BENEFEDS _DRAFT _PWS for SSN.pdf

BENEFEDS

Federal Benefits Enrollment and Premium Administration Services

Performance Work Statement (PWS)

A. Background / History As the Federal government’s human resources agency, the United States Office of Personnel Management (OPM) administers insurance and retirement benefits for millions of Federal employees, retirees, temporary wildland firefighters and fire protection personnel, employees of Federally recognized Indian tribes, tribal organizations, and urban Indian organizations (tribal employer), and their eligible family members.

OPM is responsible for establishing benefits and human resources policies government-wide and providing guidance to agencies, as well as for procuring and managing the contractual relationships with carriers for the various benefit programs. Offerors can find more information about OPM and the benefits we administer on https://www.opm.gov/healthcare-insurance/.

As part of its mission to manage insurance benefits, OPM developed a contract for certain federal benefits enrollment and premium administration services, named BENEFEDS. The BENEFEDS contract was implemented in late 2006 primarily to perform enrollment and premium administration functions for the Federal Employees Dental and Vision Insurance Program (FEDVIP)1. This centralized platform was designed to eliminate the need for each FEDVIP carrier to establish its own enrollment/premium administration interface with a multitude of Federal agencies and payroll offices. Since 2006, BENEFEDS functionality has evolved, and today the BENEFEDS Contractor is responsible for managing over 6 million FEDVIP enrollments, administering over 500,000 Federal Flexible Spending Account Program (FSAFEDS) allotments and almost 260,000 Federal Long Term Care Insurance Program (FLTCIP)2 participant premiums and interfacing with 13 FEDVIP carriers, the FLTCIP and FSAFEDS Contractors and more than 50 Federal payroll providers. In addition, the BENEFEDS service also provides participants the option of paying for these benefits through direct bill or automatic bank withdrawals (ABW).

B. Federal Program Laws and Regulations All Federal benefit programs are administered in accordance with Federal law and implementing regulations (noted in the appendices). The BENEFEDS Contractor must be intimately familiar with the laws and regulations of the Federal benefits programs they support, to ensure contractual operations under the BENEFEDS contract are in full compliance. The BENEFEDS system must be capable of recognizing sometimes very subtle nuances which can mean the difference between an individual or group of individuals being eligible for a particular benefit or not. Changes in the laws and regulations may change individuals’ eligibility for the program and the BENEFEDS Contractor must make changes to their system for compliance.

1 Statutes for FEDVIP: 5 U.S.C. Chapter 89A – Enhanced Dental Benefits (§§ 8951 – 8962); 5 U.S.C. Chapter 89B

– Enhanced Vision Benefits (§§ 8981 – 8992). Regulation for FEDVIP: 5 CFR Part 894 – Federal Employees Dental and Vision Insurance Program (§§ 894.101 - 894.901).

2 Statute for FLTCIP: 5 U.S.C. Chapter 90 – Long Term Care Insurance (§§ 9001 – 9009). Regulation for FLTCIP:

5 CFR Part 875 – Federal Long Term Care Insurance Program (§§ 875.101 - 875.414).

BENEFEDS PWS for SSN#57092 https://www.opm.gov/healthcare-insurance/

C. Federal Benefits Environment BENEFEDS functionality operates within a highly decentralized Federal benefits environment, where employees from more than 150 distinct Federal employing agencies are bound by common benefit programs. OPM does not maintain eligibility files, perform enrollments, or keep enrollment records, except those related to the Federal Employees Health Benefits (FEHB) Program, Postal Service Health Benefits (PSHB) Program, and Federal Employee’s Group Life Insurance Program (FEGLI) enrollments of its own agency employees.

For the most part, individual employing agencies are responsible for distributing benefit information to and educating their employees. Each agency has a designated Agency Benefits Officer (ABO), whose role is to advise their agency’s departments, sub agencies and bureaus and employees about various aspects of program administration. Agencies are also responsible for processing FEHB/PSHB and FEGLI enrollments, which are the insurance programs with a government contribution towards premiums. Please note, certain employing agencies, such as the Federal Deposit Insurance Corporation (FDIC) and the United States Postal Service (USPS) have independent compensation authority, which may include offering different benefits or the same benefits under different terms and conditions.

The Government does not have, nor does it require a government-wide centralized call center to assist employees during the annual Federal Benefits Open Season. Employees may attend an open season health fair if offered by their agency or can go to their employing office to get information, contact a carrier directly, or view information on OPM’s government-run website.

Most Federal annuitants can contact OPM’s Retirement Services for information. Each voluntary benefit program currently maintains its own website and call center (BENEFEDS.gov on behalf of FEDVIP carriers, FSAFEDS.gov for FSAFEDS and LTCFEDS.gov for FLTCIP).

Because of this fragmentation of roles and responsibilities, it is difficult to educate eligible employees about the various benefits available to them. Ensuring consistent, uniform benefit administration is a significant challenge for OPM.

