Final_Draft_6-22-2018_-_Task_Order_PWS_-_Investigation_Augmentation_Project_(004).pdf

ATTACHMENT II: TASK ORDER NUMBER 1 - PERFORMANCE WORK STATEMENT (PWS)

SUPPLEMENTAL NUTRITION ASSISTANCE

PROGRAM

TASK ORDER 1

Investigation Augmentation Project

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INVESTIGATION AUGMENTATION PROJECT

PERFORMANCE WORK STATEMENT

1.0 INTRODUCTION

The United States Department of Agriculture (USDA), Food and Nutrition Service (FNS), Retailer Operations Division (ROD) seeks a qualified contractor to enhance the Supplemental Nutrition Assistance Program (SNAP) in the area of retailer investigations. It is seeking personnel and advanced methods to:

1) Investigate retailers whose stores have been identified and reviewed by FNS and are suspected to be committing SNAP fraud by performing undercover work and posing as SNAP recipients.

2) Identify new methods of investigating possible fraudulent retailers.

3) Determine what other stores in the neighborhood could be committing fraud.

ROD is seeking to enhance Program Integrity by reducing the number of fraudulent retailers and increasing the awareness of zero tolerance toward fraud within the retailer communities.

2.0. BACKGROUND

FNS administers the nutrition assistance programs of the USDA. The mission of FNS is to provide children and needy families’ better access to food and a healthier diet through its food assistance programs and comprehensive nutrition education efforts. In addition to providing access to nutritious food, FNS also works to empower program participants with knowledge of the link between diet and health.

FNS was established on August 8, 1969, but many of the food programs originated long before FNS existed as a separate agency. The Supplemental Nutrition Assistance Program (SNAP), which is the cornerstone of USDA's nutrition assistance programs, began in its modern form in 1961; but it had its origins in the Food Stamp Plan to help the needy in the 1930's. The benefits were first issued in the form of stamps.

When the program was reconstituted in 1961, the benefits were issued in the form of a “Food Stamp Program” coupon. Over time, coupons were replaced by Electronic Benefits Transfer (EBT), which was built on the same technology utilized by commercial debit cards. As of October 1, 2008, the Food Stamp Program’s name was changed to the SNAP. In June 2009, paper coupons were de-obligated, and EBT became the sole method of SNAP benefit issuance.

FNS works closely with the States in the administration of the SNAP; this is most salient on the recipient side. States determine most administrative details regarding distribution of food benefits and eligibility of participants while FNS provides funding to cover most of the States' administrative costs. On the retailer side, FNS’s ROD manages the retailer application and reauthorization process, and reviews, prioritizes and investigates all stores which appear to be violating SNAP retailer regulations.

USDA’s Office of Inspector General (OIG) has the responsibility for all investigative activities within the department. The OIG, through a Memorandum of Understanding, has given FNS, ROD the authority to conduct investigations and take administrative action. In ROD, the Retailer Investigative Branch (RIB) performs the undercover investigations.

FNS’s Retailer Management Centers (RMC) are responsible for the authorization and compliance of retailers participating in the program. Firms that are authorized to participate in the program

Investigation Augmentation Project Page 3 of 16 are investigated to determine whether or not they comply with the program regulations. Retailers that are found to be non-compliant are subject to ROD taking Administrative action, which can be in the form of warnings, disqualifications, and other sanctions. The OIG, often with ROD’s assistance, conducts criminal and civil investigations that may lead to arrests, prosecution, and convictions of violators of this program.

3.0. SCOPE OF WORK

FNS must ensure that all store owners obey the program’s rules and regulations and that those who do not are (at a minimum) removed from the program. FNS has implemented systems for identifying firms that pose a risk to the program’s integrity. Retailers found violating the program may be disqualified from the program, assessed civil money penalties, or fined. Serious violations can result in the prosecution, either civil or criminal, of store owners and employees at the Federal, State, or local levels.

Due to the insufficient amount of investigators, there is a desire to acquire additional resources to assist the current team of federal investigators. These extra resources are needed to be employed to effectively and efficiently help reduce and deter this criminal activity. ROD is seeking assistance from investigative service suppliers to provide Contracted Undercover Investigators (CUI) who will be able to act as undercover SNAP recipients and conduct surveillance of retailers and others who are suspected of attempting to defraud the SNAP Program.

