Government Responses to 4.23.26 Virtual Roundtable Industry Questions.pdf

April 23, 2026 ORR Special Population Continuum of Care (CoC) Network Government Responses to Roundtable questions

Q1. Given the anticipated Firm Fixed Unit Price pricing model and requirement to maintain a minimum bed capacity across the network levels of care, does ORR envision additional on-stand-by funding for the beds, or is it just the firm fixed price for utilized beds?

Q1 RESPONSE: The Government is seeking a single Daily Bed Rate under the Firm-Fixed- Unit-Price (FFUP) model that ensures 100% operational readiness across all levels of care.

The Government recognizes that maintaining specialized staffing and facility standards requires consistent funding regardless of daily occupancy.

• Stand-by Funding: The Government does not envision a separate “stand-by” CLIN.

Instead, Offerors should propose FFUP that accounts for the costs of maintaining available beds (readiness) as well as utilized beds. A minimum capacity guarantee characterized in bed-days and max occupancy for each level of care is contemplated to best ensure availability and fair and reasonable pricing.

• Pricing Structure: It is the responsibility of the Offeror to ensure its proposed FFUPs for each level of care (LOC) are loaded with all costs (e.g., personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, overhead, profit, and other items and non-personal services) deemed necessary by the Offeror to provide the continuum of special population LOC and establish capacity for up to the maximum number of beds per LOC for UAC as specified in the Performance Work Statement (PWS) and to ensure its own fiscal sustainability for its specific proposed operating model. For each period of the contract, the Government plans to seek a single FFUP for each LOC that assumes beds are utilized/occupied and is not interested in establishing separate rates for unoccupied/reserved beds. A combination of minimum capacity guaranties on an aggregate LOC basis and actual billing for utilized beds is anticipated.

• Fiscal Efficiency: The Government’s goal is budget stability and network sustainability. The Offeror is responsible for ensuring its model is cost-effective while maintaining required capacity without the need for additional ad-hoc funding.

Offerors should account for these compliance and operational costs within their proposed FFUP CLINs.

Q2. Regarding opening of unoccupied “held” beds, with the challenge of staying fully staffed without a firm fixed unit price for unoccupied “held” beds, will industry be given time to ramp up based on when there is a need for a bed, along with a small fee to host that open bed for ORR?

Q2 RESPONSE: The Government does not envision a separate “holding fee” or a post-referral “ramp-up” period once the initial 120-day transition-in window has closed.

• 72-Hour Mandate: Per the Trafficking Victims Protection Reauthorization Act (TVPRA) (8 U.S.C. § 1232) and the Foundational Rule (45 CFR § 410.1101), ORR must place children in appropriate care within 72 hours. Therefore, the Contractor cannot be granted additional time to hire or train staff after a referral is made. Operational readiness, including fully cleared and trained staff, must be maintained for all proposed beds at all times.

• Pricing for Readiness: To account for the cost of maintaining staff for unoccupied or “held” beds, Offerors should build their FFUP CLINs such that they incorporate all costs necessary to provide the requirement as stated in the PWS. The Government plans to seek a single FFUP for each LOC that assumes beds are utilized/occupied and is not interested in establishing separate rates for unoccupied/reserved beds.

See question 1 regarding guaranteed capacity minimums.

• 120-Day Transition-In Period: The 120-day transition-in period is the maximum time allowed for full operational responsibility. If a Contractor achieves readiness (staffing and facility) for specific beds sooner, they should notify ORR that transition-in is complete and the Contractor is ready to accept placements to meet ORR’s mission.

Q3. Will there be any cushion financially in the contract for ramp up periods during the time staff are working on background checks etc. in order to maintain staff?

Q3 RESPONSE: After contract award, the Contractor will have up to 120 days to hire and train all required staff and ensure they complete ORR’s background and suitability determination process. This includes all current Contractor staff and all new hires who will work directly with UAC or have access to UAC. Contractors may only begin billing the government (in arrears) once UAC are placed in a special LOC utilizing the FFUP CLINs set forth in the contract. As such, Offerors should consider training, ORR’s background and suitability determination process, and other items necessary to meet ORR requirements during the transition-in period in their proposed FFUP pricing model with proposal submission.

Q4. How does ORR anticipate supporting providers to maintain sufficient capacity for specialized populations?

