LSC_OIG_RFP_for_QCR_services-_Final.pdf

Request for Proposals For Audit Services

April 9th, 2015

Office of Inspector General Legal Services Corporation

3333 K St, NW Washington, D.C. 20007

Inquiries should be directed to:

Mrs. Magali Khalkho Director of Management Operations mk@oig.lsc.gov mailto:mk@oig.lsc.gov

Table of Contents

I. Background

II. Purpose

III. Statement of Work

A. Scope

B. Project Objective

C. Performance

D. Timeline and Deliverables

Project Management Communication

Individual QCR Reports

Final Summary Report

E. Communication of Findings to the IPA

IV. Submission and Payment of Invoices

V. Option Years

VI. Confidentiality

VII. Instructions to Prospective Offerors

A. Proposal

Technical proposal:

a. Proposed Solution

b. Prior Experience

c. Examples of Prior QCR Work

d. Staff Qualifications

e. Subcontractors

f. Conflicts of Interest

Price Proposal

a. Base Price

b. Option Price

B. Page Limitations

C. Proposal Submission

D. Inquiries

VIII. Evaluation Procedures

Technical proposal:

a. Proposed Solution

b. Prior Experience

c. Example of Prior QCR Work

d. Staff Qualifications

e. Conflicts of Interest

Price Proposal

a. Base Price

b. Option Price

IX. Certifications

Appendix A. Travel Reimbursement Policy

I. BACKGROUND

The Legal Services Corporation (LSC) provides grants to independent legal organizations (grantees) which, in turn, provide free civil legal assistance to those who could not otherwise afford it. Each LSC grantee is required by statute to have an annual audit conducted by an independent public accountant (IPA).

Omnibus Consolidated Rescissions and Appropriations Act of 1996, Pub. L. 104-

134 § 509(a) (1996). The audit is required to be conducted in accordance with auditing standards generally accepted in the United States of America, as well as

Generally Accepted Government Auditing Standards (GAGAS), issued by the

Comptroller General of the United States, and the LSC Audit Guide for

Recipients and Auditors, issued by the Office of Inspector General (OIG). The

LSC Audit Guide incorporates some requirements of the Office of Management and Budget (OMB) Uniform Grant Guidance, Uniform Administrative

Requirements, Cost Principles, and Audit Requirements for Federal Awards

(Uniform Grant Guidance) and/or OMB Circular A-133 (depending on the year of grant issuance). In addition to a financial statement audit, the OIG requires that compliance audits be conducted as prescribed by the Office of Management and

Budget Uniform Grant Guidance, and the LSC Audit Guide for recipients and auditors. As part of an ongoing, multi-year Quality Control Program, the OIG intends to contract for a series of Quality Control Reviews (QCRs) to help ensure the quality and integrity of the IPA process.

As a federally-funded non-profit entity, the LSC OIG qualifies for GSA and non-profit rates. This Request for Proposal is not subject to the Federal Acquisition

Regulation (FAR).

II. PURPOSE

The purpose of this Request for Proposal (RFP) is to solicit proposals for a fixed-price contract for the services of a public accounting firm to assist the OIG by conducting Quality Control Reviews (QCRs) of audit documentation for 15 to 35 grantee audits over a twelve-month period according to an agreed upon schedule.

III. STATEMENT OF WORK

A. Scope

This project requires QCRs of the financial statement and compliance audit documentation for 15 to 35 grantee audits. The identity and locations of the IPAs to be reviewed is available on the IG website at http://www.oig.lsc.gov/aud/IPA%20Listing%202015.pdf

The audit work to be reviewed was required by statute, Pub. L. 104-134

§ 509(a) (1996). It was required to be conducted in accordance with

GAGAS and guidance issued by the OIG, which, in large part, incorporates OMB Uniform Grant Guidance.

The on-site portion of the QCRs will be conducted at the offices of the

IPAs that performed the audit work under review.

