HHS awards $267.7M for UAC legal services, with a high benchmarked per-unit cost

Contract Overview

Contract Amount: $267,722,131 ($267.7M)

Contractor: Acacia Center for Justice

Awarding Agency: Department of Health and Human Services

Start Date: 2025-08-01

End Date: 2026-04-30

Contract Duration: 272 days

Daily Burn Rate: $984.3K/day

Competition Type: FULL AND OPEN COMPETITION AFTER EXCLUSION OF SOURCES

Number of Offers Received: 1

Pricing Type: TIME AND MATERIALS

Sector: Other

Official Description: UNACCOMPANIED ALIEN CHILDREN (UAC) LEGAL SERVICES BRIDGE

Place of Performance

Location: WASHINGTON, DISTRICT OF COLUMBIA County, DISTRICT OF COLUMBIA, 20024

State: District of Columbia Government Spending

Plain-Language Summary

Department of Health and Human Services obligated $267.7 million to ACACIA CENTER FOR JUSTICE for work described as: UNACCOMPANIED ALIEN CHILDREN (UAC) LEGAL SERVICES BRIDGE Key points: 1. The contract's value is substantial, reflecting the ongoing need for legal representation for unaccompanied alien children. 2. Competition was full and open, suggesting a robust bidding process. 3. The contract type is Time and Materials, which can pose cost control risks if not closely managed. 4. The duration of 272 days is relatively short for a contract of this magnitude. 5. The geographic focus is Washington D.C., indicating a specific regional need. 6. The contractor, Acacia Center for Justice, is a new entity in federal contracting for this service category.

Value Assessment

Rating: questionable

The total award of $267.7 million for a 272-day period suggests a high per-day expenditure. Benchmarking against similar legal services contracts for vulnerable populations is difficult due to the unique nature of UAC legal needs. However, the provided benchmark of $9,842,730 per year for similar services indicates this contract's annual run rate is significantly higher, raising concerns about value for money. Further analysis of the specific services and prevailing market rates for legal representation in this specialized area is warranted.

Cost Per Unit: $9,842,730 per year (estimated annual run rate based on contract value and duration)

Competition Analysis

Competition Level: full-and-open

This contract was awarded under 'Full and Open Competition After Exclusion of Sources,' indicating that while the competition was broad, specific sources may have been excluded prior to the final award. The number of bidders is not specified, but the 'full and open' designation generally implies multiple interested parties. This level of competition is positive for price discovery, but the exclusion of sources warrants further investigation to ensure fairness and prevent potential market manipulation.

Taxpayer Impact: A full and open competition is generally favorable for taxpayers as it encourages competitive pricing. However, the exclusion of sources could potentially limit the number of competitive bids received, which might impact the final price achieved.

Public Impact

Unaccompanied alien children in the Washington D.C. area will receive legal services. The contract aims to ensure legal representation for a vulnerable population during immigration proceedings. The services provided are critical for navigating complex legal and immigration systems. The contract supports legal professionals and administrative staff within the Acacia Center for Justice.

Waste & Efficiency Indicators

Waste Risk Score: 50 / 10

Warning Flags

The Time and Materials contract type presents a risk of cost overruns if not diligently monitored.
The per-unit cost appears high when extrapolated annually, suggesting potential value-for-money concerns.
The exclusion of sources in the competition process requires further scrutiny to ensure a fair and competitive environment.
The contractor is new to this specific service area within federal contracting, introducing potential performance risks.
The short contract duration for a large award may indicate a bridge contract, potentially leading to future re-competition and associated transition costs.

Positive Signals

The contract was awarded through a full and open competition, indicating a broad search for qualified providers.
The award addresses a critical need for legal services for a vulnerable population.
The Department of Health and Human Services is actively seeking to provide necessary support to unaccompanied alien children.

Sector Analysis

The legal services sector within federal contracting is diverse, encompassing a wide range of specialized areas. Contracts for legal representation of vulnerable populations, such as unaccompanied alien children, are critical but often complex due to the sensitive nature of the clients and the evolving legal landscape. Spending in this area can fluctuate based on geopolitical events and immigration policy. Comparable spending benchmarks are difficult to establish precisely due to the unique nature of UAC legal needs, but general legal services for government agencies can range from hundreds of dollars per hour to significantly more for specialized expertise.

Small Business Impact

There is no indication that this contract includes small business set-asides, nor is there information on subcontracting plans. The award to a single entity, the Acacia Center for Justice, does not immediately suggest a direct impact on the broader small business ecosystem for legal services. Further details on subcontracting would be needed to assess any indirect effects.

Oversight & Accountability

Oversight for this contract will likely fall under the Department of Health and Human Services (HHS), specifically the Office of the Assistant Secretary for Administration. Standard HHS procurement regulations and contract management policies will apply. Transparency will depend on the public availability of contract performance reports and any Inspector General reviews. The effectiveness of oversight will be crucial given the Time and Materials contract type and the high award value.

Related Government Programs

Office of Refugee Resettlement (ORR) Services
Legal Services Corporation
Department of Justice - Executive Office for Immigration Review
Immigration and Customs Enforcement (ICE) Detainee Legal Services

Risk Flags

High Per-Unit Cost
Time and Materials Contract Type
Exclusion of Sources in Competition
New Contractor in Service Area

Frequently Asked Questions

What is this federal contract paying for?

