4. SOW_INVESTIGATION SERVICES - 0204202.docx

STATEMENT OF WORK (SOW)

FEDERAL BUREAU OF PRISONS (BOP) STATEMENT OF WORK (SOW) FOR ADMINISTRATIVE INVESTIGATION SERVICES - EVIDENCE REVIEW RELATED TO WORKERS’ COMPENSATION RESTRICTIONS

1.0 GENERAL

1.1 BACKGROUND

The purpose of this Statement of Work (SOW) is to obtain contractor support to conduct administrative investigations focused on identifying evidence inconsistent with an employee’s existing medical restrictions related to an active workers’ compensation case.

The Bureau of Prisons’ (BOP) seeks to identify workers’ compensation fraud based on the information obtained through administrative investigations seeking evidence that is inconsistent with existing medical restrictions or reported limitations in active workers’ compensation claims. Information obtained from public sources and direct observation may clarify whether a claimant’s reported limitations align with actual activities. This work supports the BOP’s responsibility to assess claim validity, ensure appropriate benefit administration, and maintain compliance with applicable legal standards.

Investigations may include analysis of publicly accessible social media, surveillance, and other legally compliant investigation techniques to verify or refute functional limitations reported by a claimant.

The contractor shall ensure that all investigative practices comply with applicable federal and state laws, maintain the integrity of evidence collection, and support BOP in making administrative determinations.

1.2 SCOPE

The contractor shall provide professional investigative services strictly within legal and ethical boundaries, to develop an evidence base for administrative action:

A. Social media monitoring

1. Analyze publicly available social media accounts and online content for evidence that contradicts the claimant’s reported functional limitations. Systematically review publicly accessible social media content related to the claimant to identify posts, photos, videos or tags that may contradict reported limitations.

2. Document date, platform, and content details for each contradicting item identified.

3. Provide a summary report of findings with links, videos and screenshots as appropriate.

B. Surveillance, observation, or activity monitoring

1. Conduct lawful targeted surveillance to observe and document the claimant’s physical activities as they relate to reported medical restrictions.

2. Prepare comprehensive investigative reports and present the findings in accordance with BOP standards and legal requirements.

3. Ensure all work complies with privacy laws, evidentiary rules, worker’s compensation statutes, and government regulations. Avoid trespass, hidden recordings in private spaces, or other methods that would violate applicable laws or privacy rights.

4. Maintain a chain of custody and recordkeeping procedure for all collected evidence, detailing who collected it, when, where, and how it was stored and transmitted.

1.3 OBJECTIVE

The objective of this contract action is to obtain qualified investigative services to support the BOP in verifying the accuracy of reported medical restrictions associated with active workers’ compensation claims. The contractor shall conduct a lawful, unbiased and comprehensive administrative investigation to identify any evidence that may be inconsistent with the claimant’s stated limitations. This investigation shall include, but is not limited to, review of publicly accessible social media content, Open-Source Intelligence (OSINT) gathering, and physical surveillance of the claimant’s activities.

1.4 APPLICABLE DOCUMENTS

The following BOP policies, federal regulations, and related guidance documents govern or inform the conduct, scope, evidence handling, privacy, and investigative procedures relevant to this work.

1.4.1 Compliance Documents

The following documents provide specifications, standards, or guidelines that must be complied with in order to meet the requirements of this contract:

1. BOP Program Statement 1601.04, Worker’s Compensation Program

2. BOP Program Statement 1351.05, Release of Information

3. BOP Program Statement 1210.24, Internal Affairs

4. BOP Program Statement 1210.25, Internal Affairs – supplemental guidance

5. BOP Program Statement 3420.012, Standard of Employee Conduct

1.4.2 Reference Documents

The following documents may be helpful to the Contractor in performing the work described in this document:

1. Case-specific written documents, guidance or memos from BOP designated legal authority

2.0 SPECIFIC REQUIREMENTS/TASKS

2.1 TASK ONE – Social media monitoring and documentation

2.1.1 Identify monitoring parameters:

a. Identify claimant’s public profiles, known aliases, and relevant platforms.

b. Set the date range, keywords, hashtags, locations, and any specific groups or public pages to scan.

c. Record search terms or filters so work is consistent and repeatable.

