FSAFEDS Q_A -Amendm 3.pdf

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Questions and Answers, Submitted April 20, 2020 by 2:00 PM Eastern

Amendment #3: The following list is the entire set of questions asked. It has been updated to include the answers from Amendment 1, Amendment 2, and the final set of answers being published in Amendment 3. All questions asked timely have now been answered.

A. Questions About the PWS:

Q? # Reference Question Government Response / Answer

1) PWS, Page 2 B. Additional Requirements for the Intelligence

Community. How do we find the requirements of each agency?

Answer from Amendment 2: Please see Appendix E in ATT 1b of the solicitation. An updated version of Appendix 1b was included with Amendment 1. No additional information can be provided pre‐ award due to the sensitivity of the information, for protection of the Intelligence Community.

2) PWS Page 3, ATO

If the incumbent vendor has an active ATO, will this carry over into the new contract or will a new ATO be required?

Answer from Amendment 3: An ATO is specific to a particular contract, and contractor. If the incumbent were to win award of the FSAFEDS requirement, their active OPM ATO would be able to carry over from the old contract to the new contract as long as the signing OPM Authorizing Official and System Owner remain the same; the system name and boundary has not changed and the terms of the ATO conditions are being met. A risk analysis will still be needed to be completed by OPM Cybersecurity to determine that those terms are being met. The ATO from the incumbent would expire if a new contractor wins the FSAFEDS award, as only one contractor may hold an active ATO for the same requirement at the same time.

3) PWS Page 3, ATO

If the incumbent vendor decides to submit the proposal in the name of its new parent company (incumbent is a 100% wholly‐owned subsidiary of the parent), and incumbent vendor has an active ATO and will continue to be the entity performing the services under the contract utilizing the same infrastructure/ systems/ security it has today, will the incumbent vendor's ATO be sufficient or will a new ATO be required?

Answer from Amendment 3: Yes, an active OPM ATO would be able to carry over as long as the signing OPM Authorizing Official and System Owner remain the same; the system name and boundary has not changed and the terms of the ATO conditions are being met. A risk analysis will still be needed to be completed by OPM Cybersecurity to determine that those terms are being met.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

4) PWS Page 3, ATO

What FISMA level of compliance is the system required to attest to (Low, Moderate, or High)?

Answer from Amendment 3: Per current Federal Information Processing Standard (FIPS) 199 categorization level, the system impact is at the MODERATE level.

5) PWS Page 3, ATO

Will the Contractor be provided the Current Security Assessment and Authorization (SA&A) package for the system upon contract award?

Answer from Amendment 3: Security Assessment and Authorization from the previous contractor is not provided to contractor of new system.

6) PWS Page 3, ATO

What is the NIST framework to be used for the ATO audit (ex. 800‐171)?

Answer from Amendment 3: The NIST 800‐53A Assessing Security and Privacy Controls in Federal Information Systems and Organizations: Building Effective Assessment Plans.

7) PWS Page 3, ATO

Are there any countries that are prohibited from connecting to the FSAFEDS system?

Answer from Amendment 3: No. A federal employee must have access to the FSAFEDS system from wherever in the world they are stationed, either temporarily or permanently.

8) PWS page 3, ATO

When does the current system’s existing ATO expire? Answer from Amendment 1: Irrelevant. The answer to this question is not necessary for an Offeror to prepare a proposal to provide this service, and does not affect an Offeror’s ability to accurately price the requirement. The current ATO is not transferrable to a new Contractor. The Government will not provide an answer further.

9) PWS, page 3

ATO

When does everything have to be built to obtain an ATO? Sept 1st, Sept 15th, or another date? And what is the Dry Run date?

Answer from Amendment 3: Everything has to be built no later than December 31, 2020. The ability to have a dry run prior to the Go Live date would depend on when the ATO is obtained. The system has to Go Live on January 1, 2021.

10) PWS page 3, ATO

Does OPM have a list of already approved FedRAMP cloud service providers (CSP)?

Answer from Amendment 3: Approved FedRAMP Cloud Service Providers are available within the FedRAMP marketplace

11) PWS page 3, ATO

FedRAMP Certification sponsorship: If the winning vendor is not FedRAMP certified, is OPM going to sponsor them through the process?

Answer from Amendment 3: No.

12) PWS, page 3

ATO

Are Small business subcontractors (MWBE, HUB, Veterans, etc) under the 25% small business required to meet FedRAMP certification? If so, what is the timeline i f they are not currently FedRAMP certified?

Answer from Amendment 3: Yes. FedRAMP certification requirements are the same regardless of business size.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

13) PWS page 3, ATO

In accordance with OPM Clause 1752.239‐76(c), the Contractor shall submit the signed Security Assessment and Authorization (SA&A) to OPM at least sixty (60) days prior to operation of the IT system. In order to meet the deadline to go live with operation on January 1, 2021, the Contractor shall submit its signed SA&A no later than October 30, 2020. In addition, the Contractor shall participate as requested by OPM in the completion of a Privacy Impact Assessment, which must be approved and signed by OPM’s Chief Privacy Officer prior to obtaining the ATO.

