25_-_Responses_to_Questions_-_updated_032619.xlsx

XLSX spreadsheet 35 KB Posted Mar 26, 2019

Attached to: NextGen Enhanced Processing Solution
Solicitation number: 91003119R0005
Issued by: Department of Education Office of Federal Student Aid

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Attachment 25 - Responses to Questions - updated 3/26/19

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20_-_Pricing_Template_updated_093019.xlsx	XLSX spreadsheet	Oct 1, 2019
91003119R0005_0008.pdf	PDF	Oct 1, 2019
91003119R00050007.pdf	PDF	Sep 24, 2019
26_-_Draft_DCC_CCP_Enablement_Guide.docx	DOCX document	Sep 20, 2019
25_-_Responses_to_Questions_-_updated_092019.xlsx	XLSX spreadsheet	Sep 20, 2019
27_-_DCC_Solution_Blueprint.pdf	PDF	Sep 20, 2019
20_-_Pricing_Template_updated_092019.xlsx	XLSX spreadsheet	Sep 20, 2019
91003119R0005_0006.pdf	PDF	Sep 20, 2019
91003119R0005_0005.pdf	PDF	Mar 26, 2019
Attachments_-_Updated_031919.zip	ZIP file	Mar 19, 2019
91003119R0005_0004.pdf	PDF	Mar 19, 2019
04_-_Attachments_to_Addl_Current_State_Tech_Constraints_-_updated_030619.zip	ZIP file	Mar 6, 2019
Attachments_Updated_030619.zip	ZIP file	Mar 6, 2019
91003119R0005_0003.pdf	PDF	Mar 6, 2019
91003119R0005_0002.pdf	PDF	Feb 19, 2019
91003119R0005_0001.pdf	PDF	Jan 25, 2019
04_-_Attachments_to_Addl_Current_State_Tech_Constraints_-_updated_12519.zip	ZIP file	Jan 25, 2019
19R0005_Attachments.zip	ZIP file	Jan 15, 2019
04_-_Attachments_to_Addl_Current_State_Tech_Constraints.zip	ZIP file	Jan 15, 2019
03_-_Attachments_to_Finance_Technical_Requirements.zip	ZIP file	Jan 15, 2019
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Sheet2 U.S. Department of Education Office of Federal Student Aid Next Generation Financial Services Environment

Enhanced Processing Solution

Attachment 25 – Responses to Questions

Responses to questions submitted that were relevant to responding to the solicitation have been provided below. Similar questions have been combined.

	Updated March 6, 2019: The response to questions #6, 7, 23, 24, 25, 26,and 27 have been revised. Questions 29 through 116 have been added.
	Updated March 19, 2019: Due to the chages in Amendment 04, the responses to questions 30, 38 and 84 have been revised. The questions and responses to the following are no longer relevant and have been removed: 29, 31, 32, 33, 34, 35, 39, 40, 45, 68, 70, 71, 72, 75, 77, 95, 109, 111, 112, 113, 114, and 115.
	Updated March 26, 2019: The response to question 47 has been revised, and question 117 has been added.
	Number	Question	Response
	1	Can we perform the tasks (related to RFP) outside USA?	No, per FSA 25-1, the contractor must perform all work, included those subcontracted to other parties, within the United States.
	2	Will multiple contracts for Enhanced Processing Solutions be awarded?	FSA intends to make one award for the Enhanced Processing Solution.
	3	C.3.1. – Will FSA consider a proposal for only some or all of the optional services (i.e., other than provision of a servicing system)? If so, how will FSA evaluate such a proposal?	Vendors shall provide a proposal for all operating elements, including those marked as optional.
	4	Please explain the reference to 'the separately provided Command Center'. More specifically, who is expected to perform this function in the Enhanced Processing Solution?	Another vendor will provide the command center.
	5	Will Factors 1 and 2 be weighted equally? If not, please advise how Factor 1 and 2 will be weighted.	Per section M-1.1, the evaluation will be based on a complete assessment of the Offeror’s proposal. Proposals will be evaluated based on: technical approach, past performance, and price. The non-price factors are more important than price.
	6	Is the intention to move all existing (as well as new) Direct Loans from their current servicer to the provider selected under this solicitation?	Yes. Solution shall migrate and service historical and current customer loan and grant accounts from existing servicers, including Direct Loans.
	7	Can you clarify the costs to be included in “implementation other”	Costs included in “implementation other” consist of any associated implementation costs that do not fit within other specified categories.
	8	In regards to SF1449, will FSA accept a scanned version of a signed SF1449 document submitted via email or does an offeror need to mail a hard copy signed in ink to FSA?	Email submitted SF1449s are permissible.
	9	Attachment 12 provides "Life of the Loan Servicing Intended State". Through out the RFP reference is made to the 'life of loan” servicing. To be clear on scope, FAFSA and COD process are NOT included within the scope of this contract. Is this correct?	FAFSA and COD processes are not included within the Student Financing Servicing Platform.
	10	How does the Department envision the relationship between this solicitation and the pending Optimal Processing Solution (91003119R007)? Will the R007 solicitation result in the termination of the award under this solicitation (R005)?	FSA does not intend for the award under R007 to result in the termination of this award. Per C.3.3(a), Solution shall also demonstrate the capability to eventually effectively and efficiently migrate customer accounts to the Optimal Processing Solution, should FSA so determine .