2.1.2 Conduct monitoring:

a. Perform scheduled searches at optimal intervals.

b. Capture public posts, photos, videos, check-ins, or tags that relate to claimant’s abilities or activities.

c. Note content that appears time-stamped within the monitoring period.

d. Maintain a secure log and database.

2.1.3 Interim reporting

a. Prepare a brief interim update after the first monitoring cycle or as scheduled, listing key findings, any issues, and confirmation of legal/privacy checks.

2.2 TASK TWO — Lawful surveillance, observation, and note‑taking

2.2.1 Plan observation windows

a. Identify public locations, dates, and times where observation is lawful and likely to yield relevant information.

b. Assign personnel and define roles for each shift. Confirm equipment, distances, and safety protocols.

c. Note each observed event, date, start/end time, location, description of activity, estimated duration, any person involved, and objective notes. If media (photos or video) is captured lawfully, tag with metadata: timestamp, device ID, observer name, and storage location. Do not trespass, enter private property without permission, or use hidden recording devices in non-public spaces.

d. Identify any events that warrant immediate client notification or legal review.

2.2.2 Interim report or log submission

a. Submit observation logs and any verified media with a short summary of key events after each shift or at agreed intervals.

3.0 CONTRACTOR PERSONNEL

3.1 QUALIFIED PERSONNEL

The Contractor shall provide qualified personnel to perform all requirements specified in this SOW.

3.2 CONTINUITY OF SUPPORT

The Contractor shall ensure that the contractually required level of support for this requirement is maintained at all times. The Contractor shall ensure that all contract support personnel are present for all hours of the workday. If for any reason the Contractor staffing levels are not maintained due to vacation, leave, appointments, etc., and replacement personnel will not be provided, the Contractor shall provide e-mail notification to the Contracting Officer’s Representative (COR) prior to employee absence. Otherwise, the Contractor shall provide a fully qualified replacement.

3.3 Key Personnel

Before replacing any individual designated as Key by the Government, the Contractor shall notify the Contracting Officer no less than 15 business days in advance, submit written justification for replacement, and provide the name and qualifications of any proposed substitute(s). All proposed substitutes shall possess qualifications equal to or superior to those of the Key person being replaced, unless otherwise approved by the Contracting Officer. The Contractor shall not replace Key Contractor personnel without approval from the Contracting Officer. The following Contractor personnel are designated as Key for this requirement. Note: The Government may designate additional Contractor personnel as Key at the time of award.

3.3.1 Contractor Key personnel shall not be assigned by the Contractor to more than one key position for this requirement.

3.4 PROJECT MANAGER

The Contractor shall provide a Project Manager who shall be responsible for all Contractor work performed under this SOW. The Project Manager shall be a single point of contact for the Contracting Officer and the COR. The name of the Project Manager, and the name(s) of any alternate(s) who shall act for the Contractor in the absence of the Project Manager, shall be provided to the Government as part of the Contractor's proposal. The Project Manager is further designated as Key by the Government. During any absence of the Project Manager, only one alternate shall have full authority to act for the Contractor on all matters relating to work performed under this contract. The Project Manager and all designated alternates shall be able to read, write, speak and understand English. Additionally, the Contractor shall not replace the Project Manager without prior approval from the Contracting Officer.

3.4.1 The Project Manager shall be available to the COR via telephone between the hours of 8:00 AM and 4:00 PM EST, Monday through Friday, and shall respond to a request for discussion or resolution of technical problems within 24 hours of notification.

3.5 EMPLOYEE IDENTIFICATION

3.5.1 Contractor employees visiting Government facilities shall wear an identification badge that, at a minimum, displays the Contractor name, the employee’s photo, name, clearance-level and badge expiration date. Visiting Contractor employees shall comply with all Government escort rules and requirements. All Contractor employees shall identify themselves as Contractors when their status is not readily apparent and display all identification and visitor badges in plain view above the waist at all times.

3.5.2 Contractor employees working on-site at Government facilities shall wear a Government issued identification badge. All Contractor employees shall identify themselves as Contractors when their status is not readily apparent (in meetings, when answering Government telephones, in e-mail messages, etc.) and display the Government issued badge in plain view above the waist at all times.