Q4 RESPONSE: The Government aims to achieve operational advantages and fiscal efficiencies associated with procuring commercially available evidence-based residential care models for youth with complex behavioral and mental health needs; by seeking experienced, high-quality, state licensed care providers who can offer reduced administrative overhead, budget stability and sustainability by optimizing reimbursements and negotiating FFUP. See Question 1 regarding minimum capacity guarantees.

The Government anticipates FFUP line items for each LOC. It is the responsibility of each offeror to determine the fiscal efficiencies inherent to its operating model and to propose and justify pricing structures accordingly.

Q5. Does ORR anticipate including contract line items to support start-up costs associated with new or expanded capacity?

Q5 RESPONSE: No. The Government is seeking currently operational, state-licensed care providers to provide evidence-based residential care. As such, the acquisition strategy does not include separate Contract Line Items (CLINs) for initial capital investments in infrastructure or facility development. While the Government will not fund large-scale start-up or infrastructure costs, it recognizes that Offerors may anticipate and incur specific costs to align existing operations with ORR policies and statutory requirements.

Offerors should account for these compliance and operational costs within their proposed FFUP line items. The Government intends to leverage cost-effective daily operations while shifting the risk of facility readiness and specialized staffing to the Contractor.

Q6. How does the government envision capacity scaling over the period of performance?

Q6 RESPONSE: The Government’s requirement for bed capacity at each LOC remains static as defined in the PWS with guaranteed capacity minimums anticipated. The Contractor is required to maintain 100% operational readiness, including fully cleared and trained staff for the total bed count specified in the contract throughout the period of performance. While actual child placement is unpredictable and subject to fluctuating referral trends, the Government envisions capacity scaling only through formal contract modifications should the underlying requirement change. Offerors should propose pricing that accounts for the cost of maintaining full operational readiness regardless of daily occupancy levels; and determine the fiscal efficiencies inherent to its operating model and to propose FFUP CLINs accordingly.

Q7. Regarding the fixed per child per day cost, this also includes not only the facility services but for example ER cost, medical provider costs?

Q7 RESPONSE: No, the FFUP (Daily Bed Rate) does not include costs for major medical, emergency room visits, specialty dental, optometry, or other specialized clinical services.

Specialty care expenses are handled outside of the facility's daily operational rate and will not be paid for through the contract.

• Excluded Costs: Major or specialized medical costs are paid through ORR’s Third Party Administrator for medical payment processing. Invoices for these services are submitted directly to the ORR Division of Health (DOH) for adjudication and direct payment to the medical provider.

• Included Costs: The Contractor’s FFUP must include routine, non-specialized healthcare. This typically covers on-site nursing, basic first aid, routine health screenings, and over the counter (OTC) medications as required by ORR Policy Guide Section 3.2.

• Coordination: While the Government pays the medical providers directly for specialty care, the Contractor is responsible for the coordination and transportation of the UAC to these appointments, and the costs associated with that coordination.

Q8. Can ORR provide clarification on ramp up times, the120 days after contract award but once contract is awarded beds need to be available NLT 72 hours for new placement?

Q8 RESPONSE: After contract award, the Contractor will have up to120 days to hire and train all required staff and ensure all staff who will have access to UAC complete a level 2 background and suitability determination. This includes all current Contractor staff and all new hires who will work directly with UAC or have access to UAC. The initial 120 day ramp up period includes time to prepare facilities across all six levels of care proposed and be ready to accept UAC referred to their custody and care. Once the initial 120-day period ends, the Contractor must maintain availability of the number of beds they proposed for each level of care and be able to accept new UAC admissions and transfers within 72 hours of ORR referral (TVPRA, specifically 8 U.S.C. § 1232; and Foundational Rule 45 CFR § 410.1101). There is no ramp-up time allocated once the initial 120-day ramp up period ends.

Q9. Is it possible to get more information on anticipated bed fill dates?

Q9 RESPONSE: The Government does not provide specific "fill dates" for beds, as placement of UAC is driven by unpredictable referral volumes and the unique clinical needs of each child.

However, Offerors should consider the following for their operational planning:

• Operational Readiness: Following contract award, the Contractor will have up to 120 days to hire and train staff and ensure all required background and suitability determinations are completed, including ORR’s background and suitability determination requirements.

• Availability vs. Occupancy: The Government’s requirement is for the readiness and availability of the Contractor’s proposed capacity at conclusion of the 120-day ramp-up period.

