Att. 1 - NFIP-Direct Statement of Objectives.pdf

NATIONAL FLOOD INSURANCE PROGRAM

NFIP DIRECT 2023

Statement of Objectives January 2023

Procurement Sensitive

Table of Contents 1 Purpose 2 Background 3 Scope 4 Performance Objectives and Requirements

4.1 Management

4.2 NFIP Direct Operations

4.2.1 NFIP Direct Standard Services

4.2.1.1 NFIP Policy Servicing

4.2.1.1.1 Group Flood Insurance Policy Servicing

4.2.1.1.2 Severe Repetitive Loss Target Group (SRL TG)

4.2.1.2 NFIP Contact Center

4.2.2 Write Your Own Company Assumptions

4.2.3 NFIP Direct – Flood Disaster Services

4.2.3.1 Standard Flood Disaster Services

4.2.3.2 Post-Flood Event Analyses

4.2.4 NFIP Direct Program Support

4.2.4.1 Customer Service

4.2.4.2 Correspondence

4.2.4.3 Statutory/Regulatory Compliance

4.2.4.4 Program Enhancements

4.2.4.5 NFIP Data Reporting

4.2.4.6 NFIP Direct Financial Management

4.2.4.7 Policy Appeals

4.2.4.8 Claims Appeals

4.2.4.9 Litigation Support

4.2.4.10 NFIP Direct Marketing

4.2.4.11 Print, Storage, and Postage

4.3 Customer Experience (CX) Labs

4.4 Flood Insurance Claim Office (FICO) Operations

4.5 NFIP Direct to Customer (D2C) Support

4.6 Information Technology (IT) Solutions

4.6.1 Security and Privacy Compliance

4.6.2 ATO Project Plan

4.6.3 Data Containers

4.6.4 Application Services

4.6.5 Government Furnished Information (GFI)

4.7 Transition

4.7.1 Transition-In

4.7.1.1 General Transition-in Activities

4.7.1.2 Operations Transition-In Activities

4.7.1.3 IT Transition-In Activities

4.7.2 Transition Out

4.7.2.1 Reporting

4.7.2.2 Operations Continuity During Transition

4.7.2.3 IT Continuity During Transition

4.7.2.4 IT Transition-Out Plan

5 Performance Requirements 6 Deliverables

6.1 Business Continuity Plan

6.2 Deliverables Chart

7 Personnel

7.1 Personnel Requirements

7.2 Key Personnel

8 Government Furnished Equipment 9 Contract Information

9.1 Contract Type

9.2 Period of Performance

9.3 Place of Performance

10 Constraints, Assumptions, and Required Standards

10.1 Transition-In

10.2 Group Flood Insurance Policies (GFIP)

10.3 Customer Service/Contact Center

10.4 Claims

10.5 Data Analytics and Reporting

10.6 Transition-Out

10.7 Statutes, Regulations, Policies, Guidelines, and Specifications

1 Purpose

The purpose of this Statement of Objectives (SOO) is to obtain insurance industry leading and innovative contractor support for National Flood Insurance Program (NFIP) Direct services that meet the objectives described herein in a manner that aligns with the U.S. Department of Homeland Security’s (DHS) Federal Emergency Management Agency’s (FEMA) Strategic Plan, Federal Insurance and Mitigation Administration’s (FIMA) guiding principles and values and the Federal Insurance Directorate’s (FID) Strategy.

2 Background

FEMA’s mission is helping people before, during, and after disasters. FEMA accomplishes this mission through the development and execution of the FEMA Strategic Plan.

FEMA’s Strategic Goals are:

• Instill equity as a foundation of emergency management

• Lead whole of community in climate resilience

• Promote and sustain a ready FEMA and prepared nation

FEMA focuses on building and developing a culture of preparedness across the country and unifying all levels of community and government into an integrated approach to emergency management. As part of FEMA, the FIMA concentrates on increasing the capabilities necessary to reduce loss of life and property by lessening the impact of disasters. FIMA has developed guiding principles that drive decision making.

FIMA’s guiding principles are:

• A prepared and resilient nation

• Reduce disaster suffering

• Build a world class organization by focusing on customer satisfaction and empowering people to drive action together

FIMA manages the NFIP. Congress created the NFIP through passage of the National Flood Insurance Act (NFIA) of 1968, and over the last 50 years, Congress has updated and added new requirements through various other legislation. Through passage of these acts, Congress authorized FEMA to institute regulations that govern the NFIP and the delivery of flood insurance to policyholders in eligible communities using Title 44 Code of Federal Regulations (44 CFR) parts 59 through 62. To emphasize the importance of the information, FEMA incorporated the entirety of the Standard Flood Insurance Policy (SFIP) into 44 CFR. FEMA also issues further guidance to external partners to aid in the issuance of policies and adjusting of claims, such as the Flood Insurance Manual (FIM), the National Flood Insurance Claims Manual, and various FEMA Bulletins.

Under FIMA, FID’s mission is to provide customer focused flood insurance to help survivors and their communities effectively recover from flood events.

