Legal Services for Unaccompanied Alien Children (UAC)

Solicitation / RFP / RFQ

This document is a combined synopsis/solicitation (RFP) for comprehensive legal services for Unaccompanied Alien Children (UAC) in the care of the Office of Refugee Resettlement (ORR). The services are required to support the legal needs of this vulnerable population in accordance with federal mandates. This announcement is the only solicitation, and offers are being requested.

• Provision of legal services to UAC nationwide.

• Services include legal representation, immigration court appearances, USCIS proceedings, and other related legal support.

• Emphasis on multilingual services (Spanish, Haitian Creole, Mayan indigenous languages, French).

• Development and maintenance of a data system for reporting and program oversight.

• Incorporation of pro bono representation and scalability to handle fluctuating referrals.

• Contract Type: Hybrid (Firm Fixed-Unit Price and Time & Materials).

• Period of Performance: One-year base period plus four one-year option periods, totaling up to five years.

• Estimated Value: Not explicitly stated, but CLINs detail significant ceiling amounts for each period and service type.

• Proposal Submission Deadline: December 8th, 2025, at 2:00 PM Eastern Time (or December 16th, 2025, at 2:00 PM Eastern Time as per the last sentence of L.3).

• Questions Due Date: December 1st, 2025, at 2:00 PM Eastern Time.

• Proposals to be submitted electronically in three volumes: Technical, Past Performance, and Business.

• Evaluation Factors (descending order of importance): Scalability and Pro Bono Integration Capabilities, Technical Approach, Recent and Relevant Past Performance, and Price.

• Award will be made based on the best overall value to the Government using a tradeoff process.

• Full and open competition.

• NAICS Code: 541110 - Office of Lawyers.

• Small Business Size Standard: $15.5 million.

• The solicitation incorporates FAR 12 and 15 procedures.

• Full text of incorporated provisions and clauses are available at www.acquisition.gov and https://www.acquisition.gov/hhsar.

• Several attachments are referenced, including a Performance Work Statement (PWS) and Pricing Worksheets.

Form / Attachment / Pricing Sheet

This document is a pricing worksheet for Unaccompanied Alien Children (UAC) Legal Services. It provides detailed pricing information for various legal services across the base year, option years, and a FAR 52.217-8 extension period.

• Instructions: Details on how offerors should populate the worksheet, including requirements for fully burdened pricing, estimated quantities, service descriptions, and the distinction between Full Price and Pro Bono Price levels.
• Service Descriptions: A comprehensive list of legal services (e.g., Know Your Rights, Legal Consultation, SIJS, Asylum, T Visa, U Visa, VAWA, TPS, Naturalization, Adjustment of Status, Change of Venue, Court Preparation, Non-Immigration Related Representation, Appeals/Motions, Immigration Court/DHS Appearance, Other Legal Services) with their respective billable elements and proof of delivery requirements.
• Pricing Sheets (Base Year through Option Period 4, and FAR 52.217-8 Extension): Each sheet outlines estimated quantities, units of issue, and pricing for each legal service. It also details "Other Legal Services" as Time and Materials with Not-to-Exceed (NTE) amounts and specific labor categories (Junior, Entry/Mid-grade, Senior Legal Service Providers).
• Summary Data: Provides a procurement overview including contract type (Hybrid: FFUP, FFP, T&M), period of performance, and subtotals for each year and the total procurement value. It notes that Full Rate and Pro Bono totals exclude certain categories like Legal Orientation, Legal Screening, Other Legal Services, Network Management, Data Collection, and Travel.

This worksheet is crucial for potential bidders to understand the cost structure and expected pricing for providing legal services to UACs. It details the specific services required, estimated volumes, and the pricing methodology, including considerations for pro bono services. Bidders must use this template to formulate their pricing proposals, ensuring all costs are accurately reflected according to the instructions and PWS requirements.

Questions & Answers / Clarifications

This document provides responses to vendor questions regarding Solicitation 75P00126R00003 for Legal Services for Unaccompanied Alien Children (UAC). It clarifies various aspects of the solicitation, including contract type, pricing, service delivery, and proposal submission requirements.

