70FA6025I00000003 SOW Draft.pdf

NFIP Standard Operations

DRAFT Statement of Work

February 2025

NFIP Standard Operations 2025 SoW

Table of Contents

1.0 Background

2.0 Purpose

3.0 Required Tasks

3.1 Part A: Management and Administration

3.1.1. Initiation

3.1.2. Transition-In

3.1.3. Program and Project Management

3.1.4. Business Continuity

3.1.5. Quality Management

3.1.6. Records Management

3.1.7. Transition-Out

3.1.8. Assumptions, Constraints, and Required Standards

3.2 Part B: Standard Operations

3.2.1. NFIP Programmatic Delivery Support

3.2.2. Underwriting Support

3.2.3. Claims Operation Support

3.2.4. Claims Appeals

3.2.5. Regional Support

3.2.6. WYO Oversight

3.2.7. Customer Care Support

3.3 Part C: Flood Disaster Operations

3.3.1. Flood Response Offices (FROs)

3.3.2. Disaster Operations Claims and Claims Appeals Support

3.3.3. Allowable Costs Under Disaster Operations

4.0 Deliverables

5.0 Personnel

6.0 Period of Performance

7.0 Place of Performance

8.0 Travel

9.0 Government Furnished Equipment

1.0 Background

The U.S. Department of Homeland Security (DHS), Federal Emergency Management Agency’s (FEMA) mission is to help people before, during, and after disasters. Under the Office of FEMA Resilience, the Federal Insurance Directorate’s (FID) mission is to provide customer focused flood insurance to help survivors and their communities effectively recover from flood events.

As part of this mission, FID manages the National Flood Insurance Program (NFIP), which was created by The National Flood Insurance Act of 1968 (NFIA). The NFIP aims to reduce disaster suffering by helping customers better understand their flood risk and the importance of flood insurance, providing affordable insurance to property owners, renters, and businesses as well as encouraging communities to adopt and enforce floodplain management regulations.

FID administers the Write Your Own (WYO) program, which enables participating private insurance companies to sell and service the flood insurance product as fiscal agents of the Federal Government. FID also offers policies directly for sale through its NFIP Direct Program.

Overall, the NFIP currently serves more than 4.7 million policies and $1.3 trillion in coverage in more than 22,500 participating communities. More than 80 percent of these policies are sold and serviced through private insurance companies participating in the WYO program, all of whom must report every transaction to the NFIP.

The WYO companies have been invaluable in the NFIP’s effort to increase the flood insurance policy base and the geographic distribution of policyholders. In addition, WYOs improve service to policyholders as well as insurance agents, and enhance the NFIP's ability to settle claims promptly and fairly in post-catastrophe environments.

NFIP industry vendors support the direct sale and servicing of NFIP policies; communications;

technology operations, maintenance, and development; standard business operations (current requirement); and financial reporting.

Universal objectives, assumptions, and constraints applicable are provided below and apply to all contracts that support the NFIP.

Universal Objectives:

NFIP Key Priorities:

1. Continue to Transform the NFIP Delivery Model: Enable the digital sale and servicing of flood insurance to increase the number of people covered.

2. Deliver flexible, diverse, and data informed products that provide the customer greater choice and access through simplified policy forms that meet policyholders’ needs and are easier for agents.

3. Continue to improve the customer experience by leveraging technology and innovation to enhance the policyholder experience and meet customer expectations.

Universal Assumptions and Constraints

• All activities align with DHS/FEMA strategic goals and constraints.

• Pivot is the NFIP’s System of Record (SOR).

• FEMA is updating policy forms, and while some will be finalized, not all will be completely in place at the time of contract award.

• The NFIP will continue to operate according to the current authorization and regulations but must ensure flexibility for changes.

• The NFIP will embrace data and fraud analytics to drive better operations through improved oversight, speed, quality, and customer service.

• The NFIP will leverage data analytics and behavioral science to better inform decisions and improve the program’s marketing and engagement approach.

• The NFIP will embrace industry-standard customer experience models (online sales, mobile claims through smartphone applications, agents at the contact center, etc.).

• The NFIP will strengthen and expand partnerships—including through incentives.

• Outreach activities are coordinated, integrated, and consistent with NFIP messaging.

• Data security and privacy issues are major focus of the federal Government’s information technology efforts. All program activities must be compliant with current Government Information Security Reform Act, Office of Management and Budget policies, DHS, and FEMA requirements.

• Solutions must include transition plans detailing how continuity of services will be maintained (e.g., operations of IT systems in various states of health and development, ongoing marketing and sales efforts, program management, etc.)

2.0 Purpose

The purpose of this Statement of Work (SOW) is to obtain a qualified Contractor, hereinafter referred to as “Contractor”, to support insurance standard business operations, including insurance subject matter expertise, and daily business operations of the NFIP and FID.

The Contractor will be providing support to FEMA, as directed by FEMA, which may require that Contractor staff coordinate with the WYO insurance companies and the NFIP Direct Contractor as they work together to provide the information required by the NFIP. The Contractor will also engage in support activities that include tracking, collecting, disseminating, maintaining, and updating information on the NFIP and the WYO companies.

The Contractor must establish field offices in the event of a flood disaster per FID’s concurrence. These offices are set up to expedite claims and coordinate WYO activities.

The Contractor must support NFIP outreach efforts in close coordination with FID’s Communication Contractor as directed by the Government.