B. Project Objective

The 15 to 35 QCRs to be performed under this contract have the following objectives:

1. To determine whether the financial statement audit work, compliance audit work, and the associated review of internal controls over both financial reporting and compliance were conducted in accordance with applicable standards, including GAGAS and the published guidance of the OIG, as well as the American Institute of Certified Public Accountants

(AICPA) professional standards. Because the OIG’s guidance incorporates, in large part, OMB Uniform Grant

Guidance or the OMB Circular A-133 (depending on the year of grant issuance), the QCRs will also determine whether the http://www.oig.lsc.gov/aud/IPA%20Listing%202015.pdf audits met the applicable requirements of the applicable guidance.

2. To identify any issues that may require additional attention or any additional audit work by the IPA under review.

In addition, the Contractor will identify, on the basis of all the QCRs it performs, any common issues that may require the attention of the OIG in its guidance to auditors. This additional objective will be satisfied in a separate, summary report after the 15 to 35 QCRs are completed.

C. Performance

The Contractor will perform 15 to 35 QCRs of audits covering the 2014 fiscal year. The OIG expects all 15 to 35 QCRs to be completed over a twelve-month period according to a specific schedule agreed upon at the time of contracting. The OIG will facilitate the scheduling of site visits by informing each IPA that it has been selected for a QCR. The Contractor will be responsible for making final scheduling arrangements for on-site work at the IPAs and receiving prior approval for travel from the OIG.

Depending on when the grant was awarded, the Contractor may use OMB

Circular A-133 or the Guide for Quality Control Reviews of OMB Uniform

Grant Guidance Audits (the QCR Guide) to conduct the QCR, whichever is applicable to grant award. The guide can be found at https://www.whitehouse.gov/omb/grants_docs. If the contractor uses the guide, all LSC grantees will be considered major, high-risk programs. The

Contractor’s use of the QCR Guide should take into account the audit guidance that the OIG has provided to the IPAs available at http://www.oig.lsc.gov/aud/audguide/agmenu.htm. This guidance includes the Compliance Supplement. The compliance portion of the contemplated

QCRs will consider all regulations identified in the Compliance

Supplement.

https://www.whitehouse.gov/omb/grants_docs http://www.oig.lsc.gov/aud/audguide/agmenu.htm

D. Timeline and Deliverables

Project Management Communication

Throughout the project duration, the contractor shall:

a. Provide preliminary schedules of QCR visits to the

LSC OIG project manager.

b. Provide routine updates of schedule of actual site visits conducted to the OIG project manager.

c. Accommodate questions from LSC OIG regarding

QCRs, requests to review and evaluate corrective actions taken by IPAs to address recommendations in QCR reports, and general consultation with LSC

OIG regarding the results and performance of QCRs.

Individual QCR Reports

The Contractor will transmit within 10 business days of the completion of each on-site review:

a. A report describing the work performed by the

Contractor, stating specific and overall conclusions, findings, and recommendations regarding the quality of the IPA audit work reviewed, and identifying any issues that may require additional attention or additional audit work by the IPA under review; and

b. Copies of all review documentation developed under this contract and any other documentation required to adequately support the conclusions in the QCR report.

Deliverables specified may be submitted earlier than the above schedule. However, if the Contractor does not provide deliverables within the time schedule specified herein, or if the deliverables do not conform to all of the provisions of this contract, the OIG may, by written notice of default to the Contractor, terminate the whole or any part of the contract. When it determines that there is sufficient justification for doing so, the OIG may extend this schedule upon written request of the Contractor.

Final Summary Report

Within 15 business days of the submission of the last QCR report required under this contract, the Contractor will submit a separate summary report. This summary report will identify any common issues that may require the attention of the OIG in future guidance to auditors. This summary report is intended to be a brief report, and need not repeat every finding in the individual QCR reports.

E. Communication of Findings to the IPA

The OIG will review and assess individual QCR reports and review documentation to determine what, if any, conclusions, findings, and recommendations will be communicated to the IPA. Formal communication of conclusions, findings, and recommendations to the IPA will be the sole responsibility of the OIG. In addition, the OIG will be responsible for monitoring any remedial action it requires IPAs to take as a result of QCR reports.

