Attachment B- Section C- PWS (Amd 0007) 2026.02.23.pdf

Section C- Performance Work Statement (PWS)

C.1 Background

C.1.1 ORR’s Role and Statutory Authority

The Office of Refugee Resettlement (ORR), within the Administration for Children and Families (ACF), is responsible for providing temporary shelter care and child welfare-related services to unaccompanied alien children (UAC) who are subject to immigration proceedings or removal from the United States.

ORR receives referrals of UAC from other federal agencies and places UAC in ORR funded care provider facilities.

On March 1, 2003, Section 462 of the Homeland Security Act of 2002 (6 U.S.C. 279) (HSA) transferred functions regarding the care and placement of UAC from the Commissioner of the Immigration and Naturalization Service to the Director of ORR. ORR has responsibility for the care and custody of UAC in federal custody due to their immigration status and age, as well as ensuring their safe and timely release to appropriate sponsors. The Trafficking Victims Protection Reauthorization Act of 2008, 8 U.S.C.

1232, (TVPRA) states that, consistent with 6 USC 279, the U.S. Dept. Of Health and Human Services (HHS) Secretary is generally responsible for the care and custody of UAC, and describes additional responsibilities related to providing safe and secure placements for children. As relevant to this requirement, the TVPRA requires the Secretary to ensure, to the greatest extent practicable, and consistent with 8 U.S.C. 1362 that UAC “have counsel to represent them in legal proceedings or matters and protect them from mistreatment, exploitation, and trafficking” 8 U.S.C. 1232(c)(5). The law emphasizes that, to the greatest extent practicable, the Secretary shall make every effort to utilize the services of pro bono counsel who agree to provide representation to such UAC without charge. The rules for providing legal services to UAC are also found in 45 C.F.R. 410.1309.

C.2 Objectives

The Contractor shall provide legal services to UAC in accordance with the terms and conditions of this contract, to include C.4.1, General Requirements, for UAC who are currently in, or have been released from, ORR custody. Legal services begin once ORR takes custody of a UAC for placement into an ORR facility and ends when ORR releases the UAC to a suitable sponsor; or when the UAC turns 18 years of age; or when disposition of the child's immigration case results in the child being granted lawful immigration status, voluntary departure, or ordered removed from the United States. Legal services may be required after a UAC is released from ORR custody, but such services are limited to the cases provided for under 45 CFR 410.1309(a)(4).

C.3 Scope

The Contractor shall deliver nationwide services to UAC and perform services that address the legal needs of UAC and satisfy the Government’s requirements.

Transition-In

In accordance with C.4.2.1, Task I, the Contractor shall utilize a structured process to assume full operational responsibility from the incumbent contractor without disruption to services for approximately 24,000 active cases of UAC currently or formerly in ORR care.

Legal Orientations

In accordance with C.4.2.2, Task II, the Contractor shall conduct virtual legal orientation to inform UAC of their rights and responsibilities within the immigration system.

Legal Consultations

In accordance with C.4.2.3, Task III, the Contractor shall conduct one-on-one legal consultations to assess each UAC’s eligibility for immigration relief.

Direct Legal Representation

In accordance with C.4.2.4, Task IV, the Contractor shall provide direct legal representation, to the extent required by law, and subject to ORR’s discretion and available appropriations.

Legal Service Provider (LSP) Network Management

In accordance with C.4.2.5, Task V, the Contractor shall manage and oversee a nationwide network of qualified LSPs delivering services to UAC, both funded and pro bono. Network management includes quality control, performance monitoring, and coordination across the network. The contractor shall ensure timely and consistent legal orientations, legal consultations, direct legal representation, and data collection, analysis, and reporting.

Data Collection, Analysis, and Reporting

In accordance with C.4.2.6, Task VI, the Contractor shall conduct robust data collection, analysis, and reporting, including, but not limited to, the outcomes of pro bono counsel recruitment, the scope and outcomes of representation, real time case status, and monthly reporting of pro bono and total hours by case/A Number and service type. This data shall be made available through dashboards and direct connection to existing ORR platforms and tools, including application program interfaces (APIs).

Pro Bono Maximization

In accordance with C.4.2.7, Task VII, the Contractor shall maximize the use of pro bono in the delivery of legal services: Task II Conduct Legal Orientations (C.4.2.2), Task III Conduct Legal Consultations (C.4.2.3), and Task IV Direct Legal Representation Services (C.4.2.4).

Transition-Out:

In accordance with C.4.2.8, Task VIII, the Contractor shall transfer all operational responsibilities, data, and knowledge to the incoming contractor and/or the Government, ensuring continuity and no degradation of services being performed under this contract.