• Referral Process: Once the facility is deemed operationally ready by ORR, children will be referred based on the specific Level of Care (LOC) and specialized services required.

The Contractor must accept new UAC admissions and transfers within 72 hours of ORR referral.

Q10. Regarding average lengths of stay, how long is a child is in each level of care? Is it possible to get additional data to support average lengths of stay to support pricing considerations?

Q10 RESPONSE: The Government provides the following Average Length of Stay (ALOS) data for each LOC to assist with your technical and pricing approach. Please note that these figures are based on program averages and are subject to change based on individual child needs, case complexity, and placement availability.

Level of Care Average Length of Stay (ALOS) Diagnostic Center Not to exceed 30 Days

Psychiatric Residential Treatment Facility 90 Days Residential Treatment Center 135 Days

Heightened Supervision Facility 45 Days Therapeutic Group Home 125 Days

Partial Hospitalization Program *not a bed rate; added therapeutic resource to support success in least restrictive care.

3 – 6 weeks average length of enrollment

Regarding request for additional data: The ALOS data provided above represents current and relevant metrics for this specific requirement. At this time, no further historical data or granular demographic breakdowns are available for release. Contractors should use these established averages to calculate staffing ratios, clinical services, and variable operational costs.

Disclaimer: ALOS figures provided are historical averages intended for informational and planning purposes only. They do not constitute a guarantee of future performance or a minimum/maximum duration of stay for any individual child. Actual lengths of stay are determined by the individual needs of the child, clinical recommendations, and the availability of appropriate discharge or step-down options. The Government shall not be held liable for any costs or performance variances resulting from fluctuations in these averages.

Q11. Differentiate HSF level of care from the other levels of care.

Q11 RESPONSE: Heightened Supervision Facility (HSF), also recognized as Staff Secure, is a care facility for youth who are disruptive to normal functioning of shelter care and placement is necessary to ensure safety and welfare of others. It is for youth who require close supervision but do not require placement in a secure or RTC setting. It provides 24-hour supervision, custody, care, and treatment. It maintains stricter security measures such as intensive staff supervision, supports to manage problem behavior, and prevent children from running away. It has a secure perimeter but is not equipped with major restraining construction or procedures typically associated with juvenile detention centers.

The Purpose of HSF Care includes:

• Provide humane, therapeutic environment for UAC ages 12 to 17.

• Deliver comprehensive services to UAC who have behavioral and/or criminal issues that require close supervision, but do not require placement in a secure provider placement.

• When necessary, transfer to least restrictive setting.

• When appropriate recommend safe release to an ORR-vetted and approved sponsor.

Q12. What happens if the care provider does not agree with ORR’s determination of criteria that a child meets?

Q12 RESPONSE: ORR determines the appropriate LOC for UAC based on a comprehensive assessment of their clinical, behavioral, and safety needs, in accordance with ORR Policy Guide Section 1.2 (Care and Placement). This process involves evaluating information from referring agency, clinical evaluations, and known history of trauma or specialized medical needs.

Regarding disagreements on placement criteria:

• Clinical Collaboration: ORR views the Contractor/care provider as a vital partner in the child’s treatment team. If a Contractor/care provider believes a child’s clinical picture has changed or does not align with the current LOC, ORR works closely with the facility's clinical staff to review the child’s progress and needs.

• Case Review Process: Contractor/care providers may request a re-evaluation of a child’s placement through the formal Case Review process as outlined in ORR Policy Guide Section 1.4.2. This allows the provider to submit updated clinical documentation, incident reports, or behavioral assessments to support a transfer to a more appropriate setting (step-up or step-down).

• Final Authority: While ORR facilitates a collaborative dialogue to ensure the “best interest of the child” is met, the final determination regarding the appropriate placement and LOC remains with the ORR Director (or designee) as mandated by the TVPRA.

Q13. Will ORR restrict or enforce non-exclusive agreements with facility partners?

Q13 RESPONSE: No. The Government does not require, nor will enforce, exclusive partnership agreements. Offerors are not restricted from partnering or subcontracting with entities that may also be included in other proposals. However, the Government’s evaluation will focus on the effectiveness of the proposed Community of Practice (CoP) and the stability of the built environment within the continuum.