The work that the Contractor will perform will be UNCLASSIFIED. It should be noted that a substantial amount of data is considered Personally Identifiable Information (PII) and must be safeguarded to prevent unauthorized disclosure.

3.0 Required Tasks

3.1 Part A: Management and Administration

3.1.1. Initiation

3.1.1.1. The Contractor shall conduct a kick-off meeting within 10 business days of award.

• Meeting minutes are due within two business days after the kick-off meeting.

3.1.2. Transition-In

3.1.2.1. The Contractor shall complete all transition-in activities and assume full performance of this requirement within 90 days of award.

3.1.2.2. The Contractor shall initiate or transition all scope elements from the legacy Contractor with minimal stakeholder disruption.

3.1.2.3. The Contractor shall develop and provide a transition-in project plan with a comprehensive timeline for transition, anticipating and mitigating potential problems that may hinder transition within 15 business days of award.

3.1.2.4. The Contractor shall collaborate with FEMA and the legacy Contractor to ensure a smooth and full transition of operations and knowledge.

• The Contractor shall participate in knowledge transfer sessions with FEMA and the legacy Contractor for various business operations and subject matter as identified by

FEMA.

• Within 10 business days of completion of knowledge transfer sessions, the Contractor shall complete a knowledge transfer form to document the knowledge transfer process.

3.1.3. Program and Project Management

3.1.3.1. The Contractor shall submit a Program Management Plan (PgMP) within 15 business days of award.

• If requested by the Contracting Officer’s Representative (COR), the Contractor shall submit project management plans or similar artifacts to facilitate manage elements of the scope.

3.1.3.2. If requested by the COR or Program Manager, the Contractor shall facilitate a weekly program management meeting with the COR, Program Manager, and control account managers.

• The intention of the program management meeting is to discuss the business and administration of the contract rather than to be another touchpoint for programmatic issues.

• A meeting agenda is due by 2:00 PM Eastern the day before the scheduled meeting.

3.1.3.3. The Contractor shall submit a Monthly Status Report (MSR) every month during the period of performance.

• The reporting period shall match the invoice period.

• The MSR shall be submitted with or before the corresponding invoice.

• At a minimum, the MSR shall include:

o Contract information;

o Costs invoiced for the relevant period;

o Costs invoiced to date;

o Accomplishments/status/updates;

o Deliverables/work products submitted;

o Identified risks and proposed mitigation;

o Activities planned for the next reporting period;

o Projected costs for the next reporting period;

o Project health; and o With alignment to contract objectives.

• The MSR shall include a Monthly Technical Progress Narrative (MTPN) detailing financial and technical performance for the NFIP.

o The reporting period for the MTPN may be different from the MSR reporting period.

o At the Contractor’s discretion, and in agreement with the COR, the MTPN may be submitted as a separate deliverable.

• At the Contractor’s discretion, and in agreement with the COR, MSRs for all active task orders may be combined into a single IDIQ MSR.

• Any combined report must maintain alignment to individual task orders and invoices.

• At the Contractor’s recommendation, and coordinated with the FEMA Program

Manager and COR, monthly recurring reports with similar due dates may be submitted as addenda to the MSR.

3.1.3.4. The Contractor shall submit or update deliverables as stated in the Deliverables Schedule (Appendix A).

• The Contractor shall maintain a spreadsheet or other means of tracking submittal and acceptance of deliverables and work products.

o Interim versions shall be submitted in conjunction with the Monthly Status

Report.

o A final version shall be submitted at the conclusion of the task order.

3.1.3.5. If requested by the COR, the Contractor shall facilitate quarterly in-progress review meetings to enable planning and tracking of service and delivery milestones.

3.1.3.6. FID utilizes digital platforms (including JIRA, SharePoint, Microsoft Teams) for collaborative work including the Integrated Master Schedule, Performance Management Dashboard, and Risk Register.

• The Contractor shall coordinate with FEMA and/or its Program Management Contractor as requested to inform inputs into these platforms.

3.1.3.7. The Contractor shall establish and maintain dashboards for major stakeholders (such as Claims, Underwriting, Appeals, etc.) served by this requirement.

• Dashboards under this requirement are intended to supplement and not replace other dashboards, reports, and oversight documents generated by Pivot the NFIP System of Record, other contractors, and the agency.

3.1.4. Business Continuity

3.1.4.1. The Contractor shall prepare and submit a Business Continuity Plan (BCP).

• The BCP Plan shall be due 15 business days after the date of award and shall be updated or affirmed as up-to-date on an annual basis.

• The BCP shall document Contractor plans and procedures to maintain support during an emergency, including natural disasters and acts of terrorism.

• The BCP, at a minimum, shall include the following:

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

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

o How the Contractor will communicate with the Government during emergencies;

and o A list of primary and alternate Contractor points of contact (telephone numbers & e-mails).

3.1.4.2. The BCP shall be activated immediately after an emergency has occurred.

• It shall be operational within 24 hours of activation or as directed by the

Government and shall be sustainable until the emergency situation is resolved and normal conditions are restored or the contract is terminated, whichever comes first.

• In the event of a life-threatening emergency, the COR shall immediately contact the Contractor Project Manager to ascertain the status of any Contractor personnel who were located in Government controlled space affected by the emergency.