D. Objective The principal objectives of this contract are to provide:

• A cost effective, centralized insurance and cafeteria plan (Section 125) benefit enrollment system and customer service support center for FEDVIP, FSAFEDS and

FLTCIP

• Related premium/allotment administration services

• A mechanism to completely and accurately reconcile enrollment and premium at the individual enrollee level with each FEDVIP carrier

• A mechanism to completely and accurately reconcile premium/allotments at the individual enrollee level with the FLTCIP and FSAFEDS contractors

• Superior customer service for the convenience of users

• User friendly and informative website conformed to the Section 508 standards of the

Rehabilitation Act of 19733

• Education and outreach to eligible populations

3 29 U.S.C § 794d (“Section 508”)

BENEFEDS PWS for SSN#57092

OPM requires a BENEFEDS Contractor to provide an enrollment website and customer service call center, perform payroll allotment for FSAFEDS, premium administration for FLTCIP, and enrollment and premium administration for FEDVIP. While OPM provides contractual and programmatic oversight, the BENEFEDS Contractor is solely responsible for hiring, training, and managing its own employees, subcontractors, etc. Staffing requirements for this contract will be discussed in greater detail later in this document. Performance shall focus on solutions with primarily human-based services rather than relying primarily on chatbot/AI based solutions.

Chatbot/AI tools may be offered as available options for participants to choose if they prefer, but participants should not be forced to use them, and contacting a human should be equally available as an option and just as easy to access.

Retired annuitants who are eligible to participate in certain federal benefits would receive annuity payments from the Government, from which their premiums are deducted. Although not technically “payroll,” for the purpose of simplicity, we will refer to all deductions from either employee or annuitant payments as “payroll deductions.”

The BENEFEDS Contractor will be required to interface with over 50 agencies, 13 FEDVIP carriers, the FSAFEDS Contractor, and the FLTCIP Contractor. The BENEFEDS Contractor must provide a solution that is user-friendly, agile, and secure. The Contractor shall provide a solution which enables robust employee and annuitant self-service applications. The Contractor’s solution shall enable near real-time, within 1 hour, updates to accommodate business decisions requiring immediate action. Finally, the Contractor’s solution shall include a robust system architecture with the potential to host many thousands of concurrent users, and to provide surge capabilities with little or no interruption to BENEFEDS system users.

E. Services Required The BENEFEDS Contractor shall provide the Government with the full scope of functionality currently included in the BENEFEDS program, including, but not limited to:

• FEDVIP Vision and Dental enrollment and premium administration

• FEDVIP decision support tools

• FSAFEDS allotment administration

• FLTCIP premium administration

• Customer service/Call center services

• MyBENEFEDS website – online account information and history

• Education and outreach to eligible populations

• Reporting

Currently, the BENEFEDS decision support tools offer

• FEDVIP plans’ dental and vision premium and benefits comparisons

• Link to OPM’s Plan Comparison Tool

• FEDVIP plans’ dental ADA code out-of-pocket average estimated amount Comparison Tool

See Appendix O for BENEFEDS Contractor roles and responsibilities.

1. Payroll Functions The BENEFEDS system provided by the Contractor will need to interface with the four major government e-payroll providers4, the U.S. Postal Service, and OPM Annuity.

More e-payroll providers could be added in the future, and there shall be no adjustment of the BENEFEDS Contractor’s fees to accommodate. Approximately 95 percent of Federal employees and annuitants receive their pay/annuity from one of these six entities.5 Even amongst these major payroll providers, there are many differences in system capabilities and operations. Payroll providers have different pay period start/end dates and payment frequencies and have interfaces that may vary by benefit program.

Payroll providers also vary in the information available and provided on payment files.

For example, a payroll provider may indicate that a deduction was not taken, but not indicate that this particular enrollee transferred to another agency. Or, a payroll provider may indicate that an enrollee has transferred, but not to which agency. As part of the payroll modernization effort, systems, standards and number of providers might change over the contract period. The BENEFEDS Contractor is expected to incorporate these changes for continued seamless integration.

The BENEFEDS system shall integrate with all current and future participating Federal payroll providers and their various file formats. There are some small payroll systems that may request not to integrate with BENEFEDS because of low employee participation in voluntary benefits programs (see Appendix J). The BENEFEDS Contractor shall work directly with these small payroll systems in lieu of system integration. In all cases, the BENEFEDS Contractor shall:

• Request the correct FLTCIP, FEDVIP and FSAFEDS premium/allotment amount based on each enrollee/participant’s enrollment and level of coverage and each payroll provider’s pay schedule;

• Help to identify, research and resolve missed deductions and errors, regardless of the reason or source, through various means including callouts to agencies and enrollees in a timely manner;

• Process and facilitate pre-tax refunds through the payroll provider so that all necessary payroll taxes are paid, and income is correct on the W-2 issued at the end of the tax year.

• Process post-tax refunds as needed.

2. Validate Eligibility One of the most significant challenges that the BENEFEDS functionality faces is the lack of an eligibility file. Without a government-wide eligibility file, the BENEFEDS Contractor or system is unable to validate eligibility or check demographic and other information provided by the enrollee at the time of enrollment. Instead, employees and annuitants self-certify their eligibility during the enrollment process. To help compensate for the lack of an eligibility file, the BENEFEDS Contractor uses a pre-validation process. The advantage to this process is that the payroll provider is able to confirm the employing agency selected by the enrollee during enrollment. Pre-validation also allows

4 The four e-payroll providers are The Defense Finance and Accounting Service (DFAS), the Department of the Interior’s National Business Center (NBC), the General Services Administration’s National Payroll Branch (NPB) and the Department of Agriculture’s National Finance Center (NFC).