	11	Can FSA provide an estimate of the annual volume for customer communication requests in Alternative Formats across the entire lifecycle of student financing (Braille, Large Print, Audio CD’s)?	In 2018, there were 1,246 Braille, 798 audio, 11,233 data CD, and 21,598 large print customer communications requests. The number of alternative formats requested and provided has continued to increase each year. FSA does not know future growth rates.
	12	If existing customer accounts are migrated based on account status vs. the entire servicer portfolio, how will the ALC and servicer code be handled for financial reporting and reconciliation?	Offeror shall propose a solution that follows the operating requirements as defined in C.3.3(a) and applicable attachments.
	13	Given statutory /regulatory restrictions for example, (for example, 12 C.F.R. § 1080.14, Confidential treatment of demand material and non-public nature of investigations, makes CFPB investigations non-public, and permits disclosure of the existence of the investigation only to potential witnesses or third parties "to the extent necessary to advance the investigation"), please explain how the offeror is expected to collect the information required in Attachment 19 from its teaming partner(s) and/or subcontractor(s)?	Offeror shall provide the information requested in the attachment for both itself and its subcontractors and teaming partners. In the event that an offeror is unable to obtain and submit the requested information for one or more cases, the offeror shall note why information could not be obtained and submitted. The FY19 Appropriations Act requires consideration of offerors' compliance with applicable consumer protection laws, and the offeror shall provide this information as requested.
	14	Ref C.3.1 Regarding the requirement for “dynamic and complete customer historical data” and FSA’s Current State Technical Requirements 15006.090 and 26006.010 that interest be accrued using the 365.25 standard. Certain servicers use a 365/366 interest accrual method that currently service federal loans. When those loans are converted to the Enhanced Processing System (EPS), is it expected that those historic transaction be converted to the 365.25 method and interest and principal be recalculated and the customer’s balance be restated? If not, is it expected that as part of retro-active transactions that cross over the conversion date, that EPS will alter its method of interest calculation from 365.25 to 365/366 to ensure the customer is not adversely impacted?	Per Attachment 04 - Additional Current State Technical Constraints, the EPS vendor shall operate within the constraints identified in 15006.090 and 26006.10 to use the 365.25 method for interest calculation. All active accounts shall be recalculated, including underlying loans paid in full by consolidation. All other inactive accounts shall be re-calculated if other (NSF, Late adjustment, etc) adjustments occur to re-activate the loan.
	15	How does FSA envision the solution working with the current school-addressed cancellation conditions?	Per C.3.3.(b), the solution shall be able to handle specialty claims for student financing servicing, including closed school discharges.
	16	Can we submit the proposals via email?	See L-2.2.4.
	17	What existing Perkins assignment systems, components, processing will the awardee inherit, if any. For instance, is PLAS and the campus based programs website expected to be part of the new system?	The functionality of this website will be provided through the digital engagement layer. In the Government’s effort to consolidate websites, the campus based programs website is intended to be part of the digital engagement layer. The underlying systems, components, and processing shall be provided by the EPS vendor.
	18	Will EPS have any milestones/responsibilities for decommissioning existing servicers for which customers have been migrated from?	The EPS vendor shall be responsible for managing the migration of accounts; existing servicers will be responsible for decommissioning their own systems after migration.
	19	L-1 Special Notice to Offerors (L-2.1 General) – Does the prohibition regarding the inclusion of an exclusivity provision in a subcontract/teaming agreement apply solely to small business subcontracts or any subcontracts / teaming agreements, including those with other than small business entities?	The exclusivity prohibition applies to all subcontractors and teaming partners, not just small business entities.
	20	Ref C.3.3.c requires the offeror to provide printed documents in alternative formats. Will the offeror be able to utilize the government’s alternative format print production capability, or will the offeror be required to source a FISMA compliant alternative format print production capability?	The offeror shall provide an alternative format print production capability in accordance with C.3.3(c).
	21	Will ED provide a migration schedule based on customer status to avoid customer interruption?	The vendor shall provide a migration schedule that meets the Milestones in the solicitation. FSA will support the vendor to align schedules with other plans to avoid interruption.
	22	Please confirm there are no small business goals or set asides	There are no small business set asides, but there are small business goals. See L-2.4.5.
	23	Is there is an incumbent contractor currently performing these services? If so, could I please find out the contractor name and contract number? Any information is greatly appreciated.	No, there is no incumbent contractor for the Enhanced Processing Solution. This solicitation is seeking responses from companies that would provide services to implement FSA’s Next Generation Financial Services Environment (NextGen) program. FSA intends to transform the way we serve our customers by modernizing the way student financing is provided and administered. The work encompassed by NextGen includes work undertaken by contracts throughout the lifecycle of student financing, and does not reflect a one-for-one re-compete effort.
	24	3452.208-71 Printing - Please confirm whether FSA will consider a proposal in which the printing and mailing services are proposed as a third party subcontracted service by proposer. Will such proposal receive less consideration than a proposal in which all printing and mailing services are performed in-house by the proposer? Would pre-sorting services performed by a subcontracted vendor be acceptable?	Vendors may propose either an in-house solution or a subcontractor for imaging, printing, and mailing . Proposals will be evaluated in accordance with the evaluation criteria in the solicitation.