Is the requirement for an ATO and FedRAMP certification at or before 12/31/2020 negotiable with an appropriate roadmap and milestones?

Answer from Amendment 3: Earlier than the noted dates for submission of paperwork is fine, however, the Contractor MUST be capable of achieving ATO in time to Go Live with operation on January 1, 2021. A later Go Live date based on a delayed ATO is not permissible, as it would either cause a break in service between the end of the current contract, or force the government to issue a bridge contact to the incumbent contractor until the replacement contractor can achieve ATO, neither of which is desirable. As such, ATO by December 31, 2020 for a Go Live Date January 1, 2021 is non‐negotiable.

14) PWS, Page 3

ATO

From signing of agreement when must the Contractor’s solution be FedRAMP certified, if not already certified?

Based on RFP documents, 12/30/2020 Eligibility documents will not be submitted to the (Contractor) without final FedRAMP certification.

Answer from Amendment 3: All FedRAMP Cloud Components must be FedRAMP certified by Go‐live date.

15) PWS, Page 3

ATO

From signing of agreement when must the desired features be functional? If September 2020, are manual interim solutions acceptable until coded / automated.

Answer from Amendment 3: The ATO must be in place before 12/31/2020 in order to go live on 1/1/2021.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

16) PWS page 3, ATO

In accordance with OPM Clause 1752.239‐76(c), the Contactor shall submit the signed Security Assessment and Authorization (SA&A) to OPM at least sixty (60) days prior to operation of the IT system. In order to meet the deadline to go live with operation on January 1, 2021, the Contractor shall submit its signed SA&A no later than October 30, 2020. In addition, the Contractor shall participate as requested by OPM in the completion of a Privacy Impact Assessment, which must be approved and signed by OPM’s Chief Privacy Officer prior to obtaining the ATO.

Can you confirm if there is any flexibility in delivery of the SA&A to OPM by October 30, 2020 for review by the AO?

Answer from Amendment 3: In order to meet the deadline to go live with operation on January 1, 2021, the Contractor shall submit its signed SA&A no later than October 30, 2020.

17) PWS, page 4, B #4

The carryover period for HCFSA is not a 2 ½ month grace period. The carryover allows participants who re‐enroll for the following year to carry over up to $500 to the following year. The 2 1/2 month grace period applies to DCFSA only.

Answer from Amendment 1: Noted. Edits will be made to PWS and included in an amendment to the Solicitation.

18) PWS, Page 4 B. Performance / Administration Periods: Please confirm the carryover must be used within 2.5 months for the HCFSA. The web site https://www.fsafeds.com/explore/hcfsa does not mention the 2.5 month limitation.

Answer from Amendment 3: There is a 2.5 month Carryover available for Healthcare and Limited Expense Healthcare FSAs. The PWS has been updated in this amendment to the Solicitation

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

19) PWS, Page 5 End of Contract:

a) Does the term “apps” used in this section refer to programs typically used on devices such as smart phones and tablets?

b) If so, these programs may have been developed for use across the contractor’s book of business. They will certainly be considered confidential trade secrets. Does this clause mean the outbound contractor must provide all source code to the incoming contractor?

c) If so, does this requirement apply to the current contractor?

Answer from Amendment 2:

(a) Yes.

(b) No.

(c) No.

The incoming contractor will not receive the current mobile app from the current incumbent.

Edits will be made to PWS and included in an amendment to the Solicitation

20) PWS, page 5 End of Contract: "At the end of the contract, the outbound contractor shall transfer administration of the FSAFEDS program, website, phone numbers, apps, and all accounts to the incoming contractor as detailed in the Transition section of this PWS.”

Is the expectation that the incoming contractor will continue use of the same website, phone number, and apps as the outbound contractor or is the incoming contractor able to make the determination if they will use the existing website, phone number, and apps?

Answer from Amendment 1: The incoming contractor must use the same web address (www.fsafeds.com) and phone number (1‐877‐ 372‐3337).

The incoming contractor will not receive the current mobile app from the current incumbent.

21) PWS, page 5 IV.a.6: Is there a demonstration site available for

BENEFEDS?

Answer from Amendment 1: No.

22) PWS, page 5 IV.A.8: Is this meant to be a single sign on operation?

If so, is it expected OPM programmers and the contractor’s programmers will work together on this aspect?

Answer from Amendment 2: No, and OPM Programmers do not work on the current FSAFEDS website.

23) PWS, page 5 IV.A.9: "The Contractor shall provide auto‐adjudication for the vast majority of FSAFEDS claims." Please quantify "vast majority"

Answer from Amendment 2: Greater than 80%. Edits will be made to PWS and included in an amendment to the Solicitation.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

24) PWS, page 5 IV.A.9: "The Contractor shall provide auto‐adjudication for the vast majority of FSAFEDS claims." Please clarify if the auto‐adjudication is expected for just card transactions, or if this includes manual claims submissions as well.

Answer from Amendment 1: Not just card transactions. Please see the paperless reimbursement section of the PWS.