3.6 EMPLOYEE CONDUCT

Contractor’s employees shall comply with all applicable Government regulations, policies and procedures (e.g., fire, safety, sanitation, environmental protection, security, “off limits” areas, etc.) when visiting or working at Government facilities. The Contractor shall ensure Contractor employees present a professional appearance at all times and that their conduct shall not reflect discredit on the United States or the Department of Commerce. The Project Manager shall ensure Contractor employees understand and abide by Department of Commerce established rules, regulations and policies concerning safety and security.

3.7 REMOVING EMPLOYEES FOR MISCONDUCT OR SECURITY REASONS

The Government may, at its sole discretion (in coordination with the Contracting Officer where practical), direct the Contractor to remove any Contractor employee from BOP facilities for misconduct or security reasons. Removal does not relieve the Contractor of the responsibility to continue providing the services required under the contract. The Contracting Officer will provide the Contractor with a written explanation to support any request to remove an employee.

4.0 OTHER APPLICABLE CONDITIONS

Any change in scope, methods, timeline, or budget must be documented, approved in writing and become part of an updated SOW or amendment.

4.1 SECURITY

Contractor access to unclassified, but Security Sensitive Information may be required under this SOW. Contractor employees shall safeguard this information against unauthorized disclosure or dissemination.

4.2 PERIOD OF PERFORMANCE

The period of performance for this contract is one year from the date of award.

4.3 PLACE OF PERFORMANCE

The primary place of performance will be the Contractor’s facilities with frequent visits to the Federal Bureau of Prisons at 320 1st St NW, Washington, DC.

4.4 HOURS OF OPERATION

Contractor employees shall generally perform all work between the hours of 8:00 AM and 4:00 PM EST, Monday through Friday (except Federal holidays). However, there may be occasions when Contractor employees shall be required to work other than normal business hours, including weekends and holidays, to fulfill requirements under this SOW.

4.5 TRAVEL

Contractor travel shall be required to support this requirement. All travel required by the Government outside the local commuting area(s) will be reimbursed to the Contractor in accordance with the Federal Travel Regulations. The Contractor shall be responsible for obtaining COR approval (electronic mail is acceptable) for all reimbursable travel in advance of each travel event.

4.6 POST AWARD CONFERENCE

The Contractor shall attend a Post Award Conference with the Contracting Officer and the COR no later than 10 business days after the date of award. The purpose of the Post Award Conference, which will be chaired by the Contracting Officer, is to discuss technical and contracting objectives of this contract and review the Contractor's draft project plan. The Post Award Conference will be held at the Government’s facility, located at 320 1st St NW, Washington, DC or via teleconference.

4.7 PROJECT PLAN

The Contractor shall provide a draft Project Plan at the Post Award Conference for Government review and comment. The Contractor shall provide a final Project Plan to the COR not later than 10 business days after the Post Award Conference.

4.8 BUSINESS CONTINUITY PLAN

The Contractor shall prepare and submit a Business Continuity Plan (BCP) to the Government. The BCP Plan shall be due 10 business days after the date of award and will be updated on an annual basis. The BCP shall document Contractor plans and procedures to maintain support during an emergency, including natural disasters and acts of terrorism. The BCP, at a minimum, shall include the following:

· A description of the Contractor’s emergency management procedures and policy

· A description of how the Contractor will account for their employees during an emergency

· How the Contractor will communicate with the Government during emergencies

· A list of primary and alternate Contractor points of contact, each with primary and alternate:

· Telephone numbers

· E-mail addresses

4.8.1 Individual BCPs shall be activated immediately after determining that an emergency has occurred, shall be operational within 8 hours of activation or as directed by the Government, and shall be sustainable until the emergency situation is resolved and normal conditions are restored or the contract is terminated, whichever comes first. In case of a life-threatening emergency, the COR shall immediately make contact with the Contractor Project Manager to ascertain the status of any Contractor personnel who were located in Government controlled space affected by the emergency. When any disruption of normal, daily operations occur, the Contractor Project Manager and the COR shall promptly open an effective means of communication and verify:

· Key points of contact (Government and contractor)

· Temporary work locations (alternate office spaces, telework, virtual offices, etc.)