As part of the NFIP, the NFIP Direct facilitates the issuance and administration of flood insurance policies on behalf of the Government. As such, positive public perception of the NFIP Direct and its handling of policy administration are important to FEMA. FEMA requires the NFIP Direct to fully comply with all statutes and demonstrate working knowledge and understanding of applicable regulations, policies, guidelines, and specifications that affect the NFIP, FIMA, FEMA, and DHS.

The NFIP Direct is positioned to set the standard for the entire NFIP by embodying FIMA’s guiding principles and FEMA’s strategic goals. FEMA envisions the NFIP Direct as the example and insurance industry leader for the entire NFIP and expects NFIP Direct employees to be familiar with all FEMA survivor programs to facilitate seamless service to survivors. FEMA also requires the NFIP Direct to function as a test laboratory for program innovation and initiatives that further FIMA’s guiding principles and the FEMA mission. To meet this vision, FIMA requires the contractor to continuously review, improve and innovate processes and tools as the environmental, technological, and political considerations impacting the NFIP evolve.

FID oversees a portfolio of contracts to support delivery of the NFIP. NFIP contracts support the direct sale and servicing of NFIP policies (addressed by this NFIP Direct SOO); communications; operations, maintenance, and development for NFIP technology; standard business operations; and program management. Universal objectives, assumptions, and constraints applicable to all NFIP contracts are provided below.

FIMA is transforming the NFIP to update the products, processes, and procedures that support the program. The new risk rating system has been redesigned to leverage industry best practices and current technology to deliver rates that are fairer, easier to understand, and better reflect a property’s unique flood risk. FEMA calls this effort Risk Rating 2.0 and will include updates to rates for all NFIP-insured properties over the next several years. Through these efforts, FEMA’s goal is to make flood insurance significantly easier for agents to price and sell policies, and in turn, help customers better understand their flood risk and the importance of flood insurance.

As FEMA strives to increase climate resilience, ensure equitable access and outcomes for all citizens, and promote and sustain a ready FEMA and nation, it is imperative that FEMA enable the digital sale and servicing of flood insurance to increase the number of people covered. FEMA calls this initiative “Direct to Customer” or “D2C”. The D2C Initiative is intended to supplement policy sales made through Write Your Own (WYO) partnerships and NFIP Direct agents and not replace them. This initiative is in its early planning stages, therefore FEMA is not sure when, how, or if this capability will be developed, delivered, and maintained. References to D2C in this SOO are notional, optional, and subject to change.

Universal Program Objective 1: The NFIP is growing. As the program works to close the nation’s insurance gap, support services must scale to meet the workload expected to deliver world-class operations, inclusive of day-to-day, response, and recovery activities.

Universal Program Objective 2: The NFIP must make it easier to sign up and maintain flood insurance.

From forms, to rating, to the claims process, the NFIP must continue to evolve how it delivers the program to help close the insurance gap and make it easier for citizens and communities to invest in hazard mitigation activities. All providers must directly contribute to improving the customer experience.

Universal Program Objective 3: FEMA must reduce the complexity of the NFIP and increase the program’s transparency. Leveraging process changes, improved communications, and new technology, FEMA must ensure that homeowners have insight, education, and confidence in the entire insurance lifecycle.

Universal Program Objective 4: To ready the nation for catastrophic disaster, FEMA must build and sustain long-lasting and mutually beneficial partnerships and coalitions with public and private organizations to leverage capabilities and influence, extending the reach of the NFIP’s mission.

Universal Program Objective 5: The NFIP must plan for and implement changes stemming from the reauthorization and other legislative and regulatory changes.

Universal Program Assumptions and Constraints

• All activities will align to DHS/FEMA/FIMA/FID strategies and intents.

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

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

• Updated rates will be implemented in a phased approach, with new rates going into effect over the next several years.

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

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

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

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

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

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

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

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

3 Scope

The Contractor shall perform all actions necessary to, or incidental to, policy administration services for flood insurance policies in support of the NFIP Direct. The Contractor shall have responsibility for management, operation, maintenance, and quality assurance for the services. The Contractor shall provide IT solutions to accomplish the full scope of this requirement. The actual number of policies administered by the NFIP Direct and percentage of NFIP Direct policies within the entire NFIP varies daily. Because of this, the Government does not guarantee the number of policies to be serviced by the NFIP Direct. The Government, through this contract, reserves the right to establish unique operations, standards and reporting requirements specific to the NFIP Direct and unique policies to be issued solely by the NFIP Direct. Should the situation arise, the contractor shall also assume the policies of WYO companies that withdraw or that FEMA terminates from the NFIP.

Furthermore, the Contractor will act as a laboratory for testing Government initiatives that aim to enhance customer experience and better align the NFIP Direct with FEMA’s Strategic Plan, FIMA’s guiding principles, and FIMA’s values.

The Contractor may be tasked to support the D2C Initiative for scope elements that align closely with this requirement.

4 Performance Objectives and Requirements

The Contractor shall provide solutions, which are able to be implemented in the public sector, that are innovative, flexible, reflect subject matter expertise, and increase efficiency and effectiveness, taking into consideration the Government’s continuing resource constraints.

