Attachment_C.2_RMEW_Environment_and_Requirements.docx

RFP# 16PBGC19R0005

Attachment C.2 Environment and Requirements

Contents

C.2 Risk Management Early Warning (RMEW) Environment and Requirements

2.1 Introduction/Background

To support the Office of Negotiations and Restructuring (ONR) and Office of the General (OGC) mission and contribution to Strategic Goal 1, the organizations have teamed with BISD to establish the RMEW IT program. RMEW functions as a major system within the direct management control and oversight of ONR with OGC acting as a major stakeholder of the system. RMEW components or subsystems function individually or in conjunction with other systems to complete processing objectives. RMEW’s components generally reside within the PBGC Information Technology Infrastructure Services General Support System (ITISGSS), but the content and administration of the system/component is the responsibility of ONR. As such, most security controls are inherited from the general support system. RMEW is composed of three software applications that are hosted within PBGC’s ITISGSS.

· TeamConnect is a legal matter and case management system that gives RMEW the ability to share common information and coordinate more closely on a wide range of cases and legal matters, including plan termination actions, bankruptcy matters, and reportable event filings. It’s comprised of three components: TC Enterprise, TC Data Warehouse, and the TC Reports components. The TC Enterprise is accessed via a web interface utilizing Microsoft Internet Explorer and Google Chrome. The TC Data Warehouse provides defined and ad-hoc reporting from data sources linked to the TC database.

· Document Management System (DMS) is used for the capture, storage and retrieval of documents from historical records in the archives to provide current reports, evidence, and legal testimony. DMS adds to RMEW the mechanism to store the documents in a variety of file types (MS Word, txt, MS Outlook, Excel, PDFs, etc.). It also includes searchable .pdf file format which is produced after having been scanned into the system by the Adlib Express Server OCR software.

· e-Filing Portal is the web-based application and database that interfaces with the RMEW system to push subsets of e-4010 tax filing data into RMEW. E-Filing Portal also allows for 4043 electronic filings as well as multi-employer electronic notices.

2.2 System Stakeholders

As stated earlier, the mission of the PBGC is to enhance retirement security by preserving and encouraging the continuation of private pension plans and protecting the benefits of workers and retirees in traditional pension plans. It does this through management of the single-employer and multi-employer programs referenced above with a focus on achieving the following three strategic goals:

Goal 1: Preserve Plans and Protect the Pension of Covered Workers and Retirees Goal 2: Pay pension benefits on time and accurately Goal 3: Maintain high standards of stewardship and accountability

Each organization within PBGC is held accountable for delivery against these strategic goals with that performance published annually in PBGC’s annual report.

Office of Negotiations and Restructuring (ONR) In order to carry out its mission, the PBGC relies on the Office of Negotiations and Restructuring (ONR) to manage its defined benefit plan insurance programs. ONR manages PBGC's single-employer and multiemployer plan insurance programs; administers financial assistance to insolvent multiemployer plans; provides financial and actuarial analyses regarding, and negotiates with, underfunded plans to properly address PBGC's and the insurance programs' risk exposure; reviews and acts on reportable events; and recommends involuntary or voluntary plan terminations under the single-employer program.

ONR’s work directly supports PBGC’s Strategic Goal 1 to: Preserve Plans and Protect the Pension of Covered Workers and Retirees. Under Strategic Goal 1, PBGC seeks to:

· Encourage plan sponsors to continue to maintain their defined benefit plans

· Protect workers and retirees when plans are at risk

· Create a regulatory environment that minimizes burden

· Unite more missing participants with their pensions

· Encourage flexibility to preserve plans through changes in legislation and regulations

· Aide policy makers in addressing the impending insolvency crisis in the Multiemployer Insurance Program

In 2017, ONR contributed to PBGC’s mission under Strategic Goal 1 by:

· Partnering with OGC to help protect more than 26,700 people by taking action in bankruptcy cases to encourage companies to keep their plans when they emerged from bankruptcy.

· Paying $141 million in financial assistance to 72 multiemployer pension plans, covering the benefits of over 63,000 retirees with nearly 30,000 people entitled to benefits once they retire. Seven of the 72 plans became insolvent during FY 2017. These seven newly insolvent plans cover about 13,900 participants.

