SSJ_SLISII_Extension_Redacted V3.pdf

UNCLASSIFIED

1 | P a g e FAR 13.5 Sole Source Justification exceeding SAT, v4/0, 09/10/2024

SOLE SOURCE JUSTIFICATION

UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL PRODUCTS AND SERVICES

PURSUANT TO FAR 13.501 FOR SOLE SOURCE ACQUISITIONS WITH AN

ESTIMATED VALUE EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

CONTROL NUMBER:

1. IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY.

National Geospatial-Intelligence Agency / Office of Contract Services

2. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED.

This justification seeks approval for an extension to the current Sign Language Interpreting Services (SLIS II) contract for the continue provision of services to support the Deaf and Hard of Hearing (DHH) employees in providing various modes and sign language communication and sign language interpreting techniques such as but not limited to American Sign Language (ASL)/English Interpreting, Contract Sign Language (Pidgin, Signed English)/English transliterating, tactile/close vision interpreting and oral transliterating. The current contract, , was awarded to MAF Interpreting Inc. on 10 February 2020 with a period of performance of 01 March 2020 through 28 February 2025 as a Woman Owned Small Business (WOSB) set aside.

3. DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS.

Authority for this contract is contained in the Rehabilitation Act of 1973, as amended, in Title V, Section 501, which provides for reasonable accommodations for employees with a disability, and in Title V, Section 504, which provides that no individual with a disability shall, solely because of the disability, be excluded from participation in or be denied the benefits of, any Federal program or program receiving Federal financial assistance.

SLIS II provides various modes and sign language interpreting services to those DHH employees at NGA.

Each interpreter on the contract must possess a TS/SCI clearance in order to provide daily on-site services. In addition, this extension provides the necessary time to complete pre-deployment activities for the described in section five. While this trip is approximately 5 months away, it is estimated to take 180 days to complete all necessary pre-deployment activities before the employees can travel. It will take equal time to get an interpreter assigned to the deployment and be cleared for travel. Also, state travel guidelines require some additional training to get read on and filling out all required paperwork.

While this process can usually take 180 days, MAF has turned this time around in closer to 90 days as they are well equipped and experienced in providing these services. A new vendor may not be able to make this timeline before the scheduled deployment occurs in July 2025. The extension will also ensure there is no delay or interruption of interpreting services critical to the NGA DHH employees while NGA continues to conduct acquisition activities necessary for the competition and award of the follow-on contract SLS, including time for transition time between the current contract and the follow-on contract.

B. ESTIMATED VALUE AND PERIOD OF PERFORMANCE OR PROJECTED DELIVERY SCHEDULE.

FAR 13.5 Sole Source Justification exceeding SAT

2 | P a g e FAR 13.5 Sole Source Justification exceeding SAT, v4/0, 09/10/2024

i. ESTIMATED VALUE ($M):

ii. PERIOD OF PERFORMANCE, INCLUDING ALL OPTION PERIODS, OR PROJECTED DELIVERY SCHEDULE:

The period of performance (POP) will be for one (1) three (3) month base period plus one (1) four (4) month option. Total duration will be from 01 March 2025 through 30 September 2025 (7 months).

4. IDENTIFICATION OF THE AUTHORITY PERMITTING ACQUISITION ON A SOLE SOURCE BASIS.

This acquisition is conducted using FAR 13.5 procedures in accordance with the authority of 41 U.S.C. § 1901 for acquisitions exceeding the simplified acquisition threshold but not exceeding $7.5 million for which the contracting officer reasonably expects that offers will include only commercial products or commercial services.

5. DEMONSTRATION OF THE PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR THE NATURE OF

THE REQUIREMENT THAT JUSTIFIES ACQUIRING ON A SOLE SOURCE BASIS.

