BENEFEDS - RFI.pdf

UNITED STATES OFFICE OF PERSONNEL MANAGEMENT

BENEFEDS

REQUEST FOR INFORMATION (RFI)

NUMBER 24361820S0002

August 25, 2020

BENEFEDS RFI 24361820S0002

I. Purpose The United States Office of Personnel Management (OPM) is releasing this Request for Information (RFI) with the intent to obtain information from vendors with experience in enrollment and premium administration services. OPM is seeking information on industry best practices for BENEFEDS’ existing functionality and available options to implement newly eligible populations into the Federal Employees Dental and Vision Insurance Program

(FEDVIP).

II. Background OPM is responsible for setting government‐wide benefits and human resources policies and providing guidance to agencies, as well as procuring and managing the contractual relationships with carriers for the various benefit programs. Please visit www.opm.gov/healthcare‐insurance for more information about OPM and the benefits we administer.

The BENEFEDS portal was created to perform enrollment and premium administration functions for FEDVIP. This centralized system interfaces with more than fifty (50) payroll providers and works with contractors that administer the Federal government’s voluntary benefit programs for active and retired Federal employees and their dependents. Today, the BENEFEDS portal provides enrollment and premium administration services for over five million FEDVIP enrollees, processes participant allotments for over 500,000 Federal Flexible Spending Account Program (FSAFEDS) participants, and processes premium payments for over 272,000 enrollees for the Federal Long Term Care Insurance Program (FLTCIP).

All Federal benefit programs are administered in accordance with applicable Federal laws and regulations. Responses to this Notice must demonstrate an understanding of each Federal benefit program’s laws and regulations to ensure compliance. The Federal Employee Dental and Vision Enhancement Act of 2004 (Chapter 89A of title 5 U.S.C.), the Internal Revenue Code for Cafeteria Plans under (I.R.C., Sections 105, 125, and 129), the Long Term Care Security Act (Chapter 90 of title 5 of U.S.C., Part III, Subpart G), Section 715 of the National Defense Authorization Act for Fiscal Year 2017, Section 713 of the John S.

McCain National Defense Authorization Act for Fiscal Year 2019 (FY19 NDAA), and the Tricare Dental Program (10 U.S.C. § 1076a).

III. Existing Requirements

A. Premium Administration Premium and allotment administration activities for FEDVIP, FLTCIP, and FSAFEDS include calculation of premiums or allotment amounts due (rules vary by program), requesting and receiving payments from Federal civilian, uniformed payroll, and annuity providers. In some cases, it may be necessary to receive payments directly from financial institutions or enrollees. With premium or allotment payments, the contractor would be responsible for applying premium calculation rules that have been reviewed and approved by OPM. The contractor would be responsible for remitting payments to carriers and OPM, reconciling payments with funds received, and resolving those instances in which requested amounts were not remitted or the wrong amount was remitted.

FEDVIP premiums must be taken from pay or annuity, except in limited circumstances (for example, if the enrollee’s pay or annuity is insufficient). When payroll deductions of premiums are not possible, the contractor must offer other payment options, including automatic bank withdrawal and direct bill. FSAFEDS allotments must be taken from pay. FLTCIP premium administration must include payroll deduction, automatic bank withdrawal, and direct bill. Other payment options, such as online payment capabilities, may be offered with the mutual agreement of the contractor, the FLTCIP carrier, and OPM.

For FEDVIP and FSAFEDS, the contractor is expected to offer enrollees, as appropriate, the ability to accelerate their premium/allotment payments. FLTCIP enrollees on direct bill may choose to pay their premiums annually.

B. Enrollment

The BENEFEDS system must be capable of recognizing very subtle nuances with respect to enrollment such as certain classes of employees and annuitants (e.g., temporary employees and former spouses receiving annuities) and different program eligibility criteria, which can mean the difference between an individual or group of individuals being eligible or ineligible for a particular benefit.

