E52_MISC_-_LSJ_ORR_Mission_Support_Services_Bridge_-_REDACTED_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C 501

SOLICITATION: 140D0425Q0599

This acquisition is conducted under the authority of the General Services Administration (GSA) Multiple Award Schedule (MAS) Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This is a Limited-Sources Justification by the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division I, Branch III on behalf of Department of Health and Human Services (HHS), Administration for Children and Families (ACF), Office of Refugee Resettlement (ORR).

2. Nature and/or description of the action being approved.

The purpose of this Limited-Sources Justification is to acquire Mission Support Services on behalf of ORR through a sole source award to the incumbent, General Dynamics Information Technology, Inc. (GDIT), as a follow-on requirement to the current, competitive task order (75ACF121F80034). The award will have a Period of Performance (PoP) of up to 12 months (18 months if including the extension at FAR 52.217-8) and will be issued off GDIT’s GSA MAS, Special Item Number (SIN) 541611, Management and Financial Consulting, Acquisition and Grants Management Support and Business Program and Project Management Service Contract, GS00F057CA. The proposed contract type will be a hybrid Firm-Fixed-Price (FFP) and Time and Materials (T&M).

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The ORR and the Office on Trafficking in Persons (OTIP) are two operational offices within the ACF. ORR serves refugees, asylees, Cuban and Haitian entrants, certain Special Immigrant Visa holders, Amerasians, victims of human trafficking, survivors of torture, and unaccompanied alien children. OTIP develops anti-trafficking strategies, policies, and programs to prevent human trafficking, build health and human service capacity to respond to human trafficking, increase victim identification and access to services, and strengthen the health and well-being outcomes of trafficking survivors.

ORR requires the services of a contractor to assist staff with monitoring activities for the

SOLICITATION: 140D0425Q0599

Refugee Program Bureau and the Unaccompanied Alien Children Bureau ( UACB). The services shall include but not be limited to collecting and analyzing written documentation and program data; conducting on-site reviews concerning the implementation of grants as well as reviewing the use of funds received by grantees in order to evaluate their compliance with program rules and to identify needed technical assistance support. For the Refugee Program Bureau, ORR has recently moved to a model of Monitoring and Evaluation where outcome-based monitoring is conducted, as is monitoring for compliance. This approach allows ORR to tailor its technical assistance to grantees while also informing evidenced-based decision making.

ORR also requires specialized program support from persons with experience in social and health services, and child welfare services, in addition to competence in program and data analysis regarding both refugee resettlement and Unaccompanied Alien Children ( UAC) services, as well as policies relevant to all ORR program areas. Support is also required for the initial review of grant applications; and to facilitate the collection of outcome data from the field, the quality assessment of the data collected from reports submitted quarterly, semi- annually, or annually by the State agencies, grantees and contractors through desk and field monitoring; and for the provision of technical assistance as appropriate to improve performance and outcomes.

The OTIP requires services to assist with its Adult Certification and Child Eligibility Program, and Public Awareness and Education efforts. Support is required for the processing of certification of foreign national adult victims of severe forms of human trafficking, including external communications about the certification process, database management, and training of grantees on HHS certification processes. Support is also required for the preparation of written materials and electronic postings related to certification and eligibility for relevant OTIP programs to internal and external audiences. Additional support is required for drafting policies and program instructions and conducting research on related fields such as domestic violence, sexual abuse, etc.

To help both ORR and OTIP meet their mission goals, both offices have received contractor support services since 2014. Both offices will continue to need these services after the current task order expires on September 21, 2025. The services provided under this task order are critical to ensuring mission success for both ORR and OTIP.

The estimated value of this requirement is for a 12-month base period ( with the option of up to an additional six months under FAR 52.217-8 extension). The anticipated period of performance is from September 22, 2025 through September 21, 2026.

4. The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(a)(1)(i)(C) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

GDIT is intimately familiar with the support required and is uniquely qualified to provide these services during the bridge period due to its ongoing support of ORR and OTIP programs since 2014. This bridge task order will be in place in the interim until the new recompete, competitive requirement is awarded which is expected to occur in Quarter 4 of Fiscal Year (FY) 2026. The interim bridge task order is logical in that it will continue services at a similar level of effort and scope as the current task order, 75ACF121F80034.