· Performing 10 multiemployer plan audits to protect the benefits of more than 9,000 people.

· Using plan partition, mergers and other tools to protect participants’ benefits and support the

· financial position of the Multiemployer Program.

· Through its Early Warning Program, negotiating almost $600 million in financial protection for more than 240,000 people in plans put at risk by corporate events and transactions. These agreements are also negotiated to avoid placing an unnecessary burden on premium payers.

· Conducting compliance reviews of plan sponsor calculations for plans that ended through standard terminations, resulting in 435 participants receiving corrected benefit amounts with a value of $4.6 million.

ONR is staffed by actuaries, attorneys and financial analysts and includes the following four subcomponents and associated responsibilities that support PBGC’s mission.

1. Corporate Finance and Restructuring (CFRD): Monitors the corporate events and transactions of insured defined benefit pension plans sponsors and provides financial analysis, actuarial analysis, and negotiations support that enables PBGC to mitigate risk exposure to the defined benefit insurance program, the participants, and PBGC. CFRD is further divided into:

· Corporate Finance Actuarial Section (CFAS): Provides actuarial analysis of underfunded plans and the corporate events and transactions of plan sponsors and supports PBGC in mitigating risk exposure.

· Corporate Finance and Restructuring Group (CFRG): Monitors the corporate events and transactions of insured defined benefit pension plan sponsors and provides financial analysis and negotiations support to mitigate risk exposure.

2. Multiemployer Program Division (MEPD): Manages the PBGC’s Multiemployer Insurance Program. Provides advice and technical assistance to multiemployer plan administrators, service providers and other stakeholders. The division identifies risk in the multiemployer plan universe, works with plan stakeholders to minimize that risk, and serves as the contact point at PBGC for matters concerning PBGC’s administrative oversight of ongoing and terminated multiemployer plans, including: providing financial assistance to insolvent plans, reviewing plan termination filings and plan merger notices, and acting on plan requests for PBGC approval of various transactions under ERISA’s Title IV multiemployer provisions.

3. Negotiations Restructuring Actuarial Division (NRAD): Supports the single-employer and multiemployer insurance programs by providing actuarial analysis of underfunded plans and the implications of changes to plans and their sponsors in pursuit of mitigating the risk exposure to the insurance programs, the participants and PBGC. This includes:

· At OGC’s request, providing declarations, depositions, and testimony in order to pursue recoveries for satisfaction of employer liability and unpaid employer contributions or to advance PBGC's case in other litigation with actuarial implications.

· Providing actuarial analyses for single-employer plans to determine underfunding under ERISA Sections 4044 and 4022, required contributions under Internal Revenue Code (IRC) Section 430, PBGC bankruptcy claims, and liens under IRC Section 430 (k) and assists in negotiations with plan sponsors based on these actuarial analyses.

· Providing ad hoc actuarial analysis to the PBGC Director and other departments in support of policy analysis.

· Providing support for the Standard Terminations Compliance Division (STCD) by interpreting provisions for complex and controversial plan benefits.

· Providing analyses and support to the Financial Operations Department (FOD), and the PBGC Working Groups for single-employer and multiemployer plans relative to the contingent liability included in PBGC's Financial Statement. For single-employer plans, provides actuarial certification and calculation of liabilities for plans included in the Contingency List. For multiemployer plans, provides analysis of the risk of insolvency needed to classify plans for contingent liability purposes.

· Providing actuarial data on overall plan funding trends to PBGC departments to inform policy development activities.

· Monitoring the financial condition of underfunded multiemployer plans for purposes of managing PBGC's exposure and planning for payment of financial assistance to insolvent plans.

· Providing actuarial analyses of proposed multiemployer plan mergers, spinoffs and partitions as well as proposed changes to withdrawal liability rules in order to maximize the support of contributing employers and affected labor unions for the multiemployer pension system and minimize the risk of plan insolvency.