3.1. Place of Performance

It is anticipated that the majority of work involved in the execution of the assignments referenced in this task order will be performed at investigation sites within the Northeast and Southeast areas of the U.S. and will yield approximately 150 investigations in each area. The investigator will drive to a safe location immediately after the store visit to document those observations regarding the store visit in the automated system designated by FNS and secure items purchased. All work spaces and office equipment will be provided by the Contractor. Depending on the Contractor’s proposal, some Contractor staff may be required to travel for training or to complete assignments, such as to participate in meetings between the Contractor and FNS.

3.2. Staffing

Day-to-day management, direction and oversight of this Task Order will be handled by the FNS - ROD’s Point of Contact (POC). The Contractor must provide investigation experts and manage the performance of the work described in this solicitation, as assigned by the COR. The COR is responsible for FNS project leadership and coordination with other operational branches and divisions within FNS. ROD’s POC will act as Project Manager (PM) and will be responsible for the review and acceptance of deliverables and day-to-day direction and prioritization of work.

The Contractor must work with the COR and the ROD PM to meet all responsibilities prescribed in this solicitation within the allotted schedule. The Contractor must notify the COR and the ROD PM well in advance of anticipated schedule delay and identify both the reasons for the delay and remediation efforts to prevent future occurrences.

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The Contractor must provide an experienced Project Manager (PM) as part of their key personnel.

Additional key personnel must be identified within the bid proposal. Qualifications will depend upon the staffing proposal submitted by the Contractor. The proposal must include: justification for the position, resume, and a signed and dated letter of commitment by key personnel. Examples of necessary staffing may include supervisors, training specialists, etc. Bidders must include labor and cost estimates for each proposed staffing position. Any staffing changes following contract award must be reported to and approved by the CO and COR prior to adding or removing personnel from the project.

The PM’s responsibilities for this solicitation include, but are not limited to:

• Directing, coordinating, and exercising supervisory authority for planning, organizing, controlling, integrating, and completing assignments.

• Preparing status reports.

• Serving as liaison with FNS.

• Determining work schedules, setting priorities, and implementing procedures for performing assignments.

• Directing and monitoring work results for meeting customer requirements, specifications and quality assurance standards.

The preferred qualifications for the PM include meeting all of the following:

• Bachelor’s Degree with at least 5 years of investigative experience (i.e., government/private investigative work).

• Knowledge of SNAP requirements, policies, and procedures.

4.0 APPLICABLE DIRECTIVES

Federal Regulations at CFR 278.1: Approval of retail food stores and wholesale food: Includes a description of stores for eligibility and details on owner and store documentation requirements, the use of information provided on the applications by, among others, entities contracted by FNS.

There is specific language limiting the use of owner SSNs and business EINs to the federal government. The regulations specify that a permanently disqualified store owner may not be reauthorized or otherwise seek ways to circumvent the penalty.

Federal Regulation at CFR 278.6: Disqualification of retail food stores and wholesale food concerns, and the imposition of civil money penalties instead of disqualifications: Lays out the terms and procedures for administrative sanctions and disqualifications.

Federal Regulation at CFR 274.1: Issuance system approval standards: Provides basic description and requirements on State agencies to establish Electronic Benefits Transfer systems of issuance.

Federal Regulation at CFR 274.8: Functional and technical EBT system requirements: Provides detailed information on the performance and security of State agency EBT processor systems.

The Code of Federal Regulations can be searched at https://www.archives.gov/federal-register/cfr.

https://www.archives.gov/federal-register/cfr

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5.0 CONTRACT TASKS AND REQUIREMENTS

The following tasks and deliverables are intended to provide a clear approach to effectively and efficiently meet the requirements of this contract. The tasks below are described within each contract line item number (CLIN).

The Contractor shall:

• Conduct Investigations in the manner set forth herein

• Report results of all investigations in the specified time to ROD Management

• Properly retain, dispose, and record the disposition of all evidence obtained during the course of all investigations

• Ensure data integrity is maintained in using FNS systems and information is protected

• Submit deliverables in accordance with PWS

• Achieve performance measures in accordance with PWS

• Assign qualified staff to conduct investigations

• Provide the necessary training to the staff.