• Submission Deadline: The submission deadline has been extended by one week to allow for consideration of the answers provided.
• Contract Type: The government will not consider a T&M type of contract for legal representation services. Firm-fixed-price contracts are preferred, with specific pricing structures outlined in Attachment B.
• Pricing and Payment: Progress payments will not be part of the contract. Payments are based on completed services as stated in the pricing worksheet. Travel costs are at cost and do not include indirect rates or profit.
• Pro Bono Services: The "Pro Bono Discount Calculator" is a tool for offerors and not a separate evaluation factor. The pro bono award is calculated as a percentage of the total annual direct service cost, with the successful offeror's proposed percentage incorporated into the awarded contract.
• Service Delivery: Legal orientations and consultations are to be provided to all UAC in ORR custody. The contractor must provide court room assistance to all UAC while they remain in ORR custody. Specific details on billing for various legal services, including immigration court appearances and state juvenile court proceedings, are clarified.
• Proposal Submission: Offerors may submit proposals in multiple emails if files are too large, provided they are labeled correctly. The file size limitation per email is 100MB.
• Transition Plan: The transition-out plan is not due with the proposal but 30 days after transitioning in. Offerors must provide a transition-in plan detailing how they will assume active cases from the current contractor.

These clarifications address vendor inquiries, refine understanding of contract requirements, and may influence proposal preparation and pricing strategies. The document also confirms updates to attachments and specific sections of the solicitation.

Form / Attachment / Pricing Sheet

This document, "Attachment J - Selected Controls (Low) (Amd 0003).xlsx", is an Excel spreadsheet serving as an attachment to a solicitation, specifically related to Amendment 0003. It details "Selected Controls (Low)", which are likely security or technical control requirements applicable to the opportunity. The spreadsheet provides specific information that bidders must address or comply with in their proposals.

• The document is an Excel spreadsheet (.xlsx) titled "Selected Controls (Low)".
• It includes instructions on how to interpret the data, with specific formatting conventions noted (e.g., bold for replacements, yellow for FedRAMP required, orange for guidance).
• It lists security controls categorized by Family (e.g., Access Control, Awareness and Training, Audit and Accountability), Control Number, Control Name, and Control Description.
• Supplemental Guidance, Security Control Type, Control Status (e.g., "In Place", "Not in Place", "Planned"), and Control Implementation Statements are provided for each control.
• Categories of controls may include "Common", "System Specific", "Inherited ACF", "Inherited HHS", "Inherited CSP", and "Hybrid".

This attachment is critical for bidders to understand the specific security and compliance requirements of the solicitation. It directly impacts proposal preparation, technical approach, and potentially pricing. Bidders must carefully review these controls to ensure their proposed solution meets all specified requirements and to accurately document their compliance or planned implementation. As it is part of an amendment, it may modify or add to previously stated requirements, making it essential for understanding the current scope of work and compliance obligations.

Statement of Work (SOW) / Performance Work Statement (PWS)

This Performance Work Statement (PWS) details the requirements for providing comprehensive legal services to Unaccompanied Alien Children (UAC) who are currently in, or have been released from, the care of the Office of Refugee Resettlement (ORR). These services are crucial for addressing the legal needs of this vulnerable population in accordance with federal mandates.

The contractor will provide legal services encompassing four primary components:

• Legal Orientations: Informing UAC of their rights and responsibilities within the U.S. immigration system.
• Legal Consultations: Assessing UAC's eligibility for immigration relief through one-on-one consultations.
• Direct Legal Representation: Providing legal representation as required by law and subject to ORR's discretion and appropriations. This includes a mandate for a percentage of services to be provided by pro bono counsel.
• Data Collection, Analysis, and Reporting: Maintaining a robust system for data collection, analysis, and reporting to support program oversight and improvement, with data made available through dashboards and APIs.

Services are required nationwide, including ORR shelter locations, provider network facilities, out-of-network facilities, Emergency Intake Facilities (EIFs), Long-Term Foster Care (LTFC) facilities, Unaccompanied Refugee Minors (URM) program locations, and throughout the United States including sponsor residences.

