COMBINED Solicitation 70FB8024R00000028 Questions and Answers.xlsx

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FEMA Individuals and Households Program (IHP) Field Services Contract Federal contract opportunity
Solicitation number
70FB8024R00000028
Issued by
Federal Emergency Management Agency Community Survivor Assistance Section

About this file

This document is a Questions and Answers file related to a Request for Proposal (RFP) issued by the Federal Emergency Management Agency (FEMA) for an Individuals and Households Program (IHP) Field Services Contract, Solicitation Number 70FB8024R00000028.

The RFP is for an indefinite-delivery indefinite-quantity (IDIQ) contract to conduct damage assessments in response to presidentially declared disasters throughout the United States and its territories. Key details include: the RFP will be evaluated in two phases, with Phase I focused on technical factors and Phase II focused on past performance and price; the contract will require a Small Business Subcontracting Plan; and the Performance Work Statement has specific requirements for personnel training, security clearances, onboarding, and productivity. The Questions and Answers document provides clarification on various procurement and technical requirements.

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Other files for this federal contract opportunity

Other files attached to FEMA Individuals and Households Program (IHP) Field Services Contract, newest first.
File Type Posted
70FB8024R00000028 Amendment 003.pdf PDF
Attachment 4 - Inspector WD 2000-0127 Rev 50 07222024.pdf PDF
70FB8024R00000028 Amendment 002.pdf PDF
70FB8024R00000028 Amendment 001.pdf PDF
TE 09 E-Mail and SharePoint Procedures - Amendment 001.pdf PDF
TE 01 On-Site Assessment Guidelines - Amendment 001.pdf PDF
Attachment 1 IA FSC Performance Work Statement - Amendment 001.pdf PDF
Attachment 2 Performance Requirement Summary - Amendment 001.pdf PDF
TE 03 ACE 5 User Guide August 2024 - Amendment 001.pdf PDF
TE 15 Hello Letter - Amendment 001.pdf PDF
COMBINED Solicitation 70FB8024R00000028 Questions and Answers.pdf PDF
Attachment 7 - Instruction 119-7-1 FEMA Personal Property Asset Management Program.pdf PDF
TE 16 Missed You Letter.pdf PDF
TE 12 Personnel Security 07302024.pdf PDF
TE 19 - Invoice template 2024.pdf PDF
TE 15 Hello Letter.pdf PDF
TE 05 Remote Housing Assessment Job Aid.pdf PDF
Attachment 3 - QASP.pdf PDF
TE 11 Mobile Device Agreement.pdf PDF
TE 04 Remote Housing Assessment Script.xlsx XLSX spreadsheet
Attachment 4 - Inspector WD 2000-0127 Rev 47 06302023.pdf PDF
Attachment 9 - Productivity and Staging Table.xlsx XLSX spreadsheet
TE 18 DSA SOW.pdf PDF
TE 13 JIT Hiring Activation SOW.pdf PDF
TE 10 Mandatory Training.pdf PDF
TE 22 Customer Service FAQ.pdf PDF
Attachment 5 - FEMA Personnel Standards of Conduct Directive.pdf PDF
TE 09 E-Mail and SharePoint Procedures.pdf PDF
Attachment 8 - Questions Submission Matrix - IHP Field Services.xlsx XLSX spreadsheet
TE 03 ACE 5 UserGuide November 2023.pdf PDF
TE 20 FEMA Post Travel Expense Summary 2024 updated.pdf PDF
TE 01 On-Site Assessment Guidelines.pdf PDF
Attachment 1 - Performance Work Statement.pdf PDF
TE 02 Remote Assessment Guidelines.pdf PDF
Table A - Historical Inspection Activity.pdf PDF
TE 06 FEMA Corrections.pdf PDF
TE 07 QC Spreadsheet.xlsx XLSX spreadsheet
70FB8024R00000028 issued 08-03-2024.pdf PDF
TE 21 FEMA Travel Mileage Log 2024 rates.pdf PDF
TE 17 DRC SOW.pdf PDF
TE 08 Key Contractor Personnel.pdf PDF
TE 14 Training Request SOO.pdf PDF
Attachment 2 - Performance Requirement Summary.pdf PDF
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Questions & Feedback