· Means of communication available under the circumstances (e.g., email, webmail, telephone, FAX, courier, etc.)

· Essential Contractor work products expected to be continued, by priority

4.8.2 The Government and Contractor Project Manager shall make use of the resources and tools available to continue contracted functions to the maximum extent possible under emergency circumstances. Contractors shall obtain approval from the Contracting Officer prior to incurring costs over and above those allowed for under the terms of this contract. Regardless of contract type, and of work location, Contractors performing work in support of authorized tasks within the scope of their contract shall charge those hours accurately in accordance with the terms of this contract.

4.9 PROGRESS REPORTS

The Project Manager shall provide a bi-weekly progress report to the Contracting Officer and COR via electronic mail. This report shall include a summary of all Contractor work performed, including a breakdown of labor hours by labor category, all direct costs by line item, an assessment of technical progress, schedule status, any travel conducted and any Contractor concerns or recommendations for the previous reporting period.

4.10 PROGRESS MEETINGS

The Project Manager shall be available to meet with the COR upon request to present deliverables, discuss progress, exchange information and resolve emergent technical problems and issues. These meetings shall take place at 320 1st St NW, Washington, DC in room 460E, or via video conference.

4.11 GENERAL REPORT REQUIREMENTS

The Contractor shall provide all written reports in PDF electronic format with read/write capability using applications that are compatible with BOP workstations.

4.12 INTELLECTUAL PROPERTY

All reports, data compilations, logs, photographs and video captured lawfully, analysis, summaries, and any other materials or deliverables will become property of BOP.

4.13 PROTECTION OF INFORMATION

Contractor access to information protected under the Privacy Act is required under this SOW. Contractor employees shall safeguard this information against unauthorized disclosure or dissemination in accordance with the law and Government policy and regulation.

4.14 SECTION 508 COMPLIANCE

Pursuant to Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d) as amended by P.L. 105-220 under Title IV (Rehabilitation Act Amendments of 1998) all Electronic and Information Technology (EIT) developed, procured, maintained and/or used under this contract shall be in compliance with the “Electronic and Information Technology Accessibility Standards” set forth by the Architectural and Transportation Barriers Compliance Board (also referred to as the “Access Board”) in 36 CFR Part 1194. The complete text of Section 508 Standards can be accessed at http://www.access-board.gov/ or at http://www.section508.gov.

5.0 GOVERNMENT TERMS & DEFINITIONS

5.1 COR – Contracting Officer’s Representative

5.2 BOP Bureau of Prisons

6.0 GOVERNMENT FURNISHED RESOURCES

The Government will furnish information, data and documents to the Contractor in support of this contract. The Contractor shall not release Government furnished information, data and documents to outside parties without the prior and explicit consent of the Contracting Officer.

7.0 CONTRACTOR FURNISHED PROPERTY

The Contractor shall not furnish materials, equipment and services necessary to fulfill the requirements of this contract.

8.0 GOVERNMENT ACCEPTANCE PERIOD

The COR will review deliverables prior to acceptance and provide the contractor with an e-mail that provides documented reasons for non-acceptance. If the deliverable is acceptable, the COR will send an e-mail to the Contractor notifying it that the deliverable has been accepted.

8.1 The COR will have the right to reject or require correction of any deficiencies found in the deliverables that are contrary to the information contained in the Contractor’s accepted proposal. In the event of a rejected deliverable, the Contractor will be notified in writing by the COR of the specific reasons for rejection. The Contractor may have an opportunity to correct the rejected deliverable and return it per delivery instructions.

8.2 The COR will have 15 business days to review deliverables and make comments. The Contractor shall have 15 business days to make corrections and redeliver.

8.3 All other review times and schedules for deliverables shall be agreed upon by the parties based on the final approved Project Plan. The Contractor shall be responsible for timely delivery to Government personnel in the agreed upon review chain, at each stage of the review. The Contractor shall work with personnel reviewing the deliverables to assure that the established schedule is maintained.

9.0 DELIVERABLES

The Contractor shall consider items in BOLD as having mandatory due dates. Items in italics are deliverables or events that must be reviewed and/or approved by the COR prior to proceeding to next deliverable or event in this SOW.

DISTRIBUTION

N/A

COR, Contracting Officer

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