• When any disruption of normal, daily operations occurs, the Contractor Project Manager and the COR shall promptly open an effective means of communication and verify:

o Key points of contact (Government and Contractor);

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

o Means of communication available under the circumstances (e.g., email, webmail, telephone, FAX, courier, etc.); and o Essential Contractor work products expected to be continued, by priority.

3.1.4.3. The COR and Contractor Project Manager will make use of the resources and tools available to continue contracted functions to the maximum extent possible under emergency circumstances.

3.1.5. Quality Management

3.1.5.1. The Contractor shall develop FEMA-approved Standard Operating Procedures (SOPs) for every business process, task area, and subtasks of the award as directed by the COR.

3.1.5.2. The Contractor shall provide a Quality Control Plan (QCP) within 15 business days of award and updated annually. Elements in the QCP shall include, but are not limited to:

• Distribution and storage of deliverables and work products;

• Procedures to ensure compliance with applicable Statutes, Regulations, and policies;

• Quality review processes; and

• Staffing and capabilities plan.

3.1.6. Records Management

3.1.6.1. The Contractor shall maintain a library of all Deliverables and final products as directed by the Government for the duration of the contract.

3.1.6.2. The Contractor shall maintain WYO and NFIP Direct data and information in accordance with FEMA Manual 5400.2 Records Management Files Maintenance and Records Disposition and DHS 0550.1 Records Management.

3.1.6.3. The Contractor shall maintain documents detailed below and make the copies available to FEMA upon request. The documents must be scanned within 30 days of receipt and retained according to applicable FEMA Records Disposition Schedules.

• NFIA Section 1316 (Denial of Flood Insurance) documents

• Coastal Barrier Resources Act documents

• Policy Inquiries documents

• Claims Appeal documents

• Notices sent to policyholders, as required by the Flood Insurance Reform Act (FIRA)

• Flood Insurance Reform Act (FIRA) notice acknowledgments returned by policyholders

• Severe Repetitive Loss and Repetitive Loss documents

• Underwriting documents

• Claims Documents

• Financial Documents

• Others upon request of the Government

3.1.6.4. The Contractor shall develop FEMA-approved SOPs for Records Management activities, and shall, as appropriate, recommend changes to the SOP and to FEMA Records Disposition Schedule.

• The SOPs are due annually per Appendix A: Deliverables Table.

• The media used for record keeping must follow the Federal Records Act, National

Archives and Records Administration regulations, and guidance provided by the FEMA Records Officer.

3.1.7. Transition-Out

3.1.7.1. The Contractor shall cooperate with FEMA and successor Contractor(s) to ensure a smooth and full transition of operations and knowledge and prevent stakeholder disruption.

• The successor Contractor shall lead transition, and the legacy Contractor shall support.

• The Contractor shall perform all contract requirements, as set forth in this SOW until directed otherwise in writing by the Contracting Officer (CO) or COR.

• Upon request from FEMA, the Contractor shall develop and submit to FEMA for review and approval plans for transitioning out within 15 calendar days of the COR’s request.

• The transition-out plan may be revised to accommodate elements of the successor Contractor(s) transition in plans and approach.

3.1.7.2. The Contractor shall comply with a 90-day transition period to allow for smooth transition to the successor(s), or as directed by CO and COR.

3.1.7.3. The Contractor shall participate in, and sign-off on, documents resulting from knowledge transfer sessions with FEMA and the successor(s) for various subject matters and business operations as defined by FEMA.

3.1.7.4. The Contractor shall return to FEMA, or transition to the successor Contractor(s) all Government Furnished Equipment (GFE) per guidance from the COR.

3.1.7.5. The Contractor shall provide FEMA all data, data files, audit trails, back-ups, electronic imagery, microform, and hard copy forms received, produced, and maintained throughout the life of the contract, along with specifications, documentation, and assistance to assure timely and unfettered access and use by FEMA and successor(s) within 15 days of notification by the CO.

3.1.8. Assumptions, Constraints, and Required Standards

3.1.8.1. The assigned Primary COR is the primary point of contact for this requirement.

• If the Primary COR is unavailable, the Contractor shall coordinate with the assigned Alternate COR or the Contracting Officer.

3.1.8.2. The Contractor shall provide continuous support for all tasks and scope elements identified in this requirement.

• Requirements for personnel substitutions are discussed in 5.0 Personnel.

3.1.8.3. Costs associated with performance will only be approved for reimbursement to the extent that they are reasonable, allowable, and allocable.

3.1.8.4. The Contractor shall obtain approval from the CO prior to incurring costs over and above those allowed for under the terms of this contract.

• Regardless of contract type, and of work location, Contractors performing work in support of authorized tasks within the scope of their contract shall charge those hours accurately in accordance with the terms of this contract.

3.1.8.5. The Contractor shall obtain approval from the CO prior to incurring costs to support Part C: Flood Disaster Operations.

3.1.8.6. Under the provisions of the Rights in Data General Clause (FAR 52.227-14), the Government reserves all rights, including copyrights, distribution rights, and other rights for all documents, data or software developed in the performance of this contract.

3.1.8.7. Quality Control is the monitoring and oversight performed by the Contractor to ensure that work is accomplished in accordance with the terms of the contract.

• FEMA performs quality control to verify that the Contractor is performing the work required by the contract.

• The Contractor shall manage quality. The Government will ensure quality through surveillance.

3.1.8.8. The Contractor shall ensure that deliverables and work products are free of spelling, grammatical, or punctuation errors and are precise, concise, and reflect agency values, clear writing and exemplary professionalism.