To ensure a seamless transition and high quality of care, the Government expects:

• Operational Readiness: All proposed partners and subcontractors must be state-licensed (or meet the equivalency standards per 45 C.F.R. § 410.1302(a)) and https://www.google.com/url?sa=i&source=web&rct=j&url=https://acf.gov/orr/policy-guidance/unaccompanied-children-program-policy-guide-section-1&ved=2ahUKEwj48rmslIyUAxXGMlkFHTemDMYQy_kOegYIAQgDEAE&opi=89978449&cd&psig=AOvVaw3tq7PjCK7IA5PF2Qq_4GNO&ust=1777314969368000 https://www.google.com/url?sa=i&source=web&rct=j&url=https://acf.gov/orr/policy-guidance/unaccompanied-children-program-policy-guide-section-1&ved=2ahUKEwj48rmslIyUAxXGMlkFHTemDMYQy_kOegYIAQgDEAE&opi=89978449&cd&psig=AOvVaw3tq7PjCK7IA5PF2Qq_4GNO&ust=1777314969368000 demonstrate the capacity to comply with ORR mission, policies, and the PWS requirements.

• Suitability: All partner/subcontractor staff who will have access to UAC must have successfully cleared the ORR Level 2 Suitability determination prior to providing care.

• Coordination: If an Offeror proposes non-exclusive partners, the proposal should clearly demonstrate how the Offeror will maintain a continuum, ensuring that coordination, clinical standards, and continuity of care are not diminished by shared resource arrangements.

• Capacity Disclosure: Offerors must disclose if their proposed bed capacity relies on shared resources or partner facilities that are also included in other proposals. The Government intends to award a specific number of beds; therefore, Offerors should clarify how they will ensure their proposed capacity remains available and dedicated to this contract if the shared partner is also supporting other ORR programs or awards.

Q14. Is the government open to different models for delivering specialized care, including integrated or co-located approaches?

Q14 RESPONSE: The Government is open to co-located or integrated models provided that the Offerors demonstrate how they will maintain the distinct clinical, safety, and supervision requirements for each LOC. Any proposed model must strictly adhere to state licensing standards and ORR policy and field guidance requirements regarding the separation and specialized treatment of distinct UAC populations. The following co-location and integrated models are permissible:

Shared Resources: Multiple special population levels of care may be operated on the same campus or within the same building to share indirect infrastructure and administrative expenses (e.g., kitchens, gyms, executive leadership and administrative staff). However, each LOC must have a designated wing or distinct physical location and must be state licensed specifically for that LOC. In addition, UAC LOCs must not commingle for services or use of facility amenities.

Non-Commingling Requirement: To ensure safety and specialized treatment, UACs from different LOCs must not commingle. While facility amenities (e.g., gyms, cafeterias, or outdoor recreation areas) may be shared infrastructure, their use must be strictly scheduled and partitioned so that children from different LOCs do not interact or occupy the same space at the same time.

Continuum of Care (CoC): The Government encourages a well-planned CoC where a child may transition between LOCs without moving to a different geographic location. Note, transfer between levels of care must be based on clinical need and approved and directed by ORR.

Licensing Efficiencies: If a state issues a single "Master License" covering multiple specialized programs, the Offeror shall describe the scope of that license. Regardless of licensing structure, every UAC must be admitted into and housed within the specific LOC for which they meet the placement criteria and is approved by ORR.

Prohibition on Flexible Bed Use: “Flexible bed use” (placing or shifting a child into a bed designated for a different LOC due on capacity) is strictly prohibited. UAC may only be moved to a different LOC with explicit written permission and directive from ORR.

Q15. Is the government able to provide data on anticipated levels of placement for children requiring specialized services?

Q15 RESPONSE: The Government does not provide specific placement or occupancy projections, as the arrival and clinical needs of UAC are subject to unpredictable migration trends and individual case complexities. For pricing and operational planning, Offerors should refer to the Minimum and Maximum bed capacity ranges provided for each LOC.

The Government’s requirement is for availability and readiness of this specialized capacity.

Offerors are expected to propose a model that ensures full operational readiness within the specified ranges based on their current capacity. Proposals will be evaluated on the Offeror's ability to maintain the required staffing and services for the proposed capacity, regardless of actual daily occupancy.

