A13 Attachment 1 - STATEMENT OF WORK.docx

STATEMENT OF WORK

STATISTICAL SERVICES

BACKGROUND

The OAS conducts independent audits of Health and Human Services (HHS) programs to help reduce waste, abuse and mismanagement and promote economy and efficiency throughout HHS. It is OAS’s policy that auditors use the statistical estimators for estimating a monetary recovery, for estimates other than for monetary recovery (i.e. Funds Put to Better Use), use the appropriate estimator; and report the point estimate. In addition, for rate-setting audits OAS policy requires the use of the appropriate estimator and recommend the point estimate. A statistical sampling plan is required for all audits if estimates relevant to the audit objectives are reported. Sample estimates should be based on output from OAS approved programs.

For efficiency, the OIG makes extensive use of statistical sampling projections to draw conclusions during audits. These statistical projections are the basis for most audits in which large cost savings are reported or large amounts are recommended for recovery. The sampling plans for these audits are developed in accordance with the OAS policy on Statistical Sampling and Mathematical Estimation Techniques in Auditing. We need to expand and refine our statistical capability because continually increasing demands on our audit resources create a need for us to develop more efficient and effective sampling plans.

DESCRIPTION OF SERVICES

OAS requires statistical advice and assistance including maintenance of the OIG OAS Statistical Software (RAT-STATS). RATS-STATS is a suite of statistical modules containing a Random Number Generator, variable appraisal programs, attribute appraisal programs, and sample size estimators. This computer application is complex and requires ad hoc editing to troubleshoot and resolve any problems which may arise. Furthermore, the methodology used in this software is widely used by the healthcare industry as well as Federal and State oversight agencies in matters of extrapolating overpayments due to the government and extrapolating program savings. It is necessary for RAT-STATS to function properly as it may be contested in the court system. Included in RAT-STATS is an esoteric method of statistical sampling – RHC Multistage Sampling (RHC) – module which the Office of Audit Services often uses. The computer programming surrounding RHC is complex.

Contractor shall provide a variety of services in the area of statistical methodologies and generally accepted statistical principles for use in statistical sampling and statistical analysis as it relates to OAS audits.

SPECIFIC TASKS

Task 1: Meetings via Teleconference Contractor shall, on an as needed basis, participate in a teleconference to discuss the specifics of ad hoc requests submitted by the COR, discuss troubleshooting related to the RAT-STATS Statistical Software, obtaining expert advice of legal challenges on OAS’s sampling methodologies, etc. At a minimum, Contractor and the OIG shall discuss the specifics of the request and a timeline for completing the request.

Task 2: Consultative/Ad Hoc and Software Maintenance Services The COR will request that the Contractor provide services in the area of statistical methodologies and generally accepted statistical principles on statistical sampling and analysis as it relates to ongoing audits.

Contractor shall, on an ad hoc basis, provide technical assistance to troubleshoot issues that arise as it relates to the OAS RAT-STATS Statistical Software and provide testing to changes in the RATS-STATS Statistical software that are made by other contractors.

Contractor shall on an ad hoc basis, serve in an advisory capacity to OAS to address legal challenges as it relates to statistical methods in OAS audits.

The Contractor shall provide expert advice on statistical sampling methodologies as it related to OAS audits.

The COR serves as a liaison between the Contractor and the Regional Statistical Sampling Specialists and will communicate directly with the Contractor on ad hoc requests to address:

(1) statistical sampling questions/issues related to on-going audits,

(2) issues that requires technical assistance in troubleshooting and testing the RAT-STATS software,

(3) legal challenges to OAS statistical procedures and methodologies and defend cases filed on appeal (such as providing a written statement or testifying in a court of law), and

(4) any other issues that requires the Contactor’s expertise that is in the scope of this SOW.

In the absence of the Director of Quantitative Methods, the COR may coordinate with the Director of Advanced Audit Techniques.

Task 2.1: Consultations/Legal Preparation Assistance On an as needed basis, the COR and may request that the Contractor

(1) address statistical sampling methodology and approach related to ongoing audits, and

(2) render an opinion by submitting a written statement or testifying in court when OAS’s statistical methodologies are challenged.

In some cases, important sampling procedures need to be reviewed by an outside expert statistician before the procedures are applied.

OAS will provide all pertinent audit working papers related to the statistical sample being challenged, copies of any documentation from the auditee, and any information from the official appeals process.

Contractor will either provide a written statement as to the adequacy of the sampling methodology or if necessary, will testify before formal bodies in a court of law.

Travel is not expected for this task, but in the rare event that it is necessary, travel & per diem will be funded in order for the Contractor to provide the service.

The Contractor shall complete the consultation request no later than 60 calendar days from the receipt of such request.

Task 2.2: Testing/Troubleshooting RAT-STATS Statistical Software and completing Ad-Hoc requests On an as needed basis, the COR and shall submit a request for the Contractor to troubleshoot issues, including to test or edit the computer logic in the RAT-STATS Statistical Software to resolve the problem. Contractor shall respond to the request and resolve these issues no later than 45 calendar days from receipt of the request. Contractor will provide copies of the source code and the documentation.

These requests usually require custom modification to the RAT-STATS software to fulfill a unique need that OAS has. The requests can also involve the Contractor running custom reports on the RAT-STATS software for OAS analysis. The number of days to complete an ad hoc request is 45 calendar days. The COR and Contractor shall make a determination as to the complexity of the request. If it is determined that the request will take more than 45 calendar days to complete, then the COR and Contractor will agree upon the number days to complete the ad hoc request.