• Peer reviews and proofreading are required to ensure consistent and accurate information.

• Some materials developed require significant concurrence from many program offices within FEMA and may require multiple revisions.

3.1.8.9. Where applicable, reports, communications, and deliverables must comply with DHS, FEMA, and NFIP style and branding requirements or standard mutually agreed upon by the Contractor and the Government at the time of kickoff.

3.1.8.10. Forms, manuals and publications tasks shall be coordinated with FEMA’s Printing Officer, Forms Management Officer, and Information Officers, and consistent with their guidance.

• These objectives shall also be consistent with the Paperwork Reduction Act of 1995 and implementing Office of Management and Budget (OMB) Regulation 5 CFR 1320, the Joint Committee on Printing Regulations, and U.S. Government Publishing Office (GPO) regulations.

3.1.8.11. The Contractor shall provide management for compliance with Section 508 of the Rehabilitation Act of 1973 (508 Compliance) for deliverables and work products.

• Not all deliverables and work products will require 508 Compliance.

• The Contractor shall coordinate with the COR timelines for delivery that include sufficient time to accommodate significant FEMA and other reviews and allow for the Contractor to ensure 508 Compliance.

3.1.8.12. FEMA requires full compliance with all statutes and demonstrated working knowledge and understanding of applicable regulations, policies, guidelines, and specifications that affect the NFIP, FEMA, and DHS. For the Offeror’s convenience, some of these documents and related resources are listed below.

• Regulations governing the NFIP set forth in Title 44 of the Code of Federal Regulations (44 CFR), Chapter I, Subchapter B, commencing at part 59.

• [A] Plan to Maintain Financial Control for Business Written Under the Write Your Own Program (the “Financial Control Plan”), 44 CFR, Part 62, Appendix B. (The authority for the Write Your Own (WYO) Program as set forth in 44 CFR Parts 61 and 62, Sections 61.13 and 62.63.)

• WYO Accounting Procedures Manual

• Applicable NFIP statutes and regulations

• 42 U.S.C. § 4001 et seq.

• National Flood Insurance Act (NFIA) of 1968

• The Flood Insurance Protection Act of 1973

• The National Flood Insurance Reform Act of 1994

• The Flood Insurance Reform Act of 2004

• The Biggert-Waters Flood Insurance Reform Act of 2012

• The Consolidated Appropriations Act of 2014

• Homeowners Flood Insurance Affordability Act (HFIAA) of 2014

• Flood Insurance Manual

• NFIP Claims Manual

• NFIP Adjuster Fee Schedule

• Standard Flood Insurance Policy (SFIP) and associated forms

• Applicable FEMA-NFIP bulletins

• Pivot Use Procedures

• SRL approved letters/templates and procedures

• Debt Collection Act of 1982 (31 U.S.C. 3701 et seq.)

• Chief Financial Officers Act of 1990

• Generally Accepted Accounting Principles (GAAP)

• U.S. Government Accountability Office

• Individual State Departments of Insurance training regulations

• Paperwork Reduction Act (relates to all data collection)

• DHS Instruction Handbook 121-01-007, Department of Homeland Security Personnel

Suitability and Security Program

• Federal Information Security Management Act (FISMA)

• FedRAMP security guidelines (Attachment A)

• DHS 4300A Policy Directive (Version 13.3, February 13, 2023) and Attachments

• DHS Management Directive 11042.1, Safeguarding Sensitive But Unclassified (for

Official Use Only) Information

• DHS Handbook for Safeguarding Sensitive Personally Identifiable Information Section

508 of the Rehabilitation Act, as amended by the Workforce Investment Act of 1998 (P.L. 105-220)

• DHS Management Directive 4010.2, Section 508 Program Management Office & Electronic and Information Technology Accessibility

• DHS Section 508 Compliance Test Processes

• DHS Security Authorization Process Guide

• DHS Information Security Performance Plan (current fiscal year)

• DHS Privacy Incident Handling Guidance

• FIPS 140-2, Security Requirements for Cryptographic Modules

• NIST Special Publication 800-53, Security and Privacy Controls for [Federal]

Information Systems and Organizations

• NIST Special Publication 800-88, Guidelines for Media Sanitization

• FEMA Enterprise Configuration Management (CM) Plan

• FEMA Memorandum “Configuration Baseline Standards” dated April 9, 2015

• OMB Circular A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control

• OMB Circular A-130 , Managing Information as a Strategic Resource

• NARA Authority N1–311–86–1

• NARA Authority GRS 1.1

3.1.8.13. Unless otherwise stated, all references to days shall mean calendar days throughout this SOW.

3.1.8.14. Definitions and references to relevant authorities are considered to be accurate at the time of the drafting of this requirement.

• Definitions and authorities may change due to reauthorization of the NFIP, updates to policies, changes in Agency and office governance and organization, or other major events impacting the NFIP.

• The Contractor will be informed of actual changes when they occur or anticipated changes when they are known.

• In all cases, new official definitions, authorities, policies, etc. will supersede those included in this document.

3.1.8.15. The Contractor shall be subject to Government audits at any time on all or any activity and work products under this SOW.

3.2 Part B: Standard Operations

Standard Operations tasks shall adhere to the respective Service Level Agreements (SLA) established in Appendix B: Standard Operations – Service Level Agreement.