IV. SUBMISSION AND PAYMENT OF INVOICES

The Contractor may submit an invoice to the OIG for payment upon acceptance of Individual QCR Reports and upon acceptance of Final Summary Report. The

OIG will pay invoices on a per report basis. Payments will be made within 30 days of receipt and acceptance of an appropriate invoice for work performed under the contract.

In the event the OIG rejects a report, it will state the reason(s) for the rejection in a written notification. The right to reject any particular report shall extend for thirty

(30) days after the Contractor submits the report in question.

V. OPTION YEARS

The OIG contemplates entering into a contract for the work described in this RFP with one to three option years for performance of QCRs at other, similarly situated IPAs. Each option year, if exercised, will include between 15 to 35

QCRs. The decision to exercise yearly options and the selection of IPAs to be reviewed will be solely within the OIG’s discretion, provided the Contractor does not have a conflict of interest with selected IPAs for the year in question.

VI. CONFIDENTIALITY

The Contractor will keep all information which is obtained or otherwise reviewed as a result of the contract, in the strictest of confidence. The Contractor will acquire no possessory or proprietary interests in such information. All work products under this contract are the property of the OIG. With the exception of an exit conference for IPAs under review, the Contractor will not disclose to anyone outside the OIG any information concerning the work under this contract in any fashion unless prior written approval is obtained from the OIG. The

Contractor will take such reasonable measures as are necessary to restrict access to such information to those employees of the Contractor needing such information to perform the work provided herein, i.e., on a need to know basis.

The Contractor will immediately notify the OIG, in the event that it determines or has reason to suspect a breach of any of these requirements or restrictions, and will provide subsequent written notification as soon as possible.

VII. INSTRUCTIONS TO PROSPECTIVE OFFERORS

A. Proposal

Proposals should be submitted on the most favorable terms, from both technical and price standpoints, that the Offeror can propose. Technical and price proposals shall be submitted as separate volumes not to exceed a total combined technical and price proposals of 10 pages. The QCR work will be performed under a fixed-price contract. Each Offeror shall, at a minimum, include the following in its proposal:

Technical proposal:

a. Proposed Solution

The Offeror shall describe in detail its understanding of the work to be performed, a proposed plan for covering the 15 to 35 IPAs to be reviewed, and its general review plan to be implemented in each review.

b. Prior Experience

The Offeror shall describe its prior experience in comparable review services, including the names, addresses, contact persons, and telephone numbers of current and/or previous clients.

c. Examples of Prior QCR Work

The Offeror shall include with its proposal at least two examples of its work. Reports from QCR work of A-133 Audits are preferred, but reports from similar work will be accepted.

d. Staff Qualifications

The Offeror shall describe the qualifications and relevant experience of staff to be assigned to support the QCR program.

The Offeror shall submit resumes of staff to be assigned, including descriptions of education, position in the firm, years and types of experience, continuing professional education that would satisfy

GAGAS standards over the last two years, and professional certifications. The proposal should demonstrate that the proposed staff has prior experience auditing in accordance with GAGAS for financial and compliance audits as well as prior experience in conducting quality control reviews of audit documentation.

e. Subcontractors

The Offeror must affirm that all work will be performed by the employees of the Offeror unless the Offeror fully discloses its intent to subcontract in advance of the work and the OIG gives advance written approval of any subcontracting arrangement.

f. Conflicts of Interest

Offerors are invited to submit proposals even though they may have up to five conflicts of interest with firms on the list of IPAs posted on the OIG website at http://www.oig.lsc.gov/aud/IPA%20Listing%202015.pdf. Offerors should specify the IPA firms with which they have conflicts. If the

QCR contract is awarded to such an Offeror, the OIG will adjust its list of IPAs to eliminate the conflicts.

