USDS_91003122R0007_Amendment_0002_Revised RFP.pdf

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I. Part I: The Schedule (continued) B. Section B: Services & Prices

1. B. 1 Contract Line Item Number (CLIN) Descriptions The following table describes the available CLINs under the contract for Task Orders and their associated contract types.

General CLIN Descriptions

CLIN 1

Title: Servicing System Operations Basic system operations and support, including: servicing system infrastructure (hardware, software, network, data and image storage etc.)

maintenance and upgrades and IT staffing (system support, system development and overhead) for normal operations and maintenance and routine system upgrades (i.e. interest rate changes, business rule updates, regulatory changes, etc.) in accordance with the contract requirements.

This CLIN is fixed price with economic price adjustment with tiered rates tied to the number of borrower accounts on the USDS Servicer’s system.

CLIN 2

Title: Cybersecurity Services Cybersecurity costs including, but not limited to: labor for Cybersecurity requirements, software licensing, 3rd party vendor support, overhead, etc.

required to support requirements for cybersecurity operations and maintenance. This CLIN does not include servicing system operations (CLIN 1), web/mobile (CLIN 4) or authentication (CLIN 5).

This CLIN is fixed price with economic price adjustment with tiered rates tied to the number of borrowers on the USDS Servicer’s system.

CLIN 3

Title: Contact Center and Back-Office Processing Operation & Maintenance Basic contact center and back-office operations, including: staffing, recruiting, equipment, software, training, quality monitoring, overhead, facilities, etc. to perform the requirements of the contract. This CLIN also includes the requirements for servicing military borrower accounts.

This CLIN is fixed price with economic price adjustment with one or more performance incentives and with tiered rates tied to the number of borrower accounts on the USDS Servicer’s system.

Performance Incentives

Performance Incentive for At-risk Borrowers (Applies to CLIN 3 and includes military borrower accounts) Performance Incentive for SLA/SLO Performance Metrics (Applies to CLIN 3 and includes military borrower accounts)

CLIN 4

Title: Website and Mobile Services Website and mobile costs including: web and mobile staffing (IT infrastructure, IT design & development and overhead), normal maintenance and routine upgrades (i.e. form revisions, borrower messaging and text changes, business rule updates, regulatory changes, etc.), hardware and software.

This CLIN is fixed price with economic price adjustment with tiered rates tied to the number of borrower accounts on the USDS Servicer’s system.

CLIN 5

Title: User Authentication Services User authentication (will be eliminated upon implementation of FSA SSO) including: staff, software, support for password reset and equipment .

This CLIN is fixed price with economic price adjustment and with a fixed price rate tied to the number of borrower accounts on the USDS Servicer’s system.

CLIN 6

Title: Fulfillment Services Fulfillment services including, but not limited to: : equipment, personnel, postage, paper, printing, mail scanning, other 3rd party vendor costs.

This CLIN is fixed price with economic price adjustment with fixed price unit rates for letters, scanned documents, and alternate format documents.

CLIN 7

Title: Development, Modernization & Enhancements.

Development, Modernization & Enhancement including, but not limited to:

projects or services to further develop, modernize, or enhance the requirements under this contract.

This CLIN will be firm-fixed price or fixed price with economic price adjustment (prices and contract type determined at Task Order level). This CLIN establishes a table of labor categories and associated labor rates, subject to the economic price adjustment clause, for use in future Task Orders, modifications, and Change Requests (CR).

CLIN 8

Title: Specialty Task - Image Repository See PWS section 3.3.

This CLIN is fixed price with economic price adjustment and with a fixed price rate tied to the number of borrower accounts on the USDS Servicer’s system.

CLIN 9

Title: Specialty Task - Decommissioned Servicer Data and Payment Support See PWS section 3.3.

Services in accordance with the contract.

This CLIN is fixed price with economic price adjustment and with fixed price rate tied to the number of borrower accounts on the USDS servicer’s system.

CLIN 10

Title: Specialty Task - FFEL Guaranty Agency Rehabilitation Loan Purchases See PWS section 3.3.

This CLIN is fixed price with economic price adjustment and with fixed price rate per number of successful rehabilitation.

CLIN 11

Title: Loan Consolidation Origination and Disbursement See attachment 01 – Business Operations and Servicing Requirements (section 15000) This CLIN is fixed price with economic price adjustment and with fixed price rates per number of successful originations and adjustments (different rates for each type).

CLIN 12

Title: Specialty Task - Legacy Loan Consolidation Origination and Disbursement Support Functions See PWS section 3.3 This CLIN is fixed price with economic price adjustment and with fixed price rates per number of successful originations and adjustments (different rates for each type).

2. CLIN Pricing and Rates Each CLIN contains the prices and/or rates available to be applied with the Task Orders issued under the contract, for each year of the contract base period and all option periods. The Federal Acquisition Regulations (FAR) clause 52.217-8 Option to Extend Services, is applicable to all CLINs under the contract for the contract and all Task Orders.