3.2.1. NFIP Programmatic Delivery Support

NFIP Technical Subject Matter Support

3.2.1.1. The Contractor shall provide NFIP programmatic subject matter expertise to support delivery of the NFIP.

• Providing support planning and execution of NFIP Program-wide initiatives, including but not limited to:

o Subject matter expertise and support for each of the task areas and FID branches;

o Support for proposed updates to program statutes, regulations, and policies;

o Support for programmatic delivery changes such as those resulting from statutory, regulatory, or policy updates;

o Identification and analysis of trends in various programmatic service areas;

o Programmatic analysis, recommendations, and planning; and o Programmatic enhancements.

Programmatic enhancements may include the implementation of premium payment installment plans, implementation of affordability programs, process improvements to capitalize on evolving technology, adoption of insurance industry standard practices, and other potential changes.

3.2.1.2. The Contractor shall provide subject matter expertise, technical editing, proofreading, graphic elements, and formatting support for production of NFIP documents.

(Other Contractors may be the lead for development and delivery of some deliverables). Such documents include:

• Flood Insurance Manual;

• NFIP Claims Manual;

• SFIP Commentary;

• WYO Accounting Procedures Manual;

• WYO Accounting Training Manual;

• WYO Arrangement;

• NFIP WYO Financial Control Plan; and

• Additional written products and related tasks as requested and approved by the COR, including:

o Translation of complex technical material into accurate, simple, and clear explanations or instructions;

o Identifying trends and issues and propose strategies to address them in program documentation;

o Creation and maintenance of operating forms, manuals, and other required publications, including bilingual materials, in accordance with all applicable Government regulations;

o Creation of text, tables, and graphics for the periodic revisions of NFIP documents;

o Technical review of products for accuracy and consistency;

o Ensuring all materials sent to GPO for print production are fully compliant with all FEMA, DHS, and GPO rules and regulations; and o Ensuring all web-versions of materials created are compliant with Section 508 of the Rehabilitation Act of 1973 before they are published.

3.2.1.3. The Contractor shall participate, provide subject matter expertise, and support for meetings with internal and external stakeholders (insurance agents, lenders, policyholders, independent adjusting firms, Write Your Own Companies, etc.) on the NFIP.

• The Contractor shall identify as a Contractor in all meetings and communication in accordance with FEMA policy.

• The Contractor shall prepare and supply materials, including agenda items, to facilitate communication of NFIP information to these audiences.

o These items must be approved by the Program Subject Matter Expert (SME) or

COR prior to the meeting.

• Upon request of FEMA, the Contractor shall provide meeting minutes or general notes within two business days after the meeting.

• Meeting support and participation may require travel.

3.2.1.4. The Contractor shall provide subject matter expertise and support for responses to Freedom of Information Act (FOIA) requests, Congressional inquiries, or other requests.

• The Contractor shall use existing routine reports or on-call reporting whenever possible to ensure the economy, responsiveness and integrity of the information provided.

• The Contractor shall perform quality assurance and deliver timely performance of all correspondence tasks.

Reporting Requirements

3.2.1.5. The Contractor shall be responsible for supporting FEMA HQ and Regions, Auditors, WYO Companies, other NFIP Contractors and others as identified by FEMA with each stakeholder’s report requirements.

• Reporting requirements shall be subjected to regular review for duplication and utility by the Contractor.

o FEMA will examine all reporting requests to determine the most expeditious and economical manner in which to satisfy the requirements.

• These requirements shall apply to all reports, for WYO Companies and the NFIP

Direct Contractor’s operations, including those reports generated for internal use by the Contractor as well as those provided for FEMA and NFIP stakeholder use.

• Technical reports, designs identifying source data and calculations performed within reports shall be delivered to the COR when scheduled or requested.

3.2.1.6. All reports generated from Pivot, the NFIP System of Record (SOR) shall be usable in multiple formats to fully support all NFIP stakeholders who are granted access to program data through FEMA authorization.

Program Audit

3.2.1.7. The Contractor shall furnish all pertinent files, records, documentation, procedures, data, and any other information which is in its possession that may be required by any governmental organization and requested of FEMA.

• Similarly, files, records, reports, data, other information, and assistance shall be furnished to the COR or CO for submission to the FEMA Office of Chief Counsel (OCC) for initiation or defense of litigation, or in connection with any other action or proceeding.

• FEMA will initiate all relevant requests of the Contractor, and the Contractor shall furnish these materials within the due date provided.

3.2.1.8. The Contractor shall support, upon request by the COR or CO, the Government in responding to audits or associated requests in all functional areas of Standard Operations including the annual external fiscal year audit that covers select aspects of the business processes described in this SOW, excluding those activities; roles; or duties performed by another awarded acquisition.

• The Contractor shall recommend opportunities for establishing internal audit activities for underwriting and claims analyses to assure the integrity of WYO underwriting and claims data and reporting.

• Identify, recommend, and (when approved by the Government) implement performance improvement opportunities for audit response timeliness and quality.

Policyholder Notices

3.2.1.9. The Contractor shall send with each new policy and additionally at each annual renewal by mode directed by the Government, the property’s loss history information, as required by the Flood Insurance Reform Act (FIRA), Section 202 (a)(4), the Claims Handbook, as required by FIRA, Section 204, the acknowledgment, as required by FIRA, Section 203, and a cover letter that references these enclosures.

3.2.1.10. The Contractor shall send policyholder notices for community actions as directed by

FEMA.