5 The remaining five percent receive payroll services from more than 50 payroll providers. See Appendix I for a complete list.

for faster premium/allotment initiation for those enrollees who either accidentally selected the wrong payroll location and/or accidentally submitted incorrect information.

Certain categories of employees and annuitants are not eligible for one or more of the various voluntary benefits (e.g., temporary employees; former spouses receiving annuities), and the rules can be slightly different for each program. In addition, enrollment outside of an open season is limited to specific timeframes for new hires/newly eligible individuals and persons with qualifying life events.

In accordance with Federal law and regulations that govern the benefit programs for which the Contractor performs administrative services, the enrollment process is structured to limit ineligible persons from enrolling. See the appendices for the Federal law and regulations for each benefit program.

Even with screening tools, some number of ineligible employees and annuitants may erroneously enroll in FEDVIP. Quality web design and flow are critical to help persons determine if they are eligible, and then gather necessary demographic and other information necessary to effect enrollments without errors or delays. While key pieces of demographic information are highly important, helping enrollees select the correct employing agency or annuity system is crucial to mapping to the correct payroll provider and ensuring successful deductions can be made.

A FEDVIP enrollment is effective only when the BENEFEDS Contractor has successfully taken a deduction from pay or annuity. Throughout the year as some enrollees experience a change that results in their premium deduction needing to come from a different source (for example, they retire, transfer to a different agency, or become eligible for workers compensation), their enrollment must often be re-validated.

2.1. FEDVIP Eligibility

The BENEFEDS Contractor collects the following data from persons during the FEDVIP enrollment process:

• Enrollee name

• Active employee/retired

• Date of Birth (DOB)

• Sex

• Home address

• Mailing address, if different

• Phone number(s) and email address(es)

• Agency/Retirement System

• Social Security Number (SSN)

• Eligible dependent name(s), sex, relationship, DOB, address

• Eligible for FEHB/PSHB

• Enrolled in FEHB/PSHB

• Eligibility status (civilian/military)

• Other insurance information, including Medicare and TRICARE

• Dental and/or vision enrollment, including the name(s) of the FEDVIP plan(s) and the type of enrollment(s)

• Military retirement date (if applicable)

The lack of eligibility files creates an environment where errors occur. The BENEFEDS Contractor staff shall research and resolve these errors. Two key examples of these errors are persons who mis-key their SSN and/or choose the wrong employing agency/bureau during enrollment.

The collection of enrollee SSNs is required during the enrollment process for the purpose of requesting deductions from payroll providers. If the SSN does not match the enrollee’s name in the payroll provider’s system, an error is created.

Persons enrolling must also indicate their employing agency/retirement system so that the BENEFEDS Contractor can request deductions from the correct payroll provider.

Because there are over 150 Federal agencies with numerous sub-departments, bureaus, and offices, often referred to only by their acronyms, it can be a challenge for users to understand the hierarchical structure well enough to select the correct employing agency/retirement system at the point of enrollment. The BENEFEDS website provides a comprehensive menu of employing agencies/retirement systems (Appendix H) from which a potential enrollee may choose, to facilitate the selection process. This menu is updated regularly as Federal agencies are created or consolidated. Even with this menu, enrollees do make mistakes in choosing the correct agency (or they transfer agencies shortly after enrollment).

See Appendix H for employing agencies/annuity systems. See Appendix I for a list of payroll providers to better understand the challenges this task presents.

The BENEFEDS Contractor attempts to resolve data errors by pre-validating; using database look-up tools (Enterprise Human Resources Integration System (EHRI) and OPM Annuity, see PWS Sections E.3. and E.4.); communicating with payroll provider contacts via phone and email; contacting the affected enrollees by phone, email, and/or letters; and using various research tools to locate these employees.

The pre-validation process continues for a predetermined group of payroll providers throughout the plan year as part of the normal billing cycle.

A successful pre-validation does not guarantee eligibility; it merely confirms the enrollee is an employee/annuitant is receiving pay/annuity from a payroll provider.

Some payroll providers are unable to pre-validate. In those cases, demographic verification occurs through the regular bill file process with either a payment or a status code to indicate eligibility. The BENEFEDS system must have a self-certification feature that allows potential enrollees to attest to their eligibility and are informed of federal penalties against fraud.

For any payroll provider that is not able to pre-validate, the BENEFEDS Contractor shall utilize the billing error process as a validity check. As part of the billing process, some payroll providers may send billing error files to the BENEFEDS Contractor which include information on each enrollee whose record could not be loaded to his or her payroll system.

As FEDVIP coverage is secondary to any dental or vision coverage provided by the enrollee’s FEHB/PSHB plans, the FEHB/PSHB plan enrollments are vital information for FEDVIP Carriers to receive. Currently, payroll providers pass FEHB/PSHB enrollment code data on to the BENEFEDS Contractor, which then transmits the data to one or more carriers.