Task 2.3: Update Statistical Manual Contractor maintains the technical guidance manuals that accompany the RAT-STATS Statistical Software. The COR may request that the Contractor update the statistical manual, accordingly. Contractor shall update the Statistical Sampling Manual no later than 45 calendar days from receipt of the request.

Task 3: Conduct Annual Training Contractor shall provide annual training to OAS Statistical Specialists in the use of the RAT-STATS Statistical Software.

Contractor shall provide training to OAS auditors and Statistical Specialists in current statistical sampling methodologies and practices it applies to OAS auditing.

Contractor shall ensure that the training encompass various levels of statistical sampling methodologies and concepts applicable to OAS auditing and sampling policy.

Contractor will provide all course materials and teaching aids.

OAS will provide the training facilities and pay for traveling costs incurred by the Contractor in accordance with Department of Health and Human Services (HHS) requirements. The training costs under this SOW will not include travel costs incurred by OAS auditors and Statistical Specialists that will attend the training. The training will be limited to no more than 25 students.

Contractor shall provide training once per year and no later than July 31st of the contract period.

Task 4: Reporting Requirements Contractor shall submit a Progress Report to update OAS on the progress related to ad hoc requests relating to on-going audits, testing/troubleshooting the RAT-STATS Statistical Software, and any other ad hoc requests performed during the contract period. Contractor shall submit a Final Report to summarize the work performed under the SOW during the contract period.

Task 4.1 Progress Reports on Quarterly Results Contractor shall provide a Progress Report each quarter of the contract period. The report shall contain at a minimum the progress on the results of the work performed and completed in accordance with the SOW during each quarter of the contract period. The Contractor shall submit the quarterly report no later than 20 calendar days after the end of each quarter of the period of performance.

Task 4.2 Final Reports on Annual Results Contractor shall provide a Final Report by July 31st of the period of performance. The Final Report shall summarize for the one-year period, the work performed and completed in accordance with the requirements of the SOW.

PERSONNEL REQUIREMENTS

Mathematical Statistician (Statistician) The Statistician shall have extensive knowledge of OAS’s Audit Policy and Procedures as they relate to statistical sampling. These skills shall be specialized in testing and upgrading, trouble shooting, and editing the computer logic in the RAT-STATS software. The Statistician shall have experience in teaching any advanced statistical sampling course as it applies to OAS auditing. The overall duties shall include:

· Providing expert advice for on-going audits;

· Testing/Troubleshooting the RAT-STATS Statistical Software;

· Providing statistical advice and assistance to develop and test the RAT-STATS Statistical Software;

· Providing a written statement or testifying in court to defend OAS sampling design and methodology when it is challenged; and

· Training OAS Statistical Specialist on current generally accepted statistical principles and practices.

PERSONALLY IDENTIFIABLE INFORMATION

When transmitting any information containing personally identifiable information/protected health information (PII/PHI) to OAS over the Internet, Contractor shall properly safeguard the information.

When transmitting PII/PHI Contractor shall use the HHS/OIG Delivery Server, not email or attachments to email. Information transmitted through the HHS/OIG Delivery Server complies with Federal Information Processing Standard (FIPS) 140-2, Security Requirements for Cryptographic Module. When necessary, OAS will discuss authorizing the Contractor to use the HHS/OIG Delivery Server and give instructions in its use.

Contractor shall not transmit PII/PHI information in an unencrypted format.

Contractor will ensure that HHS/OIG data stored on portable media is encrypted to FIPS 140-2 level encryption.

OAS is required to report as a security breach any information containing PII sent to OAS in a manner that does not meet FIPS 140-2 requirements.

DELIVERY SCHEDULE

Contractor shall submit all required reports and deliverables in accordance with the following schedule:

SECURITY OF DATA

HHS-Controlled Facilities and Information Systems Security

(a) Position sensitivity level(s): 5 applies.

(b) The personnel investigation procedures for Contractor personnel require that the Contractor prepare and submit background check/investigation forms based on the type of investigation required. The minimum Government investigation for a non-sensitive position is a National Agency Check and Inquiries (NACI) with fingerprinting. More restricted positions--i.e., those above non-sensitive, require more extensive documentation and investigation. The Contractor shall notify the Contracting Officer in advance when any new personnel, who are subject to a background check/investigation, will work under the contract and if they have previously been the subject of national agency checks or background investigations.

(c) Investigations are expensive and may delay performance, regardless of the outcome of the investigation. Delays associated with rejections and consequent re-investigations may not be excusable in accordance with the FAR clause, Excusable Delays--see FAR 52.249-14. Accordingly, the Contractor shall ensure that any additional employees whose names it submits for work under this contract have a reasonable chance for approval.

(d) Typically, the Government investigates personnel at no cost to the Contractor. However, multiple investigations for the same position may, at the Contracting Officer's discretion, justify reduction(s) in the contract price of no more than the cost of the additional investigation(s).

(e) The Contractor shall include language similar to this "HHS Controlled Facilities and Information Systems Security" language in all subcontracts that require subcontractor personnel to have the same frequency and duration of (1) physical access to an HHS-controlled facility; (2) logical access to an HHS-controlled information system; (3) access to sensitive HHS data/information, whether in an HHS-controlled information system or in hard copy; or (4) any combination of circumstances (1) through (3).

(f) The Contractor shall send inquiries, including requests for forms and assistance, to the Contracting Officer or designee.

(h) Within 7 calendar days after the Government's final acceptance of the work under this contract, or upon termination of the contract, the Contractor shall return all identification badges to the Contracting Officer or designee."

Contractor shall possess all other appropriate hardware, software, and telecommunications equipment to undertake this SOW.

Contractor shall maintain encrypted back-up copies of all data and work products provided to the Government.

Contractor shall not disclose or share any information to any other individual or entity.