The overall performance objective is to deliver customer-focused, secure, quality, scalable NFIP Direct service operations in a cost-effective and timely manner, while testing new initiatives of the NFIP.

4.1 Management

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

o Meeting minutes are due five business days after the kick-off meeting.

• Program Management Plan and Quality Management Plan o The Contractor shall submit a program management plan within 30 days of award.

o The Contractor shall submit a quality management plan within 30 days of award.

The quality management plan may be addressed in the program management plan or as a stand-alone document.

o At its discretion, the Contractor may submit IDIQ-level Program Management and Quality Management Plan(s) with the transition task order that can be updated as appropriate within 30 days of award for each subsequent task order in lieu of Plans for each task order.

• The Contractor shall facilitate quarterly in-progress review meetings to enable planning and tracking of service and delivery milestones.

• The Contractor shall maintain a spreadsheet to track submittal and acceptance of deliverables and work products.

o The final version is due at the end of the period of performance.

o Interim versions may be requested no more frequently than monthly.

o Interim versions shall be submitted in conjunction with the Monthly Technical Progress

Narrative.

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

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

• The Contractor shall submit a Monthly Technical Progress Narrative (MTPN) and monthly contract status reporting.

o The reporting period shall match the invoice period.

o The MTPN report shall be submitted with or before the corresponding invoice.

o At a minimum, MTPNs shall include:

Relevant contract information;

Costs invoiced for the relevant period;

Costs invoiced to date;

Accomplishments/status/updates;

Deliverables/work products submitted;

Identified risks;

Activities planned for the next reporting period;

Project health; and With alignment to contract objectives.

o At the Contractor’s discretion, MTPNs for all active task orders may be combined into a single IDIQ MTPN.

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

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

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

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

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

4.2 NFIP Direct Operations

The Contractor shall issue and administer accurate and timely NFIP products, including NFIP Direct-only products, to further FEMA’s mission and maximize stakeholder confidence in the NFIP.

4.2.1 NFIP Direct Standard Services

NFIP Policy Types

Standard Flood Insurance Policy (SFIP) means the flood insurance policy issued by the Federal Insurance Administrator or an insurer pursuant to an arrangement with the Federal Insurance Administrator pursuant to Federal statutes and regulations. (44 CFR § 59.1)

A Group Flood Insurance Policy (GFIP) is a policy covering all individuals named by a State as recipients under Section 408 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act) (42 U.S. Code [U.S.C.] 5174) of an Individuals and Households Program (IHP) award for flood damage as a result of major disaster declaration by the President. (44 CFR § 61.17)

Severe Repetitive Loss Target Group (SRL TG):

FEMA designates as Severe Repetitive Loss (SRL) any NFIP-insured single-family or multi-family residential building:

1. That has incurred flood-related damage for which four or more separate claims payments have been made, with the amount of each claim (including building and contents payments) exceeding $5,000, and with the cumulative amount of such claims payments exceeding $20,000;

or

2. For which at least two separate claims payments (building payments only) have been made under such coverage, with the cumulative amount of such claims exceeding the market value of the building. In both instances, at least two of the claims must be within 10 years of each other, and claims made within 10 days of each other will be counted as one claim.

In determining SRL status, FEMA considers the loss history since 1978, or from the building’s construction if it was built after 1978, regardless of any changes in the ownership of the building.

The term “SRL property” refers to either an SRL building or the contents within an SRL building, or both. (Biggert-Waters Flood Insurance Reform Act of 2012)

Only policies designated with a unique SRL number are eligible for billing/inclusion according to this definition/contract. For example, condominiums in the same building share the same street address (number). However, only the individual units and policies with unique SRL numbers are eligible for SRL billing/inclusion in the target group.

Individual policies may only be billed as a single policy type.

4.2.1.1 NFIP Policy Servicing

The requirements below are applicable to all NFIP policies (SFIP, GFIP, and SRL TG policies).

The Contractor is shall:

• Readily furnish, and make electronically available, when applicable, insurance policy forms and NFIP print materials to stakeholders.

• Accept and process flood insurance applications within the timeframes referenced in applicable NFIP rules and regulations, as well as those set forth in the Quality Assurance Surveillance Plan (QASP). This should include the acceptance of both electronic and hardcopy submissions.

• Underwrite and validate application information to accurately rate the policy or obtain an accurate premium quote and properly cover the policyholder’s property to mitigate policyholder risk.

• Collect and process premiums (initial, renewals, and endorsements). Payments may be made by electronic credit card submission, paper check, wire transfer or money order. Cash will not be accepted.

• Generate and provide the policy declaration page and a copy of the policy to policyholders and any applicable stakeholders within the timeframes referenced in applicable NFIP rules and regulations, as well as those set forth in the QASP.

• Proactively troubleshoot and resolve issues with policyholder agent and other stakeholders when additional information is needed to process applications, execute renewals, or administer policies.

• Generate and furnish renewal notices to policyholders and any applicable stakeholders within the timeframes referenced in applicable NFIP rules and regulations, as well as those set forth in the QASP.