Questions/ Feedback Submission Form
IHP Field Services ContractRFP: 70FB8024R00000028
First Name:Please save file as: 70FB8024R00000028_Questions_LastName_MMDDYYYY.xlsx
Last Name:
Email Address:
Company:
Submittal Date:
Category Definitions:

Critical - Refers to significant content issue that should be addressed (i.e., content would cause conflicts, flaws, confusion, and/or voids when implemented) Substantive - Refers to factually incorrect information Administrative - Refers to typographical, grammatical, or formatting errors; vague or unclear meaning New - Refers to newly submitted language

NumberPage # StartSectionParagraphOfferor QuestionGovernment Response
127RFP Section IContract Clauses, Clause 52.212-5 Contract Terms and Conditions Required To Implement Statutes or Executive Orders -
Commercial Products and Commercial Services. (MAY 2024), Paragraph b, Item 21Clause 52.212-5 includes, "[X] (21)(i) 52.219-9, Small Business Subcontracting Plan (SEP 2023) (15 U.S.C. 637(d)(4))."

At what stage is the Small Business Subcontracting Plan required?

The small business subcontracting plan will be submitted as part of Phase II of this procurement. The solicitation will be amended for clarity.
282RFP Section L.4.3Offeror Oral Presentation ParticipantsSection L.4.3 states, "Participants must be an employee of the Offeror."
Can FEMA confirm the "Offeror" is inclusive of teaming partners providing personnel who will perform essential roles after award?The term offeror is inclusive of the prime contractor and any key or major subcontractors or teaming partners.
382L.4.3 OFFEROR ORAL PRESENTATION PARTICIPANTS1Will the Government please clarify whether the term"offeror" includes the prime contractor and major subcontractors?The term offeror is inclusive of the prime contractor and any key or major subcontractors or teaming partners.
484RFP Section L.2.1PHASE I, Paragraph cSection L.2.1 states, "After notification is made, and the contracting officer has received vendor response with their intention to continue or not with Phase II, Instructions will be provided for submittal of the Phase II written submittals (Factor 4: Past Performance and Factor 5: Price) and for scheduling the oral presentation (Factor 2: Personnel Recruitment and Onboarding and Factor 3: Management Approach)."
Will offerors have an opportunity to submit questions after the down-select and additional instructions are provided?Offerors will be granted an opportunity to ask questions as part of Phase II of the procurement.
584RFP, L.9 Questions1Would FEMA please confirm that offerors will have the opportunity to submit questions for clarification from FEMA after receiving Phase II RFP documentation?Offerors will be granted an opportunity to ask questions as part of Phase II of the procurement.
657SECTION J TABLEAttachment 5.1The cost model is scheduled to be released with down select notifications. Will there be an opportunity to ask questions on the cost model after it is released?Offerors will be granted an opportunity to ask questions as part of Phase II of the procurement.
725H.103Background: "For purposes of administration of the Act, wages and hours worked by service employees under this contract; must be calculated on the basis of a fixed and regularly recurring workweek of seven consecutive 24-hour workday periods, and the records must be kept on this basis."
Will the Government please clarify the exact formula for determining compliance under the Act?Wages paid must be in compliance with the applicable Department of Labor wage determination in the area in which the work will take place, with the exception of pay for damage assessors/inspectors. The damage assessor/inspector wage determination is an unpublished, nationwide wage determination, and a copy was provided as part of the solicitation.
881L.2.1 PHASE I(a)Background: "Offerors who are rated most highly for Factor 1 will be advised to proceed to Phase II of the proposal submission process."