25) PWS, page 5 IV.A.12: "The Contractor shall provide an email confirmation notice to each participant stating the participant’s election, change in election, account balance, amount subject to forfeiture, etc., upon participant or OPM request." Please document other potential requested information that falls under "etc."

Answer from Amendment 1: Examples include claim disputes, check replacement info, Claims processed (if requested), claims received (if requested)

26) PWS, page 5 IV.A.12: "The Contractor shall provide an email confirmation notice to each participant stating the participant’s election, change in election, account balance, amount subject to forfeiture, etc., upon participant or OPM request." Is it the intent that participants could only request information related to their account, and that communication to all participants would need to be requested by appropriate OPM contact?

Answer from Amendment 1: All global communication must be reviewed and approved by OPM.

Participants can only request information related to their account or their linked accounts as it relates to spousal processing.

27) PWS, page 5‐6 IV.A.14: "The Contractor shall migrate all claims history from the previous Contractor for the year they begin contract administration and the previous calendar year. Two years’ history of claims must be searchable for the purposes of responding to inquiries from program participants, OPM and congressional inquiries." Please clarify who must be able to search the claims history and how the information needs to be accessible?

Answer from Amendment 2: The FSAFEDS contractor must be able to search the claims history and provide information from that history to participants for their own accounts, to OPM for any requested account and to congressional staff for any inquiries.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

28) PWS, page 5‐6 IV.A.14: "The Contractor shall migrate all claims history from the previous Contractor for the year they begin contract administration and the previous calendar year. Two years’ history of claims must be searchable for the purposes of responding to inquiries from program participants, OPM and congressional inquiries." Has the existing contractor agreed to migrate claim history? If so, will they support an electronic data exchange, and if so, is there a sample file format available for review?

Answer from Amendment 3: We are uncertain if the current contractor will support an electronic data exchange, and a sample file format is not available for review. The outgoing contractor and incoming contractor are expected to come to an agreement on the format after award of this contract. Please also refer to Section XII of the PWS.

29) PWS, page 6 IV.A.16: Please describe the plan design as it pertains to different agencies. For any one person, are all agencies considered part of the same plan or different plans? For example, if a person moves from one agency to another agency, is he or she considered a new hire and able to make a new and separate election or considered to still be participating in the same plan?

Answer from Amendment 1: Same plan at all participating agencies.

Moving between participating agencies does not change the plan.

Entering a participating agency from a non‐participating agency starts eligibility to participate in FSAFEDS plans.

30) PWS IV.A.2. Is the BENEFEDS interface proprietary technology? If no, can you disclose the system of record for payroll data?

Answer from Amendment 1: Yes, it is proprietary.

31) PWS IV.A.3. How many agencies participate in the program? How many additional agencies could join the program?

Answer from Amendment 1: Please refer to Appendix F of Attachment 1b for the list of current participating agencies. All agencies in the Executive Branch are required to participate. ANY agency outside the Executive Branch may choose to participate.

32) PWS IV.A.8. The Contractor shall provide a seamless link… Does the Contractor need to support SSO (Single Sign‐ ON) from Employee Express to the Contractor’s employee portals?

Answer from Amendment 1: No.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

33) PWS IV.A.14. The Contractor shall migrate claims history…

Is the Contractor required to migrate electronic claim images? If so, how are the images stored currently?

What image formats would be migrated (.tiff, .jpg, .pdf)?

Answer from Amendment 1: The outgoing and incoming contractors will need to coordinate on the format.

We do not have data to provide concerning how many images are stored by the incumbent contractor or in what format.

34) PWS IV.A.16. OPM adopted the plan for the Federal Government… How many plan effective dates for the OPM operate for adopting employers?

Answer from Amendment 1: Any agency can adopt the plan, so there can be multiple dates.

35) PWS, page 7 Is OPM amenable to payments releasing daily with a lower minimum as is done today?

Answer from Amendment 1: At their discretion, an offeror MAY choose to utilize a payment schedule that is more frequent than (exceeds) the Government’s minimum requirements as stated in the PWS. Edits will be made to PWS, and included in an amendment to the Solicitation

36) PWS, page 7 V.A.4: How can we obtain a copy of the FedFlex Plan Document?

Answer from Amendment 1: Please see ATT 1b of the solicitation, as updated by Amendment 1

37) PWS, page 7 V.A.8: May the contractor issue payments more frequently than weekly?

Answer from Amendment 1: At their discretion, an offeror MAY choose to utilize a payment schedule that is more frequent (exceeds) the Government’s minimum requirements as stated in the PWS. Edits will be made to PWS, and included in an amendment to the Solicitation

38) PWS, page 7 V.A.8: Does this minimum not apply to “debit card” transactions?

Answer from Amendment 1: This minimum does not apply to “debit card” transactions

39) PWS, pages 7, 11 & 22

The PWS says on page 7, the Risk Invoices are to be conducted twice per year, but on page 22 it indicates quarterly. Please confirm which cadence is correct.

Answer from Amendment 1: Thank you for pointing out the discrepancy. The correct cadence is quarterly. Edits will be made to PWS, and included in an amendment to the Solicitation.