C.4 Requirements

C.4.1 General Requirements

1.) Qualified Personnel Legal orientations, legal consultations, and direct legal representation, including pro bono representation, shall be provided by qualified personnel who meet professional standards and comply with all applicable tribunal and contract requirements. Qualified personnel include:

a.) Attorneys eligible to practice law in the jurisdiction where they practice and a member in good standing of the bar of the highest court(s) of the state(s), possession(s), territory(ies), commonwealth(s), or the District of Columbia b.) A representative accredited to appear before the Executive Office for Immigration Review as defined in 8 C.F.R. § 1292.1(a)(4) c.) A law student or law graduate of an accredited U.S. law school as defined in 8 C.F.R.

§ 1292.1(a)(2) under the supervision of an attorney.

2.) Interpretation, Translation, and Accessibility

The Contractor shall ensure all services performed under this contract are available in the language necessary to provide services to the UAC as required by Section C.2. This includes bilingual/multilingual staff and access to language/interpretive services within the timeframes specified in each individual task listed under section C.4.2.

The Contractor shall deliver legal services in a language in which the UAC reports to have fluency/is best understood by the UAC.

The Contractor shall provide and utilize technological solutions including hardware, communications applications, and language lines needed to facilitate communication with UAC and program staff.

3.) Attorney Ethics Conflicts Management

The Contractor shall develop and implement written policy and procedures to identify and resolve attorney-ethics conflicts of interest. In the event of a conflict precluding qualified personnel as defined in C.4.2.3 from delivering required services to an individual UAC, the Contractor shall ensure that the UAC receives the required services from an alternate qualified personnel and in accordance with the Contractor’s professional responsibilities, within 10 business days of the identification of the conflict of interest.

4.) Service Delivery Principles

Throughout performance, the Contractor shall adhere to the following legal service delivery principles:

Culturally Competent Service Delivery and Trauma-Informed Care: Many UAC have faced traumatic situations in their home countries, including dire poverty, violence, gang recruitment, human trafficking, domestic violence, abuse, and neglect. Some UAC are very young, have little or no formal education, and are primarily non-English speaking.

The Contractor shall ensure that legal services are attuned to the varied and individual needs of UAC, including being delivered in a manner that is developmentally appropriate, trauma-informed, and culturally appropriate.

Continuity of Legal Services: The Contractor shall coordinate with ORR staff and care provider staff to promote continuity of legal services to eligible UAC throughout and after ORR custody, including potential referrals, in accordance with the Contractor’s professional responsibility to the UAC clients.

Equitable Distribution: The Contractor shall use innovative means and cost-saving methods to promote access to legal services for eligible UAC, ensuring that each eligible child receives professional and robust representational services to the greatest extent possible.

Scalability: The Contractor shall provide services to eligible UAC throughout fluctuations in numbers of UAC referred to ORR.

C.4.2 Specific Tasks (Reference Column C in of the Pricing Worksheet for associated Items Numbers)

C.4.2.1 Task I: Transition In [Item 17] (Base Year Only)

Transition-in is a structured process by which the incoming contractor assumes full operational responsibility from the incumbent contractor without disruption to services for approximately 24,000 active cases on behalf of UAC currently in ORR care or released from ORR care. The Contractor shall ensure continuity, data integrity, and compliance with minimum disruption and completion of all transition in activities within 90 calendar days of award (or sooner).

1.) Requirement: The Offerors shall provide a transition in plan as part of their proposal. The transition in plan shall describe how the Contractor will ensure no interruption to case services or statutory timeframes. The Contractor shall also present its transition-in plan at the contract kick-off meeting as identified in C.5.1.4.

2.) Performance: The Contractor shall ensure that there is no service degradation during transition

in. During transition in, the Contractor shall minimize disruption using a phased migration of cases and documenting the status weekly during the 90-day transition in phase. At completion of transition in, the Contractor shall be fully staffed and fully performing the requirements of the contract. Upon completion of the transition in, the Contractor shall notify the COR that transition in has been completed. The notice shall be in writing and include the listing of all cases by A Number and type and status of legal representation service. In addition to submission of this information to the COR, the Contractor shall submit it via Application Program Interfaces (API).

C.4.2.2 Task II: Conduct Legal Orientations [Item 1 [Firm Fixed Unit Price]

A Legal Orientation is a presentation concerning the rights and responsibilities of undocumented children in the immigration system.

The Contractor shall conduct legal orientations for 100% of UAC in ORR custody in accordance with the requirements specified in 45 C.F.R. 410.1309(a)(2). These orientations shall inform UAC of their legal rights and responsibilities within the U.S. immigration system and shall be delivered by individuals under the supervision of a legal service provider. (Note: For pricing purposes, the unit of issue is one legal orientation session conducted in accordance with this section, regardless of the number of UAC participants that attend the legal orientation session.)

C.4.2.2.1 Requirements for Conducting Legal Orientations

The Contractor shall provide legal orientation sessions upon notification to the Contractor by ORR at a firm fixed unit price. COR notification may occur via email or by a method and process established during the contract kickoff meeting or by the COR after award.

1.) Legal Orientation Delivery Minimum Required Timelines:

Legal orientations shall be provided to all UAC in ORR care within the timelines identified below:

A.) Within 10 business days of notification of a UAC's admission to an ORR facility or ORR funded out-of-network facility.