Price Proposal

a. Base Price

The Offeror will provide a uniform fixed price per QCR conducted http://www.oig.lsc.gov/aud/IPA%20Listing%202015.pdf as described in this RFP, excluding travel expenses, and a firm fixed price for the final summary report. The OIG intends to have

15 to 35 QCRs performed under the contract exclusive of options, but if for unforeseen reasons that number should change, the OIG will pay on a per-QCR basis for QCRs actually performed. While the OIG intends to enter into a fixed price contract, the Offeror’s price proposal should contain, at a minimum, the estimated number of hours per QCR for planning, field work, and reporting to allow for a full evaluation of the price. The Offeror will also provide number of hours and hourly rates by professional classification. Travel expenses will be paid on a reimbursable basis by the OIG consistent with its policy. See Appendix A.

b. Option Price

The OIG would prefer to enter into a contract with options as described above in Section V. Recognizing, however, that some

Offerors may not be comfortable entering into a contract with three option years, the OIG is willing to consider proposals that include one to three option years. The Offeror shall include with its proposal option prices per QCR for each yearly option.

B. Page Limitations

The combined technical and price proposals (exclusive of appendices) should be no longer than ten (10) pages long. Examples of prior QCR work as described in Section VIII and resumes shall be included in an appendix.

C. Proposal Submission

Each Offeror will submit an electronic copy of their proposal to the OIG. To be considered, the proposal, including certifications, must be received no later than April 27th, 2015. The OIG reserves the right to exclude late proposals from consideration.

All costs incurred in the creation of a proposal are the responsibility of the

Offeror. The OIG reserves the right to reject any and all proposals in response to this RFP. The OIG expects the selection of the successful firm(s) will be made by May 20th, 2015. All Offerors will be informed in writing of the OIG’s choice.

D. Inquiries

Inquiries concerning this RFP should be directed to Magali Khalkho, Director of Management Operations, at mk@oig.lsc.gov. All inquiries and responses will be e-mailed to all prospective Offerors by the OIG.

VIII. EVALUATION PROCEDURES

The Office of Inspector General will use a Best Value source selection to select the most advantageous offer. Evaluation of each proposal will be based on the following criteria, which are not weighted equally:

Technical proposal:

a. Proposed Solution

The OIG will assess the Offeror’s understanding of the work to be performed under the contract, its proposed plan for covering the 15 to 35

IPAs to be reviewed, and its general review plan to be implemented in each review.

b. Prior Experience

The OIG will assess each Offeror’s prior experience conducting quality control reviews of audit documentation for financial and compliance audits, particularly where the audit work was subject to GAGAS. In addition, the

OIG will assess each Offeror’s experience auditing in accordance with mailto:mk@oig.lsc.gov

GAGAS. The OIG will consider past performance as determined through references and other information.

c. Example of Prior QCR Work

The OIG will assess the general quality of reports submitted as Examples of Prior QCR Work and gauge the degree to which similar reports would be an acceptable product of its QCR program.

d. Staff Qualifications

The OIG will evaluate the qualifications of the staff to be assigned to the

QCRs based on education, position in the firm, years and type of experience, continuing professional education, and certifications.

e. Conflicts of Interest

The impact of this adjustment on the QCR program will be factored into the OIG’s evaluation of the Offeror’s proposal.

Price Proposal

a. Base Price

The OIG will assess the uniform fixed price per QCR for which the Offeror proposes to perform the work.

b. Option Price

The OIG will assess the firm, fixed price per QCR that the Offeror proposes for option years to the contract. At a minimum, this assessment will consider value to the OIG, the number of option years proposed, and the impact the option year proposal would have on the OIG’s administration of its program.

IX. CERTIFICATIONS

A. The individual signing certifies that he/she is authorized to contract on behalf of the Contractor and to make these certifications.

B. The individual signing certifies that the prices quoted in this proposal have been arrived at independently, without consultation, communication, or agreement for the purpose of restricting competition.

C. The individual signing certifies that the Contractor is a properly licensed certified public accountant.

D. The individual signing certifies that the firm complies with the GAO requirement of an external quality control review at least once every three years, where applicable.

E. The individual signing certifies that the Contractor, including any individuals to be assigned to the audit, does not have a record of substandard audit work and has not been debarred or suspended from doing work with any Federal, state or local government. (If the Contractor or any individual assigned to the audit has been found in violation of any state or AICPA professional standards, this information must be disclosed.)