A person enrolling in FEDVIP may be covered as a family member under another person’s FEHB/PSHB enrollment (for example, when spouses are both Federal employees). In that instance, the payroll provider’s records will indicate no FEHB/PSHB enrollment for that FEDVIP enrollee. The BENEFEDS Contractor shall contact FEDVIP enrollees with no FEHB/PSHB enrollment data to determine whether this person is covered as a family member under another FEHB/PSHB enrollment and then obtain FEHB/PSHB plan information. The same self-reporting limitations exist in this situation.

Enrollees self-certify their eligible family members, which include a spouse, unmarried child(ren) under age 22, stepchildren and/or foster children who meet certain criteria, and children age 22 or older who are incapable of self-support because of a physical or mental condition which existed before age 22. During enrollment, potential enrollees must certify that: 1) they are eligible to enroll in a dental or vision plan under FEDVIP; 2) their family members enrolled in the program meet the eligibility requirements for FEDVIP; 3) neither they nor their dependents are enrolled in another FEDVIP plan; and 4) they understand the penalties of enrolling any family members who are not eligible to enroll in FEDVIP.

With respect to TRICARE-eligible individuals, family members include your spouse, widow or widower who has not remarried, unmarried child, a former spouse who has not remarried and meets the U.S Department of Defense's 20-20-20 or 20-20-15 eligibility requirements, and certain unmarried persons placed in your legal custody by a court.

Children include legally adopted children, stepchildren, and pre-adoptive children.

Children and dependent unmarried persons must be under age 21 if they are not a student, under age 23 if they are a full-time student, or incapable of self-support because of a mental or physical incapacity.

The FEDVIP carrier has the right to request verification of an eligible family member's eligibility (including documentation of incapability of self-support (ISS), see PWS Section E.7.3.1.) and the enrollee has 60 days from the date of that request to provide the documentation to the FEDVIP Carrier. The FEDVIP Carrier is to notify the BENEFEDS Contractor immediately whether the family member should be removed from the plan. The BENEFEDS Contractor shall not remove a family member unless specifically informed to do so by the FEDVIP Carrier or an employing office. The BENEFEDS Contractor must remove a dependent child who has aged out of the program and is not certified as ISS.

3. Education and Communication Services

The BENEFEDS Contractor is responsible for sending timely communications and education materials to enrollees and non-enrollees to inform them about their benefits.

The BENEFEDS Contractor must also share contact information for newly hired employees to other OPM benefits program contractors for education of the OPM benefits available to employees and retirees. The BENEFEDS Contractor must have a communication plan with corresponding creative pieces to communicate important information to Federal employees, retirees, and members of uniformed services before, during and after open season. The communications are in the form of emails, letters, webinars, videos and other innovative tools.

4. Enterprise Human Resources Integration System (EHRI)

Another tool that the BENEFEDS Contractor utilizes is the Enterprise Human Resources Integration System (EHRI), which is an OPM-controlled system. EHRI is an OPM initiative to maintain a data warehouse of personnel information. Currently, the BENEFEDS Contractor receives a password-protected file via OPM’s file transfer protocol (FTP) application ConnectDirect, not independent access to the EHRI system.

Such process may change in the future, at OPM’s discretion.

EHRI allows transfer of data between the losing agency and the gaining agency when an employee transfers from one agency to another agency. In addition, EHRI interfaces with OPM’s annuity system to allow retirement data to be processed more quickly and provide full annuity compensation to retired employees faster. For more information on EHRI, visit http://www.opm.gov/egov/e-gov/EHRI/.

The BENEFEDS Contractor accesses the EHRI data warehouse via a weekly batch process. Data that cannot be verified through the pre-validation process may be verified through EHRI, such as the correct employing agency. However, there are limitations.

Only agencies in the executive branch report data to EHRI. In addition, EHRI only looks back 30 days, so if the employee termination or transfer occurred more than 30 days prior, the BENEFEDS Contractor does not get that information on the return file. The BENEEFDS Contractor must request and segment the complete EHRI file between current enrollees and non-enrollees for relevant open season communications.

5. Access to the OPM Annuity Look-up Tool

The BENEFEDS Contractor will be provided with read-only access into the “OPM Annuity Look-up Tool” to allow Contractor employees, with a need to know, access rights to view limited aspects of individual CSRS/FERS annuitants’ records. This access is provided to allow the BENEFEDS Contractor to correct errors in BENEFEDS records, such as in CSA number or SSN, when a “non-match” occurs in the pre-validation process or the bill file process.

BENEFEDS PWS for SSN#57092 http://www.opm.gov/egov/e-gov/EHRI/

BENEFEDS Contractor employees with access to this OPM system will require a public trust level background investigation. See Section S of this PWS for further detail on security clearances, and background investigations, as well as forms required for requesting access.

6. Program Administration and Support Services

6.1. FEDVIP Enrollment and Premium Administration Functionality See Appendix A for detailed FEDVIP background information and statistics.

FEDVIP dental plan and vision plan enrollment actions are handled primarily through the BENEFEDS website (https://www.benefeds.gov/), or by telephone with the assistance of a BENEFEDS Customer Service Representative (CSR).

Use of a paper enrollment form is extremely limited, and in fact, the form was not used in the entire calendar year 2020. There is currently no standard government-issued paper enrollment form. The BENEFEDS Contractor must have the capability to process some paper enrollments since there may be a need for it in unique circumstances, when online/phone enrollment is not possible. The BENEFEDS Contractor may propose the content for a single, standardized paper enrollment form should the need arise on an exception basis. A standardized paper form for widespread use would require review and approval by the OPM Privacy Office prior to authorization for use.