All GSA MAS contract awardees under the SIN were given a fair opportunity to be considered for the current task order. Furthermore, the contractor has maintained specialized knowledge of the programs' operational environments, data management systems and tracking methodologies. This historical expertise enables GDIT to deliver the high-level technical assistance and monitoring required without a transition period. GDIT has consistently met or exceeded performance standards under the current and previous task orders.

The continuity of these services is critical due to their direct support of vulnerable populations, including trafficking victims, refugees, torture survivors, and unaccompanied alien children. Disruption of support services could result in delays in service, data reporting discrepancies, and compliance issues. These outcomes would adversely impact both ORR and OTIP programs and mission goals.

Additionally, HHS and ACF ORR have recently faced uncertainty about the future scope and scale of the requirement and the possible recompete action due to recent Presidential Actions, including:

• Presidential Action, Protecting the American People Against Invasion (dated January 20, 2025)

• Presidential Action, Securing Our Borders (dated January 20, 2025)

• Presidential Action, Declaring a National Emergency at the Southern Border (dated

January 20, 2025)

• Presidential Action, Realigning the United States Refugee Admissions Program (dated

January 20, 2025

These Presidential Actions have and will continue to affect migration patterns and program priorities. In order to better align with the Presidential Actions, ORR is proactively revising their plans for future requirements and requires additional time to develop the necessary strategy and documents. Furthermore, HHS has experienced recent Reduction in Force (RIFs) causing delays in the ability to adjust the requirements and to start the necessary acquisition planning. Because of this, ORR is not currently able to clearly define the long-term requirements in an expedited manner. Therefore, building a competitive requirement and solicitation would require a significant lead time to properly assess requirements, prepare acquisition documentation, and ensure a smooth transition, none of which can be completed before the expiration of the current task order.

Even though program priorities are evolving, many of the ORR and OTIP programs are statutorily mandated. This further supports the need to establish a bridge task order to ensure the continuity of services. Some of these authorities include the following:

• The Trafficking Victims Protection Act, as amended, at 22 U.S.C. 7105(b)(1), authorizes

HHS to expand benefits and services for victims and potential victims of severe forms of human trafficking in persons born outside of the United States, to fund a grant for a national human trafficking hotline, and to develop, expand, and to fund grants to strengthen victim services programs for victims born in the United States.

• The Homeland Security Act of 2002, 6 U.S.C. 279, makes the ORR Director responsible for, among other things, making and implementing placement decisions for UACs.

• The Trafficking Victims Protection Reauthorization Act of 2008, at 8 U.S.C. 1232(i), provides specific legal authority for HHS to enter into grants and contracts to carry out statutory provisions under the Trafficking Victims Protection Reauthorization Act of 2008 (8 U.S.C. 1232) and the Homeland Security Act of 2002 (6 U.S.C. 279).

• The UAC Program Foundational Rule, 45 CFR part 410, implements ORR’s statutory and other legal responsibilities, including ORR’s responsibility to make placement and release decisions.

• 8 U.S.C. 1522, provides authority to the Director of ORR to provide services including employment training and cash assistance to refugees. The statue authorizes grants and contracts for services for refugees and requires monitoring and evaluation of these grants and contracts.

• 22 U.S.C. 7105(b), provides authority to OTIP to process requests for assistance related to requirements for HHS to expand benefits and services to assist victims of trafficking, certify adult victims of trafficking and make interim eligibility determinations for child victims of trafficking.

• 22 U.S.C. 7104(b)(1) and 42 U.S.C. 7104(b), provides authority for OTIP to support activities related to requirements for HHS to increase public awareness particularly for potential victims of human trafficking.

• 22 U.S.C. 7105(c)(4), provides authority for OTIP to provide required training to federal employees and to state and local officials to improve trafficking victim identification and assistance.

• 22 U.S.C. § 7103(d) and 22 U.S.C. § 7109(a), provide authority for OTIP to support requirements for HHS to measure and evaluate progress in trafficking prevention, protection, and assistance to victims and expand procedures to collect and organize data.