Will the Government provide a general timeframe estimate between proposal submission and initial Phase I review and Advisory Down-Select Notification to offerors advised to proceed to Phase II?The government anticipates Advisory Down-Select Notifications will be provided approximately 2 weeks after the Phase I submittal due date. However, please note that this is an estimate only, and many factors could cause the notifications to be issued sooner or later than the estimate provided.
982L.3.1 PHASE I WRITTEN SUBMISSION: FACTOR 1.A AND 1.B (SCENARIO RESPONSES)1Background: "Written responses to these scenarios shall be no more than five (5) pages each, and the total written submittal provided shall not exceed ten (10) pages, not including a single title and/or cover page and the completed Attachment 9, Staging and Productivity Table."
Will the Government please clarify whether the scenario responses should be provided: (1) as a single document not to exceed 10 pages with the exception of a single cover page; or (2) as two seperate response documents not to exceed 5 pages each with a single cover page on each?A single cover page shall be submitted as part of an offeror's Phase I response. The response shall consist of a single document including the cover page, a response to each scenario that does not exceed the page limits stated, and the completed Attachment 9, Staging and Productivity Table.
1082Solicitation Document (70FB8024R00000028), L.3.1"Written responses to these scenarios shall be no more than five (5) pages each, and the total written submittal provided shall not exceed ten (10) pages, not including a single title and/or cover page and the completed Attachment 9, Staging and Productivity Table."Will the Government please confirm the Executive Summary is considered outside of the 10 page limit?All information submitted, other than the single title and/or cover page and the completed Attachment 9, Staging and Productivity Table shall be counted as part of the 10 page limit.
1182L.4.3 OFFEROR ORAL PRESENTATION PARTICIPANTS1Background: "No more than six (6) total Offeror participants shall attend the oral presentation."
Question: Will an individual solely providing audio-visual support during the presentation be counted as one of the 6 "participants"?Any participant logged into the presentation or appearing on screen as part of the presentation will be counted as one of the six (6) participants.
1288M.4.1 Factor 4 - Past PerformancePara 1M.4.1 states "Attachment 6 Past Performance Form" (on p88) has been provided but it was not included with the final solicitation documents. Would the Government please provide this?Attachment 6 Past Performance Form will be provided as part of Phase II, and the solicitation will be amended for clarity.
1357J - List of Documents, Exhibits and Other AttachmentsTablePlease provide Attachment 6, Past Performance Questionnaire prior to Phase II downselect. These items can take time to obtain and having this form immediately would facilitate our success in obtaining a completed form from our client(s).Attachment 6 Past Performance Form will be provided as part of Phase II, and the solicitation will be amended for clarity.
141SF 1449Since the SF 1449 requires the offeror to sign and return it, would the government like this returned with Phase 1 or the Phase 2 written submission and where in the proposal is it to be included, e.g., in Factor 5 Price?The submisstion of the signed SF1449 will be done along with the pricing submittals in Phase II of this procurement. The solicitation will be amended for clarity.
1558-79Section K Reps and CertsAre the Reps and Certs to be provided with the proposal? If so, are they to be provdied with Phase 1 or the Phase 2 written submission and where in the proposal are they to be included, e.g, in Factor 5 Price?Reps and Certs not addressed in FAR 52.204-7 System for Award Management will be submitted as part of Phase II of this procurement. The solicitation will be amended for clarity.
1688M.4.1 FACTOR 4 – Past PerformanceRecency is a time period during which past performance reference are considered relevant and is critical to