Level of Care Minimum Bed

Capacity

Maximum Bed

Capacity Diagnostic Center (DC) Number of Beds 10 50 Psychiatric Residential Treatment Facility (PRTF) 10 30 Residential Treatment Center (RTC) 10 70 Heightened Supervision Facility (HSF) 35 140 Therapeutic Group Home (TGH) 8 30 Partial Hospitalization Program (PHP) (*not a bed rate) *Added Therapeutic resource to support success in least restrictive care

15 Cases 50 Cases

Evaluation Note: Proposals will not be viewed more favorably simply based on the number of beds per level of care proposed for their continuum of care, within the minimum and maximum bed range. Offeror’s should propose the number of beds per each level of care which their proposed CoC can accommodate. The Government seeks superior operational models that demonstrate a high standard of clinical care, safety, and regulatory compliance. The evaluation will focus on the Offeror’s capacity to perform and the technical approach to providing comprehensive services. Offerors should propose a capacity (specific number of beds per LOC for their proposed continuum) that is both realistic and sustainable within their current or proposed operational model, ensuring the full suite of specialized services required.

Q16. Are bed counts (referenced in RFI) to be interpreted as targets or projected demand?

Q16 RESPONSE: The bed counts provided for each LOC should be interpreted as the required capacity range (Minimum and Maximum) rather than targets or projected demand. The Government is seeking to establish a baseline of operational readiness.

Offerors must propose a specific bed capacity within the identified ranges that is realistic and sustainable based on their current operational model and state licensing. Once awarded, the proposed capacity becomes a contractual requirement for availability. While actual occupancy will vary based on unpredictable referral volumes, the Contractor is responsible for maintaining the staffing and services necessary to support their proposed capacity at all times.

Q17. How does ORR envision this network coordinating with existing placement mechanisms, including single-case agreements and secure care providers? Does the government anticipate continuing the use of single-case agreements once the continuum of care contract is in place?

Q17 RESPONSE: The Government’s objective for this solicitation and resultant contract is to establish a robust, standing network of specialized providers to reduce reliance on ad-hoc placement mechanisms. Once the Continuum of Care (CoC) contracts are in place, the Government anticipates that the majority of placements for these specialized populations will be prioritized within this contracted network.

However, the Government reserves the right to continue utilizing Single-Case Agreements (SCAs) or other existing placement mechanisms on an as-needed basis. These would be utilized primarily for cases involving exceptional clinical needs, geographic requirements not met by the CoC network, or during periods where contracted capacity is fully utilized.

This contract is intended to complement, rather than completely eliminate, the Government's ability to ensure the “least restrictive” and most appropriate placement for every child as required by statute.

Q18. Will staff currently approved for ORR shelter care be eligible to serve in roles within this network, and will existing background checks and qualifications transfer?

Q18 RESPONSE: Yes. In accordance with ORR Policy Guide Section 4.3 (Background Checks), staff with a current, verified ORR Level 2 Favorable Suitability determination are eligible to serve in this network without repeating the full background check process, provided their determination remains active, valid, and was conducted in accordance with ORR’s background check standards. However, they will still have to submit their application to determine reciprocity.

However, the following requirements apply:

• Cost Allocation: If a staff member is shared between this CoC contract and another

ORR-funded program, the Contractor must provide an approved cost-allocation plan to ensure proper fiscal reporting for shared hours (e.g., part-time, overtime, or substitute coverage).

https://www.google.com/url?sa=i&source=web&rct=j&url=https://acf.gov/orr/policy-guidance/unaccompanied-children-program-policy-guide-section-1&ved=2ahUKEwjkqqmegYyUAxUQLFkFHXonJRQQy_kOegYIAQgDEAE&opi=89978449&cd&psig=AOvVaw1S3_a4OcVJCaw6jdyExUYO&ust=1777309839456000 https://www.google.com/url?sa=i&source=web&rct=j&url=https://acf.gov/orr/policy-guidance/unaccompanied-children-program-policy-guide-section-1&ved=2ahUKEwjkqqmegYyUAxUQLFkFHXonJRQQy_kOegYIAQgDEAE&opi=89978449&cd&psig=AOvVaw1S3_a4OcVJCaw6jdyExUYO&ust=1777309839456000

• Contract-Specific Training: Regardless of prior ORR experience, all staff must complete the specific onboarding, quarterly, and annual training requirements mandated under the CoC contract and ORR Policy Guide Section 4.2.

Background checks must be completed in accordance with ORR’s policies, state and local licensing requirements, and the Contractor’s licensing requirements. At a minimum, a background check must be updated every 5 years. For additional information on the specific types of checks that must be completed, please consult the ORR UAC Program Policy Guide Section 4.3 Personnel, which can be found at:

https://www.acf.hhs.gov/orr/policy-guidance/children- entering-united-states-unaccompanied-section-4.