In accordance with FAR clause 52.216-22, Indefinite Quantity, the maximum under this contract is $16,000,000,000 dollars. The minimum under this contract is the value of the initial Task Order issued against the contract.

CLIN pricing and rates proposed and/or set by negotiation shall be incorporated at award within this section on the next page.

C. Section C: Performance Work Statement (PWS)

1. Introduction

The U.S Department of Education (Department) Office of Federal Student Aid (FSA) seeks servicers to provide continued servicing capabilities for FSA’s student aid recipients using the requirements applicable under Title IV Additional Servicers (TIVAS) and Not-For-Profit (NFP) Servicers (collectively, Legacy Servicers) contracts, except as noted herein. The resulting Unified Servicing and Data Solution (USDS) contracts (Contract) will replace the existing, Legacy Servicers, and provide the following services:

• Complete Student Loan Servicing;

• Student Loan Consolidation Origination and Disbursement;

• Financial Reporting;

• Processing of Specialty Claims (discharge, forgiveness, and cancellation);

• Complete Fulfillment;

• Operational Reporting;

• Compliance Monitoring; and

• Data Integrations with other FSA Systems.

2. BACKGROUND, GOALS AND VISION

FSA administers all phases of the Federal student financial aid programs from a student’s submission of the Free Application for Federal Student Aid (FAFSA®) through retirement of student loan debt. Federal Student loans have become a core component of postsecondary education financing. FSA directly manages servicing for more than 35 million non-defaulted Federal student loan borrowers with a total value over $1.25 trillion. Currently, Legacy Servicers perform the following tasks related to pre-default loan servicing:

• Operation of the back-end systems that calculate and process transactions under complex, repayment plans;

• Process loan deferments, forbearances, and discharges;

• Operation of contact centers that provide direct information and counseling to borrowers;

• Conduct outbound call and mail campaigns to communicate important information to borrowers;

• Maintain websites enabling borrowers to manage their accounts; and

• Comply with applicable Federal, State, and local laws and regulations.

In 2017, FSA introduced the Next Generation Financial Services Environment (now referred to as Next Gen), an initiative that sought to transform FSA’s operations and approach to serving more than 70 million students, parents, and borrowers, and partners at approximately 5,600 postsecondary institutions. The Next Gen approach applies not only to student loan servicing, but to all stages of a customer’s journey, including learning about, applying for, receiving, and repaying federal student aid. The goals for Next Gen include:

• Providing a high-quality customer and partner experience throughout the student aid life cycle;

• Improving operational flexibility by creating an environment that can efficiently and effectively integrate new capabilities and features, continuously improve and innovate, and adjust to stay in compliance with applicable laws and regulations;

• Driving greater operational efficiency, reducing complexity, improving the stability, resiliency, enterprise risk management, and cybersecurity of systems; and ensuring effective and efficient use of taxpayer dollars; and

• Improving customer and partner outcomes and overall portfolio performance and facilitating compliance with consumer protection standards.

The original Next Gen procurements consisted of 10 components:

• Digital platform and related middleware

• Contact center platform and customer relationship management (CRM)

• Processing platform for new accounts

• Processing platform for legacy accounts

• Business process operations for new accounts

• Business process operations for legacy accounts

• Data management platform

• Identity and access management

• Cybersecurity

• Quality Assurance

As FSA implemented Next Gen, FSA experienced successes and failures that led the shift in FSA’s servicing strategy to reflect lessons learned. FSA gained this knowledge by managing separate servicing procurements in 2017, 2019, and 2020, gaining a better understanding of operational and resource constraints, and embarking on an unprecedented period of technological development and organizational change. In 2021, FSA worked to incorporate these lessons learned into a new approach to Next Gen servicing that FSA believes will result in a stronger and more sustainable approach to long-term servicing that will lead to better experiences and outcomes for borrowers. The evolution of the Next Gen initiative has led some components of the original strategy to be combined and some components to be incorporated into existing contracts. Table 1 describes how the 2017 Next Gen strategy maps to current activities.

Table 1: Original Next Gen Components Mapped to 2019/20 and 2022 Strategies

2017 Strategy 2019/20 Strategy 2022 Strategy

A – Digital platform and related middleware

The Digital and Customer Care (DCC) contract, which FSA awarded in February 2019, combined components A and B. The DCC contract includes the following components:

• Digital Platform –StudentAid.gov, FSA Partner Connect, and associated mobile functionality, which serve as one-stop interfaces for borrowers and partners, respectively. StudentAid.gov will ultimately serve as a repayment portal, among other functionality, for all federally managed borrower accounts.