	25	Can a subcontractor's reference be used as a past performance reference? Can multiple task orders under the same contract be used as multiple references or do all task orders under a single contract count as one reference?	A subcontractor's reference can be used as a past performance reference. Multiple task orders under one contract can be submitted as separate experiences so long as each task order is for a unique set of requirements.
	26	How does the Department envision the relationship between this solicitation and the Business Process Operations Solution (91003119R008)? Will the two award run in concert with each other (or will the award for 008 eliminate the need for this solicitation)? Will the same vendor be required to manage both awards?	The award for the separate BPO solution will not eliminate the need for this solicitation; the same vendor will not be required to manage both awards. FSA will make multiple awards for the Business Process Operations solicitation. FSA does not anticipate that the same vendor will be awarded contracts for both EPS and BPO due to an appearance of a conflict of interest; however, FSA will thoroughly review any mitigation plan submitted with the vendor’s proposal to make a final determination.
	27	How does the Department envision the relationship between this solicitation and the Components formerly solicited as A and B? Will the two awards run in concert with each other? Will the same vendor be eligible to compete for both awards?	The transitional work identified in this solicitation is optional work that will only be exercised if necessary. There is no intention of having this specific work performed concurrently with the Components formerly solicited as A and B. FSA does not anticipate that the same vendor will be awarded contracts for both EPS and the Components formerly solicited as A and B due to an appearance of a conflict of interest; however, FSA will thoroughly review any mitigation plan submitted with the vendor’s proposal to make a final determination.
	28	Does the offeror need to come to FSA for meetings?	Yes, offerors shall be available for in-person meetings in Washington, DC both before contract award (e.g., negotiations) and after award.
	29	On page 12, the Solicitation provides that "Solution may serve as the sole business process operations (both contact center support and back-office processing) provider for all customer accounts as they are migrated onto the new servicing platform until the multiple vendors to be awarded under the separate Business Process Operations solicitation are fully operational." However, the separate Business Process Operations solicitation (91003119R0008), Milestone 1, provides that "Begin scaling operations in parallel with the start of existing customer accounts migration once the Enhanced Processing Solution is fully operational and ready to start migration..." (page 14) and provides for Business Process Operations to begin work at the start of migration. Will FSA be modifying the Enhanced Processing Solution to be the same as the Business Process Operations solicitation?	No, the scope of the BPO solicitation exceeds the transitional BPO work under the EPS solicitation.
	30	For the EPS milestones, what is the milestone to onboard separate BPOs?	The schedule for the EPS vendor to support the onboarding of BPO providers is to be determined. However, FSA expects to make BPO awards within three (3) months of the EPS award.
	31	Ref C.3.3.e: Will the provider of business processing operations be required to secure licensing from states that regulate student loan servicers or will federal law preempt this licensing requirement?	In ED’s view, state licensing requirements for ED servicers are preempted. The US District Court for the District of Columbia agreed with the Department and found that DC’s licensing requirements for servicers working for ED were preempted. At this time, we do not expect that the servicers chosen under this solicitation will be required to comply with those licensing laws. However, if a court of competent jurisdiction issues a final decision upholding a state licensing requirement for activities under this solicitation, the servicers would be expected to comply.
	32	FSA’s update to the EPS solicitation posted February 20, 2019 at 3:55pm indicates the EPS vendor will only provide BPO services under the EPS contract for 12 months after BPO contracts are fully operational. Since the EPS contract will not include BPO work once BPO providers are fully operational, are FSA’s concerns regarding conflict of interest between EPS and BPO mitigated, and therefore can the EPS vendor also bid on, be awarded and perform under a BPO contract?	FSA does not anticipate that the same vendor will be awarded contracts for both EPS and BPO due to an appearance of a conflict of interest; however, FSA will thoroughly review any mitigation plan submitted with the vendor’s proposal to make a final determination .
	33	Will EPS handle default activities in its capacity as a transitional BPO provider?	Within its capacity as a transitional BPO provider, the EPS vendor shall handle activities for all borrowers on the EPS system, including those in default. FSA intends for separate BPO providers to provide all manual support associated with loans in recovery after they are fully operational. The EPS vendor shall perform all recovery activities on behalf of FSA, not in the capacity of a third party collections agency. See Amendment 03.
	34	RFP states "Solution may serve as the sole business process operations (both contact center support and back office processing) provider for all customer accounts as they are migrated onto the new servicing platform until the multiple vendors to be awarded under the separate BPO solicitation are fully operational." Question - does this mean that the awardee of the Enhanced Processing Solution must have available capacity for 100% of BPO volumes on the date of contract award? If not, over what period of time would the Enhanced Processing Solution provider be required to assemble the needed capacity?	Per C.3.3.5.6, solution shall scale and launch business process operations no later than six months after award. Solution shall support 100% of migrated borrowers on to the EPS solution, in accordance with the vendor's migration plan (in accordance with milestones 2 and 3). See Amendment 03.
	35	Can Offerors provide a response that meets all of the solution requirements but structures the award such that the contract for the platform goes to one vendor on the team and the contracts for Business Process Operations (BPO) related functions are directly signed by FSA with those BPO vendors?	The vendor will be required to provide transitional BPO functions as outlined in C.3.3(e) either directly or through one of its subcontractors.