4. Standard Termination Compliance Division (STCD): Administers PBGC’s standard termination activities, makes determinations on plan coverage and classification and responds to technical and general inquiries from the public. STCD currently uses the Office of Benefits Administration (OBA) case management system to conduct business. It is anticipated that STCD will migrate to RMEW starting in FY19. STCD includes:

· Processing and Technical Assistance Branch (PTAB): Processes to conclusion all standard termination filings; to enter initial case data and establish case files for all insurance program filings. Provides technical assistance to the public related to the standard termination program. Monitors plan administrator adherence to statutory filing requirements; perform administrative review of determinations subject to reconsideration under Subpart C of PBGC regulation Section 4003.

· Compliance and Audits Branch (CAB): Conducts the statistical audit program mandated by Section 4003(a) for standard terminations; to develop, implement and manage a program of compliance reviews, to identify and resolve individual or systemic compliance problems before final distribution of assets; and to enforce compliance through a variety of activities.

Office of the General Counsel (OGC):

In partnership with ONR, the OGC provides legal advice and counsel for the Director and the Corporation on all legal issues confronting the Corporation, including ERISA and/or bankruptcy related legal actions, decides administrative appeals of benefit coverage and other determinations, and administers the disclosure and other requirements of the Freedom of Information Act (FOIA) and the Privacy Act.

Business Innovation Services Department (BISD), Financial Management Services Division (FMSD) and Program Management

In partnership with ONR and OGC, BISD provides IT leadership and program management for the RMEW IT program. This includes IT program management, IT project management, and IT contract oversight services while establishing and utilizing proven implementation approaches to further business area goals. Within BISD, the Financial Management Services Division (FMSD) provides overall IT program and project management for ONR systems and oversight of IT contracts including RMEW.

RMEW program governance begins with the Chief Information Office (CIO), Chief of Negotiations and Restructuring (CNR) and General Counsel (GC). As sponsors of the RMEW investment, these PBGC executives articulate the business goals and outcomes for the investment which directly contribute to PBGC’s strategic goal 1 referenced above. The FMSD IT program manager, in partnership with the ONR business program manager, work to identify IT priorities and direct IT and business resources to achieve business goals set forth by the executives. This responsibility includes management of the full life cycle of the program from planning to execution, monitoring, control and budgeting. FMSD and ONR program managers brief executives on the status of program efforts and progress towards achieving outcomes on a quarterly basis at an executive steering committee meeting.

In addition, the program managers partner with the Chief Enterprise Architect to conduct Business Needs Analysis (BNAs) for program components in accordance with Enterprise Architecture (EA) standards. Currently, a BNA for the ONR area is due to be completed in FY19. The BNAs support OMB’s Architect-Invest-Implement paradigm and provides recommendations that drive performance improvements and IT investment planning and support RMEW funding and prioritizations. The outcomes of BNAs assist the program managers to establish a program roadmap for RMEW and for planning budget formulations/prioritizations for outyears. These are presented to executives for approvals and reviewed by the PBGC IT Program Review Board (ITPRB) which is chaired by the CIO.

ITPRB approved roadmaps and associated projects and efforts are then set out for out-year planning. Individual efforts supporting the program are delegated to IT and business project managers who partner to manage operations/projects and are responsible for delivering successful project outcomes. Given the complexity of the RMEW stakeholders, projects and system changes must be approved by a Change Control Board (CCB) that meets as necessary to approve scope (i.e. requirements) and schedule of efforts.

For RMEW, the business representatives making up the RMEW community include representatives from CFRD, OGC, MEPD, NRAD and soon to be STCD as it migrates to use RMEW program components. In addition, RMEW maintains an integrated project team (IPT), led by the IT project manager, that meets at the frequency discussed below to review the operational status of RMEW systems and project health. This IPT includes all business representatives, the information systems owner (ISO), information system security officer (ISSO), IT infrastructure team members and other stakeholders of RMEW systems.

In some cases, the IPT will conduct an Alternatives Analysis under guidance from the IT/Business program managers and Chief Enterprise Architect. The AA process is used to identify, compare, assess viable information technology alternatives to address a given business need or performance gap, determine and recommend the best alternative and document the associated rationale for systems covered under RMEW. The selected alternative if presented before the CIO, CNR and GC executives for approval. Once selected it is presented to the PBGC Technical Review Board (TRB) for review and approval to be added to EA’s Technical Reference Model (TRM).