Addendum for Amendment 2: We don’t find a reference to Risk Reserve Invoices on page 7 of the PWS, but we do find it on pages 11 and 22.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

40) PWS, page 8 V.B.1.g: "The Contractor shall provide all communication and enrollment materials." Does the government require co‐branded or white labeled enrollment materials

Answer from Amendment 1: Must be branded as FSAFEDS.

41) PWS, page 8 V.B.1.i: "The Contractor shall provide web‐based educational material, including the ability for individuals to model potential tax savings." Please clarify if the expectation is for tax savings to include State tax savings as well and if the tax savings needs to be customizable to the individual member level.

Answer from Amendment 1: The offeror will list inputs for the user to input their potential expenses and their tax bracket. Please see the current saving calculator on www.fsafeds.com:

https://www.fsafeds.com/support/savingscalculators/hcfsa;

https://www.fsafeds.com/support/savingscalculators/lex‐hcfsa;

https://www.fsafeds.com/support/savingscalculators/dcfsa

42) V.B.1.j: No later than… Please confirm the current contractor will handle all open enrollment inquiries related to plan enrollments for 1/1/2020.

Answer from Amendment 3: The current FSAFEDS contractor is responsible for all open enrollment inquires until 1/1/2021 when the next contract is in place and the new contractor is administering the FSAFEDS program. On 1/1/2021 through the end of the new contract, all open enrollment inquires including belated enrollment inquires both past and present will be handled by the FSAFEDS contract holder at that time.

43) PWS, Page 9 B.2.c: Please describe / define “belated enrollment.” Answer from Amendment 1: Enrollments after the close of the annual open season period.

44) PWS page 9 Contractor must develop linkages with all federal payroll systems via BENEFEDS:

(a) Will the Contractor receive incoming data separately from each payroll agency or from the BENEFEDS system for all agencies?

(b) Will separate files and frequencies be used for different payroll agencies?

(c) Do all payroll agencies have the same payroll schedule?

Answer from Amendment 2:

(a) From the BENEFEDS system

(b) Answer from Amendment 1: Yes

(c) Answer from Amendment 1: No

45) PWS, Page 10 V.C.1: Will the contractor be able to “find” a transferring employee in BENEFEDS if neither the former agency nor the employee is able to provide the contractor with that information?

Answer from Amendment 1: Yes, as long as the employee is in an eligible position at the new agency.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

46) PWS, Page 10 V.C.2: Must all claims go through FEHB and FEDVIP prior to approval through FSAFEDS? What about OTC and menstrual products?

Answer from Amendment 1: Participating employees may submit claims directly to FSAFEDS for OTC and other items that are not normally processed through FEHB or FEDVIP. Edits will be made to PWS, and included in an amendment to the Solicitation

47) PWS, V.C.5.m: "...the Contractor recognizes OPM’s right to request the Contractor to slow down the payment of claims. If instructed to do so, the Contractor shall be relieved of its performance penalties regarding claims turnaround and Call Center responsiveness for a mutually agreed upon number of days following the requested interruption of timely claims payment." The FedFlex2.pdf document states “OPM or its Plan Agent will pay properly submitted claims for reimbursement at least monthly or when the total amount of the claim to be submitted is at least a specified, reasonable, minimum amount.” Can it be assumed that the slow down of payment of claims request would never extend beyond the timeframe quoted in the FedFlex2.pdf?

Answer from Amendment 1: No assumptions can be made. If there is a reason that OPM would request a slow down; the timeframe would be discussed and communicated to the Contractor. Such slowdown may or may not extend beyond the timeframes quoted in the FedFlex2.pdf.

48) PWS page 12 6.d. Spousal Linking: For Spousal Linking does the participants request work both ways? For example if Spouse1 elects linking, a claim from Spouse2 can be paid from Spouse1's account. Does the reverse hold true? A claim made by Spouse1 can be paid from Spouse2's account? Or does Spouse2 need to elect linking for a claim from Spouse 1 to be paid from Spouse2?

Answer from Amendment 1: Both spouses must elect spousal linkages for spousal processing. When that occurs either can be paid out of the others account when their funds have been exhausted.

49) PWS Page 12 6.g. Subcontract for a vendor to provide Independent Review of Claims: How many claims per year are sent to independent review?

Answer from Amendment 1: OPM does not have this data to provide an answer.

50) PWS Page 12 6.k. Translation Services: What percentage of claims are not in English?

Answer from Amendment 1: OPM does not have this data to provide an answer.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

51) PWS page 12 6.k. Translation Services: What languages, other than

English, are required for claims translation services?

Answer from Amendment 1: Any and all languages in which claims may have been submitted. Federal employees receive services all over the world.

52) PWS Page 12 “Acceptance of Paper Claims and Paperless Reimbursement Claims.”:

(a) Currently what is the average number or overall total of manual claims per participant?

(b) Currently what is the average number or overall total of customer service calls per participant?

Answer from Amendment 1: OPM does not have this data to provide an answer.