	36	Will EPS route NSLDS reporting errors directly to the designated BPO for the customer account NSLDS reporting error to be resolved?	No, see Amendment 03. EPS will be responsible for addressing NSLDS reporting errors.
	37	Based upon reviewing the Business Processing Operations (BPO) solicitation, it appears FSA intends to award to multiple servicers and that each will have their own portfolio to manage. How many BPO providers should the offeror plan to support?	The offeror shall have the capacity to support multiple BPOs. FSA has not determined the total number of BPO awards at this time.
	38	Will EPS, in advance of the migration of existing customers, include the separate BPOs as the training material is being developed and provide training to the separate BPO trainers to prepare for customer migration to EPS?	FSA intends for the DCC vendor to train the separate BPO trainers and develop training materials leveraging input from the EPS vendor and/or BPO providers. However, the EPS vendor may be required to provide assistance in training the BPO trainers.
	39	C.3.3.e – What services would be required 24/7/365?	The servicing-related contact center is required from 24/7/365 for the business process operations operating element. However, per Amendment 03, vendor shall provide multiple pricing inputs based on specified hours in Attachment 20 - Pricing Template.
	40	Do the call volumes represented in the Pricing Template include the volume associated with all the FSA Contact Centers represented in Attachment 13? If not, can the department provide call volumes for each center to support adequate pricing of all Attachment 13 FSA Call Centers are represented by the requirement in C.3.3.e.	The transitional BPO support does not include all activities associated with existing FSA contact centers. The solution shall only provide BPO support that servicers and PCAs provide in the current state. The call volume is updated in the pricing template and totals 28 million inbound calls, which include approximately 24 million calls to current servicers and 4 million calls to the Default Resolution Group.
	41	Will all complaints be entered into the existing ECS portal and distributed to each separate BPO for customers assigned or will EPS and/or EPS BPO be responsible for this work?	Per series 32000 of Attachment 04 - Additional Current State Technical Constraints, the vendor will have access to the FDM (formerly known as ECS). Workflows will be handled by a separate vendor. The EPS vendor will need to answer complaints related to its performance.
	42	How will EPS serving as the digital engagement layer route calls if customers are not yet assigned or if the inquiries come from partners (i.e. schools)?	The EPS vendor will be responsible for routing calls in its capacity as a transitional digital engagement layer provider in the event the DCC solution is not operational. See Amendment 03.
	43	Please provide further clarity on roles & responsibilities of the EPS provider based on the statement in C.3.3.a "Solution shall support the development and execution of customer communications about the migration of
their accounts before, during, and after the migration, working effectively with the Digital Customer Care solution" Is the EPS provider there to solely provide input to the Customer Care solution or are there specific role / deliverables that the EPS provider is responsible for?	In regards to customer communications, EPS shall collaborate with the Digital Customer Care (DCC) solution in the development and execution of customer communications regarding the migration of accounts.
	44	How will EPS be required to distribute customer inquiries and processing that cannot be automated to separate BPOs for their assigned unique customer accounts for life of loan servicing beginning with the start of existing customer migration?	EPS will be required to provide APIs to enable the DCC vendor to distribute customer inquiries and processing that cannot be automated.
	45	C.3.3e - Please outline the digital formats that will be needed to process data.	Digital formats include, but are not limited to, images, emails, and chats.
	46	Temporarily supporting 100% of the Business Process Operations vendors directly, including providing the contact center technology and related capabilities used by BPO agents for customer support, will require a large deployment of desktops, phones, BPO agent tools, and so forth for a relatively short period of time. In line with FSA's intention to maximizes operational and cost efficiency, will there be an opportunity to coordinate with the DCC vendor to minimize potentially duplicative expenses relating to common capabilities between this solicitation and the DCC solution?	Yes. The Government, the DCC vendor, and the EPS vendor will coordinate prior to deploying support for the BPO solution.
	47	For C.3.2, can you expand on what the “broad integration” needs are in regards to API integrations?	The vendor’s solution shall include re-engineering existing API’s, or building new API’s to integrate with the DCC vendor for CRM integration, delinquency outreach and back office workflow routing, as well as existing vendors and other NextGen components to ensure a more efficient and effective customer experience.
	48	In paragraph 5, RFP states "Once a loan defaults, FSA transfers the loan to a default management and collection system (DMCS) and attempts to bring the loan back to good standing." - Question at this stage in the "New Enhanced Processing Solution" - what entity is attempting to bring the loan back into good standing - FSA, Servicer, or a Private Collection Agency (PCA)?	Differentiations between FSA, servicers, and PCAs are indicative of the current state, not the NextGen Financial Services operating environment. FSA (through its vendors) will attempt to bring defaulted borrowers back into good standing.
	49	In the DMCS constraints, several components (beyond the core DMCS system), such as Myeddebt.com, eIMF workflow, eIMF web application, iSIR imaging system, and PCA Invoicing subsystem are referenced. Is the intent that the EPS provider assume the O&M of these products, replace all of these products or will other components of NextGen address their functionality?	DMCS constraints were included for illustrative purposes. FSA intends for a different operating model under the NextGen Financial Services Environment. Under this environment, many current functionalities could be provided by multiple vendors or eliminated completely.
