CI23015-2_Determination.pdf

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Attached to
Master Agreement AZ|CTR069054
Contract number
CTR069054
Issued by
Arizona

About this file

This document is a State Procurement Office (SPO) Form 101 - Competition Impracticable Procurement Authorization for the Arizona Department of Economic Security (DES). The document involves Catholic Charities Community Services (CCCS) as the supplier, with the procurement request initiated by Jenae Finton, a Contracts Specialist at DES.

The contract is for the Unaccompanied Refugee Minors (URM) Program, which provides foster care provisions for refugee minors under 18 who are without a qualified parent or legal guardian. The contract (CTR069054) is being modified to continue serving this vulnerable population, with an estimated cost of $6,000,000 for the period from 10/01/2025 to 12/31/2028. The program is fully funded through DES contracts, and CCCS maintains legal guardianship of the children. The modification is necessary to ensure continued service delivery and compliance with federal policy requiring service parity with the Department of Child Safety (ADCS). The pricing is considered fair and reasonable, aligned with rates set by ADCS and subject to review through an approved itemized Service Budget.

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Page 1 of 4 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 03.21.22)

Procurement Determination:

Competition Impracticable Authorization A.A.C. R2-7-E303

SECTIONS I THROUGH III MUST BE COMPLETED BY THE REQUESTOR

USE ADDITIONAL PAGE AS NECESSARY

SECTION I - State Governmental Unit Request

1. State Governmental Unit

2. Requestor 3. Email

4. Title 5. Telephone

SECTION II - Background

6. Service(s)/Material(s)

7. Supplier

8. Contract ID

9. CI Type

10. Requesting Term 11. Estimated Cost

Department of Economic Security

Jenae Finton jenaefinton@azdes

Contracts Specialist (602) 394-1868

10/01/2025 - 12/31/2028 $6,000,000

- Modification pursuant to R2-7-E303(E) for a CI modification

Page 2 of 4 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 03.21.22)

SECTION III - Justification

12. Rationale

13. Provide details of the procurement need, reason for the competition impracticable, and how the proposed procurement is advantageous to the State

- Compliance with A.R.S. §§ 41-2533, 41-2534, 41-2538, or 41-2578 is impracticable

Page 3 of 4 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 03.21.22)

14. Describe the procurement process, strategy to promote competition, and determination that the price is fair and reasonable

15. I have conducted research and determined that no mandatory state contract is available for the service(s)/material(s)

16. Signature 17. Date of Request

In accordance with the Procurement Rules, the Arizona Uniform Terms and Conditions must be made a part of all Contracts. If you will be required to sign a software licensing agreement or sign any other agreement containing terms and conditions, these will need additional review to ensure that the terms and conditions do not invalidate the Arizona Uniform Terms and Conditions. Approval of this request does not allow for agencies to exceed their dollar acquisition amount of delegated authority.

9/23/2025

Page 4 of 4 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 03.21.22)

TO BE COMPLETED BY PROCUREMENT AUTHORITY

SECTION IV - Approval

18. Determination

19. Approved Expiration Date

20. Comments, conditions, or restrictions (as applicable)

21. Print Name 22. Title

23. Signature 24. Date of Approval

25. Use section as necessary

STATE GOVERNMENTAL UNIT NOTICE: This is an official written determination in response to a procurement authorization request.

A copy of the form shall be maintained by the State Governmental Unit and the State Procurement Office.

Upon completion, Requestor shall forward the signed form to the Contract Owner.

Contract Owner shall upload the signed approval version of this form in the eProcurement system.

If anticipated expenditure is above State Governmental Unit's delegation, forward document to SPOCompliance@azdoa.gov.

12/31/2028

David Steuber State Procurement Administrator

David Steuber (Sep 23, 2025 17:01:27 PDT)

- Request Authorized Pursuant to R2-7-E303

09/23/2025 https://na1.documents.adobe.com/verifier?tx=CBJCHBCAABAAGl_oNVrPeonmluovydg2xyv_A3JjtKi4

SPO Form 101 CI & SW 03.21.22_1
SPO Form 101 CI & SW 03.21.22_2
Text6: Unaccompanied Refugee Minors (URMP) provides foster care provisions to minors under the age of 18 within the U.S. without a qualified parent or legal guardian. Including child welfare services to refugee children according to the State's child welfare practices and standards.
Text7: Catholic Charities Community Services (CCCS)
Text8: CTR069054
Text13: The Unaccompanied Refugee Minors Program (URMP) operates as a private foster care program in Arizona where Unaccompanied Refugee Minor children enter into the State and have guardianship transferred from the federal government to a local nonprofit at the states request pursuant to the Refugee Resettlement State Plan. Under the contract established under this CI, in which CCCS obtains legal guardianship of the children and must maintain it until their 18th birthday at a minimum or their 21st birthday if they say in extended foster care. CCCS is enumerated as the Arizona URMP contracted service provider in the Arizona Refugee State Plan. All funding for this URMP is 100% derived from DES URMP contracts. CCCS maintains legal guardianship of the children in URMP under the current contract at DES' behest, failure to continue CCCS' contract under this CI would leave youth in care at a guardian without funding to pay or care and would violate federal policy (CFR 400.112) stating DES must maintain parity of services to the Arizona Department of Child Safety (ADCS).

This modification would allow for the current contract CTR069054 established under this CI to continue serving the critical needs of the vulnerable unaccompanied refugee minor population through December 31, 2028.

Text14: ADES believes it is in the best interest of the State to continue to contract with Catholic Charities Community Services.

The pricing is fair and reasonable, as the URM program must have a parity with the State child welfare program, therefore foster parents, group homes, therapeutic group homes will align with rates set by ADCS. Other services being provided will be reimbursed through an approved Itemized Service Budget which is reviewed, negotiated, and approved by the division to ensure pricing is fair and reasonable and in line with approved expenses by ORR.

In accordance with A.A.C. R2-7-604(B) The program, fully funded through DES contracts, has seen a 39.53% increase in service demands—from 4.M to 6M—reflecting growing need. Discontinuing this contract would leave youth without a guardian or funding, in violation of federal policy (CFR 400.112) requiring service parity with the Department of Child Safety. It is determined to be in the best interest of the State to allow services to continue through December 31, 2028.

Text20:
2025-09-24T00:01:30+0000
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