B.) If an extenuating circumstance exists and the Contractor cannot meet the 10-business day requirement, before the 10-business day requirement specified in 1(A) is over, and within 24 hours of becoming aware of such extenuating circumstances, the Contractor shall submit a written request to the COR via email to request relief from the 10 business day requirement.

The Contractor shall provide the legal orientation within the time specified by the COR.

C.) Every six (6) months for unrepresented UAC who remain in ORR custody.

D.) For UAC released before receiving an orientation in custody, the Contractor shall follow up as soon as practicable (but no later than 10 days) with the UAC to complete the presentation.

2.) Legal Orientation Method and Settings Minimum Requirements:

The Contractor shall provide legal orientations to UAC in accordance with C.4.1 using audiovisual tools (e.g., recorded videos, online content) and allow for active communication between the legal service provider and the UAC receiving the orientation following the orientation video/online presentation. The Contractor shall develop the audiovisual tools necessary to provide legal orientations to UAC (e.g., recorded videos, online content) and submit to the COR for approval within 30 calendar days of contract award. Any deviation from pre-approved content requires prior written approval from the COR. The cost of the deviation shall not be passed on to the Government.

3.) Legal Orientation Content and Standards Minimum Requirements:

A.) The Contractor shall deliver legal orientations to UAC that, at a minimum, include:

1.) Information notifying UAC of their legal rights and responsibilities, including:

Protections under child labor laws.

Services to which they are entitled, including educational services.

2.) Information regarding the availability of free legal assistance and that UAC may be represented by counsel at no cost to the Government.

B.) When a child requests legal counsel, the Contractor shall ensure that the child is provided with a list and contact information for pro bono counsel. At a minimum, the list provided to the UAC shall include:

1.) Notification regarding:

The Contractor's role and that of other agencies and people involved in the child's immigration matter.

The immigration court process.

The child's obligation to attend hearings.

The child's right to a removal hearing before an immigration judge.

The child’s ability to petition/apply for relief from removal and various forms of immigration relief commonly available to children, including:

o The child's ability to petition for Special Immigrant Juvenile (SIJ) classification;

o The child's ability to request that a juvenile court determine dependency or placement in accordance with 45 CFR 410.1209;

o The ability to apply for asylum with United States Citizenship and Immigration Services (USCIS) in the first instance; and o The transfer of custody to Department of Homeland Security upon reaching 18 years of age.

2.) Notification regarding the UAC’s ability to request voluntary departure in lieu of removal.

3.) Notification regarding the UAC’s ability to request repatriation in lieu of removal.

4.) Notification regarding the child's right to a hearing before an independent HHS hearing officer, to determine, through a written decision, whether the child would present a risk of danger to self or to the community if released, as described at 410.1206(c) as well as 410.1903(a) and (b).

5.) Notification regarding the child’s legal rights and responsibilities, both in ORR custody and upon release.

6.) Any additional ORR-mandated information as communicated to the Contractor in writing by the COR or CO (e.g. email).

4.) Material Development and Modality of Delivery Requirements:

A.) The Contractor shall, at a minimum, develop and maintain legally accurate and developmentally appropriate orientation materials, including scripts (standardized presentation text) and written handouts.

B.) The Contractor shall ensure orientation materials are available in the languages necessary to comply with the requirements of C.4.1.2, Interpretation, Translation, and Accessibility.

C.) The Contractor shall ensure all orientation and supplemental material is consistent with attorney-ethics rules and includes jurisdiction-specific content.

D.) Orientation materials shall promote and facilitate continuity of legal services.

E.) In person orientations shall be considered a deviation and must be approved by the COR in advance. Individual orientations shall also be considered a deviation and must and approved by the COR in advance. Group size and session duration shall consider the UAC's age, literacy, language, and educational setting. Following the orientation video/online presentation, the Contractor shall allow active communication between the legal service provider and the UAC receiving the orientation, to allow UAC to ask the legal service provider general questions related to the orientation content.

F.) The Contractor shall provide proposed changes to presentation content to the COR for approval no less than 10 business days prior to first target use date. Costs associated with changes to presentation will not be passed on to the Government.

5.) Operational Requirements Minimum Requirements:

A.) The Contractor's staffing model for legal orientations shall be flexible and able to accommodate fluctuation in the daily totals of UAC referred to ORR care and requiring legal orientations.

B.) Reporting Requirements: The Contractor shall provide the legal orientation data specified in Section C.4.2.6 in its monthly report submitted to the COR under C.5.4.1. (See F.4, Deliverables Schedule and Performance Requirement Summary Table)

C.4.2.3 Task III: Conduct Legal Consultations (Item 2) [Firm-Fixed Unit Price]

A Legal Consultation is an opportunity for qualified personnel to meet with a UAC and assess options related to their legal case. The Contractor shall provide confidential legal consultations to 100% of UAC in ORR custody to assess potential forms of relief from removal and other case disposition options in accordance with 45 C.F.R. 410.1309(a)(2). These consultations shall be conducted by qualified personnel defined as an attorney, a paralegal under the supervision of an attorney, or a U.S. Department of Justice (DOJ) accredited representative. (Note: For pricing purposes, the unit of issue is one session with one individual UAC conducted in accordance with this section.)

