R--Sign Language Interpreting Services

LIMITED-SOURCES JUSTIFICATION FOR FEDERAL SUPPLY SCHEDULE PROGRAM Upon the basis of the following justification, prepared in accordance with Federal Acquisition Regulation (FAR) 8.405-6(c), I, as Contracting Officer, hereby approve the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3 pursuant to the authority of 41 U.S.C. 251 as implemented by (See Section 4 below, FAR 8.405-6 (a)(1)(i)(B)). 1. Identification of the agency and the contracting activity. United States Environmental Protection Agency (U.S. EPA) Office of Mission Support (OMS) Office of Acquisition Solutions (OAS) Cincinnati Acquisition Division (CAD) 2. Nature and/or description of the action being approved. In accordance with FAR 8.405-6(a)(1)(i)(B), Access Interpreting Services (Access) has been determined as the only responsible source capable of responding that can satisfy agency requirements under GSA Blanket Purchase Agreement (BPA), 68HE0H18A0005, which due to increased usage will run out of capacity on June 30, 2022. The proposed action would increase the current BPA ceiling by approximately $500,000 from $5,000,000 to $5,500,000 and would allow the BPA period of performance to continue through September 30, 2022, as originally planned. 3. A complete description of the supplies and/or services required to meet the agency's needs. Under the current BPA, Access provides Basic and Scientific Interpreting Services, Computer Access Real-time Translation (CART) remote and on-site services, as well as Video Remote Interpreting Services to Deaf and Hard of Hearing EPA employees. The BPA will reach it's ceiling by June 30, 2022. Additional capacity is required to allow for services to continue through September 30, 2022. This capacity increase is necessary because of the increase in remote service requests due to the COVID-19 Global Pandemic and the hybrid work environment. 4. An identification of the LSJ rationale, and if applicable, a demonstration of the contractor's unique qualifications to provide the required supply or service. - FAR 8.405-6 (a)(1)(i) (B) - Only one source is capable of responding due to the unique or specialized nature of the work. Access is in a unique position as the only responsible contractor that would be able to provide uninterrupted services to affected employees. Any other firm would need to heavily consult Access and spend an excessive amount of time and resources establishing a scheduling system to initiate interpreting services for Deaf and Hard-of-Hearing employees. In addition, a firm would need to establish resources and/or service providers nationwide that have expertise in interpreting scientific and in some cases highly technical sensitive material. Another contractor having to establish a scheduling system and a network of interpreters would likely lead to increases in cost and unacceptable delays for those employees that must have services. 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 requested a price proposal from Access for the time period, July 1 - September 30. The price proposal utilized the current rates established for the only active call order while considering the average burn rate for services. The Independent Government Estimate was within 10% of the contractor's proposal. The order represents best value. 6. A description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted. A statement must be made that the supplies and services are available from the FSS. Market research was conducted when the BPA was initially competed. Several of the techniques of FAR 10.002(b)(2) were utilized, such as review of historical acquisitions agency wide and a review of available GSA contractors. In addition, market research was conducted for this ceiling increase by reviewing rates established for this BPA and for similar services on GSA. 7. Any other facts supporting the limited source justification. N/A 8. A statement of the actions, if any, the agency will take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for supplies and services is made. Limiting competition for a capacity increase is unique to this BPA due to the COVID-19 global pandemic. The current BPA was established with a base year and four option years. The BPA has experienced capacity issues due to the COVID-19 global pandemic and the 100% telework environment. For example, the entire capacity from Option Period 4 had to be utilized for Option Periods 3 and 2. The Government is currently in the acquisition planning phase of a re-compete acquisition. The acquisition planning team is building flexibilities into the recompete to anticipate the increase in interpreting services due to the hybrid work environment. 9. The ordering activity Contracting Officer's certification that the justification is accurate and complete to the best of the Contracting Officer's knowledge and belief and evidence that the supporting data that form a basis for the justification have been certified as complete and accurate by technical/program personnel.