Q19. For established programs, we’d like more information on translations services and how they work. Do the translators go through normal background facility checks? If the facility requires it, is that ok? How does funding for translators’ work?

Q19 RESPONSE: Yes. Any individual providing translation services, whether they are staff, contractors, or volunteers, who will have direct access to UAC or UAC sensitive information must complete the Government’s background and suitability determination process. At a minimum, a Level 2 Favorable Suitability determination is required before they may begin work.

Regarding operations and funding:

• Primary Language Access: The Contractor is responsible for hiring and scheduling bilingual staff for every shift to meet the primary language needs (typically Spanish) of the UAC in their care. Offerors should incorporate these staffing costs into their proposed Firm-Fixed-Unit-Price (Daily Bed Rate).

• Supplemental Services: For less common languages or specialized clinical/legal translation needs, the Contractor should utilize their own translation subcontracts or professional telephonic services.

• ORR Resources: In exceptional cases involving rare indigenous languages or dialects, ORR maintains centralized translation resources that can be accessed to support a UAC’s care.

• Standard translation and interpretation services required for daily operations, orientations, and clinical services are the fiscal responsibility of the Contractor and should be included in the proposed daily bed rates.

Q20. Are there any states unable to house UAC due to absence of required state-specific licensure or regulatory authorization?

Q20 RESPONSE: All Contractor/care provider facilities within the proposed Continuum of Care (CoC) must be located within the contiguous United States. While no state is legally https://www.acf.hhs.gov/orr/policy-guidance/children-entering-united-states-unaccompanied-section-4 https://www.acf.hhs.gov/orr/policy-guidance/children-entering-united-states-unaccompanied-section-4 https://www.acf.hhs.gov/orr/policy-guidance/children-entering-united-states-unaccompanied-section-4

“unable” to house UAC, some states have implemented policies that make them unwilling to issue or renew state licenses for facilities housing UAC.

The Government's requirements for licensure are as follows:

• Standard Licensure: Facilities and programs must generally be licensed by the appropriate state or local licensing authority for the LOC being provided.

• Unlicensed States (Foundational Rule): In states where a license is unavailable due to state policy or refusal to license UAC providers, facilities must operate in accordance with 45 C.F.R. § 410.1302(a).

• Equivalency Standards: Providers in states where licensing is unavailable must demonstrate the experience and capacity to meet standards equivalent to state licensing. These facilities must satisfactorily meet all applicable federal regulations, local health and safety codes, and ORR's Foundational Rule requirements to ensure the safety and well-being of children.

• Subcontractors: These requirements apply equally to any partnership or subcontracted site designated to provide physical custody and direct care.

Q21. Who determines level of care for the UAC?

Q21 RESPONSE: ORR determines appropriate LOC for UAC based on a comprehensive assessment of their clinical, behavioral, and safety needs, in accordance with ORR Policy Guide Section 1.2 (Care and Placement). This process involves evaluating information from the referring agency, clinical evaluations, and any known history of trauma or specialized medical needs.

Important Note: Psychiatric Residential Treatment Facility (PRTF) and Residential Treatment Center (RTCs) must have a recommendation from a psychologist or psychiatrist based on clinical presentation and assessments and be based on robust evidence to support why the more restrictive levels of care are required.

Regarding disagreements on placement criteria:

• Clinical Collaboration: ORR views the Contractor/care provider as a vital partner in the child’s treatment team. If a Contractor/care provider believes a child’s clinical picture has changed or does not align with the current LOC, ORR works closely with the facility's clinical staff to review the child’s progress and needs.

• Case Review Process: Contractor/care providers may request re-evaluation of a UAC’s placement through the formal Case Review process as outlined in ORR Policy Guide Section 1.4.2. This allows the provider to submit updated clinical documentation, incident reports, or behavioral assessments to support a transfer to a more appropriate setting (step-up or step-down).