• Mail Renewal Encouragement Letter to new policyholders 90 days before the end of the first policy term.

• Process renewals/endorsements and furnish updated declaration pages to policyholders and any applicable stakeholders within the timeframes referenced in applicable NFIP rules and regulations, as well as those set forth in the QASP. This should include the acceptance of both electronic and hardcopy submissions.

• Process policy cancellations, validating the reason for cancellation, and issuing refunds (if applicable) within the timeframes referenced in applicable NFIP rules and regulations, as well as those set forth in the QASP. This should include the acceptance of both electronic and hardcopy submissions and should impose minimal requirements on the policyholder.

• At the direction of the Government, coordinate with Federal, State, Local, and Tribal governments and communities regarding policy and policyholder information, community standards, and mandatory purchase requirement instructions.

• Provide FEMA access to all necessary information to conduct operation reviews, audits, and other surveillance of NFIP Direct Underwriting policy records.

• Respond to findings and recommendations of any reviews, audits, and surveillance in a timely manner.

• Carry out the policies, operations, standards and reporting for unique, requirements such as GFIP, SRL policies, Flood Insurance Reform Act (FIRA) of 2004 Section 207, and financial reporting.

4.2.1.1.1 Group Flood Insurance Policy Servicing

The additional requirements below are applicable to GFIP.

Group Flood Insurance Policy Certificates

The Contractor shall:

• At the direction of the Government, coordinate with FEMA’s IHP and personnel from State

Other Needs and Assistance (ONA) program, when necessary.

• Review list of recipients provided by FEMA IHP or the State’s ONA program, confirming the property is eligible and returning ineligible and duplicative recipients. Notify FEMA of any discrepancies.

• Coordinate and resolve any processing issues with FEMA‘s Individuals and Households Program.

• Process Premiums and return funds for ineligible or duplicative certificates.

• Issue master policy and subsequent certificates after observing any required waiting periods in accordance with applicable NFIP rules and regulations, and those set forth in the QASP.

• Furnish certificate, Summary of Coverage Brochure, and a copy of the master policy to recipient within 10 days of receipt of accurate documentation from Individuals Household Branch or ONA.

• Maintain records at both the master policy and recipient certificate level within any proposed IT solution(s). The solution(s) should have the capability to track any policy or certificate to a specific disaster declaration and individual certificate coverage dates.

• Process new owner/tenant notifications.

• Reconcile the List of Recipients with Premiums Received, notifying FEMA when there are discrepancies.

• Update GFIP Coverage limits in any proposed IT solution(s) and within any GFIP related materials annually, or at any time as requested by FEMA.

• Maintain all necessary GFIP policy administration guidelines, form letters, and procedures.

These items shall be subject to FEMA approval.

• Furnish anniversary and termination of coverage notice letters, to include respective GFIP

Buckslip inserts, to recipients, within the timeframes referenced in applicable NFIP rules and regulations. The letters shall include the master policy expiration date and the Terms and Conditions of the GFIP Certificate of Flood Insurance. The contractor must be able to generate these letters in English and Spanish.

• Assist FEMA in targeting GFIP certificate recipients for retention through the sale of a SFIP.

• Cancel the policy for any recipient that elects to purchase an SFIP during the term of the GFIP.

4.2.1.1.2 Severe Repetitive Loss Target Group (SRL TG)

The additional requirements below are applicable to SRL TG.

Special Direct Facility (SDF)

The Contractor shall:

• Operate the SDF and seamlessness transition policy administration of SRL policies with minimal policyholder disruption.

• Generate and furnish notification letters to policyholders, agents, and lenders once a policy has been identified as an SRL property.

• Provide information to the insured and their agent on how to appeal an SRL designation and in the event of an appeal, follow established NFIP appeal procedures.

• Generate and furnish pre-renewal letters to the SRL policyholders informing them of the special renewal process.

• Re-underwrite all SRL policies, transferred by the WYOs or NFIP Direct to the SDF, at their first renewal in the SDF with respect to rating factors to determine a correct premium quote, community/zone information and loss history. Maintain the SRL file with any changes. Provide audit trail that the policy has been re-underwritten.

• Provide status reporting that details re-underwritten SRL policies and review the SRL book of business per FEMA requirements.

• Coordinate and collaborate with FEMA and other stakeholders to vigorously target SRL properties for FEMA-approved mitigation projects that will remove them from the SRL program and makes them eligible for standard policies.

• Proactively campaign to communities to encourage FRED (Flood Proof, Relocate, Elevate, or Demolish) Mitigation of SRL properties.

• Track and report to FEMA the status of SRL policies, including but not limited to: removals from the SRL program, ongoing efforts to target SRL properties for mitigation, and campaign efforts to the community to encourage mitigation.

• Develop and provide guidance to current and potential policy holders to highlight potential mitigation actions to improve structure resilience and potential decreased flood insurance premiums.

o This action may require close coordination with other stakeholders at the direction of the Program Manager and the COR.