1.1 Website

The BENEFEDS website must comply with all current privacy and security guidelines 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. Focus should be placed on the website’s ability to handle a high volume of concurrent users with varying types of enrollments. In addition, the website must be user‐friendly and leverage information already provided by the user for subsequent visits.

There is no government‐wide eligibility file, which is a significant challenge associated with the performance of this contract. The contractor would be responsible for managing validation of enrollments with a self‐certification system. BENEFEDS currently uses the Enterprise Human Resources Integration System (EHRI) and OPM’s annuity look‐up tool post‐enrollment to validate information provided by certain enrollees whose information is not otherwise validated after the self‐certification process. The contractor will also be expected to use the Defense Enrollment Eligibility System (DEERS) for the Department of Defense (DoD) personnel and their eligible dependents (see Section IV for more information on the transition of TRICARE Dental Program enrollees to FEDVIP). Interfaces that may also be available include employee self‐service systems such as Employee Express, MyPay, Employee Benefits Information System (EBIS), PostalEase, among others.

1.2 Customer Service Call Center

BENEFEDS receives a large volume of calls every year, with approximately 16,000 incoming calls/per day during open season. A contractor must be able to provide trained call center Customer Service Representatives (CSRs) to answer enrollment and cancellation questions, assist with and/or perform enrollments, changes or cancellations. Billing and pay inquiries must also be serviced, as well as redirecting unrelated/misdirected calls and inquiries (for example, annuitants may call BENEFEDS when they meant to call OPM Retirement Services with a question about their annuity payments).

1.2.1 Staffing

The Contractor would be responsible for staffing a call center and training Customer Service Representatives (CSRs), 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. Due to the high volume and demand, open season requires increased staff and extended service hours. BENEFEDS customer service staff will quickly return to normal service levels after open season ends. The Contractor must also provide alternative language translation support to include, but not limited to, the following languages: French, Italian, German, Farsi, Arabic, Japanese, Urdu, Greek, Russian, Chinese (Mandarin and Cantonese), and Korean.

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.

Information on policies and regulations for each benefits program can be found at https://www.opm.gov/healthcare‐insurance/healthcare/reference‐materials/. The Benefits Administration Letters and Carrier letters are the resources provided by OPM.

C. Systems Administration and Architecture Requirements OPM has a variety of system administration and architecture requirements necessary to support a system as large and complex as BENEFEDS. These requirements comprise hosting, security, usability, system development, Federal Enterprise Architecture, and regulatory mandates.

All IT systems that input, store, process, and/or output Government Information must be provided an Authority to Operate (ATO) signed by the Contractor and the Chief Information Officer (CIO) or higher‐level executive prior to operation of the IT system. The Contractor must complete the Security Assessment and Authorization (SA&A) process independently of OPM, including the selection and funding of an approved Federal Risk and Authorization Management Program (FEDRAMP) Third‐Party Assessor Organization (3PAO) to validate the security and privacy controls in place for the systems and the overall accuracy of SA&A packages.

The Contractor must have the ability to provide a system architecture flexible enough to support technical, business, and mandatory Federal requirements without inhibiting functionality or the user experience.

The Contractor must comply with both OPM IT Security policies and OPM’s continuous monitoring reporting requirements as required by the Federal Information Security Modernization Act (FISMA). The Contractor must provide OPM with the requested information within the timeframes provided for each request. Failure to do so may result in the loss of OPM’s authorization to receive and process sensitive information or operate an IT system containing sensitive information. Reporting requirements may change each reporting period.

D. Program Management

The BENEFEDS contractor is responsible for a variety of program support activities to manage the BENEFEDS infrastructure, systems, processes, and stakeholders. This includes:

developing various outreach mechanisms to communicate with enrollees, employing agencies, OPM, payroll providers and carriers about BENEFEDS service offerings, latest events, and updates to plans impacting service to enrollees;

developing project plans, charters, schedules, management plans, a risk management approach, action item tracking and resolution;

configuration management, including a SDLC, development of a Configuration Management Plan, and a Configuration Control Board Charter, which should include OPM’s participation, and Change Request approach;

developing and managing relationships with payroll providers, carriers, employing agencies, OPM and other stakeholders.