• Final Authority: While ORR facilitates a collaborative dialogue to ensure the “best interest of the child” is met, the final determination regarding the appropriate https://www.google.com/url?sa=i&source=web&rct=j&url=https://acf.gov/orr/policy-guidance/unaccompanied-children-program-policy-guide-section-1&ved=2ahUKEwj48rmslIyUAxXGMlkFHTemDMYQy_kOegYIAQgDEAE&opi=89978449&cd&psig=AOvVaw3tq7PjCK7IA5PF2Qq_4GNO&ust=1777314969368000 https://www.google.com/url?sa=i&source=web&rct=j&url=https://acf.gov/orr/policy-guidance/unaccompanied-children-program-policy-guide-section-1&ved=2ahUKEwj48rmslIyUAxXGMlkFHTemDMYQy_kOegYIAQgDEAE&opi=89978449&cd&psig=AOvVaw3tq7PjCK7IA5PF2Qq_4GNO&ust=1777314969368000 placement and LOC remains with the ORR Director (or designee) as mandated by the TVPRA.

Q22. Can you provide examples of behaviors that would require HSF versus RTC, or other levels?

Q22 RESPONSE: See below descriptions for HSF and RTC levels of care; and for reference see Sources Sought Notice 7571MN26R00017 posted April 02, 2026 on Sam.gov.

Residential Treatment Center (RTC): Provides humane and therapeutic environment for UAC with serious mental health issues, while delivering comprehensive services. It is a sub-acute, time limited, interdisciplinary, psycho-educational, and therapeutic 24-hour-a-day structured program with community linkages, provided through non-coercive, coordinated, individualized care, specialized services, and interventions. RTCs provide highly customized care and services typically following a more intensive intervention, with the aim of moving individuals toward a stable, less intensive LOC or independence.

RTC Purpose:

• For UAC who have serious psychiatric or psychological issues that cannot be addressed in an outpatient setting and are danger to self or others.

• Sub-acute, temporary care until release recommendations to a less restrictive setting or release to an ORR-vetted and approved sponsor.

Heightened Supervision Facility (HSF): Care facility for youth who are disruptive to normal functioning of shelter care and placement is necessary to ensure safety and welfare of others. It is for youth who require close supervision but do not require placement in a secure or RTC setting. It provides 24-hour supervision, custody, care, and treatment. It maintains stricter security measures such as intensive staff supervision, supports to manage problem behavior, and prevent children from running away. It has a secure perimeter but is not equipped with major restraining construction or procedures typically associated with juvenile detention centers.

HSF Purpose:

• Deliver comprehensive services to UAC who have behavioral and/or criminal issues that require close supervision, but do not require placement in a secure provider placement.

Q23. From an industry perspective, would a regional contracting model where separate contracts are established for each geographic regions best support execution of this requirement.

Q23 RESPONSE: The Government is not utilizing a pre-defined regional or national contracting model. Instead, the strategy employs a Community of Practice (CoP) approach focused on Contractor’s specific operational footprint within the contiguous United States.

The Government’s expectations for this CoP approach are as follows:

• Geographic Flexibility: The Government does not mandate specific geographic regions. Offerors may propose a CoC based on their existing campus(es) or within a cohesive local geographic area where they can effectively coordinate with partners.

• Local Integration: A successful CoP must strengthen local resources and coordination. Contractors are expected to identify and integrate local clinicians, specialists, and community service providers who align with ORR’s mission to serve UAC with specialized needs.

• Continuity of Care: The goal of the CoP is to improve the “built environment” of the continuum, ensuring that children can transition between levels of care with minimal disruption and maximum access to specialized local support.

• Scalability: Whether services are provided on a single campus or across a localized network, the Offeror must demonstrate a superior approach to coordinating these comprehensive services within their proposed cohesive geographic area.

Q24. From an industry perspective, which contracting approach would be most advantageous, an Indefinite Delivery/Indefinite Quantity (IDIQ), Blanket Purchase Agreement (BPA), or a single contract (regional or national)?

Q24 RESPONSE: The Government anticipates that its requirements will be best met through one or more (up to three (3)) stand-alone contracts using a firm-fixed-unit price (FFUP) contract type. This allows for the establishment of fixed price(s) for unknown quantities without the need for placement of individual orders providing more flexibility than IDIQs or BPAs which require individual orders be placed for each need. The current FFUP approach was selected to ensure the highest level of stability and continuity for specialized care within the Community of Practice (CoP) framework. This model allows the Government to make up to three (3) awards to providers who demonstrate the most superior technical approach and operational readiness within their specific cohesive geographic footprints.

Q25. What are the staff ratio requirements for each level of care in the model?

Q25 RESPONSE: Given states have their own specific administrative codes, Offerors should refer to their respective state licensing requirements to determine staffing ratios for each LOC.