C.4.2.3.1 Requirements for Conducting Legal Consultations Legal Consultations will be performed at a firm fixed unit price. A legal consultation session is defined as a discrete interaction with one individual UAC which is conducted only to assess potential forms of relief from removal and other case disposition options in accordance with 45 C.F.R. 410.1309(a)(2). Legal Consultations must be performed by qualified personnel as specified in C.4.2.3. A Legal Consultation is not meant to substitute for full-scope representation of a UAC in ORR care; rather, its purpose is strictly to assess the possibility of legal relief prior to full scope legal representation, if approved.

The Contractor shall schedule legal consultation meetings with UAC that are admitted to an ORR facility or an ORR-funded out-of-network facility, and when otherwise directed by the COR. The Contractor shall provide legal consultation meetings within the required timeframes, as follows:

A.) Legal Consultation Minimum Required Timeframes:

The Contractor shall provide legal consultations to UAC within ten (10) business days of notification by ORR.

B.) Legal Consultation Method, Setting, and Confidentiality Minimum Requirements

The Contractor shall deliver legal consultations to UAC in a manner that maintains confidentiality in accordance with professional legal standards.

C.) Content and Standards of Delivery Minimum Requirements:

1. The Contractor shall deliver legal consultation services to determine and provide the UAC an individualized assessment that includes, but is not limited to:

Possible forms of relief from removal in relation to the UAC’s immigration case

(including Special Immigrant Juvenile Status)

Other case disposition options as described in C.4.2.4, Task IV: Direct Legal Representation Services

The UAC's stated preferences and best interests

2. The Contractor shall deliver legal consultation services to UAC in a manner tailored to the

UAC’s individualized needs (see generally 45 CFR part 410), including with respect UAC who may be unable to engage in traditional legal consultation such as:

Tender age UAC (under age 13)

UAC with disabilities, including UAC with developmental delays

UAC with other vulnerabilities and complexities

3. For UAC who may be unable to effectively communicate with the Contractor, including tender age UAC, UAC with disabilities, or UAC who have experienced significant trauma, the Contractor shall:

Coordinate with ORR staff and care provider staff to identify such UAC and to identify the information necessary to conduct the required legal consultation

4. When requested by ORR, the Contractor shall provide additional legal consultations for UAC identified as:

A potential victim of a severe form of trafficking

Having been abused, abandoned, or neglected

Having been the victim of a crime or domestic violence

Persecuted or in fear of persecution due to race, religion, nationality, membership in a particular social group, or for a political opinion.

5. Reporting Requirements: The Contractor shall provide data detailing the delivery of all legal consultation services in accordance with C.4.2.6 Task VI, Annual Data Collection and Transfer System / Interface and per F.4, Deliverables Schedule and Performance Requirements Summary Table.

C.4.2.4 Task IV: Direct Legal Representation Services (Items 3-13) [Firm Fixed Unit Price]

Subject to ORR’s discretion, available appropriations, and to the extent required by law, the Contractor shall offer access to direct legal representation to UAC in accordance with 45 C.F.R. 410.1309(a)(4) and the requirements of this contract. Direct legal representation is defined as all activities required to complete a specific legal service category on behalf of one UAC per this section and the evidence of service completion. The evidence required to demonstrate completion of each legal service category is stated in Section C.4.2.4.2.

Pursuant to the TVPRA at 8 USC 1232(c)(5), HHS is generally required to “ensure, to the greatest extent practicable” and consistent with 8 USC 1362 (i.e., “at no expense to the Government”) that UAC have counsel to represent them in legal proceedings or matters and protect them from mistreatment, exploitation, and trafficking—making every effort to utilize the services of pro bono counsel who agree to provide services to such children without charge.

C.4.2.4.1 General Requirements:

1.) Eligibility for Direct Representation

The Contractor may offer direct legal representation to:

a. Unrepresented UAC who become enrolled in the ORR Unaccompanied Refugee Minors (URM) Program, provided they have not yet obtained immigration relief or reached 18 years of age at the time of retention of a qualified person as defined in C.4.2.3.

b. UAC in ORR care who are in proceedings before the Executive Office for Immigration Review (EOIR), including UAC seeking voluntary departure, and for whom other available assistance does not satisfy the legal needs of the individual UAC.

c. UAC released to a sponsor residing in the defined service area of the same legal service provider who provided the UAC legal services in ORR care, to promote continuity of legal services.

d. For other unaccompanied children, to the extent ORR determines that appropriations are available.

2.) Population Prioritization

The contractor shall prioritize direct legal representation of certain categories of UAC, including:

Tender age UAC (under age 13)

Survivors of human trafficking

UAC who are eligible for asylum or other forms of immigration relief

Survivors of serious crimes

Other UAC who can be categorized as particularly vulnerable

3.) Timing of Representation

Direct legal representation of the UAC shall be initiated prior to the UAC’s 18th birthday and before immigration relief is granted.