The BENEFEDS Contractor shall process FEDVIP Open Season enrollments, changes in enrollments, and dis-enrollments. During open season, an eligible person may change their mind and make another election that will supersede any previous election(s) made during this period. Until open season ends, the BENEFEDS Contractor shall not make any enrollment action final. Throughout the year, the BENEFEDS Contractor shall also process actions such as:

• QLE enrollment actions in accordance with program regulations

• Demographic changes, such as name or address changes

• Eligibility losses, such as children turning age 22

• New hire/newly eligible enrollments

All actions are communicated to carriers on a daily file feed with different rules for the open season period. The BENEFEDS Contractor shall work with each FEDVIP Carrier if any errors or issues are encountered during this transmission. In addition, the BENEFEDS Contractor and FEDVIP Carriers shall regularly reconcile the data stored within each other’s systems. Reconciliations scheduled throughout the year include but are not limited to enrollments, premiums, refunds, account funds transfers (FSAFEDS only), and update file action codes. The BENEFEDS Contractor shall regularly conduct a retrospective audit to look for dual enrollments. The frequency of each reconciliation is subject to change depending on volume, carrier preference, time of year and results.

Individuals who expect to be in a non-pay status at some point during the plan year https://www.benefeds.gov/ may opt to pay their premiums on an accelerated basis. Typically, these individuals are seasonal employees (such as IRS agents and NPS park rangers) or anticipate some period of leave without pay (such as teachers). At enrollment, they choose the number of pay periods over which they wish to pay premiums for the plan year. In addition, some enrollees will enter non-pay status unexpectedly during the plan year.

The BENEFEDS Contractor shall make alternative arrangements to receive payments from these individuals via direct bill or automatic bank withdrawal.

When the BENEFEDS Contractor learns of a FEDVIP enrollee’s retirement, the BENEFEDS Contractor shall switch the enrollee’s payment method to annuity deduction. However, enrollees who retire under CSRS or FERS initially receive “interim” or “special pay” and continue to do so until their annuity is finalized.

FEDVIP deductions cannot be made from interim or special pay, so the BENEFEDS Contractor shall bill these enrollees directly for premiums until they are receiving regular annuity payments. Once the enrollee begins receiving regular annuity payments, the BENEFEDS Contractor shall deduct premiums from the enrollee’s annuity. (see Appendix M)

Survivor annuitant enrollments are especially challenging to administer, particularly when the survivor annuity results from the death of a Federal employee. In these cases, the Social Security Number (SSN) associated with the CSRS/FERS survivor annuity is the deceased employee’s, but the survivor enrolls in FEDVIP using their own Social Security Number. The Contractor’s system must be able to accommodate this discrepancy in the SSNs and request premium deductions from the appropriate survivor annuity.

FEDVIP premiums are determined by each carrier annually in negotiation with and approval by OPM. FEDVIP dental carriers may offer up to two plan options (Standard and High). Premiums for FEDVIP dental plans also vary according to the geographic location of the enrollee (his or her residence address). FEDVIP plans may have one or five rating regions, which may also include an international rating region.

The ZIP codes assigned to each rating region vary from carrier to carrier. In addition, some FEDVIP plans are available nationwide (and internationally), while others are regional plans that serve a limited geographic area. During enrollment, the BENEFEDS system allows enrollment in a regional plan only if the enrollee resides in a ZIP code serviced by the plan. If an enrollee moves during the plan year, the BENEFEDS Contractor determines whether the move requires a change in premium due to a change in the rating region or a change in plan because the enrollee no longer lives in a regional plan’s service area.

FEDVIP vision plans may also offer two plan options (Standard and High) but premiums are uniform regardless of the enrollee’s geographic location and, at present, all plans are available nationwide (and internationally).

The BENEFEDS Contractor is responsible for collecting, storing, and maintaining all this information.

Enrollment in more than one dental plan or more than one vision plan by an enrollee or any covered family member is generally not allowed (a “dual enrollment”). For example, the child of divorced enrollees cannot be covered under both parents’ dental enrollments. For privacy reasons, the BENEFEDS Contractor shall not collect family members’ Social Security Numbers (SSN) during the enrollment process. However, the BENEFEDS Contractor is responsible for identifying and eliminating dual enrollments post-enrollment utilizing methods other than via SSN matching.

With few exceptions, enrollees pay FEDVIP premiums through payroll deduction.

To process FEDVIP payroll deductions, the BENEFEDS system integrates with more than 50 payroll providers and the BENEFEDS Contractor is responsible for all functions related to payroll premium billing and payment processing, including:

• Generating and sending pre-validation files (see Appendix K) to those payroll providers who can accept and process them

• Generating and sending bill files to payroll providers6

• Receiving and processing bill error files

• Identifying/Resolving billing errors

• Processing and reconciling payment files against actual payments

• Adjusting deductions as necessary for overpayments or underpayments using rules that have been reviewed and approved by OPM

• Sending direct bills to enrollees when necessary

• Handling the automatic bank withdrawal (ABW) process

• Managing employment status changes

• Transmitting premiums and supporting files to carriers

In future, the BENEFEDS system may have to interface with additional payroll providers and the Contractor shall be required to accommodate such adjustments without a change in the contracted rates.