5.1. CLIN 1: Project Management and Reporting

The Contractor must provide a PM to carry out the responsibilities listed under section 3.2. The PM will serve as liaison with the COR and ROD management, and contracting staff. The PM will provide day-to-day supervision for project staff, manage project planning and communications, track project resources and budget, ensure timely and accurate completion of project deliverables, identify and coordinate mitigation of project risks, and complete the following management and reporting tasks.

The Contractor must:

5.1.1.) Within 15 calendar days of issuance of the Task Order, the Contracting Officer must organize a meeting with ROD management, COR, and Contractor to kick-off the project.

The Contractor must review all pertinent documentation, including SNAP’s regulations and policies. See Section 4.0, Applicable Directives, for information on where to access this information. At least two key staff members of the Contractor who will be working on the project must attend this kick-off meeting. The meeting location will be held at the Contractor’s choice of location with prior FNS approval.

5.1.2.) Within 15 calendar days of the project startup meeting, provide a project management plan describing the technical approach, organizational resources, and management controls to be employed to meet the cost, performance, and schedule requirements throughout execution of all assignments. The plan must show any interdependencies between related assignments and their completion.

5.1.3.) By the 15th of each month during the contract period, provide a written project status report for the previous calendar month that includes: information on total expenditures by staff person by reporting period (broken down between labor, travel, and other direct

Investigation Augmentation Project Page 6 of 16 costs); the status of each detailed assignment and deliverable in progress; any identified project issues and risks; and next steps in carrying out the project assignments. The Contractor must provide an update on the project management plan activities with the monthly status report each month.

5.1.4.) Within 5 operating days of the written project status report being submitted, present monthly oral briefings to the COR and ROD PM to review the monthly project report and current status of the work. These briefings will be conducted routinely by telephone call unless otherwise directed.

5.1.5.) No later than 60 calendar days following the end of this Task Order (base period and any option period), submit a project management status report to detail accomplishments and final financial data for the specific task period. The final project management report will be due within 60 days following expiration of the final contract period.

5.1.6.) Manage day-to-day project activities, timelines, deliverables, and provide Contractor staff supervision.

5.2. CLIN 2: Defining Investigators and Requirements

The Contractor must implement their proposed methodology for hiring/vetting individuals to perform the investigations. The Contractor’s proposal must include an assessment methodology to accurately identify personnel that may be appropriate to perform the investigations.

5.2.1.) All personnel selected for this first task must be approved by FNS during the negotiation.

Additional staff (if needed may be approved after the contract signing, but before they start any investigation). Personnel for Contract Undercover Investigators (CUI) must have undergone an in-depth background check and the PM must present written documentation that the following requirements have been met:

• Education Verification

• Statewide and National Criminal History Checks

• Prior Employment Verification

• Drug Test

• Registration Under Individual State License Requirements

• U. S. Citizenship verified though E-Verify

The CUIs must possess a high degree of self-discipline and moral character. These traits will guide behavior to legally acceptable and ethical methods of investigation. All aspects of the investigation must be carefully calculated, and no actions will be taken which might jeopardize the case, harm the integrity of FNS, or compromise the safety of the CUI. The characteristics expected of a CUI are:

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• Professionalism

• Experience with conducting criminal, civil or compliance investigations

• Adaptability

• Excellent Reasoning Ability

• Excellent Oral Communication

• Excellent Written Skills

• Exceptional Observation Skills

• Excellent Listening Skills

• Bilingual or Multilingual

• Computer Literate

• Patience

• Initiative

• Ability to sit and stand for long periods of time

5.3. CLIN 3: Training Requirements

FNS will supply initial training to the Contractor and the CUI’s before the investigations start.

5.3.1.) The training will consist of, but not be limited to,:

• Mission Statement

• FNS Definitions and Terminology

• Fundamentals of Conducting Store Visits

• Donations and Trafficking Cash Handling

• Required Reports and Report Writing

• Identification of Clerks

• EBT Card use and Handling

• Required FNS Reports and STARS System

Upon initial training provided by FNS, the Contractor shall be responsible for the training of all staff, including providing training to new staff within three days of being hired.

Contract staff should not be allowed to conduct any on-site store visits before receiving training. Based on feedback from FNS, the Contractor may need to conduct follow-up training for staff, as necessary. For example: if an investigator is achieving only negative or no result investigative results, FNS may determine that the CUI is in need of further training before being allowed to continue investigative work on their own.