• Marketing and Communications Platform – Provides FSA with the ability to directly email partners and customers with relevant information

• Customer Care Platform – Which includes a single 1-800 number, a Customer Relationship Management (CRM) tool that provides a 360-degree view of customers and partners, a command center with 3rd party independent quality monitoring of Business Process

B – Contact center platform and CRM

Operations (BPO) contact centers, and a solution for training and knowledge management for the BPO vendors.

C – Processing platform for new accounts

Optimal Processing Solution (OPS) solicitation (cancelled in 2020)

FSA anticipates awarding USDS Servicing contracts to multiple servicers to manage new and legacy accounts. These USDS Servicers will manage the platforms, contact centers, and manual processing activities for all non-specialty loan servicing tasks.

D – Processing platform for legacy accounts

2019 – Enhanced Processing Solution (EPS) solicitation (cancelled in 2020)

2020 – Interim Servicing Solution (ISS) solicitation for new and legacy accounts (cancelled in 2021)

E – Business process operations for new accounts

FSA awarded BPO contracts in June 2020. In 2021, the BPO vendors began managing contact center and manual processing for a variety of inquiries, including general questions to the Federal Student Aid Information Center, Student Loan Support Center, account authentication (FSA ID), the Ombudsman hotline, OIG fraud referral, and the borrower defense to repayment hotline. In 2022, the BPO vendors will begin managing outreach and manual processing for borrowers with defaulted loans.

Unlike past procurements, BPO vendors will not replace the USDS Servicer contact centers and manual processing. Instead, USDS Servicers will manage their own contact centers and manual processing for standard benefits, including the income-driven repayment (IDR) plans, deferments and forbearances, and most discharges. The BPO vendors will, however, begin taking on servicing tasks by managing the contact center and processing work for the following specialty servicing programs: Public Service Loan Forgiveness (PSLF), Temporary Expanded PSLF (TEPSLF), TEACH Grants, and Total and Permanent Disability (TPD) discharges. The borrowers associated with these programs will receive all other servicing from the USDS Servicers. BPOs will not need to connect to USDS Servicers’ systems; they will use platforms and tools provided by FSA. There are several benefits to this approach, and FSA will determine if additional servicing work—for example, IDR counseling and form processing and other types of discharges or forgiveness programs—should be further expanded to the BPO vendors based on performance.

F – Business process operations for legacy accounts

G – Data management platform

FSA developed the Enterprise Data Management and Analytics Platform Services (EDMAPS) via an amendment to an existing contract. EDMAPS serves as a repository for all FSA data and includes, but is not limited to, a data lake, the new Next Gen National Student Loan Data System (NSLDS), Person Master Data Management, and Education Data Warehouse and Analytics (EDWA).

H – Identity and access management

An FSA contractor provides this service, known to the public as the FSA ID (username and password) and to partners as AIMS. After award, USDS Servicers will work with FSA to implement the FSA ID for account authentication and will transition borrowers away from servicers’ proprietary authentication systems to the FSA ID. This will help enable single-sign on capabilities to provide better connectivity between StudentAid.gov and servicer sites until StudentAid.gov, ultimately, becomes the one-stop shop for all borrower account management functionality.

I – Cybersecurity Modern cybersecurity standards are included in all new contracts, including the USDS contracts.

J - Quality Assurance FSA has bolstered our workforce and business practices to improve vendor oversight for all new awards. Additionally, FSA has increased capacity to monitor the BPO contact centers via the DCC contract.

The Next Gen components address business operations throughout FSA and are relevant to loan servicing. For example, DCC is the gateway to all Federal student aid information, tools, and applications for FSA’s customers, but it can be further leveraged as a single repayment portal for loan servicing in the future.

The estimated student loan servicing and collections environment at the time of award illustrated in Figure 1 on the next page, represents progress toward the Next Gen initiative’s goals.

Figure 1: Federally Managed Student Loan Servicing and Collections Environment At Time of Award.

The USDS procurement will replace the Legacy Servicer Contracts for Title IV loans. USDS shares the goals of prior efforts, such as:

• Providing all federally managed borrowers with complete account management capabilities on StudentAid.gov;

• Reducing the disruption of account transfers; and

• Increasing accountability for servicers via clear, measurable service-level agreements.

There are, however, notable differences in USDS that will improve FSA’s ability to successfully implement the strategy and accomplish FSA’s goals.

• FSA is not seeking to purchase or build a single platform to service borrower accounts. Additionally, FSA is not seeking to reduce the number of platforms used or purchase or license platforms from servicers. Further, USDS Servicers do not need to own a processing platform to receive an award, but they must have continuous access to a platform via a subcontract, teaming, or license agreement.

• USDS Servicers will maintain separate processing platforms and work with FSA to build a common servicing data catalogue on EDMAPS. This will enable FSA to receive more fulsome data via common data management and processing rules. It will improve FSA’s ability to transfer accounts among servicers if necessary, improving FSA’s ability to hold servicers accountable by maintaining the ability to shift accounts away from underperforming servicers.