Obtaining competition for this bridge task order is impracticable under the circumstances described herein as it would require considerable lead time to identify sources, receive quotes, conduct a source selection, and process appropriate award documentation. Selecting any other source would also require a significant transition-in/ramp up period to get a new contractor up to speed on the complex services provided, including transfer of documentation, and obtaining access to controlled Government systems.

Based on this information it is in the Government’s best interest to award to GDIT as it is the only source capable of performing the services at the required level of quality and knowledge during this interim period. Awarding a bridge task order to GDIT under the authority of FAR 8.405-6(a)(1)(i)(C) is necessary to ensure mission success while the Government evaluates the future procurement strategy considering recent, evolving policy changes, and operational needs.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

The Contracting Officer (CO) will determine the anticipated price will be fair and reasonable through the use of the GSA MAS program and through the program’s schedule pricing. The rates used by GSA MAS program schedule contract holders have been determined at the time of schedule contract award to be fair and reasonable. To further ensure the price is reasonable, price evaluation will be conducted in accordance with FAR 8.405-2(d) and 8.405-4. In accordance with DOI-AAAP-0024, Enhancing Competition, and due to only one quote being received, the price analysis tools and techniques at FAR 15.404-1(b)(2) may be used to further determine the price fair and reasonable.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

The current task order, 75ACF121F80034, for ORR’s Mission Support Services effort was competed full and open via GSA MAS SIN 541611. The solicitation was issued in August of 2021. One offer was received and evaluated. GDIT was determined to be the best value to the Government. As such, ACF’s Government Contracting Service (GCS) awarded a T&M contract to GDIT for $121,493,576.99 with a Period of Performance (PoP) of September 22, 2021 through September 21, 2025.

Market research for the follow-on recompete was conducted in late 2024 and included a Request for Information (RFI) published on GSA eBuy on August 21, 2024, and closed on September 5, 2024. The Government received 43 responses and 27 of those were small businesses. Based on the information provided in response to the RFI and additional questions, it was determined that this requirement should be solicited as unrestricted with full and open competition. At the onset of the market research, several NAICS codes were evaluated for this requirement. After a thorough review by the Program Office, it was determined that NAICS 541611 – Administrative Management and General Management Consulting Services, was the most appropriate. However, due to the HHS Reduction in Force (RIF) which affected GCS’s ability to provide acquisition assistance for the recompete of the current task order, ORR brought its requirement to AQD in May 2025 to ensure AQD has time to effectively procure the required Mission Support Services for ORR.

Outside of a review of the acquisition history, a review of a previous ACF ORR-conducted RFI, and a review of the GSA MAS, AQD only validated the previous market research previously conducted and did not conduct additional market research as AQD intends to utilize a sole source, bridge task order to provide the critical support to ACF ORR until the recompete task order has been awarded in Quarter 4 of Fiscal Year (FY) 2026. As discussed above, obtaining competition for this bridge is impracticable and, therefore, the bridge task order is anticipated to be awarded to GDIT, the incumbent contractor.

7. Any other facts supporting the justification.

Since completion of the market research as described in Section 6, evolving program priorities driven by Presidential Actions and changes to migration patterns have prompted ORR and OTIP to reassess and redetermine the appropriate path forward for a revised recompete requirement.

Awarding a bridge contract to GDIT at this time will provide continuity of services for ORR and OTIP’s current requirement while the Government can reevaluate the future program and operational needs for the recompete requirement that is anticipated to be competed and awarded in Quarter 4 of FY26.

The solicitation will be provided directly to the contractor, GDIT, via email. In accordance with FAR 8.405-6(a)(2) and FAR 5.301, the approved Limited-Sources Justification will be posted on SAM.gov no later than 14 days after award and remain posted for 30 days.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

For the reasons cited above, the Government is pursuing a sole source award to GDIT, because GDIT is the only capable source of providing continuity of services at the required level of quality and in the short timeframe. AQD intends to procure a follow-on action competitively in Quarter 4 of FY26, as the barrier to competition that currently exists will be overcome with adequate time to compete and allow for transition of services without any impact in service delivery.