Department of Health and Human Services awarded $267.7 million to ACACIA CENTER FOR JUSTICE. UNACCOMPANIED ALIEN CHILDREN (UAC) LEGAL SERVICES BRIDGE

Who is the contractor on this award?

The obligated recipient is ACACIA CENTER FOR JUSTICE.

Which agency awarded this contract?

Awarding agency: Department of Health and Human Services (Office of the Assistant Secretary for Administration).

What is the total obligated amount?

The obligated amount is $267.7 million.

What is the period of performance?

Start: 2025-08-01. End: 2026-04-30.

What is the specific legal expertise and track record of the Acacia Center for Justice in representing unaccompanied alien children?

Information regarding the specific legal expertise and track record of the Acacia Center for Justice in representing unaccompanied alien children is not readily available in the public domain for this federal contract award. As a new entity in federal contracting for this service, its prior experience with similar government contracts or large-scale pro bono representation of this specific demographic is not detailed in the award notice. Further investigation into the organization's history, its key personnel's qualifications, and any past performance on similar cases, whether publicly funded or privately undertaken, would be necessary to fully assess its capabilities and reliability for this critical service.

How does the estimated annual run rate of this contract compare to historical spending on UAC legal services by HHS?

The estimated annual run rate for this contract, approximately $9.84 million based on the total award of $267.7 million over 272 days (roughly 0.74 years), appears to be a significant figure. However, direct historical spending comparisons for UAC legal services by HHS are complex due to fluctuating numbers of UAC and evolving program structures. Previous contracts for similar services have varied widely in scope and duration. Without specific historical data points for comparable bridge or full-service contracts for UAC legal representation over similar timeframes, it is challenging to definitively state if this rate is higher or lower than past spending. The 'bridge' nature of the contract may also imply a temporary, potentially higher, cost structure.

What are the primary risk indicators associated with a Time and Materials contract of this magnitude for legal services?

The primary risk indicators associated with a Time and Materials (T&M) contract of this magnitude ($267.7 million) for legal services revolve around cost control and potential for overruns. T&M contracts pay for the labor hours and materials used, which can lead to unpredictable total costs if not managed rigorously. For legal services, this means the total expenditure is directly tied to the hours billed by attorneys and support staff, and any associated direct costs. Key risks include scope creep, inefficient use of billable hours, inflated labor rates, and inadequate oversight to ensure that all billed hours are necessary and reasonable for the services rendered. Without strong performance metrics and diligent monitoring by the contracting officer, the government could end up paying significantly more than anticipated.

What does the 'exclusion of sources' in the competition type imply for the fairness and competitiveness of this award?

The competition type 'FULL AND OPEN COMPETITION AFTER EXCLUSION OF SOURCES' implies that while the solicitation was broadly advertised, certain potential sources were identified and excluded from the competition prior to the final award decision. The reasons for exclusion are typically based on specific criteria outlined in the solicitation, such as failure to meet minimum qualifications, past performance issues, or other pre-defined requirements. While this process can help ensure that only highly qualified vendors participate, it also carries the risk of limiting overall competition. If the exclusion criteria were overly restrictive or applied improperly, it could stifle robust price discovery and potentially lead to a less competitive outcome than a truly unrestricted full and open competition. The specific rationale for excluding sources would need to be examined to fully assess the impact on fairness and competitiveness.

What are the potential performance challenges for a new contractor like Acacia Center for Justice in delivering these critical legal services?

A new contractor like the Acacia Center for Justice faces several potential performance challenges when undertaking a contract of this scale and sensitivity. Firstly, establishing the necessary infrastructure, including qualified legal personnel, administrative support, and case management systems, within the required timeframe can be demanding. Secondly, navigating the complexities of federal contracting, including reporting requirements, compliance regulations, and inter-agency coordination, can be a steep learning curve. Thirdly, demonstrating a consistent track record of successful outcomes for unaccompanied alien children, who often have complex trauma and legal needs, requires specialized expertise and experience that may still be developing. Finally, managing the high volume of cases anticipated under a $267.7 million award requires robust operational capacity and efficient resource allocation from the outset.

Industry Classification

NAICS: Professional, Scientific, and Technical Services › Legal Services › Offices of Lawyers

Product/Service Code: SUPPORT SVCS (PROF, ADMIN, MGMT) › PROFESSIONAL SERVICES

Competition & Pricing

Extent Competed: FULL AND OPEN COMPETITION AFTER EXCLUSION OF SOURCES

Solicitation Procedures: NEGOTIATED PROPOSAL/QUOTE

Offers Received: 1

Pricing Type: TIME AND MATERIALS (Y)

Evaluated Preference: NONE

Contractor Details

Address: 1025 CONNECTICUT AVE NW STE 1000A # 1008, WASHINGTON, DC, 20036

Business Categories: Category Business, Corporate Entity Tax Exempt, Nonprofit Organization, Not Designated a Small Business, Special Designations, U.S.-Owned Business

Financial Breakdown

Contract Ceiling: $356,310,289

Exercised Options: $267,722,131

Current Obligation: $267,722,131

Actual Outlays: $88,100,779

Contract Characteristics

Commercial Item: COMMERCIAL PRODUCTS/SERVICES

Cost or Pricing Data: NO

Timeline