For Residential Treatment Center (RTC), Heightened Supervision Facility (HSF), and Therapeutic Group Home (TGH), ORR requires care providers to supervise UAC in accordance with their respective state licensing administrative codes and ORR policy, whichever is the strictest staff to child ratio. ORR requires the following minimum ratios for less restrictive levels of care. However, it is critical for Contractors and Contractor’s in-network care providers to determine when additional staff or higher staff ratios are necessary or beneficial:

One (1) on-duty staff for every four (4) children during waking hours.

One (1) on-duty staff for every twelve (12) children during sleeping hours.

One (1) case manager for every six (6) children.

One (1) clinician for every six (6) Children.

When transporting UAC to appointments, such as medical and dental appointments, or immigration court hearings. A minimum of two (2) staff during transport outside the facility is required; one (1) staff must be of the same gender as the UAC.

Contractors/care providers are subject to the provisions of the Service Contract Act (SCA).

Additional or backup staff (PSA Compliance Consultants, Disabilities Coordinator Consultants, etc.) shall be made available for emergency situations or to meet the special needs. Rotating after-hours and holiday coverage personnel shall be available when needed. To ensure continuity of care, safety and timely discharge of children, care providers shall maintain a 7-day case manager coverage schedule.

Licensing requirements for Diagnostic Center (DC) and Psychiatric Residential Treatment Facilities (PRTFs) staff-to-child ratios vary by state and are typically categorized by the time of day (staffing shifts) and child acuity levels. Because PRFT and DC handle high-needs populations, ratios are significantly stricter than standard shelters. Offerors should refer to their respective state licensing administrative codes. However, general industry and state benchmarks for DC and PRTF include:

Direct Care Staff:

• Daytime/evening (Waking Hours): range is from 1:3 to 1:4.

• Nighttime (sleeping hours): range from 1:6 to 1:10

Professional/Clinical Ratios:

• Mental Health Clinicians: ORR generally requires at least 1 clinician per 12 UAC in care.

• Nursing: many states require at least one Registered Nurse (RN) or Licensed Practical Nurse (LPN) to be on-site or available 24/7.

States typically mandate higher staffing (lower child-to-staff ratios) based on specific conditions:

• High Acuity: Children exhibiting aggressive, assaultive, or self-harming behaviors often require ratios higher than the 1:6 baseline.

• Developmental Disabilities: Some states, like Ohio, increase the daytime ratio to 1:2 for youth with intellectual or developmental disabilities.

• Facility Size: Smaller units (e.g., 9–24 patients) may have specific minimum headcount requirements regardless of mathematical ratio (e.g., a minimum of two staff at all times)

Partial Hospitalization Program (PHP) is not a residential placement but a therapeutic resource which is provided to UAC struggling in their current LOC. PHP provides UAC with wraparound therapeutic and treatment services to help them remain in a less restrictive

LOC.

Q26. How does the Government intend to transport each UAC to and from the facility where services will be provided?

Q26 RESPONSE: Transfer of UAC between ORR’s network of care providers is a complex process requiring close coordination among case managers, case coordinators, and medical coordinators/staff at both the referring and the receiving care facilities, Federal Field Specialist (FFS) staff, and the UAC Division of Placement Operations (DPO). The Contractor shall be responsible for leading coordination and providing transportation for UAC when they are the transferring care provider. In most cases, the transferring care provider shall be responsible for transportation from their care facility to another ORR funded care facility. In some cases, it may be necessary for a care provider to support transfer into their residential program services. See UAC MAP 1.4 Transfers within the ORR Care Provider Network.

The Contractor shall also provide transportation services for UAC to local airports and to local services and appointments such as medical and dental appointments, immigration court hearings, or community services as part of the Individual Service Plan (ISP). (See ORR UAC Bureau Policy Section 3.3.14, Transportation Services and 45 CFR 410.1401).

Additionally, as will be specified in the solicitation and awarded contract(s): A minimum of two (2) staff shall be present during secure transport outside the facility is required; if one

(1) UAC is transported, one (1) staff must be of the same gender as the UAC.

Q27. When will the Request for Proposal (RFP) be released?

Q27 RESPONSE: The Government anticipates publishing an RFP on or about Sam.gov in July 2026, with proposals due 30 days from published date.

Q22 RESPONSE: See below descriptions for HSF and RTC levels of care; and for reference see Sources Sought Notice 7571MN26R00017 posted April 02, 2026 on Sam.gov.