Based on a review of investigation results, FNS will determine if there is a need to conduct follow-up training sessions. Such training will be held at a location to be determined by FNS. If after such additional training, the CUI is still achieving negative or non-positive results, FNS reserves the right to request the contractor immediately replace the CUI. The Contractor, throughout the term of the contract, shall be responsible for providing its staff with refresher training that covers topics that impact the on-site store visits. The ROD PM may wish to participate in the development of training as necessary.

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5.4. CLIN 4: Investigation Requirements

The CUI shall travel to all retail stores identified in the assigned request for investigation (RFI). Before entering the store, the investigator will have reviewed any pertinent documents supplied by FNS such as hours when EBT activity may peak, store visit photos as well as the demographics of the area enabling the CUI to adapt their technique to maximize investigative outcomes.

Some investigations may require video surveillance work which the CUIs must perform;

if so, additional direction and training by FNS will be given to the Contractor.

CUI will not engage in any activity not authorized by FNS. For example, the CUI will not engage in:

• Any audio or video recording of conversations between any involved parties (unless previous written approval by FNS is obtained)

• The carrying of weapons of any kind

• The use of non-employed staff of the contracting agency

• Threatening, coercing or any promises for providing information or engaging in any conduct which may jeopardize the investigation or the integrity of FNS.

• CUI will NOT use cash for the purchase of any items from the retailer or their representative.

5.4.1.) Conducting the investigations.

The training of Investigators will be assigned after the award of the contract. This decision will be made by FNS. Regardless, the timeframe for starting investigations will remain the same unless mitigating reasons are presented and agreed upon by FNS.

The CUI will be provided an EBT card(s) in an undercover name of which they feel best fits their undercover role. These EBT cards are issued at no cost to the vendor and are the property of FNS; they shall be safeguarded at all times. The EBT card is only to be used for the purchase of eligible and ineligible items and trafficking purposes between the CUI and the Retailer. Any misuse of any EBT card may result in the immediate termination of the contract.

EBT cards lost, stolen, or misplaced shall be reported immediately to the FNS liaison1. If a CUI fails to report such lost, stolen, or misplaced card to the Contractor, said investigator would be relieved of any FNS contract work. If the Contractor fails to report any lost, stolen, misplaced, or misused EBT card within 24 hours, the contract may be terminated.

All items purchased by the CUI will be processed in accordance with the FNS guidelines2.

Items will be donated to local charities to be determined by FNS and done daily or by the

1 The contractor will have one main FNS POC for their communications with FNS which will be designated after contract award.

2 The detailed guidelines and procedures for investigations are sensitive and will therefore be provided to the selected contractor after contract award.

Investigation Augmentation Project Page 9 of 16 next day (if purchased after donation center hours). The charities approved by FNS will be required to sign a receipt attesting to the donation. Items not fit for donations such as ineligible items (beer, cigarettes, etc.) will be destroyed by Contractor management and witnessed by an FNS staff member or representative.

Any items purchased by the CUI which become lost or missing due to circumstances beyond the contractor's control shall be reported to the FNS liaison within 24 hours of said loss. Failure to report such loss may result in the termination of the contract.

Any cash received from the retailer or their representative during an investigation conducted by the CUI shall be turned over to the Contractor’s Manager where it will be recorded and secured until the cash is surrendered to FNS. At no time should the cash be utilized, replaced, and/or kept by the CUI.

Any improper handling use or misuse of trafficking cash will result in the immediate termination of the contract. Any loss of trafficking cash through means uncontrollable by the contractor or CUI shall be reported within the first 24 hours. Failure to report such loss may result in the termination of the contract.

5.4.2.) Creating the Investigation Reports

Investigative reports will be created and maintained in an automated manner. The format of these reports will be determined at a later date

5.4.3.) Transmitting the Investigation Report

The transmission of investigative reports by the CUI will be done in an automated manner.

The format will be determined at a later date.

5.4.4.) Handling of the purchased items and/or cash

ROD PM will select the donation sites for each of the investigative areas and will conduct training on how to complete the donation sheets. The POC or ROD management will train the PM with regard to finding and utilizing donation sites within the investigative area.

