EPA Translation and Interpretation Services

Limited Source Justification (LSJ) – Bridge

In Accordance with FAR Section 8.4011

General. 8.405-6 and EPA Policy (EPAAP) Subsection 6.3.1

1. Identification of the agency and contracting activity:

Agency: U.S. Environmental Protection Agency (EPA)

Contracting Activity:Office of Mission Support (OMS) Office of Acquisition Solutions (OAS)

Project Identification: Office of Mission Support (OMS), Office of Resources and Business Operations (ORBO)

Contract/Order: GS-10F-0372 / 68HERC22F0512

2. Nature and description of action being approved:

The purpose of this limited source justification is to extend the period of performance and increase the ceiling of the Office of Resources and Business Operations (ORBO) agencywide ordering mechanism under contract GS-10F-0372 task order (TO) number 68HERC22F0512, with Access Interpreting Inc. (Access) for up to an additional three (3) month period, inclusive of a 2-month base extension period, and a one (1) month option. The estimated total value of the cumulative three (3) month extension period is (redacted)  This action is necessary to ensure these agencywide interpreter services (remote and onsite) in compliance with federally mandated statutory responsibilities under Sections 501 and 508 of the Rehabilitation Act of 1973 remain available to EPA employees who are deaf or hard of hearing, so they are equipped to perform their essential job functions, actively participate in training, meetings, and seminars, and fully engage as an EPA employee while the competitive acquisition process is completed for the follow-on task order.

This limited source justification requests an extension of the task order used to provide agencywide interpreter services from the current incumbent contractor from 9/30/2025 through a maximum potential end date of 12/31/2025. The need for a bridge extension under the existing task order is necessary due to unforeseen circumstances that have prolonged the reprocurement process and delayed the subsequent award of the follow-on task order. Initial delays to the reprocurement process were prompted by the unanticipated requirement for the program officials to revisit the performance work statement (PWS) to reassess the follow on requirements to ensure the scope of services being procured and the terminology used were appropriately aligned with the administration’s priorities. In addition to the unforeseen procurement delays attributable to newly implemented compliance processes, the agency received a preaward agency level protest on 6/30/2025 in response to the Request for Quotation (RFQ1761426) issued for the reprocurement on 6/9/2025. Following the agency’s review of the protest allegations and their merit, the agency determined corrective action to be the appropriate course of action and took steps to cancel the RFQ and revise the RFQ attachments to remedy the issues raised in the protest notice. An updated version of the RFQ (RFQ1767101) was issued on 7/14/2025 via GSA’s e-Buy portal which closed on 8/1/2025. The additional time expended by the Government to take conective action in response to the preaward protest was unforeseen and has impacted the award timeline for the reprocurement. The Government also requires post­award transition time for interpreters to complete the agency's onboarding process and receive the security clearances required to gain remote/virtual access to infonnation technology (IT) systems and networks and onsite access to secured agency facilities. The estimated time for the post-award transition period is one (1) to two (2) months. The Government does not anticipate any change to the existing scope during the extension petiod. 

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

The continued interpreter services to be provided under the limited somce justification are as follows: 

• Basic and scientific interpreter services, including Ametican Sign Language (ASL)
• Cued Language Transliterator (CLT)
• Comnunication Access Real-time Translation (CART) captioning for deaf and hard of hearing (D/HH) employees at EPA agencywide events, whether remote or on-site

These services cover various technical subjects, including environmental science, legal matters, enforcement material, infonnation technology, and general professional workplace discussions. This ensures EPA's commitment to maintaining continuity of services for D/HH employees, enabling them to fulfill their professional responsibilities and obligations in a hybrid workforce environment. The task order Performance Work Statement provides the complete scope of services. 
 