53) PWS page 12 “Acceptance of Paper Claims and Paperless Reimbursement Claims.”, for Healthcare FSAs (both types):

(a) How many claims were submitted by paperless reimbursement by month for the last 12 months?

(b) How many manual claims were submitted by month for the last 12 months?

(c) How many claims were submitted by fax by month for the last 12 months?

(d) How many claims were submitted on the website by month for the past 12 months?

(e) How many claims were reimbursed by EFT by month, or the smallest available time period, for the last 12 months?

(f) How many claims were reimbursed by check by month, or the smallest available time period, for the last 12 months?

Answer from Amendment 1: Operations report attached to Amendment 1.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

54) PWS page 12 “Acceptance of Paper Claims and Paperless

Reimbursement Claims.”, for Dependent Care FSAs:

(a) How many manual claims were submitted by month for the last 12 months?

(b) How many claims were submitted by fax by month for the last 12 months?

(c) How many claims were submitted on the website by month for the past 12 months?

Answer from Amendment 1: Operations report attached to Amendment 1.

55) PWS page 12 Develop enrolment, claim forms: Please detail the steps employees take to enroll annually. Is this process the same, or different and how for new participants and re‐enrolling participants? What system(s) are used to allow employees to elect their annual election (allotment) amounts?

Answer from Amendment 1: Most enrollments are performed electronically. It is the same process annually for all. Details on the current enrollment system are not required to submit a proposal or to provide accurate pricing.

56) PWS V.C.: "The Contractor will reissue checks to participants whose uncashed checks, in an amount of at least twenty‐five dollars ($25) have become ‘stale’ 180 days after issue." Would this only be applicable to active employees? Can it be assumed the request to reissue checks would safely supersede any state specific escheatment laws?

Answer from Amendment 3: OPM considers state escheatment laws to fall under FEDFLEX plan Section 5.12‐ Nonalienation of Benefits.

57) PWS, page 13 V.C.6: Re‐issued Checks: To create a better member experience, would OPM be agreeable to 1) removing the $12 fee, 2) simply resending the check versus requiring participant action and 3) reducing the minimum amount and simply including all outstanding checks?

Answer from Amendment 3: The re‐issue fee has been eliminated.

Edits will be made to PWS, and included in an amendment to the Solicitation.

58) PWS, page 13 V.C.6: Who keeps the $12 re‐issue fee? Answer from Amendment 3: The re‐issue fee has been eliminated.

Edits will be made to PWS, and included in an amendment to the Solicitation.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

59) PWS page 13 Debit Card: Would the contractor allow the participant to use an existing debit card, or would the contractor issue the debit card? If Contractor issues the card would the card be single use or reloadable?

Answer from Amendment 3: The contractor would issue a reloadable debit card.

60) PWS page 13 Debit Card:

(a) What factors and circumstances have thus far prevented OPM from offering a debit card for

FSAFEDS?

(b) What are the decision criteria being used to determine if a debit card will be offered (in the future)?

Answer from Amendment 1: The answer to either question is not necessary for an Offeror to prepare a proposal to provide this service, and does not affect an Offeror’s ability to accurately price the requirement. The Government will not provide an answer.

61) PWS, Page 13 Debit Card: What would motivate OPM to choose to add Debit Card service to their FSA benefit?

Answer from Amendment 1: The answer to either question is not necessary for an Offeror to prepare a proposal to provide this service, and does not affect an Offeror’s ability to accurately price the requirement. The Government will not provide an answer.

62) PWS, page 13 V.C.6: Is the Debit Card option intended to function the way most FSA debit cards work or is it merely an option for a participant to receive funds for payment of claims submitted in another way?

Answer from Amendment 3: The debit card is intended to be an option to the participant and will function the way most FSA debit cards work, provided the employee chooses that payment option.

Edits will be made to PWS, and included in an amendment to the Solicitation

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

63) PWS, page 13 V.C.6.l, 3rd bullet: "Debit Card – (Optional

Requirement) OPM is considering implementing a debit card reimbursement process. This is an option that is not currently offered to FSAFEDS participants. If implemented, participants would have the ability to accept payment for their claims made to a debit card account in lieu of their bank account if they designate by choosing to Opt‐In. The Contractor shall comply with the Government‐approved implementation process and administration procedures, which will be incorporated to the PWS by modification of the contract if the Government decides to implement the Debit Card reimbursement feature." Please clarify if the Debit Card solution is referencing that the consumer could make a payment out of their FSA using a debit card, or if the intent of this requirement is to reimburse the employee on to a debit card for a purchase the employee made out of pocket.

Answer from Amendment 1: The intent of this requirement is to reimburse the employee on to a debit card for a purchase the employee previously made out of pocket, instead of by direct deposit to a bank account, if the employee chooses debit card as their FSA reimbursement method.

64) V.C.6.l: Debit Card. The debit card as a standard offering for participants would reduce the per participant per month administrative fee. Are we able to quote administrative services for a debit card based program?