After initial training, the PM will be responsible for training staff as to the location(s) of the donation sites to be utilized. Investigators are to only use those sites approved by the

ROD PM.

5.5. CLIN 5.: Technology and Operational Constraints

All contracted personnel using FNS data systems must ensure that data integrity is maintained and all must adhere to Personally Identifiable Information (PII) security procedures. No FNS data will be put or stored on unauthorized systems.

5.5.1.) Security

The Vendor shall be responsible for properly protecting all information used, gathered, or developed as a result of this contract. The Vendor shall implement procedures that ensure appropriate administrative, technical, and physical safeguards are established for the security and confidentiality of government information, data, and/or equipment. The Vendor’s procedures shall be consistent with Government, OMB Circular A-130, Management of

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Federal Information Resources, the Computer Security Act of 1987, the Federal Information Security Management Act of 2002 (FISMA), and the Privacy Act. In addition, during all activities and operations on government premises, the Vendor shall comply with the policies, rules, procedures and regulations governing the conduct of personnel or protection of government facilities and data as expressed by USDA, written or oral.

USDA Federal Employees, Contractors, & Affiliates

If you are a USDA Federal Employee, Contractor, or Affiliate of the USDA, you must register for a USDA Internal Account.

Request Level 2 Access to:

• Submit official business transactions via the Internet

• Enter into a contract with the USDA

• Submit forms or applications for the USDA via the Internet

• What is an eAuthentication account?

An eAuthentication account is a way for you to interact with USDA websites online. It gives you the ability to identify yourself to the USDA via your User ID and password. It permits you to access a wide range of USDA applications across the many USDA agencies and their services.

You gain the convenience of transacting business with USDA online at any time and from any computer, with internet access, that is convenient to you.

Your eAuthentication account consists of a User ID, a password and your customer profile which contains information about you that will permit USDA applications to identify if you have the correct permissions to view the website you attempted to access.

Currently, USDA offers Accounts with Level 1 Access and Accounts with Level 2 Access for the general public and USDA customers.

Note: You must have a valid email address to register for all types of eAuthentication accounts. If you do not have an email account already, there are several online email providers, such as Yahoo.com, Gmail.com or Hotmail.com, that have free email services.

What is Level 2 Access?

An account with Level 2 access allows the user to enter USDA Web site portals and applications that have been determined to have the need of higher security requirements or restrictions and the need of a verified identity for each User ID and profile.

Registering for an account with Level 2 access is easy but requires a few more steps than Level 1.

You will create a customer profile with your name, personal contact information, a User ID and a password for your USDA account. You will then receive a confirmation email from the USDA https://identitymanager.eems.usda.gov/registration/selfRegistrationForm.aspx?level=2 https://www.eauth.usda.gov/MainPages/eAuthWhatIsAccount.aspx#Level1Account https://www.eauth.usda.gov/MainPages/eAuthWhatIsAccount.aspx#Level2Account

Investigation Augmentation Project Page 11 of 16 asking you to respond to the email to confirm your account within seven (7) days. A response to the email message is required in order to complete the process.

(a) Sensitive Information Storage and Disclosure Sensitive-but-Unclassified (SBU) information, data, and/or equipment will be disclosed only to authorized personnel on a Need-To-Know basis. The holder shall ensure that appropriate administrative, technical, and physical safeguards are established to ensure the security and confidentiality of this information, data, and/or equipment is properly protected. When no longer required, this information, data, and/or equipment will be returned to Government control; destroyed; or held until otherwise directed. Destruction of items shall be accomplished by tearing into small parts; burning; shredding or any other method that precludes the reconstruction of the material, consistent with GSA guidelines.

(b) Protection of Information All information about the USDA networks and/or the security posture of any USDA information asset gathered or created under this contract will be considered SBU information. It is anticipated that this information will be gathered, created and stored within the primary Government work location. If the Vendor personnel must remove any information from the primary work area they should protect it to the same extent they would their proprietary data and/or company trade secrets. If the Vendor must remove any materials from the primary work location prior approval must be obtained from FNS.

(c) Security and Privacy The use of any information that is subject to the Privacy Act will be utilized in full accordance with all rules of conduct as applicable to Privacy Act Information.

(d) Security Classification The preparation of the deliverables under this contract will be completed at a Sensitive-But- Unclassified (SBU) level unless otherwise stated, in writing, by FNS.