By law, OPM’s contracts with the FEDVIP carriers are for a term of seven years.

The most recent contract was awarded in 2020, with new FEDVIP dental and vision plans offered on January 1, 2021. It is possible during the next FEDVIP contract term that new carriers and/or an additional number of carriers could join the program or current carriers could leave the program. It is also possible that carriers could leave the program mid-contract term, although this has not happened to date. The BENEFEDS Contractor and system must be prepared to accommodate these types of changes without adjustment to contracted rates.

6.2. FSAFEDS Premium Administration Functionality

See Appendix D for detailed FSAFEDS background information and statistics.

6 While most payroll providers accept “changes-only” bill files, some still require the BENEFEDS Contractor to submit “full files” and return “full files” payment files each pay period. See Appendix N for a list of “full file” providers.

The BENEFEDS Contractor is authorized by OPM to handle allotment processing for FSAFEDS’ Health Care FSA (HCFSA), Limited Expense Health Care FSA (LEX HCFSA) and Dependent Care FSA (DCFSA) on behalf of the FSAFEDS Contractor.

The FSAFEDS Contractor is responsible for enrollment, changes to enrollment including qualifying life events, claims processing, and customer service.

Enrollments occur on www.FSAFEDS.gov or via the FSAFEDS Contractor’s toll-free number. The BENEFEDS Contractor is not responsible for FSAFEDS enrollments, claims processing, or customer service, nor for ensuring performance of the FSAFEDS Contractor.

The FSAFEDS Contractor transmits enrollment files each business day to the BENEFEDS Contractor. The FSAFEDS Contractor and the BENEFEDS Contractor must work together if any errors or issues are encountered during this transmission.

In addition, the BENEFEDS Contractor and the FSAFEDS Contractor shall regularly reconcile the data stored within each other’s system. Reconciliations scheduled throughout the year shall include but are not limited to enrollments, refunds, account funds transfers, and update file action codes. The frequency of each reconciliation is subject to change depending on volume, time of year, and results. These functions include calculating the per pay date allotment based on the enrollee’s annual HCFSA, LEX HCFSA, and/or DCFSA election, payroll billing, and payment processing with all payroll providers participating in the FSAFEDS program.

To process FSAFEDS allotments, the BENEFEDS system integrates with more than 50 payroll providers and is responsible for all functions related to allotment billing and payment processing, including:

• Generating and sending pre-validation files to those payroll providers who can accept and process them

• Generating and sending the bill files to payroll providers

• Receiving and processing bill error files

• Resolving billing errors

• Processing and reconciling the payment file against actual payments, and

• Using rules reviewed and approved by OPM, recalculating allotment amounts due based upon missed allotments, employment status changes and qualifying life events (QLEs) approved by the FSAFEDS contractor.

• Processing special HEART Act off-cycle refunds for reservists who want to cash out their accounts and stop allotments

Currently, payroll providers send allotment payments directly to the FSAFEDS Contractor, while BENEFEDS Contractor receives the payment files.

6.3. FLTCIP Premium Administration Functionality

See Appendices E and F for detailed FLTCIP background information and statistics.

The FLTCIP application and enrollment process is handled by the FLTCIP administrator, which administers the FLTCIP Program on behalf of the FLTCIP Contractor. Eligible persons can apply on the www.LTCFEDS.gov website or via a

BENEFEDS PWS for SSN#57092 http://www.fsafeds.gov/ http://www.ltcfeds.gov/ paper application. The FLTCIP administrator handles the application process for FLTCIP. The BENEFEDS Contractor shall handle the premium administration process for FLTCIP. The BENEFEDS Contractor is not responsible for FLTCIP enrollment or applications.

The BENEFEDS Contractor is responsible for storing FLTCIP premium tables and receiving annual premium amount information on an individual payor basis from the FLTCIP administrator. This is due to the large number of benefit options and the complexities of premium calculations. The BENEFEDS Contractor collects FLTCIP enrollee premiums by payroll or annuity deduction, automatic bank withdrawal, and direct billing (see Appendix L). Other payment methods may be required as well, and will not change the Contractor’s pricing for services. The BENEFEDS Contractor is responsible for determining the amount of premium to request per pay period in order to meet the annual premium total based on the pay schedule for the individual payor’s payroll provider. Enrollees can change their payment method at any time, and BENEFEDS Contractor is responsible for managing those changes.

Currently, FLTCIP is the only OPM-sponsored insurance program that includes active members of the uniformed services, which necessitates interface with additional payroll providers that service this population.

A FLTCIP payor may not necessarily also be an enrollee. Employees and annuitants, regardless of whether they are enrolled themselves, may pay qualified relatives’ (spouses, adult children, and parents) individual premiums.