Estimated Value o(Extension Period: 
The total estimated value for the increase in ceiling capacity to maintain continuity of agencywide interpreter services for a up to a three (3) month petiod, inclusive of a 2-month base extension petiod, and a one (1) month option period is as follows: 
 

  Base Extension Period: 10/1/2025 - 11/30/2025

  Two- Month Extemion Estimated Value: (redacted)

  Optional Extension Period: 12/1/2025 - 12/31/2025

  One-Month Extension Estimated Value: $(redacted)

Total Estimated Maximum Value Extension Period:$(redacted)

4. The authority and supporting rationale, and, if applicable, a demonstration of the proposed contractor's unique qualifications to provide the required supply or service:

In accordance with FAR 8.405-6(a)(l)(i)(B), [Note: See FAR 538. 7104-3 Sole source justifications (b)(J)(ii) (deviated text)] only one source is capable of providing these unique and highly specialized services at the level of quality required to support the immediate needs of the deaf and hard of hearing employees across the agency. The cunent contractor, Access Interpreting, Inc., has perfonned at a satisfactory level under the existing task order and is familiar with the service requirements to meet the volume and agency need for these critical services. Furthermore, the cunent contractor is readily equipped with staff who are integrated into the agency's IT infrastrncture, possesses the required clearances to access virtual networks and facilities, and is postured to comply with all applicable agency policies and the federal statutes that mandate these services to be made available to the deaf and hard of hearing employees. The interpreting services currently provided by Access are critical to support the functional capabilities of EPA staff who use these services to perform their essential job functions seamlessly across different agency platforms both virtually and in-person. Extending the task order with the current contractor will ensure no interruption in services while the follow-on task order is being reprocured. Disrupting these critical services will result in the agency's non-compliance with the statutory mandates prescribed in Sections 501 and 508 of the Rehabilitation Act of 1973 (29 U.S.C § 794 (d)) which requires EPA to afford disabled employees and member of the public the light to access Federal electronic and information technologies. 

Continuation of services with the cunent contractor is in the best interest of the Government to maintain seamless operations and fulfill statutory obligations to provide interpreting services. Competing a three­month task order plior to the expiration of the cunent task order is not feasible, would prove administratively inefficient, and ultimately increase the risk of statutory non-compliance due to the time it would take another contractor to ramp-up to fulfill the agency's needs. Another contractor would need to become familiar with the scope of services, deploy a compatible IT and scheduling system, onboard personnel, and train agency employees to use the new system. 
 

5. Determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d): Note: See FAR 538.7102-2(d)(2) (deviated text).
 

It is in the agency's best interest to extend the existing task order contract with Access consideling the critical need for continuity of agencywide interpreter services, the satisfactory performance by the current contractor, the time previously expended to resolve the preaward protest, and the time required to complete a competitive procurement process. The contractor's knowledge, experience, established working relationships, integrated access into EPAs IT infrastmcture, active clearances, and proven success make them the only capable source to meet the service requirements at the current levels during the extension period. Additionally, EPA will avoid an unnecessaiy duplication of contract placement efforts and costly start-up costs associated with bringing on a new contractor to include onboarding, training, and operational costs, which are significant in terms of financial and administrative resources. The current contractor, Access, is familiair with the scope and they have the operable systems required to meet the agency's on­demand need without disrupting the currently level of quality and services. 
 

The agency will ensure compliaince witlh applicable agency policies, federal laws and regulations, maintain high-quality service delivery for users of these services, and safeguard against any potential disruption while the competitive procurement process is completed. GSA has detennined the proposed rates for services on the schedule contract under which the existing order was placed against as fair and reasonable. Furthermore, the total value of the current task order GS-10F-0372X/ 68HERC22F0512 was evaluated and deemed fair and reasonable.

The contractor has proposed the same pricing, level of effort and mix of labor offered for the extension thus the total price associated with the extension period for this task order is hereby detennined fair and reasonable.The ceiling increase will be a continuance of the same scope of work cunently provided under the existing Task Order, 68HERC22F0512, at the same pricing offered under Access's GSA Schedule Contract, GS-10F-0372. The task order is currently . The potential three-month extension will increase the value of the task order by (redacted) to (redacted).

6. Description of the market research conducted:

Extensive market research efforts were conducted as a part of the acquisition planning phase of the reprocurement process. A market research analysis was performed based on data gathered using GSA's market research as a service, and a market research report compiled to shape the acquisition strategy for the reprocurement. Consistent with FAR 8.404(d) [Note: See FAR 538.7102-2(d) (deviated text)], this order was originally competitively awarded on October 1, 2022, with a period of perfonnance that consisted of a 12-montli base period, one 12-month option period, and a 6-month option period to extend the services pursuai1t to FAR 52.217-8. A non-competitive 6-month bridge extension was issued via Modification P00012 extending the task order period of performance from 4/1/2025- 9/30/2025. The cunent period of performance is set to expire 9/30/2025. The extension must be executed via task order modification prior to that date to avoid a lapse in service and afford the agency the time necessary to complete the procurement process.