4.) Notice of Representation

The Contractor shall:

Ensure the entry of all qualified personnel as defined in C.4.2.3 of record are timely filed with EOIR, the Department of Homeland Security (DHS), and with any other tribunal or administrative agency requiring notice of representation.

Ensure timely notice of representation to ORR in the designated system of record designated by the COR and care provider staff, including the submission of a Form L-3 Notice of Attorney Representation (See F.4, Deliverables Schedule and Performance Requirement Summary Table).

5.) Funding Constraints and Resource Management

The Contractor:

Shall maximize use of non-federal funding and cost-saving strategies to provide direct legal representation services.

Shall maximize the use of pro bono in providing legal services.

Is prohibited from using contract funds for any non-immigration-related UAC legal matters or litigation against the U.S. Government unless expressly authorized in writing by the COR in advance, regardless of whether such representation has previously been authorized.

6.) Continuity of Representation and Referral Resources:

The Contractor shall provide a legal referral for unrepresented UAC in ORR custody upon a UAC's transfer between ORR facilities. See F.4, Deliverables Schedule and Performance Requirements Summary Table.

For any represented UAC who leaves a legal provider’s defined service area prior to the resolution of the UAC's immigration case, the Contractor shall provide a referral to a legal representative in the new location of the child's residence.

The Contractor shall provide legal referrals for each UAC consistent with identified legal relief and the jurisdiction where the UAC resides.

The Contractor shall create a State-by-State list of free legal service providers, at minimum, compiled quarterly, to be given to UAC at the Legal Orientation required by C.4.2.2.1.

C.4.2.4.2 Requirements for Direct Legal Representation Services

The Contractor shall perform direct legal representation services (corresponding to Pricing Worksheet Items 3-13) in accordance with rules of professional conduct and ethical responsibilities for eligible UAC on an as required basis at a firm-fixed unit price. Invoicing and payment shall be made based upon completion of the following services, on a per UAC basis, based on the specified evidence of completion required for each service.

1.) T Visa Application Services (Item 3) The Contractor shall provide legal services relating to the application of a T nonimmigrant status visa (“T visa”), a temporary federal visa for victims of severe form of human trafficking, which includes sex trafficking and labor trafficking involving force, fraud, or coercion, which, at a minimum, shall include the following services:

A.) Case Assessment and Application Preparation and Submission Minimum

Requirements:

1. The Contractor shall conduct a case assessment to confirm the UAC’s eligibility for the form of relief.

2. The Contractor shall prepare and file the appropriate application/petition with USCIS (e.g. Form I-360, I-914, I-918, I-485).

3. The Contractor shall provide evidence of service completion by submitting all of the following as part of the Contractor’s invoice submission:

Copy of G-28, Notice of Entry of Appearance as Attorney or Accredited

Representative Copy of USCIS filing confirmation (e.g. Form I-797, Notice of Action)

B.) Post-Submission Follow-Up and Representation Minimum Requirements:

1. The Contractor shall provide post-filing services, including any responses to Requests for Evidence issued by USCIS and any post-adjudication actions to terminate or administratively close removal proceedings.

2. The Contractor shall provide evidence of service completion by submitting the following as part of the Contractor’s invoice submission:

Copy of Form I-797, Notice of Action Copy of EOIR filing receipt and/or order related to immigration removal proceedings, if applicable (e.g., order terminating removal proceedings)

2.) U Visa Application Services (Item 4) The Contractor shall provide legal services relating to the application of a U nonimmigrant status visa (“U visa”), a temporary federal visa for victims of substantial mental or physical abuse resulting from certain crimes, such as domestic violence, sexual assault, or trafficking, which at a minimum shall

1. The Contractor shall conduct an assessment to confirm the UAC’s eligibility for the form of relief.

2. The Contractor shall prepare and file the appropriate application/petition with USCIS (e.g. Form I-360, I-914, I-918, I-485).

3. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of G-28, Notice of Entry of Appearance as Attorney or Accredited administratively close removal proceedings.

2. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of USCIS decision (e.g. Form I-797, Notice of Action) Copy of EOIR order related to immigration removal proceedings, if applicable

5.) Violence Against Women Act (VAWA) Services (Item 5) The Contractor shall provide legal services relating to Violence Against Women Act (VAWA) applications allowing abused immigrant spouses, children, or parents to self-petition for legal status by filing Form I-360, Petition for Amerasian, Widow(er), or Special Immigrant, without the abuser's knowledge, which at a minimum, shall include the following services:

2. The Contractor shall prepare and file the I-360 and any other appropriate application/petition with USCIS (e.g. Form I-360, I-914, I-918, I-485).

3. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of G-28, Notice of Entry of Appearance as Attorney or Accredited administratively close removal proceedings.

2. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

6.) Adjustment of Status Services (Item 6) The Contractor shall provide legal services relating to Adjustment of Status applications, specifically the legal services necessary for eligible foreign nationals already in the U.S. to apply for lawful permanent residency without leaving the country, which, at a minimum, shall include the following services:

2. The Contractor shall prepare and file the I-485 and any other appropriate application/petition with USCIS.

3. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of G-28, Notice of Entry of Appearance as Attorney or Accredited

1. The Contractor shall provide post-filing services, including any response to Request for administratively close removal proceedings.

2. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

7.) Temporary Protected Status Services (Item 7), Minimum Requirements The Contractor shall provide legal services relating to Temporary Protected Status (TPS) applications, a temporary, renewable immigration designation granted by the DHS Secretary to foreign nationals in the U.S. who cannot safely return to their home country due to armed conflict, environmental disasters, or extraordinary, temporary conditions. These services shall, at a minimum, include the following services:

A.) The Contractor shall conduct a case assessment to confirm the UAC’s eligibility for TPS.

B.) The Contractor shall prepare and file the I-821 and any other required application/petition with USCIS (e.g. Form I-821) C.) The Contractor shall provide post-filing services, including responses to any Requests for

Evidence issued by USCIS and any post-adjudication actions.

D.) The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of G-28, Notice of Entry of Appearance as Attorney or Accredited Representative

8.) Employment Authorization (Item 8), Minimum Requirements The contractor shall provide legal services relating to the application for an Employment Authorization Document (EAD or Form I-766) which, at a minimum, shall include the following services:

A.) The Contractor shall conduct a case assessment to confirm the UAC’s eligibility for employment authorization.

B.) The Contractor shall prepare and file the I-765 and any other required forms with USCIS (e.g.

Form I-821, I-765, N-600)

C.) The Contractor shall provide post-filing services, including responses to any Requests for Evidence issued by USCIS and any post-adjudication actions.

D.) The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

9.) Applications for Certificate of Citizenship Based on Parents’ U.S. Citizenship (Item 9), Minimum Requirements The Contractor shall provide legal services relating to application for certificate of U.S. citizenship, which, at a minimum, shall include the following services:

A.) The Contractor shall conduct a case assessment to confirm the UAC’s eligibility for a

Certificate of Citizenship.

B.) The Contractor shall prepare and file the Form N-600, Application for Certificate of

Citizenship, and any supporting documentation with USCIS.

C.) The Contractor shall provide post-filing services, including responses to any Requests for

Evidence issued by USCIS and any post-adjudication actions.

D.) The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

10.) Special Immigrant Juvenile Status Services (Item 10) The Contractor shall provide legal services relating to Special Immigrant Juvenile Status (SIJS) classification, a process a classification for vulnerable, undocumented children under 21 who have suffered abuse, neglect, or abandonment by a parent and cannot return home. These services shall, at a minimum, include the following services:

A.) Case Assessment and State Juvenile Court Proceeding Minimum Requirements

1. The Contractor shall conduct a case assessment to confirm the UAC’S eligibility for

SIJS.

2. The Contractor shall file for a predicate order in the appropriate state juvenile or family court.

3. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of signed contract for legal services Copy of state predicate order

B.) USCIS Proceedings Minimum Requirements

1. The Contractor shall prepare and file Form I-360, Petition for Amerasian, Widow(er), or

Special Immigrant with USCIS.

2. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of G-28, Notice of Entry of Appearance as Attorney or Accredited

C.) Post-Submission Follow-Up and Finalization Minimum Requirements

1. The Contractor shall provide post-filing services, including responses to any Requests for administratively close removal proceedings.

2. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of USCIS I-360 decision (e.g. Form I-797, Notice of Action) Copy of EOIR Order related to immigration removal proceedings

11.) Affirmative and Defensive Asylum Application Services (Item 11) The Contractor shall provide legal services relating to the application for asylum, a legal protection for individuals who fear persecution in their home country due to race, religion, nationality, political opinion, or membership in a particular social group. These services shall, at a minimum, include the

A.) Case Assessment and Application Preparation and Submission Minimum Requirements

1. The Contractor shall conduct a case assessment to confirm the UAC’s eligibility for asylum.

2. The Contractor shall prepare and submit Form I-589, Application for Asylum and for Withholding of Removal to USCIS (and with EOIR to preserve possible relief, if necessary).

3. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of G-28, Notice of Entry of Appearance as Attorney or Accredited

Representative Copy EOIR-28, Notice of Entry of Appearance as Attorney or Immigration Court

Representative Before the Immigration Court (E-28), as applicable Copy of USCIS I-589 filing confirmation (e.g. Form I-797, Notice of Action or stamped copy from Asylum Office) Copy of proof of filing with EOIR, as applicable

B.) Post Affirmative Asylum Submission Follow-Up and Representation Minimum

Requirements

1. USCIS Asylum Interview Representation. The Contractor shall prepare the UAC and represent the UAC during the interview.