4.2.1.2 NFIP Contact Center

• Develop and operate a contact center to interact with NFIP stakeholders and address inquiries through various channels (phone calls, chat/instant messaging, emails, etc.) with scalable staffing levels between normal and surge periods based on demand.

• Maintain core operating hours Monday through Friday, 8:00 a.m. to 8:00 p.m. Eastern Standard/Daylight Saving Time. Operating hours may be extended up to 24 hours per day during surge level demand associated with disaster events, as needed per the direction of the Government.

o All federal holiday observances should follow the Government schedule. The Government does not expect for operations to take place during observed federal holidays. However, during disaster surge, the Contractor may be required to operate on observed federal holidays per direction of the Contracting Officer Representative (COR).

• The proposed contact center solution shall include ways for stakeholders to submit inquiries both during (phone calls, chat/instant messaging, emails, etc.) and outside (voicemail, emails, etc.) of operating hours.

• Assume operation of the FEMA-owned NFIP Direct Customer Support national toll-free telephone line (1-800-638-6620) and claims number (1-800-767-4341) as part of the contact center solution.

• Ensure adequate staffing to address English and Spanish speaking inquiries in each of the contact center departments. A third-party translation service is not allowed.

• At a minimum, staff shall be able to:

o Change or correct the insured’s name o Add an additional insured’s name o Remove an insured’s name with supporting documentation o Change or correct the insured’s mailing address o Add or remove a lender from the policy o Make minor corrections to submitted new business applications if money has not been applied o Approve primary residence for the Present Term o Approve endorsements to change residency status to non-primary o Approve Renewal Instruction applications to apply primary residence or non-primary residence o Acknowledge receipt of documentation o Staff and operate Section 508 Compliant Contact Center Phones and IT Systems.

o Supply knowledgeable staff capable of addressing, at a minimum, Agency Services, Underwriting, and Claims interactions and inquiries.

• The proposed contact center solution shall include real-time visibility into relevant information, including, but not limited to call wait times, contact center personnel status, and number of pending inquiries by outreach channels.

• IT components of the proposed contact center solution shall be remotely- accessible and subject to all IT related requirements, objectives, and constraints described herein.

• Maintain, and provide to FEMA, a contingency plan for when the Contact Center solution is unable to connect with stakeholders (i.e. unexpected office closure, full utilization of contact center staff, etc.)

• Provide FEMA full access to recorded calls and transcripts of written interactions (i.e. emails and live chats) between the contractor & NFIP stakeholders for quality assurance purposes.

• Respond to voicemails and written inquiries, not covered under correspondence guidelines, within the timeframes referenced in applicable NFIP rules and regulations and those set forth in the QASP.

• Provide FEMA, and once approved, implement, a plan for receipt and handling of return mail.

• Provide FEMA access to conduct surveillance of live customer calls, remotely and in- person, and visit Contact Center location(s) after advanced COR notification to the contractor for quality assurance purposes.

• Identify and provide timely feedback to FEMA on common themes (both positive and negative) that arise through stakeholder interaction.

4.2.2 Write Your Own Company Assumptions

• Assume WYO policies, at the direction of the Government, should the need arise.

• Collaborate with FEMA to develop a project plan, with a comprehensive timeline, for the assumption of WYO company policies and execute the plan as necessary. The final Project Plan must be approved by FEMA.

• Provide strategies for efficiently and expeditiously assuming WYO policies under different policy assumption levels.

4.2.3 NFIP Direct – Flood Disaster Services

The Contractor is required to provide capable disaster or surge staff to support the following flood disaster activities. In this context, the terms “flood disaster” and “disaster” mean an area with widespread flood losses that require scaled up or “surge” support. The Contractor should note that disaster operations may be required with or without a Major Disaster Declaration under the Stafford Act.

4.2.3.1 Standard Flood Disaster Services

The Contractor shall:

Management

• Develop and maintain a Catastrophe (CAT) Plan that sets forth how the contractor shall successfully respond to events (including planning, response/recovery operations, and event closeout), including, but not limited to, those objectives set forth in this subsection. The plan shall reflect how the contractor responds to varying size events, from one small event to multiple location simultaneous events.

o Effectively evaluate flood situations and execute the CAT Plan as necessary.

• Provide FEMA a timely pre-event assessment of potential NFIP Direct claims exposure and update, as necessary, to reflect actual exposure as the event progresses.

• Coordinate with the FEMA Flood Response Offices, (FRO) as directed by the COR.

• Coordinate with State & Local stakeholders, other NFIP contractors, FEMA’s IHP, U.S. Small

Business Administration (SBA), and other Federal Loan or Assistance Programs when instructed by the Government.

Claims

• Provide scalable and cost-effective solutions for the processing and adjudication of claims at normal and surge levels in accordance with NFIP rules and regulations.

• Maintain a claims diary to ensure timeliness of claims handling consistent with the NFIP Claims

Manual and NFIP requirements.

• Maintain claim examiner payment authorization threshold document with up-to-date authorizations with a minimum retention period of three years.

• Ensure adequate adjuster presence within 48 hours in any given flood area, paying attention to multi-location and multi-event conditions.