To process FLTCIP payroll deductions, the BENEFEDS system integrates with more than 50 payroll providers and is responsible for all functions related to payroll premium billing and payment processing, including:

• Generating and sending pre-validation files (see Appendix K) to those payroll providers who can accept and process them

• Generating and sending the bill files to payroll providers

• Receiving and processing bill error files

• Resolving billing errors

• Processing and reconciling the payment file against actual payments

• Adjusting deductions as necessary for overpayments or underpayments

• Sending direct bills to enrollees

• Handling the automatic bank withdrawal (ABW) process

• Managing payment method changes, and

• Transmitting premiums and supporting files to the FLTCIP administrator

7. System Requirements

Rather than be prescriptive, OPM has provided its known BENEFEDS system requirements in the attached Requirements Traceability Matrix (RTM), which should be used as a reference in development and implementation of the Contractor’s solution.

7.1. Initial Development and Transition

On January 1, 2027, the BENEFEDS Contractor will be expected to launch and operate an enrollment website, call center, and a premium administration system that provides all of the functionality described in the RTM. The Contractor will provide a solution that facilitates a seamless transition to its services.

There is a Start Up Period included in the contract post-award of up to 6 months.

This Start Up Period is intended to allow a new BENEFEDS Contractor to perform development and testing of systems and transition of services to facilitate the January 1, 2027 full performance of services. This period also includes time for the new BENEFEDS Contractor to obtain an Authority to Operate (ATO) from OPM’s Chief Information Officer (CIO); see 1752.239-74 Security Assessment and Authorization (SA&A) (Dec 2023), complete a Privacy Impact Assessment approved by OPM’s Senior Agency Official for Privacy, and work with OPM’s Office of Privacy and Information Management and the Contracting Officer (CO) or Contracting Officer’s Representative (COR). The Privacy Office will obtain clearance from the Office of Management and Budget. The existing ATO under the expiring contract is not transferrable to a new Contractor. As indicated in PWS Section N, the Contractor will be responsible for any costs associated with completing these requirements and shall include them in their fixed price for Start Up Costs.

7.2. BENEFEDS Enrollment and Premium Administration System Qualities and

Specifications (MANDATORY / MINIMUM REQUIREMENTS) The BENEFEDS Contractor shall create and manage an enrollment and premium administration system comparable to (or better than) the existing BENEFEDS system functionality, to include:

• FEDVIP Enrollment

• FEDVIP Premium Administration

• FSAFEDS Allotment Administration

• FLTCIP Premium Administration

Post-Tax Refunds must be processed timely and approved refunds mailed within 15 business days.

Pre-Tax Refunds must be processed and submitted timely to payroll providers and monitored through disbursement to enrollee within 3 business days.

Please refer to the RTM for specific requirements regarding enrollment (including call center) and premium administration.

7.2.1. Enrollment / Website

At a minimum, all current enrollment functionality must continue to be available in the new BENEFEDS Contractor’s website.

The “BENEFEDS.gov availability”, the phrase “fully functional” refers to the ability for users to access the BENEFEDS.gov homepage and process complete and successful transactions via the following functions on the website:

a. Login

b. Registration

c. Enrollment

d. Identify all Qualifying Life Events (QLEs)

e. View / Edit Profile (personal information of enrollee & dependents)

f. Change User ID / Password

g. Email form

h. Research Plans / Rates Tool

i. FEDVIP plans’ dental ADA code out-of-pocket average estimated amount

Comparison Tool

The BENEFEDS website shall conform to the Section 508 standards and be available to users 24 hours a day, 7 days a week for open season enrollment activities, new hires/newly eligible enrollments, qualifying life event changes, and demographic changes. Particular focus should be placed on usability (the website is visually pleasing, intuitive and mobile-friendly); ease of enrollment; length of the enrollment process; and that the system leverages information already provided by the user for subsequent visits.

The BENEFEDS website shall utilize multi-factor authentication in the participant / enrollee login process, to ensure user identity7 and ID verification.

The Contractor shall provide a system with an OPM CIO-approved multi-factor solution and shall not allow access by simply a username and password. Two currently approved multi-factor systems are the use of federal Personal Identity Verification (PIV) card, the use of GSA’s LOGIN.gov, or OKTA. BENEFEDS will use LOGIN.gov. Use of any other alternative multifactor authentication solution will require prior approval from OPM CIO.

Please note that the BENEFEDS website is the system of record for enrollments, not the carrier(s) systems. The information in the BENEFEDS system is subject to the Privacy Act of 1974 and as such the website must include a Privacy Act statement, approved by OPM. At the point of collection, the Contractor must be prepared to respond to, in coordination with OPM staff, requests made by individuals for access to and, where appropriate, amendment of their records.

As previously noted, there is no government-wide central eligibility file. The BENEFEDS Contractor will be responsible for managing the validation of enrollments with a self-certification system. The current BENEFEDS system uses the Enterprise Human Resources Integration System (EHRI) and OPM’s annuity look-up tool post-enrollment to help validate information provided by

7 As required by Executive Order on Improving the Nation’s Cybersecurity, issued May 12, 2021: Modernize and Implement Stronger Cybersecurity Standards in the Federal Government. The Executive Order helps move the Federal government to secure cloud services and a zero-trust architecture, and mandates deployment of multifactor authentication and encryption with a specific time-period. Outdated security models and unencrypted data have led to compromises of systems in the public and private sectors. The Federal government must lead the way and increase its adoption of security best practices, including by employing a zero-trust security model, accelerating movement to secure cloud services, and consistently deploying foundational security tools such as multifactor authentication and encryption.

certain enrollees whose information is not validated after the self-certification process. The Contractor’s solution shall address the method to be used for managing enrollment validation with a self-certification system.