Answer from Amendment 1: No. We are not interested in a program which is solely debit card based.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

65) PWS, page 13 V.C.6.l, 4th bullet: "Spousal Linking. Acceptance of spousal linkages and spousal processing of healthcare FSA accounts. The Contractor will allow for married participants that both individually signed up for FSAFEDS accounts to link to each other’s accounts. This linkage will allow for spousal processing. If one spouse’s account of the same type has exhausted its funds, submitted claims will automatically be reimbursed out of the other spouse’s account, provided the participants have both requested this link and unused funds are available." Please clarify the level of verification required to determine both parties meet the feds definition of "spouses"

Answer from Amendment 1: Verification is to be done by the contractor. This can be verifying spouses name and social security number.

The definition of “spouses” should be the same as defined by the IRS for tax purposes.

66) PWS, page 13 V.C.6.l, 4th bullet: “The Contractor will allow for married participants that both individually signed up for FSAFEDS accounts to link to each other’s accounts.”

Is this linkage sign‐up an annual election and can an individual opt out of linking at any point of in time?

Answer from Amendment 1: Linkage can be done at any point in time.

67) PWS, page 14 V.C.6: We understand that OPM is not responsible for fees associated with obtaining a line of credit.

However, is OPM responsible for interest costs on this line of credit?

Answer from Amendment 1: No, the Government is not responsible for the Contractor’s interest costs. ALL costs of doing business under this contract are to be included in the appropriate Period of Performance, either by inclusion in CLIN 00001 if relative to the Start Up Period, or Total Agency Fees proposed on a per Participant Per Month basis in CLINS 00002 – 10001 for the Base Periods and Option Period. Edits will be made to PWS, and included in an amendment to the Solicitation

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

68) PWS page 14 m. Funding Claims Payments. “The Contractor has the responsibility for paying claims that are not funded and may request temporary assistance from OPM’s Risk Reserve Account if needed...Third – Risk Reserve Fund once cash forecasts exceed five days cash on hand… “

(a) Please provide the calculation for determining 5 days cash on hand, or provide an estimate of the average cash balance needed to maintain a cash balance for 5 days of cash on hand?

(b) Will cash on hand balances held by the current Contractor be transferred to the new Contractor?

(c) What is the balance for the Risk Reserve Account as of December 31, 2019?

(d) What is the projected balance for the Risk Reserve Account as of December 31, 2020?

Answer from Amendment 1:

a. This information will be provided to the awarded contractor

b. Yes

c. The answer to this question is not necessary for an Offeror to prepare a proposal to provide this service, and does not affect an Offeror’s ability to accurately price the requirement. The Government will not provide an answer.

d. The answer to this question is not necessary for an Offeror to prepare a proposal to provide this service, and does not affect an Offeror’s ability to accurately price the requirement. The Government will not provide an answer.

69) PWS, page 14 n. Sources Available to Pay Claims: Can OPM provide detail amounts of claims payment made from each of the four sources?

Answer from Amendment 1: No, however the order in which the sources are listed is the order of priority.

70) PWS, page 15 V.C.6 Monthly: The third bullet states “Transfer interest to OPM.” However, the sixth bullet states “Transfer interest to OPM.” In addition, the contractor is responsible for income taxes on the interest earned.

Does the contractor keep all interest and pay all fees?

These two bullets seem to be contradictory. The section under Ongoing states that all interest belongs to the FEDFSA program. On page 19, it is stated:

”Interest earned over the bank fees belongs to the FSAFEDS program.” The question is, does all interest belong to FEDFSA or just the portion, if any above related bank fees?

Answer from Amendment 2: Transfer interest funds to the Claims Reimbursement Account if interest earned exceeds bank fees.

Bank fees that exceed interest are the contractor’s responsibility.

The PWS will be edited in an amendment to the Solicitation.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

71) PWS, page 15

#7 Under Monthly, bullet #3, it says to transfer interest to OPM, but under bullet #6, it says to transfer funds to the Claims Reimbursement account. Please clarify which step is preferred.

Answer from Amendment 1: Thank you for pointing out the discrepancy. Funds will go to the Claims Reimbursement Account.

Edits will be made to PWS, and included in an amendment to the Solicitation.

72) PWS V.C.8: Paperless Claims. What percentage of paperless claims were processed in 2019, 2018, 2017?

Answer from Amendment 1: This can be extrapolated from the Operations report attached to Amendment 1.

73) PWS page 17 9. Customer Service:

(a) Currently, what is the average number (or overall total) of service calls per participant?

(b) Please provide the number of participant emails, calls and appeals received each month for the most recent full plan year (January – December 2019).

(c) Please provide the FSAFEDS call volume by month, or the smallest available time period, for the last full plan year (January – December 2019)

(d) By week, or the smallest available time period, please provide the call volume during each of the last two open enrollment periods (Fall 2018 for 2019 participation & Fall 2019 for 2020 participation)

(e) By month, or the smallest available time period, please provide the average amount of time a transaction took that was handled by a customer service representative (i.e. Average Handle Time) for the last full plan year (January – December 2019).

(f) By month, or the smallest available time period, please provide the number of claims‐based calls in the last full plan year (January – December 2019).