• Establish ad hoc, urgent strategies for distributing NFIP information materials to adjusters and policyholders to expedite claims processing and assist policyholders in filing claims.

• Operate and maintain appropriate secure field-based technology to support effective adjuster assignments and prompt claims payments.

• Swiftly and efficiently assign claims to adjusters by taking into consideration impacting factors including, but not limited to, geographical location of damaged property and adjuster workload and experience.

• Adequately stock and furnish to adjusters, and other stakeholders, those forms and other printed supplies used in connection with claims processing. These shall be made available electronically and in paper format.

• Report daily claims polling information per FEMA requirements, as needed.

• Assign an adequate case-loss reserves as payments are made and as information becomes available; and report the reserve, and any updates to the reserve, to the SOR.

• Expedite claims advance payments, whenever possible, to assist the policyholder in recovery efforts.

• Verify the repair of prior claims’ damage before determining eligible damages on current claim

• Promote and assist the efficient adjustment and settlement of multiple peril losses.

• Accurately and efficiently process claims, including, but not limited to, processing the

Preliminary Reports, Proofs of Loss, Interim Reports, and Final Reports.

• Swiftly and accurately issue claims payments based on eligible losses, including, but not limited to, advanced payments, partial payments, final payments, and Allocated Loss Adjustment Expenses (ALAEs) including Special Allocated Loss Adjustment Expenses (SALAEs).

• Cooperate with any claim reinspection by FEMA.

• Reopen claims when necessary.

• Provide FEMA unrestricted online access to all open and closed claims files including, but not limited to, all photographs, correspondences related to the claim, and all notes from contractor personnel and outside parties involved in the claim. Additionally, provide reports on claim status and payments made.

• Deliver a reliable, timely, and cost-effective strategy for providing the quality control functions of claims processing under normal and surge conditions. Functions should measure both accuracy and efficiency of the claims process.

• Establish an approach for re-inspecting and re-examining claims, and after FEMA approval, implement the approach.

• Reset all case-loss reserves to $0 upon the closure of a claim.

• Ensure any funds received by the contractor as a result of salvage or subrogation rights or collection are separately accounted for and deposited in the depository account within 24 hours of receipt.

• Aid Policyholders and Agents in filing the First Notice of Loss, and open claims records within the proposed IT solution.

• Negotiate and maintain throughout the contract, pre-positioned vendor agreements with Independent Adjusting (IA) Firms, outside examiner firms, and other temporary employment agencies, as appropriate, to allow for quick response when implementing the CAT Plan.

4.2.3.2 Post-Flood Event Analyses

• Conduct post-event analyses on current CAT Plan and update the plan to reflect improvements based on lessons learned or to address areas that require improvement discovered during the event.

• Maintain records of adjuster assignments in a manner that information can be retrieved by tax identification number, flood control number, adjuster name, and adjusting firm.

• Provide access to all necessary information for FEMA and/or DHS to conduct operation reviews, audits, and other surveillance of NFIP Direct Claims records.

• Respond to findings and recommendations of any reviews, and surveillance in a timely manner.

4.2.4 NFIP Direct Program Support

4.2.4.1 Customer Service

The Contractor shall:

• Positively and professionally represent FEMA to the public throughout all aspects of services provided on FEMA’s behalf.

• Deliver robust and dynamic customer service processes, tools, and reporting that leverage industry best practices, support the needs of the NFIP, and align with FIMA’s guiding principles.

• Support FEMA’s attendance at conferences such as National Flood Conference, the Association of State Floodplain Managers and other appropriate national, regional, and state insurance and related industry conferences, conventions, and meetings upon consultation with the government.

4.2.4.2 Correspondence

Controlled correspondence is considered VIP (Congressional), White House, and DHS correspondence.

Controlled correspondence is processed by FEMA’s Intranet Quorum (IQ) system. Only select FEMA personnel have access to the IQ system, and currently all controlled correspondence status reporting is conducted through the FEMA IQ system. FID’s Correspondence Tracker application supports controlled correspondence processes provide templates and tracks status that is reconciled with FEMA’s IQ system on a regular basis.

Uncontrolled correspondence (UCC) is defined as General correspondence. General correspondence is received by postal mail, and hard copies are scanned into a web-based document library, such as SharePoint. Email correspondence is also classified as uncontrolled correspondence. Uncontrolled correspondence is not handled by the IQ system; however, FID’s SharePoint Correspondence Tracker supports UCC workflows and reporting to assess workloads and performance by federal and contracted support personnel.

The Contractor shall:

• Establish and maintain detailed written procedures for handling correspondence. Procedures shall be subject to FEMA approval and shall, at a minimum, demonstrate an ability to effectively control incoming and outgoing correspondence; perform a high level of quality assurance; and handle all correspondence tasks in a timely manner.

• Respond to all correspondence (controlled and uncontrolled) in accordance with the timelines and reporting requirements set forth in applicable NFIP rules and regulations, as well as those set forth in the QASP and the Contractor’s written procedures.

• Support correspondence activities in accordance with the timelines and reporting requirements set forth in applicable NFIP rules and regulations, as well as those set forth in the QASP.