2. The Contractor shall provide post-filing services, including responses to any Requests for Evidence issued by USCIS and any post-adjudication actions to terminate or administratively close removal proceedings.

3. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of USCIS I-589 decision (e.g. Form I-797, Notice of Action or other Asylum

Office decision) Copy of EOIR Order related to immigration removal proceedings

C.) Defensive Asylum Minimum Requirements Defensive asylum services are applicable when

USCIS denies an affirmative asylum application and refers the case to EOIR. The Contractor may pursue a defensive asylum claim or other case dispositions with EOIR (e.g. voluntary departure, removal order).

1. The Contractor shall ensure that a Final Hearing for the adjudication of an asylum case is scheduled with EOIR.

2. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of order from Immigration Judge scheduling a final merits hearing

D.) Post Defensive Asylum Submission and Representation Minimum Requirements

1. The Contractor shall prepare for and participate in a full merit hearing that includes advocacy for termination or administrative closure of proceedings.

2. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of decision from Immigration Court adjudicating the asylum petition Copy of order related to immigration removal proceedings (if applicable)

12.) Voluntary Departure and Repatriation Services (Item 12) The Contractor shall provide legal services relating to voluntary departure, an immigration benefit allowing a foreign national facing removal to leave the U.S. voluntarily at their own expense within a set timeframe, avoiding a formal order of removal. These services shall, at a minimum, include the

A.) Case Assessment and Application Preparation and Submission Minimum Requirements

1. The Contractor shall assess eligibility for voluntary departure or any other form of repatriation and evaluate whether returning to the home country is in the best interest of the child, as appropriate. The Contractor shall also determine the child’s intent to return, as appropriate.

2. The Contractor shall prepare the UAC for the hearing and represent the UAC during the hearing.

3. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of E-28 Copy of voluntary departure order from Immigration Judge

E.) Post-Submission Follow-Up and Representation Minimum Requirements

1. If voluntary departure is granted, the Contractor shall coordinate all travel arrangements in collaboration with the ORR, Immigration and Customs Enforcement (ICE), or DHS.

2. The Contractor shall monitor compliance with the voluntary departure order to confirm that the child departs the United States within the required timeframe.

3. Upon completion of travel, the Contractor shall obtain proof of departure from a consulate abroad or by providing a sworn statement that the Contactor witnessed the departure.

4. The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Order granting Voluntary Departure (or other relevant documentation confirming participation in the program) Proof of departure

13.) Change of Venue / Address Filings (Item 13), Minimum Requirements

The Contractor shall provide change of venue and address filings. These services shall, at a minimum, A.) The Contractor shall prepare and file motions and forms necessary to request a change of venue and update address information, as necessary.

B.) For a Motion to Change Venue, the Contractor shall draft and submit a formal request to transfer the UAC’s immigration case to a different immigration court, typically one closer to the UAC’s current residence.

C.) For a Change of Address filing, the Contractor shall complete and submit the appropriate forms within five working days of any change in the UAC’s address.

D.) The Contractor shall provide evidence of service completion by providing the following as part of the Contractor’s invoice submission:

Copy of Change of Venue/Change of Address filing

C.4.2.5 Task V: Annual Legal Service Provider (LSP) Network Management Minimum Requirements (Item 14) [Firm Fixed Price]

The Contractor shall provide LSP network management on a fixed price, annual basis. The Contractor shall, at a minimum, perform the following services:

1.) Network Composition Minimum Requirements:

A.) The Contractor shall establish and manage a robust nationwide network of qualified LSPs delivering services to UAC that ensures timely and consistent legal orientations; legal consultations; direct legal representation; and data collection, analysis, and reporting, in accordance with the requirements of this contract. The Contractor shall maintain quality control, performance monitoring, training, and coordination across the network and with all LSPs.

B.) The network shall include qualified volunteer pro bono qualified personnel as defined in C.4.2.3 representatives to provide legal services to UAC in and released from ORR care. The Contractor shall achieve the minimum percentage of pro bono legal service hours as described in C.4.2.7 Pro Bono Maximization and C.5.2.3 Pro Bono Service Plan.

C.) The Contractor shall build and maintain a roster of qualified personnel as defined in C.4.2.3 volunteers to provide legal services. For all legal services, the Contractor shall ensure that supervision, as required, is maintained for legal services to UAC, whether the services are paid or provided pro bono.

2.) Pro Bono Attorney Screening and Supervision Minimum Requirements:

A.) Before a pro bono attorney on the Contractor’s roster provides any legal services to a UAC, and no less than annually following award, the Contractor shall confirm with state licensing authorities that the pro bono attorney is:

1. Licensed to practice law and in good standing with the bar of the relevant U.S. state, district, and/or territory; and

2. Not subject to any disciplinary matters that call into question the attorney’s fitness to represent UAC in their immigration case.

B.) The Contractor shall ensure all services delivered by pro bono attorneys on the Contractor’s roster are in accordance with applicable rules of professional conduct, including competency, and ethical responsibility.