• Policyholders’ addresses are available through the NFIP’s System of Record, Pivot.

3.2.1.11. The Contractor shall implement and maintain electronic record-keeping procedures for the acknowledgement letter to show proof of mailing and receipt or lack of receipt of a policyholder’s signed acknowledgement.

3.2.1.12. The Contractor shall establish and maintain internal controls to assure the security and accounting for all postage, express delivery, freight, and delivery expenses of the program.

• The Contractor shall manage postage and express delivery activities to minimize costs to FEMA.

• The contractor shall identify and recommend efficiencies or modernizations that may lower the cost of printed materials and postage.

• The Contractor shall make best efforts to reduce postage, freight, and delivery costs by, for example, preparing mailing lists annually, using the most economic classes of mail, and using all applicable U.S. Postal Service discounts.

• The Contractor shall report to the COR all postal and express delivery expenditures, any unusual or unanticipated expenses, measures being taken, and progress being made to reduce the costs.

3.2.2. Underwriting Support

3.2.2.1. The Contractor shall provide underwriting subject matter expertise (SME) and customer experience (CX) to support FEMA, the WYO companies, the NFIP Direct, policyholders, and any other FEMA NFIP stakeholders to support in the underwriting policies to enable effective and consistent program implementation, providing clear guidance at all times.

• Contractor staff supporting this task shall have a minimum of five years of experience underwriting flood insurance.

3.2.2.2. The Contractor shall provide the following underwriting support:

• Technical assistance, as directed by FEMA, to WYO companies and the NFIP Direct

Contractor with applying the proper rules, guidance, and regulations of the NFIP to their policies as directed by the Government.

• Analysis, support, development, implementation, and communication of the requirements for any NFIP program changes.

• Collection of rating and payment information, calculate refunds, perform quality control, and process prior term premium refunds as directed and approved by FEMA, including HFIAA Section 28 provisions, and coordinate with the POC for financial management when applicable or as directed by the Government.

o The Government will provide payment of the refunds.

• Drafting responses to NFIP inquiries from a WYO, NFIP Direct, or other NFIP stakeholders, as directed by the Government.

• Underwriting technical expertise in Operation Reviews.

• Review of NFIP policies for accurate rating and processing to ensure valid documentation and policy information was obtained by the WYO or NFIP Direct as directed by the Government.

• Coordinating Coastal Barrier Resource Act (CBRA) eligibility with the U.S. Fish and Wildlife Service and the WYO or NFIP Direct as directed by the Government.

• Providing the status of ongoing and completed inquiries and tasks to the NFIP’s Underwriting and Customer Care Branch POCs and COR weekly.

3.2.2.3. The Contractor shall receive, resolve, and track underwriting inquiries and coverage problems referred by FEMA, policyholders, agents, WYO companies, state insurance departments, and others.

• For inquiries where there is a question of coverage involving policy interpretation, the Contractor shall notify the Customer Care Branch (CCB) Team Lead for clarification within 24 hours of receipt of the inquiry.

• The Contractor has three business days from the date of receipt to respond to a WYO company or NFIP Direct Contractor inquiry or forward it to FEMA.

• The Contractor has three business days from receiving FEMA’s response to an inquiry to send it to the WYO Company or NFIP Direct Contractor.

3.2.2.4. The Contractor shall perform data analytics of internal performance metrics to demonstrate timeliness of inquiry responses, policy appeals, and other metrics associated with Underwriting as determined by FEMA.

3.2.2.5. The Contractor shall review, track, and process CBRA properties, leased federal properties, properties ineligible for coverage under Section 1316 of the NFIA (1316 Properties), and prior loss appeals for the resolution by FEMA.

3.2.2.6. NFIP Related Inquiries: The Contractor shall support NFIP inquiries, activities include:

• Support the collection and submission of data to substantiate policy inquiries, including but not limited to NFIA Section 1316 designations, CBRA eligibility, severe repetitive loss, floodproofing, any type of waivers and leased federal properties.

• Review and recommend approval or denial of the policy inquiry.

• Coordinate with other FEMA contractors to ensure that the policy inquiries are fully adjudicated in a timely manner.

• Implement any adjustments or corrective actions because of FEMA’s adjudication of the policy inquiry.

• Coordinate CBRA eligibility with the U.S. Fish and Wildlife Service and the WYO or

NFIP Direct as directed by the Government.

• Draft responses for incoming FEMA Underwriting correspondence.

o This includes obtaining and validating the information from the WYO or NFIP Direct, drafting the response, and providing the draft to FEMA.

o The Contractor shall use approved language and templates by FEMA at the time of kickoff or as directed by the Government.

3.2.2.7. Prior Term Refunds: The Contractor shall:

• Validate requests for prior term refunds within 14 days of receipt;

o The Contractor shall adhere to the process specified in the Flood Insurance Manual.

• Submit requests to issue refunds to the NFIP Financial Management Contractor within two business days of validating the initial request;

o Requests for refunds of over $10,000 must be approved by FEMA before being sent to the NFIP Financial Management Contractor.

• Coordinate with the NFIP Financial Management Contractor regarding check processing and the disposition of stale-dated checks;

• Coordinate with FEMA stakeholders to notify WYOs when checks have not cleared in a 30-day, 60-day, 90-day, and greater-than-90-day timeframes; and

3.2.3. Claims Operation Support

3.2.3.1. The Contractor shall provide support for claims processing to NFIP stakeholders to ensure the proper collection of accurate claims information for all claims.