• This strategy allows FSA to avoid the cost and performance risks associated with purchasing and relying on a single servicing platform, while achieving a variety of goals, including enabling more-straightforward account transfers, creating opportunities for enhanced oversight, and, eventually, providing borrowers with complete account management on StudentAid.gov.

• USDS Servicers will manage the platforms, contact centers, and manual processing activities for all non-specialty loan servicing tasks. All borrower accounts will be assigned across USDS Servicers at FSA’s discretion, including borrower accounts historically associated with “specialty programs” under the legacy servicing environment (e.g., PSLF, TEPSLF, TPD, and the TEACH Grant Program). New borrower accounts will be assigned across all USDS Servicers based on the performance allocations described in Future Borrower Allocation Methodology (Attachment 21). However, BPO vendors will manage the processing and contact center work associated with these programs and will use tools and systems developed by FSA to receive application data, process forms, and send account status updates and discharge and forgiveness notices to USDS Servicers. BPO vendors will not directly access USDS Servicer platforms; instead, they will use tools provided by FSA to manage the specialty program work. Borrowers will have access to all tools, forms, and information they need on StudentAid.gov. Like other federal student loan benefits, such as closed school discharges, all USDS Servicers must be able to answer basic programmatic questions related to the specialty servicing programs; specific questions will be redirected to BPO vendors.

• FSA will hold USDS Servicers accountable for their portfolio performance, prioritize more support for borrowers at risk of delinquency and default, and ensure servicers are compliant with applicable consumer protection rules.

• FSA will take an incremental approach to implementing major initiatives, such as transitioning all repayment to

StudentAid.gov. As such, at go-live, USDS Servicers will be required to modify borrower-facing websites and communications to co-brand with FSA and provide borrower account authentication through the FSA ID. This approach will help transition borrowers from associating repayment only with their servicer to a more FSA-centered approach and will help borrowers better access forms and tools on StudentAid.gov. Within the base contract period, FSA will expand functionality on StudentAid.gov, eventually transitioning full borrower account management, branding, and repayment away from USDS Servicers’ websites.

• To enable repayment through StudentAid.gov, FSA will work with USDS Servicers to determine what data are necessary to the appropriate functioning of various web elements, such as making a payment, changing a repayment date, enrolling in a new repayment plan, or applying for a deferment or forbearance. Using this information, FSA will leverage the common data model that is being built in collaboration with USDS Servicers to report data elements to EDMAPS at an appropriate frequency for them to be displayed and operationalized on StudentAid.gov. FSA will develop and publish a set of data reporting standards, including Application Program Interfaces (APIs), to USDS Servicers to create the necessary connectivity between USDS Servicers’ platforms to FSA’s systems.

The target state for the student loan servicing and collections environment is illustrated in Figure 2 on the next page.

Figure 2: Target state for the federally managed student loan servicing and collections environment.

3. REQUIREMENTS, MILESTONES, AND DELIVERABLES

1) General Operating Requirements

The USDS Servicers shall provide services as more fully described in Attachment 01 - Business Operations Servicing Requirements (Attachment 1), Attachment 02 - Financial Technical Requirements (Attachment 2) and associated attachments; and Attachment 03 - IT Requirements Repository (Attachment 3). As fully described in Attachments 1, 2, and 3, the services and related requirements provided by the USDS Servicer includes but is not limited to the following:

a. Integration: USDS Servicers shall integrate with existing FSA or third-party solutions, and Next Gen solutions, as necessary. Post-award integration requirements will be managed by the Change Management Process, as described in Attachment 05 – Business Change Management Plan (Attachment 5 or Change Management).

b. Adaptability, Flexibility, and Ongoing Performance: USDS Servicers shall adapt and adhere to changes in FSA’s operating environment. USDS Servicers shall adhere to FSA’s Change Management Process. The USDS Servicers’ solution shall have the ability to efficiently scale to changes in borrower account and transaction volumes. Performance testing results are a requirement of this effort.

c. Customer Experience Focus: USDS Servicers shall prioritize borrower needs and preferences to deliver an improved borrower experience. USDS Servicers shall implement an approach that minimizes risk and disruption to borrowers while deploying more efficient and effective solutions.

d. Monitoring and Adhering to Changes in Laws, Regulations, and other Policies: USDS Servicers shall comply with all applicable Federal, State, and local rules, laws, regulations, and Department guidelines applicable to the USDS Program (including all accessibility elements such as 504/508 compliance). USDS Servicers shall establish a process to monitor changes to applicable laws and regulations to ensure compliance. If the USDS Servicer identifies a change in applicable law, the USDS Servicer must notify FSA to determine the implications of such change to the Contract, the technical design, and/or operational procedures. This Contract includes any scope changes to the Contract to ensure compliance with applicable laws and regulations.