Answer from Amendment 1:

(a) We do not have this data available to provide

(b) See Operations report attached to Amendment 1

(c) See Operations report attached to Amendment 1

(d) See Operations report attached to Amendment 1

(e) See Operations report attached to Amendment 1

(f) See Operations report attached to Amendment 1

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

74) PWS V.C.9.c. Customer Service: The Contractor shall host and operate a specific website for FSAFEDs. Does the system implementation require a government only platform architecture?

Answer from Amendment 3: Yes, due to sensitivity of government data which should be segmented from public and non‐government entities. Yes, due to sensitivity of government data which should be segmented from public and non‐government entities.

75) PWS The Contractor shall host and operate a specific website for FSAFEDS. The website must include at least the following services and information: secure participant login, two‐factor authentication for account access, account information, claim status, online claim submission, enrollment portal, ….

Is Two factor authentication required in all cases or at log on only? Specifically, secure participant login, account access, account information, claim status, online claim submission, enrollment portal? Are there other defined use cases for two factor authentication?

Answer from Amendment 3: Yes, Two‐factor authentication must be implemented for all activities involving PII including access to the site. Yes, factor authentication must be implemented for all activities involving PII including access to the site.

76) PWS, page 17 V.C. 9.s.iii: Does the requirement for the separate number for OPM and HR mean this number must be staffed 24x7?

Answer from Amendment 1: No

77) PWS In section V,C,9,iii the requirement references the need for employer support to accommodate a workforce that "operates around the clock and across the globe."

Can you provide the days/times the current contractor has support available to meet this need?

Answer from Amendment 3: No. The performance of the current FSAFEDS contractor is irrelevant to the requirements of the new contract as defined in this solicitation.

78) PWS, page 19 VI.B.2.: This section states that the amount of outstanding checks issued for the prior year must be sent to OPM within 90 days after the end of the year or grace period. This will be before checks are considered stale (180 days). How are checks clearing after the 90 days and before 180 days funded?

Answer from Amendment 1: From the program funds held by the contractor.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

79) PWS In section VI,B,3, there is a statement that "Interest earned over the bank fees belongs to the FSAFEDS program." In addition, the leading sentence of this section states "The Contractor may invest a portion of the funds in the FSAFEDS claims reimbursement account. Can OPM answer the following:

a) Is the "interest earned over the bank fees" referring ONLY to the interest in the claims reimbursement account, not the portion of funds swept into investments?

b) May the contractor determine the portion of the Claims Reimbursement Account funds to invest based on its own judgement? Or does OPM regulate the portion which may be invested? If the latter is true, can you describe how OPM determines the portion which may be invested and historically (on average) the dollar amount available for investment has been?

Answer from Amendment 3:

a) This refers ONLY to the claim reimbursement account.

The contractor makes the decision regarding the amount of funds to invest based on its own judgement and the funds needed to pay claims.This refers to the claim reimbursement account.

a)b) The contractor

80) PWS VI.H.2.j Financials: “OPM is not responsible for delinquent payments owed by participant agencies and cannot be billed for delinquent agency fees for other agencies. Under NO CIRCUMSTANCES, shall the Contractor disrupt or discontinue services for participants whose agency has failed to pay timely for the Total Agency Fee for services.” Over the last 5 years how many agencies became more then 180 days delinquent

Answer from Amendment 1: The answer to this question is no longer relevant to the requirement as stated. The previous contract structure differed significantly from the structure of the contract to be awarded, and the Contractor for this requirement will have the reduced risk for non‐payment of having task orders issued by the participating agencies, thereby creating a contractual obligation for those agencies to pay in accordance with the Prompt Payment Act

81) PWS, page 22 H. Fee Structure and Profit #2: The third bullet references three elements above, but there are only two elements above. What is the third element?

Answer from Amendment 1: Account Maintenance / Administrative Fee and Profit. An edit to the PWS will be included in an amendment to the Solicitation.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

82) PWS page 24

Travel If the selected vendor does not intend to bill OPM for any travel, does this still apply given this is a firm fixed price contract?

Replaces answer from Amendment 1: Although the Contractor shall not bill the Government separately for any travel expenses, and the cost of the required travel shall be built in to the Account Maintenance / Administrative Fees, Section VII of the PWS nonetheless applies. A minor edit will be made to the PWS and include in an amendment to the Solicitation.

83) PWS, page 24 J. Unpaid Agency Invoice Recovery Protocols: What has been the history of agencies never paying fees?

Replaces answer from Amendment 1: The answer to the question is not relevant under the new contract type. The new contract type gives a direct contractual relationship between the Contractor and the participating agencies through issuance of task orders which previous contracts did not include.

84) PWS, page 24 VIII. Reporting Requirements: What does OPM consider to be “waste and abuse?”

Answer from Amendment 2: The 2018 Generally Accepted Government Auditing Standards provide the following more concrete definitions of waste and abuse:

8.120 Waste is the act of using or expending resources

carelessly, extravagantly, or to no purpose. Importantly, waste can include activities that do not include abuse and does not necessarily involve a violation of law. Rather, waste relates primarily to mismanagement, inappropriate actions, and inadequate oversight.