3.2.3.2. The Contractor shall provide experienced flood insurance claims personnel to respond to and support FEMA, the WYO companies, the NFIP Direct Contractor and other NFIP stakeholders in the implementation of the NFIP.

3.2.3.3. The Contractor shall provide general adjusters who serve as subject matter experts for NFIP claims experience, as follows:

• General adjusters for residential claims must have a minimum of five years flood insurance claims experience.

o The Contractor shall provide a team general adjusters for residential flood claims estimating.

• General adjusters for commercial and condominium claims must have a minimum of five years of flood insurance claims experience and five years of commercial and condominium insurance, including experience with RCBAP.

o The Contractor shall provide a team general adjusters for commercial and condominium flood claims estimating.

• General adjusters shall be proficient and have direct claims experience handling claims under the Standard Flood Insurance Policy – all forms.

• General adjusters shall possess knowledge in Increased Cost of Compliance (ICC), mitigation, and NFIP underwriting rules.

3.2.3.4. General Adjusters: The Contractor shall provide a team full time general adjusters with NFIP flood insurance claims experience to support reinspections, correspondences and other NFIP Program inquiries/issues.

• The general adjusters are required to be claims professionals, have correct authorization with an active Flood Control Numbers (FCN), have appropriate NFIP flood insurance claims experience to expertly address difficult technical claims issues with policyholders and their representatives and have the computer and software skills necessary to perform the duties.

• The general adjusters shall demonstrate excellent customer service skills and shall be proficient in technical writing and communication skills.

3.2.3.5. NFIP general adjusters may be required to travel extensively in the United States, and the U.S. Territories.

3.2.3.6. Flood Adjuster Registration Management: The Contractor shall obtain information regarding adjusters seeking NFIP registration or annual reregistration from the NFIP training Contractor.

• The Contractor shall transition in from the NFIP training Contractor information (dates, names, etc.) regarding adjusters seeking NFIP registration or annual registration renewal.

o FEMA requires all registered adjusters to renew registration annually to ensure that information in the database or SharePoint is current for every registered adjuster.

o All Adjuster registration and status shall be uploaded to SharePoint.

• The Contractor shall use this information to track the adjuster’s training, which is a prerequisite for NFIP registration and reregistration, distribute adjuster authorization documentation with FCN cards, and maintain historical records.

• The Contractor shall maintain a list of active adjusting companies and training plans from all Flood Adjuster Capacity Program (FACP) WYO approved adjusting companies.

3.2.3.7. The Contractor shall submit a plan to provide additional qualified and registered adjusters with an active FCN to the COR for approval prior to May 1 each year.

3.2.3.8. Collection of Claims Information: The Contractor shall be the focal point for the collection of information about coverage issues, policy interpretation, severity questions, and all other claims matters.

• If the issue is critical or time sensitive, the issue shall be referred to FEMA within 24 hours of such determination.

• Otherwise, the Contractor shall process all claims information and subsequently notify FEMA of issues encountered and all actions taken by the Contractor within seven business days.

3.2.3.9. Increased Cost of Compliance (ICC) Reporting: The Contractor shall maintain a log of all claims reported where the policyholder consents to the assignment of the ICC claim payment.

• The Contractor shall obtain a copy of the Assignment of Increased Cost of Compliance and supporting documentation to be disseminated to the appropriate WYO carrier or the NFIP Direct Contractor.

• The Contractor shall submit an ICC report detailing the status of all ICC activities quarterly.

3.2.3.10. Claims Operation Reviews: The Contractor shall provide NFIP subject matter experts to support claims Operation Reviews.

• FEMA will annually define minimum capabilities of the SMEs via the SOP prior to the Reviews.

3.2.3.11. WYO Operation Reviews: The Contractor shall support the oversight team in the assessment and evaluation of WYO operations on a recurring basis.

3.2.3.12. Subrogation and Discovery: The Contractor shall support the FEMA Office of Chief Counsel (OCC) and the DHS Office of the Inspector General (OIG) with FEMA’s Subrogation and Discovery Response initiatives by conducting special subrogation claims projects and analyses involving but not limited to:

• Appearing as witnesses for hearings, proceedings, or depositions, investigatory assistance, retention of expert witnesses or retention of outside counsel, etc. in the time frame communicated by OCC;

• Performing claim reviews and litigation discovery assistance;

• Collecting and maintaining information on all Cause of Loss and Subrogation

Reporting forms submitted by WYOs and NFIP Direct;

• Performing field investigations to identify and target subrogation prospects;

• Requesting claims and underwriting files from WYOs and NFIP Direct; and

• Support other ad hoc claims analyses and subrogation initiatives as required.

• The Contractor may be required to perform this task on site (FEMA Headquarters).

• The Contractor shall submit a report detailing the status of subrogation tasks quarterly.

3.2.3.13. Claims Reinspections: Under FEMA direction, the Contractor shall plan, implement, and manage the NFIP Claims Reinspection process.

• There are three routine categories of reinspections: Congressional, Appeals, and Special Assists.

• Major Functions for Claims Reinspections:

o The Contractor is required to have NFIP authorized general adjusters make on-site property reinspections; one general adjuster is required at each reinspection.

o Adjuster Preliminary Damage Assessment (APDA): The Contractor shall collect APDA forms via email and enter necessary data into the SOR for reports used by community floodplain management and FEMA.

o The Contractor shall analyze and summarize the results of the reinspections, including identifying trends, overpayments, and underpayments, etc.