7. Any other facts supporting the justification [EPAAP 6.3.1.5.1):

(i) Rationale

For the duration of the task order, Access Interpreting, Inc., has performed satisfactorily, developed a strong knowledge base, and possesses the expertise and personnel required to meet the volume and agency's need for these critical services. Furthermore, the current contractor is readily equipped and integrated into the agency's network and systems and capable of accessing virtual networks and on-site facilities. Disruption to these critical services will result in the agency's non-compliance with the statutory mandates prescribed in Sections 501 and 508 of the Rehabilitation Act of 1973 (29 U.S.C § 794 (d)) which requires EPA to afford disabled employees and member of the public the right to access Federal electronic and info1mation technologies. Therefore, moving forward with an extension of the existing task order with the cunent contractor will ensure no interuption in services while the follow-on task order is being reprocured. 
 

(ii) Cost

• Consistent with FAR 8.404(d) (Note: See FAR 538.7102-2(d) (deviated text)]], this order was orginally competitively awarded on October 1, 2022, with a task order ceiling of $(redacted) for a period of performance that consisted of a 12-month base period, one 12-month option period, and a 6-month option period to extend the services pmsuant to FAR 52.217-8. 
• Bridge extension issued via modification on 3/25/2025 to extend the task order period of performance for an additioal six(6) months from 4/1/202 - 9/30/2025 which increased the value of the task order by $(redacted) to $(redacted).
• Estimated cost of the current bridge extension is $(redacted) for a maximum of three (3) months
• Total combined cost for the previously executed bridge extension and the requested bridge extension (totaling 9-months) is (redacted) which will increase the task order ceiling to (redacted).

(iii) Period of Performance

• Existing task order period of perfonnance expiration date: 9/30/2025
• CmTent bridge extension period of perfonnance: 10/1/2025- 11/30/2025 (2-month base extension); 12/1/2025 -12/31/2025 (I-month optional extension)
• Previous approved bridge extension petiod ofperfo1mance: 4/1/2025- 9/30/2025

(iv) Follow-on Procurement Status Recap

The agency is in the process of procuring a new task order vehicle via the GSA schedules to provide agencywide interpreting services, which is currently anticipated to be awarded on or around October 2025. The RFQ for the follow-on requirement was issued via GSA e-Buy originally umder RFQ1761426 on 6/9/2025. Following a preaward protest which required the agency to take conective action, the original RFQ was cancelled and an updated RFQ reposted on 7/14/2025. Quote submissions were received by the agency 8/1/2025.

The agency must account for post-award transition time that is required for interpreters to complete the agency's onboarding process and obtain the required security clearances to gain remote/virtual access to information technology (IT) systems/networks, and onsite access to secured facilities. The estimated time for the post award transition period is one (1) to two (2) months which is accounted for in the duration of the bridge extension.

(v) Previous Bridge Copy of one (1) previous bridge extension justification is attached hereto.

8. Actions, if any, the agency may take to remove or overcome any barriers:

In accordance with FAR 8.405-6(a)(2)(ii) [Note: See FAR 538. 7104-3(b)(3) (deviated text)] sole source justifications, within 14 days after issuing the modification to increase the capacity of the task order, a notice of this Limited Sources Justification will be published in accordance with FAR 5.301 and the justification will be posted at the Government Point of Ently (GPE) (https://sam.gov) and on FedConnect (https://www.fedconnect.net), which will provide access to the justification by linking to the GPE, for a minimum of 30 days. Any responses received to the LSJ notice will be recorded and retained as a listing of interested and/or prospective sources to be included in EPA's market research for the future recompete, which will be conducted as a competitive acquisition. 

Further, the agency is presently in the midst of a competitive reprocurement process for the follow-on requirement, quote packages have been received, and award of the follow-on task order is imminent. 

A Notice of Intent to Sole Source GS-10F-0372 / 68HERC22F0512 was published in SAM.gov on September 02, 2025.