Attachment 3-RFI 47QRAB25N0003-Revised Q_As-2025.05.27.pdf

RFI 47QRAB25N0003 - Q & A

Questions GSA Response

1 Under GSA's notice 47QRAB25N0002-Demos titled "GSA Charge Card and Commercial Payments" (dated 4/15/2025), GSA released a limited number of time slots from 4/23/2025 to 4/30/2025 for companies to provide a demo / presentation of capabilities and/or solutions under the scope outlined in the initial 3/20/2025 notice number 47QRAB25N0002.

Today, however, in the middle of the time frame for these demos/presentations, GSA has issued a new RFI 47QRAB25N0003 (dated) 4/28/2025 titled "Charge Card and Commercial Payments - Additional Request for Information". This 4/28/2025 RFI not only references the 3/20/2025 and subsequent 4/15/2025 RFIs (and includes a copy of the same) but states it expands the scope and now-- "This potential acquisition will seek an end-to-end solution(s) for an innovative charge card and commercial payments platform designed to leverage commercial best practices, integrated technology, and financial controls of current innovative and enhanced spend management tools."

"GSA has considered increasing the scope of this potential acquisition to include multiple agencies and organizations, up to the entire federal government in one or more centrally issued or managed contract(s). This effort includes purchase, travel, and fleet business lines, and could also potentially include government agency to government agency (i.e., inter-governmental and/or intra-governmental) transactions. Additional considerations may include customization of agency or organization interface functions for non-charge card or commercial payment functions, such as order management, receipt tracking, and travel management."

Additional information regarding financial systems across government and states that "...potential financial system encumbrance..." is now part of the scope of work being considered.

It is known that at least one business, a known small business with SBA socioeconomic certifications, held their demo/presentation the week prior to GSA's disclosure of this expanded scope on 4/28/2025. Companies who presented on or prior to 4/28/2025 did not get the same opportunity to incorporate this new RFI information into the information provided to GSA (and other agency participants) as companies whose appointments fall after 4/28/2025.

How is GSA ensuring that market research is being conducted ethically and with integrity, and is achieving its stated goals, when the agency has chosen to disclose a significantly expanded scope DURING its own demonstration / presentation timeline and all companies are not presenting against a common known scope?

2 GSA has released information "...that there is currently not one uniform financial system that is deployed across the entire federal government; each agency or organization manages and develops systems to meet specific policies, regulations, laws, needs, and missions. Additionally, it is not uncommon for large organizations with complex missions and structures to have multiple financial systems and some may have shared service organizations or other agencies managing either a single or multiple financial systems."

Can GSA provide any additional information about the numbers of potential financial management systems as well as the agencies acting as financial management shared service providers (i.e, USDA, FAA's ESC, etc) to better state the depth / breadth of diversity in systems utilized?

Context:

Question:

Context:

Question:

GSA is conducting market research in accordance with the FAR, GSAM, and internal guidance.

At the market research stage, GSA has discretion to conduct additional research or request more information about specific aspects that may arise while reviewing industry responses and demonstrations/presentations. This new RFI is within scope of the potential requirements being considered and developed; GSA is researching whether or not the scope of this potential acquistion will increase to include the entire federal government. GSA is not requesting or expecting past or scheduled demonstrations to include the information requested in this new RFI. RFI 47QRAB25N0002-Demos provided specific areas of interest and topics to address in the demonstrations/presentations Those areas of interest and topics have not changed.

Information received from the various RFIs and/or demonstrations/presentations will be used to shape GSA's acquistion strategy.

GSA has broadly stated the scale of the various agency/organization financial systems given the potential for future administration/agency changes. However, to assist respondents with understanding the possible scale, GSA provided a link to GSA SmartPay statistics and reporting tools. If/when a solicitation is issued for this potential acquisition, it will include necessary details about the scale of the requirement.

3 GSA's expanded scope states --

"Additional considerations may include customization of agency or organization interface functions for non-charge card or commercial payment functions, such as order management, receipt tracking, and travel management."

"...that there is currently not one uniform financial system that is deployed across the entire federal government; each agency or organization manages and develops systems to meet specific policies, regulations, laws, needs, and missions. Additionally, it is not uncommon for large organizations with complex missions and structures to have multiple financial systems and some may have shared service organizations or other agencies managing either a single or multiple financial systems."

"Many large and/or complex agencies may also have more than five hierarchy levels for program and account administration, based on organization, operations, and appropriations."

"Further, there are agencies that require additional or higher levels of security, due to mission needs and sensitivity of operations and personnel."

These statements are listed as specifications any solution must meet and that they are unique to the Federal Government (otherwise they wouldn't be mentioned), and GSA's own statements are that customized solutions are required.

GSA's PIRC Guide for CSO procurements states-- "The goal of the CSO pilot program is to implement a competitive solicitation methodology outside the normal Federal Acquisition Regulation (FAR) procurement methods to provide a streamlined approach for acquiring new innovative commercial solutions."