	50	Per Section C.3.1 of the solicitation, the “Enhanced Processing Solution (Solution) will serve as the student financing servicing environment for FSA’s existing customers. Solution will provide full “life of the loan” servicing: servicing loans for customer accounts of all statuses, including those that are in default.” o Is the collection/recovery of defaulted accounts incorporated into the Solution? o If yes, where and how within the Solution workflow? o If not, what is FSA’s intent for addressing and handling the collection/recovery of defaulted accounts, including outside of the Solution?	The Enhanced Processing Solution shall handle pre- and post-default activities. See Attachment 04 - Additional Current State Technical Constraints for detailed illustrative constraints related to recovery. Solution shall provide support, primarily through automation, associated with loans in recovery for the duration of the contract.
	51	Will the 200 million accounts (referenced in Section C.2.2 on page 6 of the Solicitation) that are to be migrated from the servicers as part of the Enhanced Processing Solution contract include accounts currently held by PCAs? What is the intended priority of account categories and statuses to be migrated?	Per C.3.3(a) solution shall migrate historical and current customer loan and grant accounts from existing servicers and the Default Management Collection System (DMCS). All defaulted loans are on DMCS, including those assigned to PCAs. The solution will migrate accounts, even if the entire account balance is $0 with the existing servicer. See Amendment 03 for revised milestones for migration of accounts from DMCS. Offeror shall propose the priority of account categories and statuses in their migration plan.
	52	Collection activity is typically priced as a percentage of dollars collected, which is a combination of calls, emails and other contact types along with back office processing functions. How should the offeror price current PCA activities in the template provided?	Offeror shall complete Attachment 20 - Pricing Template in accordance with the provided instructions. FSA does not intend to continue use of the current PCA pricing structure.
	53	Attachment 20 – Pricing Template – as the details surrounding many of the tasks are yet to be fully defined, will FSA consider pricing based on a productively hourly rate where a representative is dedicated to and performing services for the Solution versus on a per task basis? If not, would FSA provide a workflow that is currently performed and time estimate that is currently takes to perform each of the requested tasks where pricing is requested on a per-task basis?	Offerors may propose any alternate pricing methodologies in the "Proposal Alternate Methodology" tab. The offeror must fill out all required tabs on Attachment 20 - Pricing Template, not just the "Proposal Alternate Methodology" tab.
	54	Does FSA intend on identifying and documenting administrative resolutions, including deceased and incarcerated borrowers or will that function be performed by an entity awarded contract(s) through this solicitation or other related NextGen solicitations?	Please see Attachment 04 - Additional Current State Technical Constraints, Debt Management and Collection System Additional Information.
	55	In regards to Section C.3.3(b), the Solicitation states that “Solution shall execute the full range of ‘life of the loan’ servicing functions, including consolidation origination and default support.” How does FSA define “default support” for purposes of Section C.3.3(b)?	See section C.3.3(b) for details on default support.
	56	Additional Current State Technical Constraints 52000 series seem to indicate that the offeror must use the existing DMCS platform. Is this a correct interpretation of these constraints or can the offeror propose its own solution?	The offeror shall provide its own solution.
	57	If the scope of work for this solicitation is to include debt collection services currently performed by PCAs, will FSA allow an offeror to perform both loan servicing, as described in this solicitation, and debt collection services? If yes, then how does FSA intend to avoid the conflict of interest between loan servicing and debt collection servicers?	The Enhanced Processing Solution shall handle pre- and post-default activities. The pricing structure, and other terms of the contract, for the various services to be provided under the contract will be designed to avoid any potential that a contractor performing loan servicing would benefit by having loans go into default. This would mitigate the appearance of a conflict of interest.
	58	In Section C.3.3 - Operating Elements and Related Requirements (page 9), the solicitation states "Solution shall migrate historical and current customer loan and grant accounts from existing servicers and the Default Management Collection System (DMCS)." Our interpretation of this statement is that defaulted accounts will be converted from the current DMCS platform to the selected servicing platform. This instruction appears to conflict with Technical Constraint 52031.000, which states that DMCS accounts should be consolidated within DMCS. Our interpretation of this statement is that the defaulted accounts will remain on the DMCS platform which will be hosted and maintained by the winner of this solicitation. If we have misinterpreted the solicitation, please clarify.	The offeror shall provide its own solution. The solution is responsible for migrating loans from the current DMCS platform to EPS. The constraints provided are illustrative.
	59	Requirement attachments were added for the 14000 series for the Default Management and Collection System. It is our understanding that EPS will be providing life of loan servicing including post-default. Why would these requirements and attachments be needed for EPS?	The constraints are included to ensure that the EPS vendor is able to interact with DMCS until all applicable customer accounts have been migrated.
	60	In Section C.3.3 - Operating Elements and Related Requirements (page 9), the solicitation states "Solution shall migrate historical and current customer loan and grant accounts from existing servicers and the Default Management Collection System (DMCS)." As it relates to DMCS we are aware that there are commercial defaulted loans on their system. If these loans are rehabilitated at any point, should offerors assume that the solution will continue to support a sale of the rehabilitated loan on the commercial market?	No, once a commercial loan is in the government's system it becomes a government asset that must be serviced.