F. The individual signing certifies that the Contractor carries professional malpractice insurance.

G. The individual signing certifies that the Contractor is an Equal Opportunity

Employer and does not discriminate in hiring, employment or activities because of race, color, religion, sex, age, national origin, disability, or any other basis prohibited by law.

(Contractor's Firm Name)

(Signature of Contractor's Representative)

(Printed Name and Title of Individual Signing)

Dated this day of , 2015.

APPENDIX A. TRAVEL REIMBURSEMENT POLICY

Contractor Travel Reimbursement Policy

I. Purpose

This policy governs the OIG’s reimbursement of travel costs incurred by OIG contractors.

II. Reimbursable Travel Expenses

When a contract calls for reimbursement of travel expenses, the OIG will reimburse (1) the cost of airplane tickets or other appropriate mode of transportation and (2) the cost of necessary lodging, provided the costs claimed by the contractor are reasonable. In such cases, the OIG will also pay (3) a per diem payment for each traveler as determined below. The OIG will not reimburse other travel costs except as described below.

To be reimbursable, travel expenses must be reasonable and necessary to complete the work contemplated by the contract. The expenses must represent the lowest available rates for accommodations of the sort ordinarily used in the contractor’s field of business. The OIG will not reimburse travel costs when the location of the work to be performed under the contract is within 50 miles of the contractor’s offices and/or the traveler’s place of residence. If personal and business travel are combined, the traveler and/or contractor is responsible for any additional transportation cost; LSC will only reimburse the cost of business travel.

A. Mode of Transportation

Travel is to be completed by means of transportation most beneficial to the OIG and the traveller considering cost, time, and other pertinent factors. Travel by common carrier is presumed to be the most advantageous method of transportation and must be used when reasonably available. The OIG will not pay for first class or business class travel unless it is documented that no other options are available. The OIG will reimburse baggage fees based on the requirements of the carrier. Rental cars expenses must be pre-approved. The OIG will not reimburse for rental car insurance other than that minimally required by law or for expenses arising out of any damage to a rental car. If a personal automobile is used, reimbursement for mileage will be available at the IRS established rate, currently 51 cents per mile. See http://www.irs.gov.

The cost of buses, streetcars, subways and taxicabs incurred in connection with out-of-town travel are reimbursable provided they are reasonable as defined in this policy.

The OIG will not reimburse taxi expenses to and from restaurants. If a personal automobile is reasonably used as transportation to and from an airport or the terminal http://www.irs.gov/ of origin, the OIG will reimburse parking costs. The total reimbursement for mileage to and from that airport or terminal and parking is limited to the cost of the same travel by taxi.

B. Lodging

Lodging expenses are reimbursable when reasonable and incurred in connection with out-of-town travel. While the contractor may not be eligible for GSA rates, the OIG will use those rates as one factor when evaluating the reasonableness of lodging expenses.

Lodging expenses may exceed the GSA rate and still be deemed reasonable.

C. Per Diem

The OIG will reimburse meals at a per diem rate as specified in Chapter 5, Part III.D of

LSC’s Administrative Manual. Per diem rates are available on the GSA website at http://www.gsa.gov/portal/content/101518.

D. Other Allowable Expenses

For purposes of this policy, the term “other allowable expenses” shall refer to baggage fees, reasonable and necessary taxi fees, mileage to and from a principal mode of transportation, airport or terminal parking fees, reasonable internet connectivity at a place of lodging to the extent that other access is not available, and similar items, as limited by other sections of this policy.

E. Non-Reimbursable Expenses

Expenses that will not be reimbursed include the following:

(1) Alcoholic beverages and entertainment;

(2) Laundry, dry cleaning, and pressing;

(3) Travel insurance;

(4) Parking fines;

(5) Charges incurred because of indirect travel for personal reasons;

(6) Gratuities and tips paid to potters, waiters, bellboys, and hotel maids inside the lodging facility;

(7) Nonproductive time related to official travel to and from one’s out-of-town destination;

(8) Any charges, fees, or other associated costs related to the making of reservations or other accommodations for travel; and

(9) Similar expenses.

