LSJ - OnSite Interpreter Support Services for Hurricane Ian (DR4673)

LIMITED SOURCE JUSTIFICATION

This acquisition is justified by the following facts and rationale required under FAR 8.405-6.

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA), Office of External Affairs (OEA) proposes to enter into a call under on a limited source basis for a contractor to provide Spoken Language On-site Interpretation Services for all its components (Disaster Operations, International-Intergovernmental-Congressional and Public Affairs, Private Sector and Resource Management) and all FEMA Operations to include joint efforts with other FEMA Directorates, Programs and Offices, Federal, State, Local, Tribal and Territorial partners, international and domestic organizations, voluntary/ community/faith based, profit/non-profit and private organizations in support of response and recovery operations for Hurricane Ian in Florida (DR4673-FL).

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

FEMA has a requirement on a limited source basis to provide on-site interpreters for the federally supported response and recovery for Hurricane Ian operation in Florida. The assignments will be located within all the 67 counties in Florida with the initial priority given to the following counties: Brevard, Charlotte, Collier, DeSoto, Flagler, Glades, Hardee, Hendry, Highlands, Hillsborough, Lake, Lee Manatee, Monroe, Okeechobee, Orange, Osceola, Palm Beach, Pasco, Pinellas, Polk, Putnam, Sarasota, Seminole, St. Johns and Volusia. On-site interpreters may be required to travel or rotate between sites. Interpreters are required for the following languages: Spanish, Haitian Creole, German, Portuguese, Vietnamese, Italian, Gujarati, Hindi, Mandarin, French, Tagalog, Russian, Hmong, Hebrew, Arabic, Korean, Urdu, and Russian.
FEMA intends to issue a 30-day call order on a sole-source basis to the following contractor for the reasons outlined below.

Proposed Contractor:
JTG, Inc.
11190 Sunrise Valley Drive Suite 301
Reston VA 20191-4375

3) Description of Supplies/Services.

FEMA Region 4 requires on-site interpreters at multiple locations across the state of Florida, while the Joint Field Office (JFO) is in Tampa, Florida. It is expected to establish multiple locations across the state for the intake of disaster assistance applications and teams will visit the affected areas where interpretation might be needed. On-site interpreters must be continuously available in a variety of different schedules, that could range from two (2) hour assignments, eight (8) hour shifts and up to twelve (12) hour shifts.
As a result of Hurricane Ian, the President approved a Disaster Declaration to make FEMA disaster assistance available in the affected communities. FEMA’s Office of Response and Recovery immediately deployed response personnel to assess the damage and initiate intake of registrations from individuals seeking Individual Assistance under the Individual and Household Program. FEMA staff is mostly English-speaking personnel, for which they will rely on the intervention of a spoken language interpreter to serve as conduit in the communication between the survivor with Limited English Proficiency and the FEMA staff filling out the application. This registration intake period is 60 days from the date in which the disaster was declared. Also, FEMA has established Disaster Recovery Centers across the affected communities where the survivors can visit and ask questions regarding the assistance available from FEMA, SBA, USACE, HUD, HHS, and many other federal, state and local partners. In these centers, the staff also requires the assistance of spoken language interpreters to assist in the communication.

Period                      Total
30 days              $3,960,000.00
                   Total $3,960,000.00

(4) Identification of the justification and the rationale.

Cite the authority under one of the three exceptions listed under FAR 8.405-6 (a).

• An urgent and compelling need exists and following the ordering procedures would result in unacceptable delays. See 8-405-6(a)(1)(i)(A)

This acquisition is being conducted under the authority of the Multiple Award Schedule Program in accordance with FAR 8.405-6 Limited sources justification and approval. In accordance with FAR 8.405-6(A)(1), the Agency seeks to restrict competition for this acquisition because an “urgent and compelling need exists and following the procedures would result in unacceptable delays.” The current award was competitively solicited and awarded and is necessary for on-site interpreters for the federally supported response and recovery for Hurricane Ian operation in Florida. However, that award has been protested and is subject to a CICA stay. The Agency seeks to re-solicit and re-award the contract. At this moment, however, FEMA is in day 34 out of 60-day DR4673-FL registration period for federal assistance. Delaying the full deployment of the interpreters to the field will affect the delivery of equal access to the information during the registration, outreach and application follow-up. To completely curtail FEMA’s on-site translation services pending the outcome of the protest would be detrimental to the mission and cause confusion among the assets FEMA has available in the field.

(5) Determination by the ordering activity Contracting Officer that the anticipated order represents the best value consistent with 8.404(d).

The Contracting Officer has determined that (1) the price has already been deemed to be fair and reasonable under the price of the BPA and it accords with the definition of best value under 2.101. Issuing the proposed Call Order to JTG, Inc. to continue this effort represents the best value and will result in the lowest overall cost alternative, considering price and administrative costs, to meet the Government’s needs. JTG, Inc. started the work and the costs associated would be duplicative to utilize a different BPA holder.

(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.

Market Research was conducted in August 2022, and this research remains current, accurate, and relevant. The Agency continues to rely on this prior market research to justify this proposal.

(7) Any other facts supporting the justification.

See No. 4 above.

(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that preclude the agency from meeting the requirements of 8.405-1 and 8.405-2 before any subsequent acquisition for the supplies or services is made.

The Government will utilize section 8.405-2 for the new call order, thereby competing it among the BPA holders. This is a stop gap solution to fulfill mission needs until such competition can be accomplished as prescribed by the FAR. A stop work order was issued October 27, 2022, to JTG, Inc. and therefore FEMA has been unable to provide the interpretation services which greatly affects the 60-day timeline for individuals to obtain Individual Assistance.

(9) Contracting Officer’s Certification.

In accordance with FAR 8.405-6(c)(2)(ix), I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Signed

Rashurn Harrison       Date 11.02.2022
Contracting Officer

(9) Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Signed

Peter Santiago Ocasio                Date 11.02.2022
Technical Representative/COR

APPROVAL:
_________________________________ ___________ Not exceeding $750,000 Date Contracting Officer
_________________________________ ___________Over $750,000 but not exceeding $15million 

Signed

Tyuana Bailey                                 Date 11.03.2022

Component Competition Advocate

Awarded contract 70FA4022A00000012 to unknown vendor for unknown amount on 2022-11-04.