3.) Reporting Requirements

The Contractor shall provide data detailing the delivery of all services under Task V per Section C.4.2.6 and F.4, Deliverables Schedule and Performance Requirements Summary Table to enable Government assessment of the effectiveness of the LSP network and the Contractor’s ability to provide nationwide delivery of services, both paid and pro bono.

C.4.2.6 Task VI: Data Collection and Transfer System / Interface (Item 15) [Firm Fixed Price]

The Contractor shall establish and maintain a comprehensive data collection, analysis, and reporting system to support ORR program oversight, performance monitoring, and continuous service improvement. Data shall be collected in accordance with ORR policies and reported in accordance with this section and Section F.4, Deliverables Schedule and Performance Requirements Summary Table.

To support program oversight and continuous improvement, the contractor shall provide robust data collection, analysis, and reporting, which shall include, but is not limited to, the outcomes of pro bono counsel recruitment, the scope and outcomes of representation, use of money received under this contract, and real time case status. This data shall be made available through:

• Secure, interoperable dashboards with role-based access controls

• Direct connection to existing ORR platforms and tools via documented integration methods that comply with HHS security standards (including application programming interfaces (APIs), secure file transfer protocols, and cloud storage solutions such as S3 buckets)

• Network infrastructure development and ongoing maintenance to ensure reliable, secure connectivity between systems, including uptime monitoring, security patching, and performance optimization

• Documentation of data definitions, collection methodologies, and reporting specifications, system architecture diagrams, and data flow maps, and network topology to ensure transparency and reproducibility.

The Contractor shall use the data to identify trends, assess service delivery effectiveness and contractor performance, and provide actionable recommendations to ORR. Data shall be made available in a structured, searchable database format (Parquet, JSON, XML, or CSV as appropriate for system integration).

1.) Performance Requirements

A.) Data Collection and Data Management Infrastructure and Systems: The Contractor shall maintain a data collection and management system that (1) ensures compliance with ORR reporting requirements, and (2) centralizes all information related to each individual UAC including, but not limited to, the UAC’s biographical information (e.g., name, date of birth, country of birth, A Number, and other assigned ORR unique identifier(s)); information regarding the UAC’s assigned legal services representative; detailed information about the legal services provided pursuant to this contract, including case status, case deadlines, case progress, and case outcomes or final dispositions. To the maximum extent practicable, data entry into the system shall be concurrent with services provided. The Contractor shall maintain all data and information related to individual legal services and shall not delete, destroy, or permanently remove any data throughout the duration of this Contract and for the time further required by H.14, Records Management.

B.) Secure Data Reporting Infrastructure: The Contractor shall maintain a secure and scalable data infrastructure and computing environment that enables:

1. Raw data ingestion from disparate sources;

2. Extract-transform-load (ETL) processes to clean, organize, and connect data from various sources; and

3. Analysis of quantitative data at a scale, appropriate for the work completed.

2.) System Capabilities Requirements:

The infrastructure shall comply with applicable federal regulations and be capable of ingesting, housing, and, where necessary, securely merging data from multiple sources. The Contractor's data environment shall also be able to respond and adapt to:

A.) Routine changes (service areas, policy updates, service delivery modifications):

Implementation within 30 calendar days of notification.

B.) Volume fluctuations: Automatic scaling to accommodate up to 50% increase or decrease in data volume without performance degradation.

C.) Emergency response services include time-sensitive adaptations necessary to support urgent operational, statutory, oversight, interagency, or humanitarian needs as determined by ORR. These may include rapid modifications to data collection, reporting, system access, integration interfaces (including APIs), or data transmission processes.

Such adaptations may require accelerated configuration, development, testing, or deployment activities. The Contractor shall implement required changes within five

(5) business days of notification, unless otherwise directed by the COR.

The Contractor shall:

• Acknowledge receipt of emergency change requests within four (4) business hours

• Provide daily status updates to the COR during implementation

• Conduct expedited testing protocols while maintaining data integrity and security standards

• Document all emergency changes and provide post-implementation reports within ten (10) business days

D.) Upon notification by the COR, the Contractor shall submit a detailed implementation plan outlining scope, timeline, risks, and resource requirements. Implementation shall occur within ninety (90) calendar days unless otherwise approved by ORR.

The implementation plan shall include, at minimum:

• Technical approach and architecture diagrams

• Detailed timeline with milestones and dependencies

• Risk assessment and mitigation strategies

• Testing and validation approach

• Data migration or transition plans (if applicable)

• Impact analysis on existing system functionality

• Resource allocation and staffing plan

• Rollback procedures

• Training requirements for ORR staff or end users

The plan shall be submitted within fifteen (15) business days of notification and approved by the COR prior to implementation.

E.) Material changes to program services are defined as programmatic, statutory, policy, operational, or oversight changes determined by ORR to have a meaningful impact on system functionality, data requirements, reporting obligations, integration needs, user access, or performance expectations.

Such changes may require updates to:

• Data elements or data transmission formats

• API specifications or…