PBGC expects the contractor project manager to partner with the IT and business project managers to successfully plan and execute all projects while supporting the above-mentioned BNA/AA activities along with providing efficient operations of all systems. The RMEW contract program leadership and executives are expected to work closely with PBGC’s program managers and executives to ensure success of the program and conduct monthly Program Management Reviews (PMRs) to provide a detailed snapshot of all program activities and status.

2.3 System Overview

2.3.1 Systems

2.3.1.1 Case/Matter Management and RMEW System

A significant portion of ONR work requires management of case/matter work and associated documentation. These business processes are currently supported by the Risk Management Early Warning (RMEW) system. RMEW supports approximately 250 users, provides case management features, efficient document management capability, increased data quality, automated workflows, and enhanced search and reporting capabilities. At its core is TeamConnect, a commercial off-the-shelf (COTS) matter management product sold by Mitratech. TeamConnect has been highly customized with 5 custom developed, .NET add-ins produced for integration with scanning/ORC software and Microsoft Office. There are 712 custom Java files and 328 custom screen modifications. RMEW also includes a custom, .NET document management solution, based on IBM Filenet, that is paired with TeamConnect to provide document storage, searching and retrieval. There are approximately 70 reports developed for RMEW with half in Oracle Reports the remainder in Oracle APEX. RMEW was first deployed in November of 2009 and sits on an Oracle technology stack including RHEL, Oracle (Weblogic, RDBS, Access Manager) and Windows. Since the initial deployment, additional modifications to the basic system have been deployed and TeamConnect has been upgraded to version 3.4, update 2. An effort is currently underway to upgrade TeamConnect to version 5.2 along with the associated customized code. In addition, RMEW has interfaces with the following:

· Premium Practitioner System (PPS) – Import of PPS filing and eFAST 5500 data

· PBGC Document Management System/Image Processing System (DMS/IPS) – Exchange and storage of document images relating to FileNet

· Case Management System (CMS) – Import of case and termination information and creation of cases by RMEW in CMS

· eFAST Filing Server – Import of eFAST 5500 data

· e-Filing Portal – Night import of 4010 forms, every 5 minutes import of reportable events, multiemployer events and financial assistance

Finally, the user community uses TeamConnect functionality in the following ways:

· Corporate Finance and Restructuring Department (CFRD)

· Tracking and monitoring Pension Plan health through Financial Statement (FS) Classification levels

· Processing of Reportable Events (received from the RMEW e-Filing Portal interface)

· Opening, processing, approving, and closing Cases and Case Issues

· Opening, approving, tracking compliance, and closing Settlement Agreements

· Opening Actuarial Work Requests

· Requesting Advice and Counsel

· Opening Lien Recommendation Records

· Opening, calculating, and completing Recovery Valuations

· Processing and initiating plan Terminations

· Initiating plan Termination cases in CMS (through the RMEW-CMS interface)

· Receiving Standard Termination and Coverage Determination cases (through the RMEW-CMS interface)

· Sharing documents with OBA via ImageViewer (through the RMEW-IPS interface)

· Analyzing single employer Form 5500 data (received from the RMEW-PPS interface)

Multiemployer Program Division (MEPD)

· Processing of Multiemployer Events (received from the RMEW e-Filing Portal interface)

· Processing of Financial Assistance requests (received from the RMEW e-Filing Portal interface)

· Opening, conducting, approving, and closing plan Audits

· Analyzing multiemployer Form 5500 data (through the RMEW-EFAST2 interface)

Negotiations Restructuring Actuarial Division (NRAD)

· Fulfilling Actuarial Work Requests

· Preparing and uploading PIP calculations

· Completing yearly Contingency List Calculations

· Analyzing Form 4010 data (received from the RMEW e-Filing Portal interface)

· Analyzing single employer Premium Filing data (received from the RMEW-PPS interface)

· Analyzing single employer Form 5500 data (through the RMEW-PPS interface)

Office of the General Counsel (OGC)

· Opening, processing, monitoring, and closing Matters

· Opening and tracking Key Events

· Completing Advice and Counsel requests

· Opening, filing, and tracking Notices of Liens

· Opening, filing, and tracking UCC Claims

· Opening, filing, and tracking Mortgages

Office of Benefits Administration (OBA)