The definition of "Commercial Product or Service has the meaning given the term “commercial item” includes a commercial product or a commercial service, as defined in sections 103 and 103a, respectively, of title 41, United States Code."

This statement has a footnote that says "The FY23 NDAA defines “commercial product” by referencing the term “commercial item” in FAR 2.101, as part of the definition. However, “commercial item” is no longer defined in the FAR."

Given the FAR 2.101 definition of commercial product and commercial service, can GSA provide the specific regulatory rationale for the continued planned use of the CSO process?

Context:

Question:

GSA is conducting market research to explore the potential development of an acquisition using the referenced CSO authority and increase the agency's understanding of available commercial products and services. The potential for customization does not automatically render the solution or acquistion non-commerical in nature. Information received from the market research will be used to shape GSA's acquisition strategy, including applicability of the CSO authority.

RFI responses are not evaluated. An RFI is not a solicitation for proposals/solutions; they are in support of the government's market research efforts. Information received from the market research (including various RFIs and/or demonstrations/presentations) will be considered and may be used to shape GSA's acquisition strategy.

Information received from the market research (including various RFIs and/or demonstrations/presentations) will be considered and may be used to shape GSA's acquisition strategy. Additional RFIs may be posted to support GSA's market research efforts. Specific timelines are not established at this time.

4 Can you share how the agency will evaluate or use the responses received?

5 What are the next steps and expected timeline following this RFI?

6 Why were fleet card capabilities/requirements removed from the second iteration of the RFI?

7 What is the timeline for the release of an official RFP? Will the scope/number of agencies be included in that RFP? Additionally, will award criteria be included in that RFP?

8 What is the overarching strategy regarding the future of the SmartPay 3 contract?

9 What is your ideal timeline for running a pilot and/or a full rollout?

10 How, if at all, does the government's fleet card use case materially differ from large private sector use cases?

11 If there will be a limited pilot prior to full rollout, what are your expectations for the following reporting integrations during a pilot period? a) NECS for fuel tax recovery b) Intellilink for compliance management c) FPDS reporting d) FedRooms and CityPair

e) are there any other notable reporting systems to integrate with?

12 Do you intend to impose SmartPay 3 requirements for physical card design, or disseminate new requirements specifically designed for a pilot and/or a new full rollout (i.e., SmartPay 4)?

13 Number of Participating Agencies: How many direct government agencies are anticipated to be part of this program initially?

14 Number of Participating Agencies: What is the potential for future expansion to additional agencies?

152 Number of Participating Agencies: Estimated number of cardholders across all participating agencies?

16 Number of Participating Agencies: Will there be a tiered approach to agency onboarding?

17 Program Duration & Review: What is the planned duration of this program?

18 Program Duration & Review: Will there be periodic reviews and potential adjustments to the the program based on performance & needs? If so, has a cadence been determined?

19 Spend Projections: What are the estimated total annual spend projections for the entire program?

(Y1, Y2, & Y3)

20 Spend Projections: What is the estimated monthly or annual spend per cardholder?

Removal of fleet questions had no significance at all. The intent of the additional RFI was to capture any updated pricing and pricing structure for a government-wide solution vice subset of GSA cards/accounts as published in the first, related RFI. The original general Questions to Industry were included in the response template for this RFI to reflect this change from the previously published response template.

Information received from the market research (including various RFIs and/or demonstrations/presentations) will be considered and may be used to shape GSA's acquisition strategy. Additional RFIs may be posted to support GSA's market research efforts now or in the future. Specific timelines are not established at this time.

Information received from the market research (including various RFIs and/or demonstrations/presentations) will be considered and may be used to shape GSA's acquisition strategy now or in the future.

Specific timelines are not established at this time. Information received from the market research (including various RFIs and/or demonstrations/presentations) will be considered and may be used to shape GSA's acquisition strategy now or in the future.

Fleet card requirements and/or use cases will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Reporting integration requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Card design requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about anticipated agency participation will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about anticipated agency participation will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about the anticipated number of cardholders will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about agency onboarding approach will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Contract period of performance will be provided will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific requirements for reviews will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about estimated spend will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about estimated spend will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

21 Spend Projections: How will spending limits be allocated to individual agencies and cardholders?

What is the methodology?

22 Spend Projections: Do you have shareable historical spending data available from these agencies to inform projections?

23 Spend Projections: Will there be different spending limit tiers based on employee roles or agency needs?

24 Source of Funds: What is the designated source of funds for this program (e.g., specific appropriations, agency budgets)?

25 Source of Funds: How will funds be allocated and managed at the program level?

26 Funding/Loading Mechanism: What mechanism will be used to settle the outstanding balances on these credit cards? Will it involve direct withdrawals from agency accounts, payments from a central program fund, or an alternative approach?

27 Funding/Loading Mechanism: What are the processes for initial card funding and subsequent replenishments (if applicable)?

28 Funding/Loading Mechanism: Will there be controls or approvals required for funding/loading?

29 Funding/Loading Mechanism: Will virtual card options be considered, and how would they be funded?

30 User Roles & Access Levels: What different user roles will be required within the platform (e.g., cardholder, agency administrator, program administrator, finance/oversight)?