e. Cybersecurity, Hosting, and Middleware: USDS Servicers shall ensure the USDS solution meets Federal Information Security Management Act (FISMA) and National Institute of Standards and Technology (NIST) standards. See Cybersecurity and IT Requirements as fully described in Department of Education Security and Privacy Requirements for IT Procurements within Attachment 03 and referenced under section C.5 of this document.

f. Financial Accuracy and Compliance: USDS Servicers shall adhere to the requirements listed in Attachment 2, and associated Financial Technical Requirements, and provide measures for ensuring the compliance and accuracy of financial transactions and reporting.

g. Requirements Changes: Changes to the business operations, finance, technical, and/or cybersecurity requirements delivered under this Contract will follow the change management process as described in Attachment 5.

h. Specialty Servicing Programs: The specialty servicing programs (e.g., PSLF, TEACH, TPD) require the USDS Servicer to strictly adhere to the requirements in Attachment 1. USDS Servicer will be responsible for the following: providing borrowers with basic information about these programs; connecting borrowers to resources on StudentAid.gov and at 1-800-4-FEDAID: and processing borrower account status changes, discharges, and forgiveness based on information transmitted by FSA.

i. Specialty Servicing Tasks. There are discrete specialty tasks that FSA intends to award to USDS Servicer(s) via task orders (Task Orders) under the Contract. Anticipated Task Orders include: FSA Image Repository;

Decommissioned Servicer Data Support and Payment Support; Legacy Loan Consolidation Adjustments (work contained within CLIN 12); and FFEL Guaranty Agency Rehabilitation Loan Purchases. These anticipated Task Orders are further described in Section C.3. Specialty Servicing Tasks.

j. Trained Personnel: USDS Servicers shall ensure personnel are trained and aware of pertinent, applicable laws, regulations, programs, and FSA’s performance expectations. Development of training content and material shall be done in coordination with FSA and/or FSA’s designees, as required.

k. Performance Management: USDS Servicers shall adhere to FSA’s Service Level Agreements/ Objectives and shall include performance management mechanisms that would enable improved and ongoing achievement of metrics. FSA will utilize the performance management framework and methodology in Attachment 08 - Service Level Methodology Performance Metrics (Attachment 8) and Attachment 09 –SLA and Future Borrower Allocation Calculator (Attachment 9) to support USDS performance management and to document achievement of the established Service Level Agreements (SLAs) and Service Level Objectives (SLOs). Attachment 9 explains the process by which the SLAs and SLOs will be measured. In order to strengthen transparency, FSA reserves the right to publicly release data related to USDS Servicer’s performance including, but not limited to, call center performance and timeliness. See also “Service Level

Agreements & Objectives Performance Incentive” under Part II Contract Clauses, Section I, Subsection 3 Additional Clauses, of this document for the functioning of these requirements as a performance incentive.

l. Quality Control and Compliance Management: USDS Servicers shall document, provide policies and procedures, and adhere to its quality management system to ensure quality is measured and managed on a consistent basis. USDS Servicers shall maintain a sound compliance management system (CMS) that is integrated into the overall framework for product design, delivery, and administration across the entire product and service lifecycle. Compliance should be part of the day-to-day responsibilities of management and the employees; issues should be self-identified; and corrective action(s) should be initiated by the USDS Servicer. USDS Servicers are also expected to manage relationships with USDS subcontractors and service providers to ensure such subcontractors and service providers effectively manage compliance with applicable statutory, regulatory, and contractual requirements.

m. Allocation of Current Borrower Accounts: FSA reserves the right to unilaterally shift current borrower accounts among USDS Servicers at the Contracting Officer’s (CO’s) direction when it is in the best interest of FSA or its borrowers, at no additional cost to FSA. It is anticipated that the movement of borrower accounts will be done with reasonable and prudent cause.

n. Allocation of New Borrower Accounts: The allocation of new borrower account volume during Task Order performance will be determined based on the performance of each USDS Servicer in relation to the other USDS Servicers awarded as further described in Attachment 21 and Attachment 9.

o. Non-Compliance and Invoicing: For any borrower accounts that the USDS Servicer caused or substantially contributed to non-compliant servicing of such borrower accounts shall not be billable to FSA from the initial point of occurrence. Such non-compliant servicing includes accounts not being serviced in compliance with any applicable statutory requirements, regulatory requirements or the terms and conditions of the Contract (including FSA guidance). Examples of non-compliant servicing of borrower accounts includes but are not limited to: inaccurate payment counts towards forgiveness, incorrect interest calculations, incorrect balances, incorrect interest determination and calculations, notices not being sent properly or not adhering to due diligence requirements; FSA reserves the right to request reimbursement of fees that have been invoiced for improper servicing and paid to the USDS Servicer, in a manner determined by FSA, and all other remedies available to FSA under the Contract and law.