8.122 Abuse is behavior that is deficient or improper when

compared with behavior that a prudent person would consider reasonable and necessary business practice given the facts and circumstances, but excludes fraud and noncompliance with provisions of laws, regulations, contracts, and grant agreements. Abuse also includes misuse of authority or position for personal financial interests or those of an immediate or close family member or business associate.

85) PWS, page 25 VIII. Reporting Requirements A #5: Can you provide a sample of this report?

Answer from Amendment 1: A sample of the current report is not available for sharing. OPM will work with the awardee to develop an acceptable format for the report.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

86) PWS, page 26 VIII. Reporting Requirements D: Can you provide examples of these reports?

Answer from Amendment 1: A sample of the current report is not available for sharing. OPM will work with the awardee to develop an acceptable format for the report.

87) PWS, page 27 VIII. Reporting Requirements F #4: Are the expenses included in this report those that are out of the ordinary and specific to FSAFED? Expenses that are common across the contractor’s book of business could include rent, utilities, some payroll costs and other overhead. Are these types of expenses required to be reported? (We have a similar question for start‐ up costs.)

Answer from Amendment 3: The Annual Report of Expenses will be removed from VIII.F. The PWS will be edited in Amendment 3.

88) PWS Page 29 (Subcontracting)

Would OPM accept subcontractors being entered post award if not all are able to complete the SAM registration request by May 4th?

Answer from Amendment 1: No. All Subcontractors being proposed must be registered in SAM prior to proposal submission. We must be able to verify their status before an award can be made, and SAM registration / compliance of subcontractors is part of one of the evaluation factors. As stated in the PWS, “Changes to the subcontracting plan post award require approval of the Contracting Officer (CO) prior to implementation.”

89) PWS In section XII,B, there is a requirement to transfer the FSAFEDS phone app to the incoming contractor. Given that any phone app will need to be integrated to the contractor's platform, does OPM have any expectations regarding this transfer beyond passing ownership and control of the app to the incoming contractor?

Answer from Amendment 2: The mobile phone app does not have to be transferred. The PWS will be updated in an amendment to the Solicitation

90) PWS, page 29 XIII. Continuity of Services C: Do the provisions of this paragraph apply to the current contractor?

Answer from Amendment 1: No.

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

91) PWS C. End of Contract 2. At the end of the contract, the outbound contractor shall transfer administration of the FSAFEDS program, website, phone numbers, apps, and all accounts to the incoming contractor as detailed in the Transition section of this PWS.

Will the current mobile application be provided or is the expectation the application be rebuilt by the new contractor?

Answer from Amendment 1: Mobile application will not be transferred from the incumbent to the awardee.

92) PWS B Ownership and Place of Performance Restrictions

3. All employees (and subcontractor employees) supporting performance of this Contract must be physically located within the 50 United States. Can non‐ production support personnel who will not have access to CUI data or systems be located outside of the 50 United States?

Answer from Amendment 1: No. We are adding the District of Columbia to the allowed locations but not expanding any further.

Additional Comment from Amendment 2: The PWS will be updated in an amendment to the Solicitation

93) PWS, QASP

(general)

Are the performance guarantees outlined within this section up for negotiation?

Answer from Amendment 1: No.

94) PWS Page 31

(QASP)

Would OPM consider agreeing to an annual adjustment for the last week of the annual FSAFEDS Open Season upfront during this process versus handling annually?

Answer from Amendment 1: No.

95) PWS, page 34

(QASP)

#2, items 7 & 8: Earlier in this document, it stated that claims are paid weekly, but the standards here are two and four days. Weekly payments will mean that this requirement is rarely met. In addition, the 100% level means that will certainly be missed at some point unless there is rounding up allowed. For example, if one claim out of a million is not paid within four days, this standard will be missed.

Answer from Amendment 2: No question has been asked for the Government to answer

RFP 24361820R0002 – Federal Flexible Spending Account Program (FSAFEDS) Administration Services Amendment 3

Q? # Reference Question Government Response / Answer

96) PWS, page 34

(QASP)

#2, item 9: What is meant by “current and “offeror’s error out on the first pass?” Does this preclude internal quality control after a claim is originally keyed?

Answer from Amendment 2:

”Current” refers to not having a backlog of unprocessed paper claims.

“Offeror’s error out on the first pass” refers to paperless claims being processed correctly the first time they are processed.

Quality control must be completed before a claim is processed to not count towards this measure.

The PWS will be updated in an amendment to the Solicitation

97) PWS, page 35

(QASP)

#2, item 12: What is meant by “95% accuracy?” Answer from Amendment 2: Accuracy is defined by Merriam Webster dictionary as “freedom from mistake or error.” 95% refers to the acceptable level of accuracy.

98) PWS, page 35

(QASP)

#2, items 13‐18:

(a) What is the AQL for these standards and how are they measured?

(b) Are they merely subjective judgements by OPM?

(c) If so, how can the contractor control or influence this measurement?

Answer from Amendment 3:

(a) The AQLs for these standards are as stated in…