· Viewing cases, matters, and plans and their documents for processing terminations

2.3.1.2 Filing Receipt and e-Filing Portal

To accomplish its mission, ONR must receive and process filings and documentation from external plans under PBGC oversight. This includes receipt of 4010 filings, 4043 reportable events and required filings by multiemployer plans. This process is currently supported by the e-Filing Portal (formerly e-4010 portal) being used by approximately 2000 internal and external users. For 4010 filers (those companies required to submit additional financial and actuarial data to PBGC on an annual basis), this web-based application offers a secure method to submit confidential information, provides validation of filings to ensure they are complete prior to submission, and enables users to create new filings using data from the previous year’s filing. It also allows filers to create the filings and associated schedules, route it to their actuary for the necessary actuarial certification and electronically submit the validated filing to PBGC. Use of the e-Filing Portal is mandatory for companies that must file. Each filing contains information from five categories: (1) Schedule G – General Information, (2) Schedule FG – Filing Gateway, (3) Schedule I – Identifying Information, (4) Schedule F – Financial Information, (5) Schedule P – Plan Actuarial Information. The application has been updated to reflect changes required by the Pension Protection Act of 2006 and the amendments to PBGC 4010 regulation.

In December 2015, Practitioners were provided enhanced capabilities to help file 4043 reportable events for Single-Employer Plans (per Section 4043 of ERISA requiring notification to PBGC of the occurrence of certain events that may signal problems with a pension plan or business) and Multiemployer Plan notices (per 29 CFR Parts 4281, 4245, and 4041A), electronically via the one consolidated website. For more information regarding e-Filing Portal filing requirements, please visit the following site: https://www.pbgc.gov/prac/reporting-and-disclosure

The e-Filing Portal extended functionality included:

· 4010 electronic filing along with supporting document attachments

· 4043 electronic filing along with supporting document attachments

· Multiemployer electronic notice filing along with supporting document attachments

Major features of the application include the ability to:

· Offer a secure website for submitting confidential information

· Review the filing and generates a list of omissions and inconsistencies prior to submission to ensure that a filing is complete

· Enable filers to create a new filing using data from a filing submitted for a prior year

· Enable filers to view documents after they are attached to the filing

· Walk the filer through various screens, prompting the filer to answer questions and enter required information. The application identifies whether a question needs to be answered based on the answers to previous questions and skips any unnecessary questions.

· Useful features include:

· Save, print and edit information on partially or completed filings at any time.

· View form - To create a form filled out with whatever information has been entered into the system

· Validate - To generate a list of errors, omitted information, inconsistencies, etc. to ensure a filing is complete and consistent before submission

· Reassign filing - To allow a filing coordinator to reassign a filing to someone else

· Assign an actuary - To allow an actuary direct access to Schedule P (Plan Actuarial Information) for a particular plan or plans

· Amend filing - To allow filers to amend a previously submitted filing or to attach files to an already submitted filing (for example, if the valuation report is not available at the time the filing was submitted)

· Manage account” feature — To allow filers to update personal information (name, address, title, etc.) or to change the secret question and answer needed for forgotten user IDs or passwords

The e-Filing Portal interfaces with RMEW to provide all of the source documentation for RMEW cases being worked by ONR.

2.3.2 System Technology Stack

RMEW requires skilled, technical services to resolve production issues, provide subject-matter expertise, and ensure that the RMEW system remains operational and effective in supporting ONR business processes.

The RMEW O&M team shall be familiar with the following technologies that make up the system. Also see Attachment C.2.a TRM AD Tools, for a list of active directory tools currently used.

2.3.3 System Diagrams

RMEW Infrastructure

TeamConnect System Components

E-Filing Portal System Architecture

2.3.4 System Data

The data provided in the table below are historic numbers and are provided for context to enable the offeror to better understand the requirements.

PWS Section Reference

Program/Project Management

· TC: June 18, July 18, Sept 18 end FY, and Oct 18 (these dates change slightly each FY)

This should not affect staffing levels.