Please note that BENEFEDS is the system of record for enrollments, not the carrier(s), and all data is owned by the Government. Further, note the Contractor will be required to comply with direction from OPM regarding use of the appropriate domain name in accordance with Office of Management and Budget (OMB) Memorandum M-23-22 Delivering a Digital-First Public Experience (Sept. 22, 2023), and with event logging requirements under OMB Memorandum M-21-31, Improving the Federal Government’s Investigative and Remediation Capabilities Related to Cybersecurity Incidents (Aug. 27, 2021).

7.2.2. Customer Service Call Center

The BENEFEDS Contractor shall provide users with access to trained call center Customer Service Representatives (CSRs) to answer enrollment questions, provide enrollment assistance and/or perform enrollments. Billing and pay inquiries must also be serviced, as well as redirecting unrelated/misdirected calls and inquiries (For example, annuitants may call the BENEFEDS Contractor when they meant to call OPM with a question about their annuity payments.).

The Contractor will be responsible for staffing a call center and providing trained customer service representatives fluent in both English and Spanish to support enrollment activities at least ten hours per day Monday through Friday, with expanded hours during open season. The Contractor’s awarded proposal shall determine the method for handling written or telephonic inquiries from employees and retirees working and living overseas. The Contractor shall offer on-call alternate language translation support in the event a language other than English or Spanish is used by the caller. Potential languages include, but are not limited to: French, Italian, German, Farsi, Arabic, Japanese, Urdu, Greek, Russian, Chinese (Mandarin and Cantonese), and Korean.

The BENEFEDS call center is an important component to customer service during open season. Due to the high volume and demand, open season requires increased staff and extended service hours. After open season ends, BENEFEDS customer service quickly returns to normal pre-open season service levels. The volume reduces by more than 70 percent after open season ends. During open season, call volumes historically average 15,000 calls per day, and calls are expected to be answered within 90 seconds. Outside of open season, normal call volume levels average 4,000 to 5,000 calls per day and the calls are expected to be answered within 30 seconds.

In addition to answering general and even misdirected questions, the customer service team will be expected to respond timely to emails and other correspondence from users, as well as service calls in response to communications from BENEFEDS, carriers or OPM.

Historically, BENEFEDS call center expenses have accounted for a significant percentage of the BENEFEDS’ services costs. Most of these costs are driven by three factors:

• Call volume

• Average handle time (AHT) required to service calls

• Complexity of calls

The BENEFEDS Contractor shall:

• Successfully manage call center volume, including “spikes”

• Provide enhanced Voice Response Unit (VRU) capabilities

• Provide first call resolution

• Match call types to CSR capabilities

• Enhance customer service staffing as needed in response to volume surges in a short period of time

The BENEFEDS Contractor shall provide OPM with proposed quarterly phone call and email projections no later than 1 ½ months before the beginning of the quarter for which the proposed projections apply (i.e., Q2 2027 projections are provided by February 15th). OPM and BENEFEDS work together to finalize these projections, including OPM’s approval, no later than the end of the first week of the month prior to the quarter for which the proposed projections apply.

If call and email volumes exceed or fall short by 10% of that stated in the approved plan projections, the award of all or part of the period is subject to assessment of performance deductions based on the QASP.

Please refer to the RTM for requirements. See Appendix C for additional call center information.

7.2.3. System Administration and Architecture Requirements

The BENEFEDS system must provide architecture flexible enough to support technical, business, and mandatory Federal requirements without inhibiting or limiting functionality or user experience.

OPM has a variety of system administration and architecture requirements necessary to support a system as large and complex as the BENEFEDS system.

These requirements comprise hosting, security, privacy, usability, systems development, Federal Enterprise Architecture, and regulatory mandates. The Contractor is responsible for the costs to meet evolving government IT requirements and maintain certifications. Please see the RTM for a list of IT requirements and certifications required of the BENEFEDS Contractor.

The BENEFEDS system must meet requirements for Executive Order on Customer Experience Delivering a Digital-First Public Experience | OMB | The White House and also the Cybersecurity Executive Order 14028 – Memorandum on Improving the Cybersecurity of National Security, Department of Defense, and Intelligence Community Systems

• Requirements for phishing resistant multifactor authentication

• Requirements for cyber logging listed in M-21-31 (whitehouse.gov) o The BENEFEDS Contractor must supply the OPM CISO team with the required logs from the system - Guidance for Implementing M- 21-31: Improving the Federal Government's Investigative and Remediation Capabilities (cisa.gov) o There will be ongoing consumption costs to process the logs that the Contractor will need to cover.

https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.whitehouse.gov%2Fomb%2Fmanagement%2Fofcio%2Fdelivering-a-digital-first-public-experience%2F%23IIIA&data=05%7C02%7CJillian.Gill%40opm.gov%7Cf2693a82ffbe45ab347c08dc3d1937d1%7C844ef9977b6348f0882a7dc8162e363b%7C0%7C0%7C638452425802013040%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C0%7C%7C%7C&sdata=IXRiyjhhp%2BfXhnSSv8NSCHkJ5Uw06GlHmcTVGcpHP6k%3D&…