	61	For the word document embedded in attachment 04 Additional Current State Technical Constraints, Debt Management and Collection System Additional Information, the volume for the portfolio and processing work listed appears to be prior to 2014, will FSA provide updated DMCS volume to consider for EPS and BPO work?	As of January 2019, there are approximately 7,600,000 borrowers in default.
	62	Both Solicitation 0005 and 0008 appear to require that all communications with customers regarding defaulted loans be conducted under the FSA brand (see Section C.2.2 of both Request for Proposals (RFPs) and Section C.3.3.d of RFP 0005 and C.3.1 of RFP 0008). The federal Fair Debt Collection Practices Act and similar state laws require that, among other things, default resolution activities be conducted in the name of the debt collector, though an exception is made where the collector obtained the debt prior to default. Does FSA contemplate that defaulted debt resolution activities will be undertaken only by vendors that interacted with the customer regarding the debt prior to default? If the answer to that question is “no”, does FSA contemplate that vendors who interact with the customer only with respect to default resolution activities will be permitted to do so in their own name and not under the FSA brand in order to comply with the law? If the answer to that question is “no”, could FSA please elaborate, particularly given the requirements noted above?	FSA intends that all communications to students and partners will be done under a single, unified brand rather than under the name of the servicer. However, we are continuing to analyze the impact of applicable laws and legal developments on the unique NextGen structure. If we conclude that communications must be branded differently once loans are in default, we will instruct the vendor to comply with the applicable legal requirements.
	63	C.3.3.e. – This section notes that the Solution shall provide tailored customer assistance throughout the life of the loan to ensure that no borrower ever becomes a defaulted borrower, to the maximum extent practicable. What is FSA’s expectations as a reduction in future account defaults as a result of these additional efforts as a percentage of accounts currently defaulting? Further, for accounts that nonetheless do default despite such efforts, what services/collection/resolution efforts will be provided on these accounts?	FSA intends to reduce future account defaults through the suite of solutions provided under NextGen Financial Services. For accounts that do enter default, FSA intends to provide omni-channel support to move borrowers back into active repayment status.
	64	If it is the intent of FSA to have enhanced servicer provider (or business process operations (BPO) provider) handle these defaulted loans - can FSA provide in C.4 Expected Volumes - the number of calls per loan in a post 360 day default status that currently the PCAs are providing this service as those volumes do not appear to be in the 'expected volumes' table. Additionally, will these default collections be priced on a contingency basis, as is currently the pricing methodology or a different pricing methodology as it appears there is no mechanism in the current pricing table for these types of inbound and outbound communications.	Per Attachment 04 - Additional Current State Technical Constraints, there are approximately 1,400,000 annual live operator-assisted calls for defaulted accounts. FSA does not intend to continue use of the current default collections pricing structure. Vendors are free to propose alternate pricing methodology per the pricing template instructions.
	65	Federal regulations (see, e.g., 34 CFR 685.102(b) and 34 CFR 682.200(b)) provide that default occurs when non‐payment persists for 270 days if the Secretary finds it reasonable to conclude that the obligor no longer intends to honor the obligation to repay. Is it FSA’s position that default does not occur until after expiration of the 60 day “cure” period following transfer of the account to DMCS at day 360 of delinquency?	Under the law, a borrower is in default if the borrower has not made payments for 270 days. However, there are certain collection related actions that cannot be taken until the borrower has received a notice of the default and of the opportunity to contest the debt and enter into a repayment agreement. FSA intends to provide these notices much earlier in the process.
	66	Ref C.3.1: With respect to the sentence "Solution will provide full “life of the loan” servicing: servicing loans for customer accounts of all statuses, including those that are in default." Defaulted accounts are serviced by Private Collections Agencies (PCAs) today, who each have their own technology platforms, separate from DMCS and the platforms used by the Federal Servicers (i.e., TIVAS and NFPs). Is FSA expecting the proposed solutions will displace use of the current technology platforms by the PCAs either: a) Move this functionality to an enhanced version of the DMCS platform or b) Move this functionality to the servicing platform selected by this solicitation?	FSA is expecting the EPS solution to provide this functionality.
	67	Does FSA intend for offerors under the Solicitation to identify PCAs they intend to use during contract performance as part of their proposals or after award of the contract(s)?	Offerors shall identify any teaming partners and subcontractors as part of their proposals using the appropriate volumes.
	68	C.3.3.e/Attachment 12 - For the life of the loan servicing – what daily/monthly due diligence steps are expected as it relates to calls/letters/emails/text in the:

Pre-zero

0-90 DPD

91-270 DPD

271+ DPD	For the Transitional BPO support, offerors shall propose daily/monthly due diligence steps related to calls/letters/emails/text for each time frame to provide a best-in-class solution in line with existing laws and regulations. Once the transition to the DCC vendor is complete, then all due diligence activities will be established by DCC.
	69	C.4. – Are the outbound emails send solely comprised of standard template/language emails or do they require manual intervention/typing? If all are not standard templates, what percentage require manual intervention? What is the average handle time associated with an outbound email requiring manual intervention? How many standard email templates are currently used?	Outbound emails currently use both templates and manual intervention. FSA does not have data on the percentage of manual intervention at this time or the average handle time or number of standard email templates as this varies by servicer.