• Develop, operate, and maintain a remotely accessible IT solution(s) for tracking and maintaining records of all correspondence.

• IT components of the proposed correspondence solution shall include, at a minimum, automated controls and routing for approvals based on type of correspondence; the ability to search correspondence by various data points (i.e. topic, received date, sender, etc.); the ability to calculate correspondence related selected service performance area (SSPA) metrics; and a copy of the correspondence.

• Provide FEMA full access to the proposed IT solution for visibility into current and past correspondence.

• IT components of the proposed correspondence solution shall be subject to all IT related requirements, objectives, and constraints described herein.

4.2.4.3 Statutory/Regulatory Compliance

• Identify innovative ways to develop and implement strategies and technologies that significantly improve the Flood Insurance Reform Act of 2004 (FIRA) Compliance percentages, with the goal of having all NFIP Direct agents with active policies be fully compliant.

• Manage communication and produce reporting of agency compliance with flood insurance training requirements.

• Recommend ways to improve NFIP Direct and agency participation in training “refreshers”, advanced training or other training as deemed appropriate by the DSA.

• Provide other services as set forth in applicable rules and regulations of the NFIP, including, but not limited to, 44 CFR, the FIM, the SFIP, and FEMA Bulletins.

4.2.4.4 Program Enhancements

• Continuously review and improve existing processes and tools as the environmental, technological, and political considerations impacting the NFIP evolve.

• As a NFIP Subject Matter Expert (SME), provide FEMA with timely feedback, from all levels of the NFIP Direct staff, aimed to improve the NFIP and its products and services. This includes, but is not limited to:

o Identify and report common themes of inquiries or complaints from all stakeholders.

o Suggest ways to simplify and improve ease of use of NFIP products and services.

o Suggest process or tool improvements that positively affect the stakeholder perception of/trust in the NFIP and/or that are in the spirit of FIMA’s guiding principles.

o Develop and execute marketing initiatives and communications products to support the increase of NFIP Direct policies.

o Provide timely feedback on clarity of FEMA communications, making suggestions for improvement where applicable.

o Provide timely feedback on how FEMA may improve to better work with the NFIP

Direct, WYO Companies, and other stakeholders.

o Develop and institute mechanism(s) for collecting both unsolicited and solicited stakeholder feedback while adhering to all applicable rules and regulations on data collection.

o Provide FEMA access to data collected or calls recorded for purposes of better understanding the current customer experience.

o Recommend ways to improve NFIP Direct agent and agency participation in training “refreshers”, advanced training or other training as deemed appropriate by the NFIP Direct.

• If requested, design a mobile application that enables a current or potential policyholder to obtain a quote, locate an agent, submit a claim, check the status of their policy or claim, and submit payments.

o Support FEMA review and approval, including cybersecurity and privacy approvals, the application will be deployed on a pilot basis.

o Incorporate lessons learned and make necessary improvements discovered during the pilot launch and implement a broadly available application.

• Agent Referral Database –Enable potential policyholders to locate agents to obtain quotes and/or new policies through the NFIP Direct.

• NFIP Direct Agent Snapshot – Enable the Government to readily access and download agent activity.

• Insurance Cards – Produce and distribute water-proof wallet size insurance cards to policyholders. The card should contain the policy declaration information including: policy number, effective dates, name, address, coverages, deductibles, agent information and claim reporting information.

• NFIP Direct Portal – host a robust secured and user-friendly portal for the Government to be able to readily query NFIP Direct data and reports.

4.2.4.5 NFIP Data Reporting

• Ensure FEMA data are not intermingled with other data unless approved by FEMA.

• Ensure the protection of FEMA intellectual property (IP) and data ownership rights and those of any licensors.

• Provide FEMA subject matter experts access to all raw data collected or stored in the proposed

IT solution(s).

• Deliver and provide FEMA access to all recurring reports required in a timely manner, including, but not limited to those listed in the Deliverables section of the SOO.

• Provide data visualization to FEMA personnel in a timely manner for information related to topics of regular inquiry.

• Fulfill time-sensitive ad-hoc data and reporting requests.

• Deliver meaningful Customer Experience reporting metrics such that quality, effectiveness, and efficiency of the customer experience can be assessed. Customer Experience includes service, product features and brand image.

• Manage communication and produce reporting of agency compliance with flood insurance training requirements.

• Perform quality control on all data, reports, and visualizations prior to submission to FEMA.

• Ensure all reports are professionally formatted for distribution and printing with the source of data cited and assumptions/parameters/criteria footnoted on the report.

• Provide regular and ad-hoc submissions of data as required by FEMA, including but not limited to, Pivot daily and monthly submission and informal claims polling.

• Comply with the information and reporting requirements, including the statistical and other requirements, of the PUP, as modified to accept GFIP data.

• Perform proactive data quality checks to maximize accuracy of information within the IT solution(s) and limit errors within Pivot submissions.

• Leverage subjective and objective data from the provider’s reports, and other FEMA sources, to deliver continuous improvement in customer experience.