The Contractor shall provide a recurring report on reinspection activities to

FEMA.

FEMA must approve the format of these reports.

o The Contractor shall maintain a detailed database in SharePoint of the reinspections and the associated findings.

o The Contractor shall provide feedback to FEMA, the WYO companies, and the

NFIP Direct Contractor on claims matters arising from reinspections, including repeated issues and trends.

o The Contractor shall support FEMA by reviewing and investigating losses through claim file desk reviews or on-site reinspections.

o The general adjusters shall record and report their findings on the reinspection form, which shall be completed in full and signed by both the WYO company representative and the NFIP general adjuster indicating agreement with the findings.

o The reinspection form shall include if there was an under/over payment.

3.2.3.14. Special Claims Projects: As requested of the COR, the Contractor shall support special claims projects and ad-hoc analyses.

• Projects may involve an in-depth review of claims files and field surveys of specifically identified areas (e.g., condominiums, ICC, repetitive loss, subrogation, CBRA, etc.).

• Projects may involve reviewing, recommending approval, and processing CBRA Properties, Leased Federal Properties, NFIA Section 1316 designations, and Severe Repetitive Loss (SRL) Properties appeals for resolution by FEMA.

• Projects may involve a complete review and reregistration of independent adjusters based on updated categories.

3.2.4. Claims Appeals

3.2.4.1. Claims Appeals: The Contractor shall support the claims appeals process. Such support includes:

• Provide two teams of specialists:

o One team that supports the substantive aspects of appeals process through triage, insurer response, and examiner determination queues in Pivot.

This team shall be comprised of flood insurance adjusters and examiners during periods of regular operations, with demonstrated prior experience handling Dwelling, General Property, and Residential Condominium Building Association Policy (RCBAP) flood insurance claims and no less than seven years of experience.

o One team that writes appeals decision memos, to be reviewed and approved by FEMA, in the editorial review queue within Pivot.

This team shall be comprised of technical writer capabilities that are experienced in using the Issue, Rule, Application, Conclusion (IRAC) format.

o Specialists shall comply with the most recent edition of the Appeals Desktop Reference (included separately) on all applicable documents and deliverables submitted to the Government.

• At the direction of the COR, coordination with other stakeholders to ensure that the policy appeals are fully adjudicated in a timely manner as directed by the Government.

• Requesting claims files, uploading the documents and synopses, and facilitating the reviews of these files.

• At the direction of the COR, scheduling calls and meetings for FEMA and policyholders about post-decisions call requests.

• Implement any adjustments or corrective actions as a result of FEMA’s adjudication of the policy appeal.

• Monitor and report legal action taken by policyholders who have active appeals.

• Monitor and include carrier resolved activities within decision recommendations.

• Review and recommend approval or denial to FEMA of the policy appeal. FEMA makes the final determination.

• Support the collection and submission of data to substantiate policy appeals including but not limited to NFIA Section 1316 designations, CBRA eligibility, repetitive loss, severe repetitive loss, property address waivers, floodproofing, special rating, leased federal properties, and prior term refunds.

• Support the maintenance of the FEMA Appeals email inboxes, including logging and responding to inquiries from policyholders, when appropriate.

o There are currently two inboxes.

• Support the training of WYOs and NFIP Direct Contractor, upon their receiving access to the Pivot Appeals application.

3.2.4.2. The Contractor shall update the Claims Appeal claim file and synopsis requests to WYOs and the NFIP Direct shall be complete within one business day of receipt and assignment in Pivot.

3.2.4.3. The Contractor shall deliver a recommendation regarding the substance of the appeal to FEMA in the Examiner Determination queue after receipt of the synopsis from the WYO or NFIP Direct within five or ten business days, based on the following criteria:

• If the appeal is determined by FEMA examiners to be simple, the recommendation must be completed within five business days of assignment.

• If the appeal is determined by FEMA examiners to be complex, the recommendation must be completed within 10 business days of assignment.

3.2.4.4. The Contractor shall adhere to the most recent edition of the Appeals Desktop Reference (included separately) on all applicable documents and deliverables submitted to the Government.

3.2.4.5. The Contractor shall clarify any questions during the memo drafting process with the FEMA examiner who completed the examiner determination as quickly as practicable and before delivery to the Editorial Review queue.

3.2.4.6. The Contractor shall deliver a final draft decision memo to FEMA in the Examiner Determination queue within 10 days (within 15 days if complex, as determined by FEMA) following FEMA examiner determination and assignment to the Contractor in the Examiner Determination queue.

3.2.4.7. The Contractor shall submit a weekly report detailing the status of all appeals.

3.2.5. Regional Support

3.2.5.1. The Contractor shall provide a full-time liaison to support each of the FEMA Regional Offices on flood insurance inquiries and issues.

• The Contractor may be required by the Region to sit within one of the Regional Offices or FEMA Joint Field Offices (JFO) with COR approval.

• The Contractor shall identify as a Contractor in all meetings and communication in accordance with FEMA policy.

• The Contractor shall provide meeting minutes during all meetings to ensure mission objectives and outcomes are captured during regional calls.

3.2.5.2. The Contractor shall provide support for the following activities:

• Assist stakeholders (policyholders, insurance agents, community officials, realtors,…