	70	C.3.3.e - The RFP says the vendor should be able to text/chat with the customer – will the permission be transferable from ED to the vendor?	Customer consent will be provided to the government and its agents.
	71	C.3.3.e - The RFP says the vendor should email – will the email consent be transferable from ED to the vendor?	Customer consent will be provided to the government and its agents.
	72	C.3.3.e - Will ED allow the use of electronic signatures/vendors to process necessary paperwork that is required to be signed by the borrower?	ED will allow electronic signatures to process paperwork if permitted by statute and/or regulation.
	73	C.4. – What are the average handle times associated with processing each of an inbound piece of physical mail, email and complaint? The handle time would be of significance as pricing is requested on a per-task basis.	FSA does not have data across existing vendors for the requested information.
	74	Ref C.4: References the support of web chat. What’s the projected volume and average handle time?	FSA does not have the projected volumes and AHT as this functionality will be provided by a solution that has not yet been implemented.
	75	Ref C.4: References 27 million outbound non-collection calls. What’s the projected right party connect rate and average handle time?	Per C.4, the average handle time (AHT) for calls (inbound and outbound) is about 7 minutes. FSA does not have data on the right party connect rate.
	76	Ref C.3.3.a requires the offeror to “tag” all accounts with a unique FSA account number. Does this account number already exist, and the offeror must adopt this numbering scheme, or can the offeror propose its own scheme?	FSA will provide the EPS vendor with a unique identifier for each customer. See Amendment 03.
	77	C.3.3.e - Please further explain what is meant by contact information routine updates when referring to back office?	The vendor must ensure that customer and partner contact information is up-to date and accurate as part of the requirements within C.3.3(e).
	78	C.1.2 - After implementation of the Enhanced Processing Solution, will all newly issued loans be loaded to this system instead of existing servicing systems?	After implementation of the EPS, all first-time student loan and TEACH Grant accounts will be loaded to either the EPS or Optimal Processing Solution.
	79	Does the Enhanced Processing Solutions Solicitation and associated attachments constitute all information that FSA has on the requirements of the anticipated solutions required thereunder?	Per C.3.2(i) in addition to security and financial requirements, vendors shall understand other categories of current state technical constraints as relevant (e.g., processing, websites, and communications). For a broader informational view of FSA’s current environment, vendors are encouraged to review the attached “04 – Additional Current State Technical Constraints,” which provides a representative, though not comprehensive, set of technical constraints. A comprehensive set of binding requirements will be defined post award.
	80	In today's environment, transfers from and to DMCS do not follow the same requirements as other servicer-to-servicer transfers. Will DMCS be required to follow EA27, EA80 and supplemental file requirements during the migration to ensure complete and accurate historical customer data?	Offeror shall propose a migration plan in accordance with C.3.3(a).
	81	Please provide more detail on what FSA’s expectations are around the consolidation Origination Data conversion.	Solution shall migrate all underlying loan detail and payoff information including all loan verification detail, loan summary statements, initial payoff information (including all financial and non-financial transactions), and under and over payment detail. Solution shall be able to process all under and over payment adjustments regardless of performing the actual origination of the consolidation loan.
	82	C.3.3.a - What is the time frame that is expected to migrate existing loans from current servicers through loan migration while minimizing customer disruption?	See section C.3.5.
	83	Will the migration follow the normal course of transfers? i.e. EA27 file v4, EA80, PAYE/REPAYE/PLSF supplemental files, and the turnaround time to release the loans to the servicing system (14 days).	Offeror shall propose a solution that follows the operating requirements as defined in C.3.3(a) and applicable attachments. Per L-2.4.1.2(a), offeror shall explain in their PWS how the solution will ensure full migration of customer accounts (e.g. the existing dynamic and complete customer historical data) within FSA’s portfolio across all existing products (e.g. specialty programs, specialty claims, consolidation origination, etc.) and customer service data (e.g., audio files, etc.).
	84	The EPS solicitation references migrating existing customers, will EPS also provide the solution including BPO work (contact center and back-office processing) for new customers?	See Amendment 04. The EPS vendor will support all new customers, but will no longer provide transitional BPO support.
	85	Please provide data on current award year volume of students/dollars that are reported as overpayments, broken down by aid program.	There are approximately 83,000 outstanding grant overpayment debts across all award years, representing approximately 1% of accounts currently held on DMCS. By program, there are 12 for ACG, 53,465 for Pell, 636 for SEOG, 2 for SMRT, and 29,367 where the grant program is not known by FSA. See Amendment 03 for updated volumes for the pricing template.
	86	In the Solicitation, Section C.3.2- General Operating Requirements, there is reference to Pell grant support. Details depicted in the "04 - Additional Current State Technical Constraints" attachment refer to Grant Overpayment processing. Does FSA expect Pell Grant support beyond the stated Grant Overpayment processing requirements? If yes, when will these requirements be shared with offerors?	At this time, Pell Grant overpayment recovery is the only Pell Grant servicing support included in this solicitation.
	87	How does FSA foresee the awardee working directly with schools? Will FSA mandate that all Perkins Loans be migrated to this functionality?	The EPS awardee will not service loans on behalf of schools; the only Perkins Loans to be serviced under this contract will be loans held by FSA.