• Universal Representation Model: Representation will not be denied based on the perceived likelihood of success.
• Culturally Competent and Trauma-Informed Care: Services must be attuned to the varied and individual needs of UAC, delivered in their language and in a developmentally appropriate, trauma-informed, and culturally appropriate manner.
• Service Capacity: The contractor must offer legal orientations and screenings to 100% of UAC in ORR care and direct legal representation as required by law.
• Scalability: Services must be scalable to accommodate fluctuations in UAC numbers.
• Personnel Qualifications: Staff must have requisite training and experience, be licensed attorneys or DOJ accredited representatives, and meet background investigation requirements.
• Interpretation and Translation: Services must be available in multiple languages, especially Spanish and English.
• Attorney Ethics Conflicts Management: A policy must be in place to resolve conflicts of interest.
• Security Requirements: Includes background investigations, compliance with federal regulations, and adherence to information security standards.
• Records Management: Strict protocols for handling, storing, and disposing of federal records.
• Pro Bono Network: Establishment and maintenance of a network of qualified volunteer pro bono attorneys.
• Data Rights: Government ownership of all data and deliverables produced under the contract.
• Transition Plans: Requirements for both transition-in and transition-out plans to ensure continuity of services.

Form / Attachment / Pricing Sheet

This document, "Attachment E- ORR Facilities By State," provides a breakdown of the number of Office of Refugee Resettlement (ORR) facilities by state. This information is relevant for understanding the geographical distribution of facilities related to the "Legal Services for Unaccompanied Alien Children (UAC)" opportunity.

• A table listing states and the corresponding quantity of ORR facilities in each state.
• The data includes states such as Texas (45 facilities), California (32 facilities), New York (30 facilities), Michigan (18 facilities), and Illinois (15 facilities), among others.

This attachment helps potential bidders understand the scale and geographical scope of the opportunity. It may inform decisions regarding resource allocation, logistical planning, and understanding the potential demand for services across different regions.

Form / Attachment / Pricing Sheet

This document, "Attachment F - Quality Assurance Surveillance Plan (QASP) [Rev1](Amd 0003)(12.09.2025)", outlines the Government's systematic method for evaluating contractor performance on a stated contract. It details what will be monitored, how monitoring will occur, who is responsible, and how results will be documented. It is intended to inform the contractor's quality management.

• Purpose: To evaluate contractor performance and ensure compliance with contract terms.
• Roles & Responsibilities: Defines roles for the Contracting Officer (CO), Contracting Officer's Representative (COR), Program/Project Manager (PM), and other government personnel in overseeing and coordinating surveillance activities.
• Surveillance Matrix: Guides surveillance activities linked to the Performance Work Statement (PWS) and managed via an Excel spreadsheet.
• Continuous Assessment: Outlines a rating system (Exceptional, Very Good, Satisfactory, Marginal, Unsatisfactory) aligned with CPARS for assessing performance.
• Performance Standards: References PWS Section 12 for performance standards and acceptable quality levels (AQLs).
• Surveillance Methods & Frequency: Details methods like risk management, sampling, and periodic surveillance, with frequency determined by the COR based on assessed risk.
• Documenting Performance: Explains that performance will be documented and may support non-conformance reporting or government remedies.
• Mandatory/Regulatory Compliance: States the contractor will be monitored for compliance with items like combating trafficking in persons, EEO, and wage determinations.
• Appendix A: Non-Conformance Reporting: Defines terms like Corrective Action Request (CAR) and Non-Conformance, and outlines the CAR process, contractor response requirements, verification, validation, escalation, and closing procedures.
• Attachment 1: Provides the format for a Corrective Action Request.

This QASP is crucial for bidders to understand how their performance will be monitored and evaluated if awarded the contract. It highlights the importance of meeting contractual requirements, adhering to performance standards, and the process for addressing any deficiencies through Corrective Action Requests (CARs). Bidders should review the performance standards, acceptable quality levels, and the CAR process to ensure their quality management plans align with government expectations.