http://www.gsa.gov/portal/content/101518

III. Authorization of Travel

Excepting emergency situations and expenses qualifying as “other allowable expenses,” the OIG will only pay travel costs that are preapproved. The contractor will submit proposed travel costs using the attached Travel Request Form at least three weeks in advance of travel to the

Administrative Manager1. If the proposed costs are reasonable and consistent with this policy, the Administrative Manager will forward the Travel Request Form to the Project Manager with a recommendation for approval. To the extent he or she agrees with the recommendation, the

Project Manager will sign the Travel Request Form. The Project Manager’s signature indicates approval. Once signed, a copy will be forwarded to the contractor via email by the

Administrative Manager. Other allowable expenses, defined in Section II.D of this policy, need not be submitted for preapproval provided they are reasonable.

When the field work under an OIG contract necessitates changes in preapproved travel plans, the contractor shall inform the Administrative Manager of the changes as soon as possible. If the change occurs before scheduled travel, the contractor shall submit updated approval requests. Emergency travel expenses, defined to include unforeseeable travel costs that arise in the course of business travel, will be reimbursed if they are reasonable and consistent with this policy. In such emergencies, the contractor will submit details of the change and a justification by email to the Administrative Manager at the earliest date possible.

Official travel by independent contractors of the OIG outside the contiguous 48 states of the

United States must be approved in advance by the Inspector General.

IV. Submission and Payment of Travel Expense

The contractor will submit a Travel Expense Report for each instance of travel to the

Administrative Manager with supporting documentation, including receipts for transportation, lodging, and fees associated with Other Reimbursable Expenses. It is recommended that the traveller keep a record of all expenditures to be used in the expense report. The contractor will specify the number of full and partial days of travel for each traveller. All Travel Expense

Reports must be signed and returned within 15 days of the conclusion of the travel.

Travel Expense Reports will be reviewed by the Administrative Manager. Where the OIG determines that the full claim is not adequately supported or reimbursable, it will communicate its determination to the contractor as soon as possible and allow the contractor to provide additional documentation. Any corrected Travel Expense Report must be returned for processing within 10 days.

The Administrative Manager will determine which expenses are allowable (based on the contractor’s submitted Expense Report form and supporting documentation) and indicate his or

Should the needs of a particular contractor dictate that it gives shorter notice; the OIG will be amenable to establishing a shorter deadline on a per-contract basis.

her determination on a copy of the contractor’s reimbursement form. The Project Manager will then review the submission, indicate approval or disapproval by notation and signature, and, if approved, forward the package to the Comptroller of LSC for payment. The OIG has the final authority to determine whether claims are reimbursable under this policy.

V. GSA Rates

The OIG is not entitled to use the GSA rates for airplane tickets where those tickets will be used by contractors or other persons not employed by LSC.

VI. Applicability of LSC’s Travel Policy

To the maximum extent possible, the OIG will interpret consistent with the LSC Travel policy contained in Chapter 5 of LSC’s Administrative Manual. Use of LSC’s travel Policy as an interpretive guide is not, however, intended to establish an employer employee relationship between the OIG and a traveler employed by or working at the direction of a contractor.

Travel Request Form

FROM: (Contractor Name) _____________________________________

(Contractor Address) ____________________________________

PROJECT: _________________________________________________

AUTHORIZING OFFICIAL: _____________________________________

AUTHORIZING SIGNATURE: ___________________________________ DATE: ________________

TRAVELER NAME: ___________________________________________

PURPOSE OF TRAVEL: _____________________________________________________________________

Dates of Travel

Departure City & State

Arrival City & State

Departure Time

Carrier & Flight/Train #

Fare Other Fees

Approval (Initialize)

Total: $ $

Total Fares and Fees: $ _______

Booking Agent: _______________

Fare & Fees Confirmed Through (Date):

Optional

Name and Locations of Hotel No. of Nights Cost Per Night

Total Per Trip $ _______

Rates Confirmed Through (Date):

Optional

Rental Car Company City & State No. of Days Vehicle Type Total Cost

Total: $ _______

Rates Confirmed Through (Date):

Optional

Other Requirements: _______