(e) Special Requirements All work performed must meet and comply with all National Institute of Standards & Technology (NIST), other government-wide laws and regulations, and USDA and OCIO (Office of the Chief Information Officer) directives, guidelines, and requirements for protection and security of Information Technology. Such directives and guidelines include, but are not limited to:

• Computer Security Act of 1987

• Federal Information Security Management Act (FISMA)

• OMB Circular A-130, Management of Federal Information Resources

• Presidential Directive Decision 63, Critical Infrastructure Protection (CIP)

• Presidential Directive Decision 67, Enduring Constitutional Government and

Continuity of Government Operations

• Homeland Security Presidential Directive 7

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• NIST’s Guide for Developing Security Plans for Information Technology Systems (Special Publication 800-18)

• U.S. Government “Plain Language” Guidelines

• http://www.ocio.usda.gov/directives/files/dm/DM3535-000.htm

(f) Confidentiality and Non-Disclosure The Vendor may have to access proprietary information and shall be required to have their non-disclosure and conflict of interest statements signed by their employees. The preliminary and final deliverables and all associated working papers, and other material deemed relevant by the agency that have been generated by the Vendor are the property of the U.S. Government and cannot be reproduced, or retained by the Vendor. When no longer required, this information, data, and/or equipment will be returned to Government control. All documents and information pertaining to network vulnerabilities, security policy, operational procedures or related functions shall be maintained under absolute accountability and relinquished to FNS upon completion of the contract.

Any unauthorized disclosure or breach of Personally Identifiable Information (PII) shall be reported to FNS immediately upon discovering the incident.

• Time Constraint: Investigations must be completed within 30 days of having received the assignment (unless FNS approval for an extension is granted before the deadline).

• Documentation: All visits to the store need to be fully documented.

6.0 DELIVERABLES AND PERFORMANCE REQUIREMENT

SUMMARY

The following are required deliverables. Vendors are encouraged to recommend additional deliverables that are appropriate to their particular solution.

The contractor shall provide a Draft Summary Memorandum on the project kick-off meeting within 5 days of contract award.

The contractor shall provide summary results of the investigation which shall include the following elements:

• A list of stores investigated with the name of the CUS, the number of passes (store visits) made, and the number of sanctionable investigations and the number of trafficking passes made.

• Any other information or documents necessary to fulfill the objectives of the Investigation Augmentation Project.

The investigative report results are due weekly.

All CLINs are located in Section 5, Contract Tasks and Requirements, of this Task Order.

http://www.ocio.usda.gov/directives/files/dm/DM3535-000.htm

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FNS reserve the right to incorporate other surveillance methods should the Contractors proposal or performance deem necessary.

CLIN # Deliverable Format/

Quantities Due Date

5.1. CLIN 1: Project Management and Reporting

5.1.1. Kick-off Meeting Oral and Email Within 15 calendar days of issuance of Task Order

5.1.2. CS plan Email Within 15 calendar days

of project startup meeting

5.1.3. Written project status report Email 15th each month

5.1.4. Oral briefings Oral Within 5 operating days

of written project status report submitted to FNS

5.1.5. CS status report Email 60 calendar days

following end of this Task Order

5.1.6. Manage day to day activities, timelines, deliverables, and provide Contract staff supervision.

Daily

5.1.7. Weekly Investigative Reports Email Weekly

5.2. CLIN 2: Defining Investigators and Requirements

5.2.1. Identifying the Program Manager &

other personnel Email At contract kick-off meeting or before

5.3. CLIN 3: Training Requirements

5.3.1. Training Electronic Within 15 calendar days

of FNS approval of second outline

5.4. CLIN 4: Investigation Requirements

5.4.1. Conducting the Investigation 5 calendar days of

receipt of the Task Order

5.4.2. Creating the Investigation Report Day the investigation was conducted

5.4.3. Transmitting the Investigation Report Day the investigation was conducted.

5.4.4. Handling of Purchased Items/Cash Training to be

provided on handling Purchased Items & Cash

Daily or Within 24 hours

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5.5. CLIN 5.: Technology and Operational Constraints

5.5.1. Security Electronic Daily

PERFORMANCE REQUIREMENTS SUMMARY (PRS)