31 User Roles & Access Levels: What level of access and permissions will each role have (e.g., viewing transactions, setting limits, generating reports, managing users)?

32 User Roles & Access Levels: How will roles and permissions be managed and provisioned for new users and agencies?

33 Single Sign-On (SSO) & Integration: Will our platform be required to integrate with existing government identity management systems (e.g., for SSO)?

34 Single Sign-On (SSO) & Integration:What other government systems will the platform need to integrate with (e.g., accounting, procurement)

35 Reporting & Analytics Access: What reporting capabilities will be required for different user roles?

36 Reporting & Analytics Access: What level of customization will be required for reports?

37 Reporting & Analytics Access: How will data security and privacy be maintained for reporting at the accounting or agency level?

38 Audit Trails: What level of audit trail functionality will our platform be required to provide government and ovresight tracking within the platform?

39 Defining "Unusual Spend": What criteria will be required to identify "unusual" or potentially unauthorized spending?

Applicable information about spending limits and methodology will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

As noted/linked in the RFI, historical spend information is available on our website, at:

Applicable information about spending limit information will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about potential sources of funding will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about funds allocation and management information will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about outstanding balances requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about initial card funding and replenishments will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about funding approvals or controls will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific requirements for virtual cards (if any) will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about user roles will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about user roles, including access and permissions, will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about user roles, including access and permissions, will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about system integration will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about system integration will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about reporting capabilities will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about reporting capabilities will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about security requirements and privacy will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Applicable information about audit trail functionality will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

https://smartpay.gsa.gov/about/statistics/.

40 Defining "Unusual Spend": Will there be specific Merchant Category Codes (MCCs) or transaction types that will be flagged or restricted?

41 Defining "Unusual Spend": How will thresholds for unusual spending be determined (e.g., amount, frequency, location)?

42 Pre-Authorization and Approval Workflows: Will pre-authorization be required for certain types of purchases or amounts?

43 Pre-Authorization and Approval Workflows: What approval workflows will be in place for these pre-authorizations?

44 Pre-Authorization and Approval Workflows: Who will be responsible for approving these requests?

45 Real-time Monitoring and Alerts: Will real-time monitoring capabilities for transactions be required at the program or agency level?

46 Real-time Monitoring and Alerts: What types of alerts will be required for triggered or unusual spending, and who will receive them?

47 Spending Limits and Controls: Will spending limits be required and enforced at the cardholder and agency levels?

48 Spending Limits and Controls: Will there be temporary limit increases allowed, and what approval processes will be required?

49 Spending Limits and Controls: What specific Merchant Authorization Controls (MACs) will be required to be in place to manage and restrict transactions at certain types of merchants?

50 Violation Handling and Remediation: What processes will need to be in place for addressing and resolving instances of unusual or unauthorized spending?

51 Violation Handling and Remediation: What disciplinary actions or reporting requirements will be in place for violations?

52 Government Regulations and Policies: What specific government or agency-level rules and regulations will need to be considered to govern this program?

53 Data Security and Privacy: Are there any specific government security measures that need to be contemplated as it pertains to protect cardholder and transaction data?

54 Data Security and Privacy: Are there any required data retention policies that will need to be in considered for this program?

55 Accessibility (Section 508 Compliance): Will the platform and all related materials need to be compliant with Section 508 accessibility standards?

56 Legal Review and Agreements: What legal reviews will be required for program agreements and policies?

57 Implementation Timeline: What is the proposed timeline for the implementation of the program?

58 Implementation Timeline: What are the key milestones and dependencies?

59 Card Issuance and Distribution: Is there a current process for card issuance and distribution to employees?

Specific requirements for restrictions (if any) will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific requirements for pre-authorization and/or workflows will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific requirements for pre-authorization and/or workflows will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific requirements for pre-authorization and/or workflows will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific monitoring and/or alert requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific monitoring and/or alert requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific limits and/or control requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific limits and/or control requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific limits and/or control requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Specific requirements will be provided if or when a solicitation is issued for a potential charge card and payment solutions contract.

Disciplinary actions are handled by the agencies, not contractors. Reporting requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Specific requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about security requirements and privacy will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about data retention requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about accessibility requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Specific requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about the potential implementation will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about the potential implementation will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about card issuance and distribution will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

60 Training and Support: Will training be required for cardholders, agency administrators, and program managers? Or are there already processes in place?

61 Training and Support: What ongoing support mechanisms will be available?

62 Communication Strategy: How will program information and updates be communicated to participating agencies and cardholders?

63 Performance Monitoring and Reporting: What key performance indicators (KPIs) will be required to monitor the program's success?

64 Performance Monitoring and Reporting: How frequently will performance reports be required and to whom?

Applicable information about training requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about training and support requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about communication requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about performance indicator requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.

Applicable information about performance reporting requirements will be provided if or when a soliciation is issued for a potential charge card and payment solutions contract.