establishing the relevancy of past performance information. Recency is past performance information that

is within three (3) years of the due date provided for the written past performance submittal.Will the Government please consider allowing past performance for projects completed within five (5) or seven (7) years of the due date for the written past performance submittal? Large-scale disaster events, while seemingly increasing in frequency, do not happen every year, so allowing projects that have been completed within the past seven (7) years will allow vendors to provide the Government past performance for large storm events requested in the RFP as few of these events have occurred within the past three (3) years.The government will amend the solicitation allow for past performance information for projects completed within 5 years.
1784L.6 PHASE II - FACTOR 5: PRICE - PROPOSAL SUBMITTAL REQUIREMENTSInstructions for price submittals will be provided after receipt of the offeror's notification that it intends to
proceed to Phase II of the procurement as outlined in paragraph L.2.1 of this solicitation.Please provide the instructions for the price submittal prior to Phase II downselect. It is important for us to understand how the Government will review and award task orders from a pricing standpoint as it pertains to our response to the two scenarios that make up the Phase I submittal.Specific instructions for pricing will not be provided prior to Phase II. Pricing will not be evaluated as part of Phase I, and pricing information is not required as part of the Phase I submittal.
1857J - List of Documents, Exhibits and Other AttachmentsTablePlease provide Attachment 5.1 Cost Model prior to Phase II downselect. It is important for us to understand how the Government will review and award task orders from a pricing standpoint as it pertains to our response to the two scenarios that make up the Phase I submittal.The pricing spreadsheet will not be provided prior to Phase II. Pricing will not be evaluated as part of Phase I and pricing information is not required as part of the Phase I submittal.
193AContract/FormWith the pricing options are you looking for us to price just one or all of them?Specific instructions for pricing will not be provided prior to Phase II. Pricing will not be evaluated as part of Phase I, and pricing information is not required as part of the Phase I submittal.
203AContract/FormWill vendors be required to pick and use one pricing model or is there variability depending on the event and the SOW put forward?Specific instructions for pricing will not be provided prior to Phase II. Pricing will not be evaluated as part of Phase I, and pricing information is not required as part of the Phase I submittal.
2112E.2Performance EvlauationWhat are the required number of performance evaluations to be completed on an assignment?Section E.2 refers to the Gov’t right to inspect and/or evaluate the work being performed and the location its being performed. Gov’t has the authority to visit/audit the contractor’s facility(ies) to confirm compliance. The COR or designated personnel will evaluate the Contractor’s performance, quality and timeliness of services provided as outlined in the QASP and PRS.
228B.6Other Direct CostsBy Contractor Acquired Property does that indicate rental expense for a local office space or temp facility to the event?If during an event contractor requires local office space or temporary facilities to support disaster operational activities, contractor must receive prior authorization. Contractor must comply with rules and procedures for Disaster Specific Contractor Acquired Property as referenced in Attachment 7 Personal Property Manual 119-7-1
2382RFP, L.3 Proposal Parts and Planned Due DatesTable of DatesWould FEMA please resolve the conflict in RFP language between the Table of Planned Due Dates (which indicates oral presentations will take place approximately 2 weeks from Advisory Down-Select Notification) and Section L.2.1.c (which indicates they will take place three weeks from Advisory Down-Select Notification)?The correct timeframe is 2 weeks from Advisory Down-Select Notification. Solicitation has been amended to correct this discrepancy.
243Attachment 2 PRS Section IIIRequirement Section 1: Quality Management and Production ObjectivesThe PRS states, "The Contractor shall provide FEMA their Quality Management System (QMS) demonstrating acknowledgement of FEMA’s IHP Field Services contract requirements." and "Submitted proposals demonstrating the interactions between QMS processes in order to achieve deliverables will need to be deemed acceptable by FEMA."
At what stage is the QMS required?QMS plans are due at the close of the Phase-In activity (post award). Reference section III of the PRS opening paragraph.
256Attachment 2 PRS Section IIISSPA # 1.C – Customer Service, Threshold, Item #3The PRS states, "Surveys shall measure the assessor’s conduct, performance, professionalism, timeliness (assessor meeting scheduled time) and capability to convey the assessment process and next steps to the survivor with a 95% satisfaction rating."
For meeting the timeliness rating, can assessors schedule appointments for a window of time (e.g., between 1 - 5 PM) or are they required to be at a specific time (e.g., 1 PM).This stipulation is part of the inspector's customer service rating. Contractors should know and understand survivor needs to include acceptable appointment timeframes while meeting production and timeliness requirements.
261TE 01 On-Site Assessment GuidelinesContacting the ApplicantTE 01 states, "The assessor will establish an appointment for the assessment with the applicant, co-applicant, or authorized 3rd party via phone call or text on each attempt. Email is not authorized."
Is the contractor responsible for scheduling all appointments for contractor assessors, or will FEMA assessors also be scheduling appointments for contractor assessors?The contractor, and or their contracted or employed contingent is responsible for establishing the appointed schedule with the applicant.
271TE 01 On-Site Assessment GuidelinesContacting the ApplicantCan FEMA provide more information on how contractor assessors can contact survivors, schedule appointments, and arrive at scheduled locations without access to PII on their personal devices such as cell phones and GPS?At this time, FEMA is not limiting contracted entities from contacting the applicant using personal devices via telephone or text.
28TE # 12TE # 122Will the Government please clarify the pre-screening requirements including the minimum type and recency of background checks required? Will the Government please clarify how we will be held accountable to the pre-screening process, such as whether the Government will require an associated deliverable such as a number of favorably adjudicated backgrounds to ensure adequacy in the pre-screening process? Will pre-screening reports need to be submitted to the Government and, if so, on what schedule?PSD can accommodate 60 per month per vendor for normal monthly submissions and attrition offset. The number of submissions is based on available budget of the vendor. Each vendor will need to determine their own attrition percentage as appropriate to their operations model. TE 12 outlines the 5-year review cycle for standard full MBI processing - Eligibility determinations based on a T2, or T4 (or the equivalent DCSA investigation) are valid for five years from the date that the investigation was completed and closed.