p. Borrower Account Data Ownership: FSA has exclusive ownership of all information stored in, retrieved, modified, and/or archived as part of this Contract. The USDS Servicer shall have no rights in such information and no rights to such information shall vest in the USDS Servicer by virtue of its performance of this Contract. The USDS Servicer shall not use borrower account data in any manner other than as authorized under the Contract and necessary for performance in accordance with applicable laws and regulations.

q. Immunity: USDS Servicer acknowledges that it is not the U.S. Department of Education, and is not acting as the Government under this Contract. As such the USDS Servicer acknowledges that any claim or defense of Sovereign Immunity or Qualified Immunity is not applicable to work performed under the Contract and any Task Order issued under the Contract.

r. Personnel Security Requirements: The USDS Servicer shall comply with the Department of Education Acquisition Regulation (EDAR) clause 3452.204-72 Contractor Vetting Security Requirements and the Contractor Vetting Security Requirements document contained in Attachment 03.

s. Identity, Credential, and Access Management (ICAM) Requirements:

i. General ICAM Requirements:

1. All contractors accessing ED and FSA networks and/or data centers who are classified as Privileged Users (PU) are required to use government furnished Personal Identity Verification (PIV) cards for authentication and access. Note: FSA prohibits contractors from granting access to FSA systems without approval by the Department.

2. The USDS Servicer shall not issue the PIV-I card to the Privileged Users of the FSA system until after FSA has approved access for these users.

3. The USDS Servicer shall ensure that both Privileged Users and non-Privileged Users, who work on IT resources and applications (for example, the USDS Servicer systems) containing or accessing FSA’s data utilize, PIV/PIV-I cards. The USDS Servicer shall provide card readers and require Privileged Users and non-Privileged Users to use the PIV/PIV-I card for authentication and access to IT resources and applications containing or accessing FSA’s data satisfying an Identity Assurance Level (IAL3) and Authentication Assurance Level 3 (AAL3) as defined in NIST

SP 800-63-3.

4. The USDS Servicer shall ensure that a Privileged Access Management (PAM) system is utilized for all privileged user access to information systems. The PAM solution will manage access and log user activity. USDS Servicer must provide monthly access logs to FSA.

5. The USDS Servicer shall ensure that websites require multi-factor authentication when providing access to PII and other sensitive information.

6. The USDS Servicer shall request ed.gov accounts, and ensure PIV cards are issued, for all individuals that require access to Department and/or FSA business information systems, networks, or email accounts.

7. For a USDS Servicer(s) using a government furnished equipment (GFE) Laptop, the user shall use the Department provided Virtual Private Network (VPN) solution(s).

ii. ICAM Reporting Requirements:

1. The USDS Servicer shall provide a monthly PIV Card report to FSA including:

a) Number of privileged users with PIV cards disabled in the last 30 calendar days.

b) Number of privileged users with PIV cards enabled in the last 30 calendar days.

c) Total number of privileged users with PIV cards.

2. The USDS Servicer shall track and retain records of everyone who has approved access (user ID) to the servicing system, including clearances, training, and signed security documents; ensure that necessary clearances do not lapse; and suspend FSA access for anyone not in compliance.

3. The USDS Servicer shall provide a monthly PIV and/or PIV Card report(s) to FSA including:

a) Number of privileged users with PIV cards disabled in the last 30 calendar days.

b) Number of privileged users with PIV cards enabled in the last 30 calendar days.

c) Total number of privileged users with PIV cards.

4. The USDS Servicer shall send an email to all FSA System Security Officers at any time a user is no longer employed or no longer requires access to FSA systems, advising the FSA System Security Officers that the status of the person(s) identified is "no longer employed" or "no longer requires access to FSA systems." This email shall be sent at least 5 calendar days prior to an employee's removal from the Contract or immediately in cases that require immediate removal of an individual for security or suitability reasons.

t. Contractors shall submit their Background Investigation Requests electronically.

i. Upload the documents into Electronic Questionnaires for Investigation Process (E-QIP) and release the Investigation Request Packet to the COR in E-QIP.

ii. Send an electronic copy of the completed coversheet to your contract COR and system ISSO(s). If contractors require a blank coversheet, please contact the COR. When transmitting the cover sheet, please use the following subject in the header of the Microsoft Outlook Message:

Subject: [Name of Prime Contractor-Company Name (Name of Sub-Contractor- Company Name, if applicable)]: [Background Investigation (BI) Type] [BI Level] [Date of Submission] [Name of Company Official Responsible for Background applications]

iii. Please ensure that each coversheet is encrypted, and password protected with a unique password.

Do not send the password with the coversheet; instead send a separate email with the exact same subject line with the password in the body of the email. The password should include upper- and lower-case letters, numbers and special characters.

iv. Other than entering the requested data, do not modify the cover sheet format, structure or any other part of the spreadsheet. Any such change may result in the return of the cover sheet and background investigation paperwork for corrections and delay the processing of the packages.

v. Do not submit System Access Requests (SARs) with the background investigation paperwork. SARs are to be submitted to the Information System Security Officer (ISSO) that is responsible for your system. Please contact the ISSO(s) for specific information regarding the delivery (email, etc.) of the System Access Requests.

vi. Contact FSAPersonnelSecurity@ED.gov or your assigned Personnel Security Specialist or by phone (202-377-3400) with questions.