• Providing FEMA, a list and templates of the types of information in which the IT solution(s) currently produce on a reoccurring basis.

4.2.4.6 NFIP Direct Financial Management

• Operate and maintain a secure and comprehensive financial control system for NFIP business that conforms to requirements, including, but not limited to, those set forth in the Statutes, Regulations, Policies, Guidelines, and Specifications section of this SOO, as well as requirements identified by the FEMA Office of the Chief Financial Officer (OCFO) and Generally Accepted Accounting Principles (GAAP).

• Establish internal controls and submit document of internal controls to FEMA for approval within 90 calendar days of contract award.

• Maintain up-to-date expertise in the requirements of and in compliance with all audits, operation reviews, and contract surveillance activities.

• Provide detailed deposit accounting per GAAP.

• Accurately calculate and deliver adjuster and agent commissions in a timely manner.

• Process new and renewal premium payments, as well as premium adjustments within the timeframes referenced in applicable rules and regulations, as well as those set forth in the

QASP.

• Establish and maintain at least one bank account in a minority owned bank within 90 calendar days of the award.

• Utilize Treasury General Account (TGA) Approved depository and disbursement Bank(s) for all financial transactions.

• Safeguard, log, and deposit all received funds into a TGA Approved Bank within the timeframes referenced in applicable rules and regulations, as well as those set forth in the QASP.

• Establish and maintain a separate bank account for GFIP funds.

• Separately account for and deposit all funds received as a result of money endorsements, salvage or subrogation rights, or collection in a timely manner.

• Utilize TGA Approved Lockbox Service. Exceptions to this will be considered and must be approved by FEMA, however if contractor chooses to use a non-TGA approved lockbox service, the costs of lockbox services cannot be transferred to FEMA or included in the proposal/overhead.

• Comply with The Payment Card Industry Data Security Standard (PCI DSS) regulations as mandated by the FEMA Office of the Chief Information Officer (OCIO).

• Prepare financial reporting per FEMA requirements, including, but not limited to, monthly Financial Statements and all supporting reports associated with the Financial Statements, Schedule 9 Accounts Receivable Statements, FEMA fiscal year-end statements, and supporting schedules.

• Aggressively collect and repay debts due the United States Government per applicable rules and regulations, including, but not limited to, the Debt Collection Act of 1982.

• Reimburse the Government directly and in a timely manner for all claims over payments, all premium refunds returned to policy holder by mistake, all erroneous adjuster payments or agent commissions, and all other scenarios where Government/program funds have been disbursed by the contractor and are required to be reimbursed to the Government.

• Reimburse the Government within 30 days of notification of over payment by the COR.

• Issue 1099 Earning Statements to adjusters and agents as a result of their work with the NFIP

Direct.

4.2.4.7 Policy Appeals

The Contractor shall:

• Support the collection and submission of data to substantiate policy appeals, including but not limited to designations of 1316, Coastal Barrier Resource System, Repetitive Loss, SRL, property address waivers, floodproofing, and prior term refunds.

• At the direction of the Government, coordinate with other FEMA contractors to ensure that the policy appeals are fully adjudicated in a timely manner.

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

4.2.4.8 Claims Appeals

The Contractor shall:

• Support the Appeals Branch for claims appeals.

• Make readily available all records created or maintained for the claim file.

• Develop a claim file synopsis that:

o Summarizes the appeal issues; and o States the Contractor’s position on each issue.

• Notify the Appeals Branch if it is determined that the claim may be settled without further review of the appeal.

• Resolve and document the appeal based on guidance and a final determination by FEMA.

4.2.4.9 Litigation Support

The Contractor shall:

• Support FEMA’s Office of Chief Counsel (OCC) and FEMA’s Office of the Inspector General (OIG) activities related to NFIP Direct, at the direction of the Contracting Officer (CO) and/or the COR.

Such support includes:

o Claim review and litigation discovery assistance o Investigation assistance o Appearance as witnesses and or support at hearings, depositions, and other proceedings including trial.

o Furnish all files, records, data, and other information for legal proceedings or investigations. Furnish the requested files within three business days and any systems data within seven business days, of request – presuming compatible and programming formats.

4.2.4.10 NFIP Direct Marketing

• Promote the sale of flood insurance.

• Provide at least five dedicated Regional Sales Managers (RSMs) located in FEMA Regions and with the capacity to support all 10 FEMA Regions to act as the designated personnel, or liaison, responsible for activities regarding community derived initiatives, projects, etc.

• RSMs must promote the sale of flood insurance by the NFIP Direct by coordinating with local NFIP Direct insurance agents to increase their capabilities and capacity to market, sell and service policies.

• At the direction of the Government, closely coordinate with FID’s Marketing and Training contractors to ensure that NFIP Direct Agents are capable, delivering acceptable customer service, and can deliver appropriate marketing information (produced by NFIP Direct and other FEMA sources) to current and potential policyholders.

• Coordinate with local agents to establish NFIP Direct sales goals. Collect and analyze regional sales trend data, report information to the NFIP Direct Project Director, and recognize top sellers.

• Design,…