· Manage all risks in compliance with PBGC Risk Management policy

· Conduct an initial risk assessment for the RMEW system

· Update RMEW Risk Management Plans with assessment findings, risk identification, quantification, and ranking of all identified risks and a strategy for avoidance or mitigation of each risks

· Keep risk registers updated in P3M on a weekly basis, report changes to the risk profile to the COR as soon as identified and report risks monthly at system IPT, Production meetings and during FMS Program Management Reviews

· Identify a method to identify issues, propose resolutions, estimate timeframe for issue resolution, track the status of issues (by project phase and business area) through closure and report status on the weekly and monthly status reports or other reporting mechanism

· The CCB meets up to 5 times a year

· Documentation edited or produced for the RMEW system will be quality reviewed to ensure accuracy both from a technical perspective, but also from a grammatical, spelling and formatting perspective

· Newsletter called RMEW “Tip of the Month” highlights changes, new functionality, work arounds, and answers questions for users from a user-friendly perspective and is required after a release is deployed and/or a monthly basis

Execution

Operations

· e-Filing Portal; 3 tickets per month averaging 5 hours per ticket

· 8 integration testing/updates to system required based on changes to integrated systems per year

· 4 integration tests/updates related to infrastructure changes per year

· Approximately 5 configuration changes of average 8 hours each per month

· Support is expected on demand with little time for response. Examples include number of users, table structure, configuration settings, historical information, etc.,

· Audit support will be required in support of PBGC’s audit review of all FMS systems on an annual basis. For RMEW upon demand the contractor will need to provide records of all release and project material completed in the past fiscal year

· Daily additional reports regarding RMEW historical information, release information, detailed service ticket information, presentations, agendas, meeting minutes in support of IT and business project managers for meetings and briefings will be required

· Provide artifacts to RMEW IT Security, Enterprise Cybersecurity Department, and ITIOD Security regarding Continuous Monitoring and RMEW POAMS

2.4 RMEW-Specific Requirements

2.4.1 Hours of Support

The hours listed below are to provide an understanding of the environment and overall requirements. A full complement of contractor personnel is not needed on-site or to staff each area during all of these hours. The contractor is to propose its staffing levels.

All Hours are East Coast

Support

Operations support personnel should be available during Core Hours and for Tier-3 on-call needs. Program/Project Management and Execution staff are not required on a regular basis after 5:30 PM. The contractor shall follow FAR and PBGC policy regarding holidays and inclement weather in coordination with the COR.

2.4.2 ONR Production Support

Production Support items are defined as bug fixes or functional enhancements that both the contractor and PBGC business units agree can be done outside of a typical IT deployment. A list of these items is maintained in the Quality Center (QC). ONR and the contractor will review of the items stored in QC and prioritize and categorize each item small in size, scope and impact. When prioritized the contractor will provide analysis that confirms the item is appropriately categorized as a production support item. The contractor can expect up to 70 production support requests a year, each item is generally a 15-hour level of effort (LOE). These requests are not urgent requests, nor do they arise from emergencies. They are to be planned and implemented based on government priorities and do not require the assistance PBGC’s Oracle DBA team to implement.

2.4.3 Contingency Plan

The following requirement is in lieu of PWS 4.2.3.7 COOP Support. In the future COOP may replace the Contingency Plan.

In the event of a contingency activation or other disruption of system operations, PBGC may activate its contingency plan (see Attachment C.2.4) to restore system functionality at PBGC or a remote location. During a contingency activation, the contractor will need to support the restoration of RMEW system RMEW support contractor will need to provide assistance in restoring system functionality. After activation and notification of the Information System Contingency Plan (ISCP) the contractor shall:

· Participate in and support Tier 3 technical assistance for Contingency Recovery activities

· Participate in Reconstitution - the process by which a recovered system is tested to validate system capability and functionality. During the Reconstitution Phase, recovery activities are completed, and normal system operations are resumed. This phase includes validation of a successful recovery

· Perform Validation data testing - the process of testing and validating recovered data to ensure that data files or databases have been recovered completely. To validate the data recovered, a complete check of the recovered data shall be verified against the last available backup

· Perform functional testing - the process of verifying that recovered system functionality has been tested and the system is ready to return to normal operations. This will be completed by the RMEW Development/Support Team in collaboration with ONR Business Representatives.

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