2) Operating Elements and Related Requirements The USDS Servicers shall provide operating elements and related requirements as more fully described in Attachment 1. Such requirements include:

a. Customer Accounts Migration:

i. USDS Servicers shall receive historical and current customer borrower accounts from Legacy Servicers. This includes both active and non-active borrower accounts. USDS Servicers shall cooperate with Legacy Servicers in transferring borrower accounts to USDS Servicers. USDS Servicers should expect reasonable cooperation from Legacy Servicers. USDS Servicers shall promptly report to FSA any issues or disputes regarding the transfer of borrower accounts.

ii. USDS Servicers shall ensure that borrower accounts successfully transfer. Transfer data includes: borrower account’s historical record of balances and transactions, loan consolidation, origination and disbursement records (e.g., underlying loan pay-off, lender detail, funding histories), auto-pay preferences, complete payment history, deferment and forbearance history, repayment plan history, contact preferences, and prior loan transfer imaged records. Additional borrower data types may be added through contract modification, Task Order modification or through the Change Management Process over the life of the Contract.

iii. USDS Servicers shall transfer loan data and images from closed/inactive borrower accounts from each non-default retiring Legacy Servicer. USDS Servicers must be able to reopen/ rebuild loans and return the borrower accounts to active servicing.

iv. USDS Servicers shall send and support the development and delivery of customer communications about the migration of borrower accounts before, during, and after the migration per FSA instructions. Communications under this Contract to customers being transferred cannot start until after Authorization to Operate (ATO) has been granted.

v. USDS Servicers shall convert Loan Consolidation Origination and Disbursement data. USDS Servicers shall convert 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 from active consolidation origination and disbursement systems. USDS Servicers shall ensure the solution is able to process all under and over payment adjustments.

vi. Upon decommissioning as a Federal Loan Servicer, the USDS Servicer shall support the offloading and transfer of historical borrower account data in accordance with the Phase-Out Plan, reviewed and approved by FSA, as further described in paragraph C.4.c below and in the records retention section of Attachment 1.

b. General Borrower Account Servicing Requirements:

i. USDS Servicers shall ensure the solution can execute the full range of servicing functions as fully described in Attachment 1, Attachment 2, and Attachment 3. The services provided by the USDS Servicers and associated requirements include, but are not limited to:

1. Provide staff, either in-house or through subcontracting, who perform front-end contact center agent and back-office agent work necessary to deliver all requirements.

2. Establish the following: Contact Center hours of operation at award: Monday 8 AM to 11 PM EST, Tuesday through Friday 8 AM to 8 PM EST, and Saturday 10 AM to 2 PM EST. This excludes Federal holidays.

3. USDS Servicers shall have a Call Management System that will be used to handle all inbound and outbound calls including required recording and reporting, as well as Interactive Voice Response capabilities.

4. Provide the migration of all physical documentation, for borrower accounts assigned to them, from the existing Legacy Servicers. USDS Servicers are required to cooperate with existing Legacy Servicers in transferring physical documentation to the USDS Servicer. USDS Servicers should expect reasonable cooperation from Legacy Servicers. USDS Servicers must report disputes regarding transfer of physical documentation to FSA without delay.

5. Provide Loan servicing for all borrowers in all loan statuses and monitor borrowers as they move through those statuses.

6. Establish repayment plans for borrowers across FSA-held Title IV Loans.

7. Determine and execute eligibility determination, annual recertification, and payment recalculation for Income- Driven Repayment (IDR) plans tied to a customer’s income, family situation, and other characteristics that may fluctuate. IDR plans include, but are not limited to Income-Contingent, Income-Based, Pay-As-You-Earn, and Revised-Pay-As-You-Earn.

8. Process, predetermine, and/or execute discharge/forgiveness under various Title IV programs (e.g., Income- Driven Repayment, Closed School, Automatic Closed School, Death, False Certification).

9. Execution, discharge and forgiveness for Public Service Loan Forgiveness, Teacher Loan Forgiveness, Total Permanent Disability, and Borrower Defense.

10. Determination, execution, and implementation of eligibility for various forbearance/deferment programs.

11. Engage in delinquency management and default prevention to assist borrowers in staying current with their repayment plans.

12. Accurately report the status of borrower accounts to the national Credit Reporting Agencies (CRAs) in compliance with the Fair Credit Reporting Act (FCRA) and respond timely to borrower disputes.

13. Process loan consolidation origination and disbursement, including application, pay off, booking new loans, maintaining borrower account histories, performing all reconciliation and financial reporting, and other activities.

o This includes the processing of under/over payment adjustments for legacy consolidation loans and any future decommissioned consolidation origination systems.