Form / Attachment / Pricing Sheet

This document, "ACF External System Control Implementation Policy and Procedures," outlines the requirements for external systems that connect to, interface with, or provide services to the Administration for Children and Families (ACF) systems. It establishes baseline security controls to ensure a consistent security posture and risk management across the enterprise.

• Policy Statement: Mandates ACF baseline security controls for all external systems.
• Authority: Cites relevant legislation and policies including FISMA, NIST SP 800-53 Rev. 5, and OMB Memoranda.
• Scope: Applies to various external systems such as cloud service providers, contractor-operated systems, and partner agency systems.
• Compliance and Enforcement: Details consequences of non-compliance, including connection termination, and outlines regular audits and escalation procedures.
• Roles and Responsibilities: Defines roles like ACF ISSO/SSPO, A&A Team, External System Owner, Contracting Officer (COR), and Authorizing Official (AO) and their respective responsibilities.
• Requirements: Specifies the need for an approved Authority to Operate (ATO) memo (within 3 years), documented data handling procedures, and specific controls for Cloud Service Providers (e.g., access controls, monthly reviews, least privilege).
• Access Control-20 (AC-20): Requires external systems to implement ACF's system baseline controls, provide documented evidence (SSPs, SARs, POA&Ms), and undergo independent security control assessments.
• Protecting Controlled Unclassified Information: External system providers must establish security programs, demonstrate executive commitment, and provide regular compliance reporting.
• Appendix: Lists relevant standards and guidelines (NIST SPs, CISA Framework, HHS Policy) and references an Interagency Agreement.

This document is crucial for any bidder whose system will connect to or interact with ACF systems. It details the mandatory security controls, documentation requirements (ATO, SSPs, SARs), assessment processes, and compliance obligations that must be met. Understanding these requirements is essential for successful proposal development and contract execution, particularly concerning data security and system authorization.

Form / Attachment / Pricing Sheet

This document, "Attachment I - Selected Controls (Moderate) (Amd 0003).xlsx", is an Excel spreadsheet provided as an attachment to a solicitation. It details specific security controls, categorized as 'Moderate', and has been updated by Amendment 0003. Bidders must use this document to understand the security requirements applicable to the opportunity.

• Instructions Tab: Provides guidance on using the "Security Controls" tab, noting system-specific columns (I and M) and static columns. Formatting conventions include bold/bracketed placeholders, yellow for FedRAMP required controls, and orange for guidance.
• Moderate Control Catalog Tab: Lists security control families (e.g., Access Control, Audit and Accountability) with classes, control numbers, names, descriptions, supplemental guidance, and implementation statements. It details specific requirements and ACF-defined parameters.
• Control Categories: Includes 'Common', 'System Specific', and 'Inherited' controls (ACF, HHS, CSP).
• Status Indicators: Lists statuses such as 'In Place', 'Not in Place', 'Partially in Place', 'Planned', and 'Not applicable'.

This attachment is critical for bidders to assess their capability to meet the moderate security control requirements. It directly informs proposal preparation, including security plans, compliance strategies, technical approaches, staffing, and cost estimations. Understanding these controls and their implementation status is essential for a compliant and competitive bid, especially considering the updates from Amendment 0003.

Form / Attachment / Pricing Sheet

This document is Standard Form 1449, "SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES." It is a standard government form used for soliciting bids, awarding contracts, and placing orders for commercial items.

• Blocks for solicitation number, offer due date, contract number, and other key identifying information.
• Sections for detailing the schedule of supplies/services, including item number, description, quantity, unit price, and amount.
• Fields for contractor and government representative signatures, dates, and contact information.
• Sections for accounting and appropriation data, and total award amount.

Bidders will need to complete specific blocks on this form (e.g., Blocks 12, 17, 23, 24, and 30) when submitting their offer. It serves as the primary document for the solicitation and potential contract award. Understanding the fields and requirements of SF 1449 is crucial for preparing a compliant and accurate proposal.