PERFORMANCE

MEASURE

PERFORMANCE

STANDARD

PERFORMANCE

DELIVERABLE

MONITORED

SURVEILLANCE

METHODOLOGY

PERFORMANCE

RATING

SURVEILLANCE

FREQUENCY

MONITORING

PERFORMED

Store Visit/Pass Results

Timeliness:

Enter into designated FNS system or reported to FNS the same as pass completion

95% are entered on time

100% Inspection

Exceptional Very Good Satisfactory Marginal Unsatisfactory

Daily Task Orders via the Contractor Performance and Rating System(CPAR S)

Store Visit/Pass Results

Quality: Data are of sufficient quality such that FNS does not have to return it for re-work of the product

95% of reports are error-free upon submission to

FNS

Satisfactory Marginal Unsatisfactory

Daily Task Orders via the Contractor Performance and Rating System(CPAR S)

Investigation Results

Timeliness:

Investigation completed and submitted to FNS via FNS’s tracking system

At least 95% of investigations are completed and submitted to FNS within 30 days of being assigned

Satisfactory Marginal Unsatisfactory

Monthly Task Orders via the Contractor Performance and Rating System(CPAR S)

Investigation Results

Quality:

Sanctionable success rate

At least 40% of investigations are sanctionable

Satisfactory Marginal Unsatisfactory

Monthly Task Orders via the Contractor Performance and Rating System(CPAR S)

Investigation Results

Quality:

Trafficking success rate

At least 8% of investigations contain a trafficking pass

Satisfactory Marginal Unsatisfactory

Monthly Task Orders via the Contractor Performance and Rating System(CPAR S)

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Business Relations

Professional and respectful of all parties

Regular and ad-hoc meetings between contractor and

FNS

Quarterly Performance Evaluation

Exceptional Very Good Satisfactory Marginal Unsatisfactory

Quarterly Contractor Performance and Rating System(CPARS)

Management of Key Personnel

• Appropriate credentials experience for the work involved

• Attends scheduled meetings

• Available for ad-hoc meetings as necessary for contractual concerns

Regular and ad-hoc meetings between contractor and

FNS

Quarterly Performance Evaluation

Exceptional Very Good Satisfactory Marginal Unsatisfactory

Quarterly Contractor Performance and Rating System(CPARS)

Rating Definitions

Exceptional Performance meets contractual requirements and exceeds many to the FNS’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with few minor problems for which corrective actions taken by the contractor were highly effective.

Very Good Performance meets contractual requirements and exceeds some of the FNS’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with some minor problems for which corrective actions taken by the contractor was effective.

Satisfactory Performance meets contractual requirements. The contractual performance of the element or sub-element contains some minor problems for which corrective actions taken by the contractor appear or were satisfactory.

Marginal Performance does not meet some contractual requirements. The contractual performance of the element or sub-element being assessed reflects a serious problem for which the contractor has not yet identified corrective actions. The contractor’s proposed actions appear only marginally effective or were not fully implemented.

Unsatisfactory Performance does not meet most contractual requirements and recovery is not likely promptly.

The contractual performance of the element or sub-element contains a serious problem(s) for which the contractor’s corrective actions appear or were ineffective.

If an “unsatisfactory” rating is obtained, FNS has the right to opt out of the contract at any time after the unsatisfactory rates are issued. Ratings will be given to the contracted investigative firm(s) on a quarterly basis. Satisfactory ratings must be met and maintained quarterly. If a less than Satisfactory rate is obtained, the Contractor must provide FNS with a written action plan which explains how the performance will be improved. Two consecutive quarters of less than satisfactory ratings may result in the immediate termination of the contract.

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FNS will collaborate with the contractor’s day-to-day operation. Weekly communication between the FNS and the contractor is paramount to the agreement. The contractor will be required to meet with the FNS representative as deemed necessary by the FNS upon reasonable notice.

No investigation will be conducted in any store other than those stores given to the contractor. Periodically, an investigation may be recalled from the contractor. When this occurs, no further action or visits to the store shall take place without the approval of FNS. Violating this provision may result in immediate termination of the contract. Independently received information, tips, complaints, or any other information received by the contractor regarding a store not currently assigned for investigation must be made known to FNS. If the information can be verified and the store is cleared for investigation, FNS will assign it to the contractor.