14. Accommodate changes in repayment plan options, in accordance with Attachment 5.

15. Accurately complete retroactive adjustment processing (e.g., retroactive application of deferments, forbearances, payments, and manual adjustments).

16. Respond to control mail, congressional mail, FSA escalations, FSA feedback, borrower complaints and borrower account disputes.

17. Comply with all applicable Federal, State and local laws, rules, and regulations applicable to its performance under this Contract (e.g., the Fair Credit Reporting Act, the Fair Debt Collections Practices Act, the Truth in Lending Act, etc.) and shall maintain a sound compliance management system (CMS) that is integrated into the overall framework for product design, delivery, and administration across their entire product and service lifecycle.

18. USDS Servicers shall execute internal quality control on all operational activities, submit operational and performance reports to facilitate transparency, oversight, and accountability, promptly notify FSA of any issue or instances of non-compliance, and support monitoring and oversight.

c. Financial Functions:

i. USDS Servicers shall perform all financial functions as outlined in Attachment 2 and associated attachments.

This includes, but is not limited to:

1. Process specific financial and non-financial activity/transactions to correctly record all transactions processed to the servicing system and sending equivalent summary transactions to FSA’s general ledger (FMS). Perform various accounting process flows for loan account types unique to the Government sector.

2. Utilize specific file transmission mechanisms and processing channels for various system integration processes associated with the Oracle Financial Management System (FMS) used by FSA.

3. Utilize specific financial report and reconciliation file layouts to complete accurate financial deliverables that comply with all associated requirements by the required due date as indicated in the Finance Requirements. Generate various reports and reconciliations to demonstrate that the underlying servicing system data and process flows incorporated in the various reports and ensure reconciliations generated are accurate.

4. Incorporate a system of internal controls consistent with requirements derived from applicable Federal laws, regulations, policies and authoritative guidance. These laws, regulations, and guidance include, but are not limited to: Federal Financial Management Improvement Act (FFMIA); Federal Managers' Financial Integrity Act (FMFIA); CFO Act; Government Performance and Results Act (GPRA); GAO's Standards for Internal Control (i.e., the "Green Book"); OMB Circulars A-123 and A- 130; FISMA; NIST Special Publications; the Treasury Financial Manual (TFM); GAO's Financial Audit Manual (FAM); and GAO's Federal Information System Controls Audit Manual (FISCAM).

ii. USDS Servicers shall conduct error and dispute resolution investigation and processing, including, but not limited to:

1. Borrower account maintenance, including manual correction of errors identified through data integrity scans and manual adjustments as identified by FSA.

2. Payment and refund processing, including researching lost or misapplied payments and payment reapplication at the request of customers or FSA.

iii. USDS Servicers shall maintain data history, including retroactive processing (e.g., “as-was” vs “as-is”), and tracing loans through consolidation payoff (initial payoff, under and over payments) transactions. This data shall be available and shared with other solutions and systems as directed by FSA.

iv. USDS Servicers shall provide timely support for FSA’s future-state processing solution from requirements gathering through development, including access to the USDS Servicers’ Subject Matter Experts and solution set (e.g., system code, workflows, processing tools and infrastructure/environment, etc.).

d. FSA Branding:

i. FSA requires that all public-facing, USDS Servicer products shall follow the FSA Servicer Brand Guidelines, as more fully described in Attachment 11 (FSA Servicer Brand Guidelines). The FSA Brand Guidelines include the FSA Writing Style Guide and co-branding elements for all public-facing products.

In addition, when directly presenting FSA brand elements such as the FSA logo, the USDS Servicers shall follow the FSA Brand Style guide and FSA Design System (collectively, Style Guide and Design) attached hereto as Attachment 10.

ii. As further described in the FSA Servicer Brand Guidelines and Style Guide and Design, the USDS Servicers shall comply with the following FSA brand requirements when creating, designing, developing, writing, updating, and maintaining both information technology products and document products:

1. FSA Servicer Brand Guidelines and Style Guide and Design requirements apply to all websites and mobile apps, all configured screens within information systems, all mobile application screens, all social media, and all customer-facing documentation/content that is intended for use by students, parents, borrowers, or schools.

2. The FSA Servicer Brand Guidelines and Style Guide and Design requirements apply to all new or edited content and does not imply the need to audit all past content for compliance.

3. Documentation that is purely internal in nature for use by FSA staff and contractors, such as project management documentation and documentation used to manage information systems, shall not be subject to the branding requirements. Information technology that is purely back-end in nature (the user base consists of system administrators or only IT-personnel) shall not be subject to the branding requirements.

4. USDS Servicers shall submit brand layouts or plans, appropriate to the product they are producing and specified by the FSA Servicer Brand Guidelines and Style Guide and Design…