Gathers, analyzes, translates, and composes technical information into clear, readable documents to be used by all levels of government and for the public. Composes and edits technical documents including reports, correspondence, and any other deliverables and documents. Conducts research and ensures the use of proper technical terminology. Produces and edits written materials that adhere to the agency’s guidelines, standards, and requirements and appropriate use of citations.

9. Travel

Travel is not anticipated at this time. No travel will be reimbursed.

10. Government Furnished Information and Equipment

The Government will provide necessary information, equipment, data, and documents to the contractor for work required under this order. The contractor shall be responsible for returning all Government furnished information, equipment, data, and documents to the Government at the end of the performance period or for destroying the information at the instruction of the Government. The contractor will provide a certification in writing for all information destroyed at the agency’s request. The contractor shall not release Government furnished information, data, and documents to outside parties without the prior and explicit consent of the Contracting Officer. All contractor personnel performing services under this task order shall be required to complete a non-disclosure agreement. Contactor personnel will be provided with systems access in order to provide quicker access to USCIS rulemaking documents). Contractor personnel will perform all work considered deliberative, sensitive, FOUO or higher on government furnished equipment. All work containing PII/SPII must be performed on government furnished equipment. All contractor personnel who are authorized to use government furnished equipment will be required to undergo a background investigation; see Attachment B- Security Requirements. All contractor personnel will be required to return government furnished equipment at the end of the contract.

The Government will issue laptops to selected contractor employees based on job functions. The Contractor bears full responsibility for any and all loss of this equipment, whether accidental or purposeful, at full replacement value. This equipment will be provided on a rent-free basis for performance under this task order. It shall not be used for any non-order or non-governmental purpose. The Contractor shall ensure the return of the equipment immediately upon the demand of the Contracting Officer of the end of task order performance. A Contractor request for equipment may be for a subcontractor employee. If so, the Contractor retains all the responsibilities for equipment issued to that employee.

11. Hours of Operation

Normal hours of operation shall range from 8:00 AM to 5:00 PM ET, Monday through Friday, excluding Federal Government holidays.

12. Documentation

The contractor shall review and approve all work products in draft form prior to use or distribution. The Government will make all regulatory, policy, and interpretative decisions resulting from contractor-provided advice and assistance. The contractor shall not publish or otherwise release, use, or disclose any work product generated under this task order without express authorization of the COR or CO. All documentation, deliverables, and written reports developed by the contractor shall become the property of the Government.

Project Management and Quality Control The contractor must provide adequate project management and quality control measures to ensure the acceptability of all deliverables. This includes a dedicated Project Manager, as identified in Section 8, Key Personnel, and creation of a Project Plan and a Quality Control Plan to ensure sufficient monitoring and oversight of contractor personnel.

The contractor’s Project Plan must include:

· An internal project management plan with

· A strategic plan for addressing staffing issues and turnover.

· A transition and training plan for internal staff.

· Mitigation strategies and corrective action plans for addressing slow turnaround and quality issues with deliverables.

· Strategies to correct for schedule slippage issues.

The contractor’s Quality Control Plan must include:

· A Communication Plan for maintaining contact with the Government.

· An oversight plan.

· A Quality Assurance Plan with

· A proofing plan.

· A compliance check with DHS/USCIS Branding and Style Guides.

· An assessment of key personnel’s ability to provide professional products in a timely manner.

· A review of personnel’s overall quality of work including proofing and editing documents.

The contractor must adhere to all approved quality assurance control measures and plans.

The contractor must provide and perform quality control to ensure high quality services.

2 Regulatory Coordination Division August 2024