The type of services being procured under this effort are identical to the original requirement, which was competed as a commercial service. A February 2025 web search resulted in multiple companies offering ASL interpreting services to the public, especially in the medical and education sectors. As a result, this procurement meets the definition of a commercial service as defined in FAR Part 2.101, as these are services of a type offered and sold competitively in substantial quantities in the commercial marketplace

The present Contractor staff has the current skills, experience, and TS/SCI clearance to continue to perform the required functional areas of support throughout all required locations. These attributes provided by the current contractor are essential to NGA’s logistics operations to ensure there are no gaps in mission until the follow-on competitive contract is completed. MAF is uniquely postured to offer continuity of services as they hold the largest share of cleared interpreters in the St. Louis and DMV area.

NGA’s DHH professionals have unique acronyms and specialized lexicon, which has a steep learning curve and takes time for the interpreters and DHH employees to build a working relationship and knowledge of preferred language modes. The current team is also fully experienced with the specialized skill sets such as planning, scheduling and processing deployments for DHH employees. MAF, now in their fifth year of the contract, are SMEs in these areas and no ramp up time is required, however that would not be the case for a new vendor to come on board.

Additionally, a DHH employee is currently scheduled to deploy OCONUS to from July through September 2025. While this trip is approximately 5 months away, it is estimated to take 180 days to complete all necessary pre-deployment activities before the employees can travel. It will take equal time to get an interpreter assigned to the deployment and be cleared for travel. Pre-deployment activities include

. Also, state travel guidelines require some additional training to get read on and filling out all required paperwork. While this process can usually take 180 days, MAF has turned this time around in closer to 90 days as they are well

3 | P a g e FAR 13.5 Sole Source Justification exceeding SAT, v4/0, 09/10/2024 equipped and experienced in providing these services. A new vendor may not be able to make this timeline before the scheduled deployment occurs in July 2025.

A sole source to MAF to extend services will not only allow for transition time to the new vendor once the follow-on contract is awarded but also will satisfy the need for an interpreter traveling OCONUS in July 2025 without impeding on the timelines for pre-travel requirements.

6. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED FROM AS MANY

POTENTIAL SOURCES AS IS PRACTICABLE.

Per FAR 5.2, a Notice of Intent (NOI) was publicly posted to SAM.gov on 18 December 2024, to extend the contract period of the current vendor, MAF Interpreting, Inc.

7. CONTRACTING OFFICER DETERMINATION THAT THE ANTICIPATED PRICE TO THE GOVERNMENT WILL

BE FAIR AND REASONABLE.

The Contract Officer will conduct price analysis by reviewing GSA schedules and current historical rates on the contract to ensure fair and reasonable pricing. Additionally, the CO may compare pricing with other IC agencies to ensure rates of interpreters are in line with those that also possess a TS/SCI clearance. Results thus far indicate that the required services are commercial in nature in accordance with FAR 2.101 and MAF costs were already considered fair and reasonable at time of award. The CO will ensure anticipated pricing is similar or the same to the current rates to include inflation if applicable.

8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE RESULTS OR A STATEMENT OF THE

REASON MARKET RESEARCH WAS NOT CONDUCTED.

Market Research in the form of a NOI to sole source was publicly posted to SAM.gov on 18 December 2024. All responses were analyzed; however, none were determined to sufficiently meet the Government’s needs.

9. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION TO ACQUIRE ON A SOLE SOURCE BASIS.

The current contract included FAR clause 52.217-8, Option to Extend Services during the solicitation.

However, when the contract was awarded the 52.217-8 clause was removed and the option was not evaluated, and therefore is not considered to be available for use.

10. LISTING OF SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST IN THE ACQUISITION.

NGA received a total of 3 responses to the NOI posted to SAM.gov on 18 December 2024. The vendors who responded to the NOI include .

11. STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR OVERCOME ANY

BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION FOR THE SUPPLIES OR SERVICES

REQUIRED.

NGA is actively pursuing the follow-on competition. The anticipated PoP of the extension, specifically the optional periods, were created to minimize the amount of time between this action and the follow-

4 | P a g e FAR 13.5 Sole Source Justification exceeding SAT, v4/0, 09/10/2024 on competitive effort. Due to the unanticipated OCONUS deployment no additional steps are anticipated to be taken than those already identified.