Prescreening of potential contractor personnel ensures the most viable candidate is submitted, potentially decreasing Denials. Government does not require a pre-screening report.

29 2 TE 18 DSA + SOW SECTION 3 3 Background: "25% of the deployed contingent should be Spanish/English multilingual."

Will the Government please clarify how bilingual proficiency will be assessed, including specific testing criteria used or metrics evaluated? Is 25% the standard for ALL deployments or will it vary by task order?FEMA has not established proficiency tests validating multilingual personnel. At a minimum, multilingual personnel should be proficient in both speaking and writing in both Spanish and English for this condition. The request is to have up to 25% of deployable personnel with this capability, but it is understood that this condition is contingent by disaster assignments.
302TE 13 JIT + HIRING ACTIVATION + SOW SECTION 21Background: "Minimum number of 10 candidates at a time to be transported."
Will the Government please clarify whether there is a maximum number of candidates to be transported?The Just in Time processing centers typically curb the volume of candidates arriving to the facility in increments of 10 - 20 per hour per contractor.
311TE 13 JIT + HIRING ACTIVATION + SOW SECTION 11Is there a limit to the number of candidates we can submit to the Government in order to meet the minimum quota while addressing natural workforce management issues such as lack of approval, lack of participation, or unforeseen circumstances?The number of candidates for a JIT Hiring Activation is based on the minimum output of X number of candidates for adjudication processing and subsequent activation to perform work on current active disaster task orders.
323PWS + TE 104Will the Government please clarify if the training content currently exists, will be created by the Government, or is expected to be created by us as part of this contract? TE 10 indicates that the content is created as part of the contract, but the PWS says we must create it and submit it for approval. Will the Government please clarify this approval process?The mandatory training outlined in TE 10 is provided through government links, and vendor purchased options for unconscious biases. Operational training will be provided by the vendor using FEMA provided instructional documents such as guidelines, PWS and the PRS.
332852.204-21(a), (b)May we leverage survivor address data for workforce scheduling and deployment purposes?Retaining applicant PII data on GFE is permissible when following the Section 7.5 PWS requirements.
3416Attachment 1, PWS, 5.3 Duty Readiness Plan"The plan shall contain the baseline personnel to meet the requirements of the contract, to include the quantity, positions (assessor, reviewer, supervisors) to fulfill the production minimum requirement to return 10,000 assessments per day by day 15 for combined Task Orders."Can the Government confirm that each scenario (Scenario 1 and 2) should be responded to independently and separately from other PWS language, e.g., Duty Readiness Plan?Each scenario for Factor 1.a and 1.b should be responded to separately. Factor 2 should address vendor capacity to meet the 10,000 per day requirement.
3516Attachment 1, PWS, 5.3 Duty Readiness Plan"The plan shall describe support processes to ensure that every assessor is fully equipped with functional tools to perform the work assigned, access to home office support for problem solving, utilization of FEMA approved contractor travel policies (Reference Federal Travel Regulation (FTR) in PWS Section 6.2), following personnel security adjudication criteria, and develop training courses to be taught to assessors and personnel assigned to the contract."Is the Contractor responsible for contractor personnel lodging (and other services, e.g., office space, food service, bathrooms, laundry services) or will FEMA provide some or all these services?The contractor is responsible for it's personnel's wrap-around services such as lodging, food, laundry services. Such services are subject to reimbursement by the Government per negotiation.
3615Attachment 1, PWS, Section 5.1 General Information"In today’s environment affording remote communication capabilities, it is incumbent on the Contractor to be conscientious when exercising administrative cost and assessment measures
under this contract."Can the Government clarify if FEMA life safety requirements require a minimum of two (2) persons for on-site work at each HH inspection site under this contract work?Within the scope of work defined in this solicitation, there is not a current Government requirement of a minimum of two persons for an onsite inspection/assessment.
37Attachment 9 - Productivity and Staging TableColumn HeadersWill the Goverrnment clarify the meaning/requirement of the column heading titles, as below, for daily activities? Issued Daily - is this the number of HH site inspections assigned each day? Return Daily - is this the number of assigned HH site inspections completed each day? # of Inspectors Returning Work - is this number of inspectors put into the field that day? Average Ret. (?) Per Inspector - is this the average of HH inspections returned that day per each inspector? Issued Total - what does this mean? Return Total - what does this mean?To clarify each header:
•Issued Daily – The number of assessments issued by FEMA to the Contractor for the specific day using GMT (note, GMT is the standard for production timeframes in this contract).
•Return Daily – The number of assessments returned to FEMA by the Contractor for the specific day.
•# of Inspectors returning work – the count of inspectors who communicated and returned work via the contractor to FEMA for the specific day.
•Average return per inspector – the average number of returned assessments to FEMA divided by the number of inspectors returning work for the specific day.
•Issued Total – The total count of assessments issued by FEMA to the Contractor.
•Return Total – The total count of assessments returned to FEMA by the Contractor.
•% Returned – The total returned assessments divided by the total issued assessments.
•Threshold – FEMA’s requirement to return issued work for the specific day. This will vary by peak activity periods stipulated in SSPA #2.G Production of the PRS. Vendors will follow and respond to the listed Scenario thresholds in their proposals for Factors 1.a and 1.b.
•# of Reviewers – Count of reviewers verifying the inspector’s work on a daily basis.
•# of QC Inspectors – Count of deployed inspectors conducting quality control assessments.
38If the property damage inspector/assessor finds HH site damage estimates rising above $36,000 (maximum amount for FEMA disaster grants?), would that damage estimate amount then be the cut-off for the inspection effort?This ask is not a stipulation of the scope of work requested in this contract.
39Does the Government require the Contractor to use the Sheltering and Temporary Essential Power (STEP) program or rebuild the house?This ask is not a stipulation of the scope of work requested in this contract.
40Please detail the hours of the expected workday for inspectors/assessors?Onsite damage assessments are to be conducted during daylight hours.
4123 (RFP);
16 (Att. 1 PWS)RFP, H.1, Transition; Att. 1, PWS, 5.5 Duty Readiness Progress Reporting2 (H.1)
1 (5.5)Would FEMA please resolve the conflict in RFP language between Section H.1 which indicates "The contractor will provide FEMA a progress report at the first of each quarter disclosing staff that have received training and types of training" and Attachment 1, Performance Work Statement which states "The Contractor shall provide FEMA a progress report by the 10th day of each month disclosing personnel that has received training and the types of training achieved. The report shall include the assessor ID number and last name. FEMA may audit the training as frequently as necessary."?The PO is in agreement for a quarterly confirmation of training and will include a revised PWS noting this change in Section 5.5.
4212 (Att. 2 PRS)
3 (Att. 3 QASP)Att. 2 PRS, VII SSPA #3 Timelines;
Att. 3 QASP, 6. QASP Evaluation Matrix1 (PRS)
1 (QASP)Would FEMA please resolve the conflict in RFP language between the QASP evaluation matrix which indicates an average FCOR aging shall not exceed 3.0 calendar days and the PRS which indicates an individual aging return rate measurement?There is no conflict. Individual corrections shall be returned within 72 hours per the PRS. The quality assurance surveillance plan provides for an average of corrections to be returned within 72 hours.
431Technical Exhibit #94Would the government please revise to add the red/bold text below for clarity?: “Contracted members may only send, receive and review PII on Government Provided Equipment (GFE), systems and Government e-mail accounts."? This clarification would enable contractors to utilize FEMA’s Citrix, reducing the costs associated with procuring additional GFE laptops.The PO is in agreement with the requested to add "systems" to the text clarifying the use of government provided services to process PII.
4437Att. 1 PWS, 7.3 Information (Data) Sharing, Item 61Would FEMA please revise to add the red/bold text below for clarity? “Contracted Personnel PII: Individual name, Phone Number, Email Address, Assessor’s iPad/Tablet number with their activation and training dates. FEMA will not permit any survivor/FEMA-derived PII data elements to be stored on any contractor systems unless an approved Authority to Operate (ATO) has been secured. Reference PII Data Restrictions within this PWS.” This clarification will enable contractors to maintain personnel and payroll records of their staff outside of government systems.At this time, the PO does not see the need for this change since the hyperlinked placeholder for PII Data Restrictions directs one to follow section 7.5. Section 7.5 clarifies the data to be restricted.

Definitions

Category Definitions
CategoryDescription
CriticalRefers to significant content issue that should be addressed (i.e., content would cause conflicts, flaws, confusion, and/or voids when implemented
SubstantiveRefers to factually incorrect information
AdministrativeRefers to typographical, grammatical, or formatting errors; vague or unclear meaning

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