	88	Is the initial scope of Perkins Loan servicing limited to those Perkins Loans currently assigned/serviced by the contracted Perkins Loan servicer? If so, what is the volume of these loans? Is there a annual forecast for growth of these assignments?	Offeror shall service all federally-held Perkins Loans. The volume of assignments in 2015, 2016, and 2017 was approximately 26,000, 29,000, and 38,000, respectively. FSA does not have a current forecast for a Perkins assignment growth rate due to the high variance in past assignment rates, which were approximately 10% for 2016 and 33% for 2017. Institutions are currently able to assign their Perkins portfolio to FSA at any time.
	89	Please explain the process associated with defaulted Perkins loans.	See Amendment 03 for an updated version of Attachment 04 - Additional Current State Technical Constraints.
	90	Our interpetation of the 51000 series requirements for Perkins loans is that the requirements appear to cover the placement but not the complete servicing requriements for Perkins loans. If we have misinterpreted the solicitation, please clarify.	See Amendment 03 with updated constraints regarding Perkins.
	91	Has the Department identified the key measures of success that will be used to track performance?	The selected vendor and FSA will jointly provide and align on key performance indicators and outcomes to include in the contract to track performance. Vendor shall suggest measures of success and associated targets. Some example categories may include error rates, uptime(s), system adaptability, and automation of manual tasks.
	92	Is the intention that per unit pricing be added into each of the fields (Year 1 – 10) for each stage listed under assumptions (i.e. each delinquency level, etc.)	No, offerors shall fill out each row on the "Volume Assumptions" tab with the volume assumptions used by the offeror for each specified category.
	93	In section c.3.2 it references the potential for the EPS provider to provide the Contact Center backbone until the other NextGen components are ready. Should this pricing be placed in the Digital Engagement pricing (optional) or in the core EPS system pricing and O&M? Should provider expect to provide telephony licenses to future procured BPOs?	This pricing should be placed in Digital Engagement pricing (optional), not in the core EPS system pricing. The vendor is not expected to provide telephony licenses to future BPOs.
	94	Please confirm that the scope around "Solution Delivery no more than 3 months from award" only pertains to the scope of having a system ready to initiate the ATO process.	FSA confirms.
	95	Will EPS vendor also need to complete SLA Tracker for Past Performance (similar to BPO RFP) since EPS will also be providing BPO?	No, see Amendment 03. BPO support in EPS is now an optional, transitional task.
	96	Should EPS vendors also provide a staffing plan (similar to BPO RFP)?	Yes, see Amendment 03.
	97	Ref L-2.4.5: Please clarify if the small business subcontracting goal of 32% represents 32% of subcontracted dollars or 32% of the total contract value?	The subcontracting goal is 32% of the total contract value.
	98	Please confirm that in Volume 2 - Past Performance, sections A, C, D, and E are for each reference where as section B and F only pertain to the Offeror (i.e. prime bidder) and not each past performance reference.	All offerors shall address A-F in Volume 2 - Past Performance.
	99	FSA 22-2 – Will FSA provide a list of positions and Wage Determinations that it believes are relevant to each of the services, including each of the optional services, requested under this RFP?	No, offerors shall provide this information.
	100	Can companies outside of the United States apply for this solicitation?	All work, including those subcontracted to other parties, must be performed within the United States.
	101	Ref L-2.4.2.f: FSA requests a listing of all litigation against a vendor as a measure of consumer protection compliance. This type of broad request can be prejudicial to large firms operating multiple businesses in multiple jurisdictions, where various lawsuits and other actions may arise in the normal course of business. Would FSA amend its request to require a listing only of those lawsuits and other actions alleging a violation of federal consumer protection laws that have resulted in a final judgment against the offeror?	No.
	102	L-2.4.5 - Is there a limit to how much of the work may be subcontracted by the awardee? If so, what is the limit and what is the basis for the limit (e.g., number of subcontractors, percentage of revenue received from FSA, etc.)?	No.
	103	Will FSA agree to remove contradictory data rights requirements in FSA 27-1, H-2, FAR 52.203-13, and FAR 52.239-70(e) and include FAR 52.227-19 'Commercial Computer Software License' instead?	No.
	104	Please explain any differences between the reference to "Student Aid Servicing Platform" on Attachment 21, the Performance Measurement Template, and "Student Financing Servicing Platform" which is listed as one of the Operating Elements in Section C.3.3.	The two phrases are both references to C.3.3(b) Student Financing Servicing Platform. Please see Amendment 03 for a corrected attachment.
	105	Would FSA be willing to restrict the rights to use the system for FSA purposes only and not allow use by FSA or third parties to be used for commercial purposes outside of providing services to FSA?	Use of the system by FSA and its third-party vendors will be restricted to supporting FSA activities only.
	106	FSA 04-2, 1.2, 6. – As the Contractor is required to obtain the Contracting Officer’s approval prior to subcontracting any services, please confirm that FSA is agreeable to proposals that include the subcontracting of certain services, as the services being requested by this RFP are diverse, especially as this RFP includes a 32% small business utilization goal, which will necessitate the use of subcontractors.	Yes.
	107	In the event that a past performance reference does not have 3 years of history, is a shorter duration acceptable?	Yes.

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