IV. Implementation of a newly eligible population Beginning on or after January 1, 2022, current TRICARE Dental Program (TDP) beneficiaries will become eligible for dental coverage under FEDVIP. OPM is working with DoD, which currently administers TDP, to implement the upcoming transition. This section briefly describes the TDP offered by the Defense Health Agency (DHA) through the current TDP contractor. OPM is currently working with DHA to establish the parameters for the TDP to FEDVIP transition.

The TDP program contractor uses information received from DEERS, managed by the Defense Manpower Data Center. DEERS will serve as the primary source for eligibility information in the transition and throughout the performance of the contract.

The estimated 1.8 million current TDP beneficiaries are comprised of Active Duty Family members (ADFMs), reservists, and survivors. A portion of current TDP beneficiaries, depending on their eligibility category, do not pay the entire premium for their dental coverage. The TDP enabling statute, at 10 U.S.C. § 1076a (d), provides that plans for certain eligible enrollees are subsidized by the DoD (i.e. premium sharing plans) while other eligible enrollees must pay the full cost of premiums. The statute did not set the percentage of premium sharing; this was established by regulation at 32 CFR 199.13(d). Currently, TDP beneficiaries share of premiums are as follows:1

TDP Beneficiaries Premium Sharing

1. Family member of active duty service member

2. Family member of an active duty National Guard or Reserve sponsor

3. Selected Reserve of the Ready Reserve and Individual Ready

Reserve (IRR) special mobilization category sponsor

Beneficiaries pay 40%, Government pays 60%

4. IRR non‐special mobilization category sponsor

5. Selected Reserve family member

6. IRR family member

Beneficiaries pay 100%, Government pays 0%

7. Eligible survivor Beneficiaries pay 0% Government pays 100%

TDP Reservists, who are sponsors, are required to enroll separately from their dependents because the statute requires a separate plan for Reserve sponsors and dependents. Reservists are also eligible for a subsidy while their families are not. See 10 U.S.C. 1076a(a). Currently, this requirement simplifies administration of the benefit and premium subsidies for the sole TDP contractor and, more importantly, supports military readiness for the reservists and minimizes the impact on families when a reservist is deployed.

TDP offers discounted cost sharing to pay grades E‐1 through E‐4 for endodontic, periodontic, and oral surgery services. Pay grades E‐5 and above are subject to a greater beneficiary cost sharing for these three categories of service. The TDP statute specifically provides at 10 U.S.C. § 1076a(d)(1)(D) that the Secretary “may” reduce the premium share paid by enrollees of pay grades E‐1 through E‐4.

The relevant TDP regulation is found at 32 CFR 199.13(d)(4) and states; “For enlisted members in pay grades E–1 through E–4, the ASD(HA) or designee, may reduce the cost‐shares that active duty, Selected Reserve and Individual Ready Reserve members pay on behalf of their enrolled dependents and that members of the Selected Reserve and Individual Ready Reserve pay on their own behalf for selected benefits as specified in paragraph (e)(3)(i) of this section.”

Providing the TDP program Outside the Continental United States (OCONUS) is authorized under 10 U.S. Code § 1076a(g) which states “The Secretary of Defense may exercise the authority provided under subsection (a) to establish dental insurance plans and dental benefits plans for dental benefits

1 See p. 19 of TRICARE Dental Program Handbook, available at https://tricare.mil/- /media/Files/TRICARE/Publications/Handbooks/TDP_HB.ashx provided outside the United States for the eligible members and dependents of members of the uniformed services. In the case of such an overseas dental plan, the Secretary may waive or reduce any copayments required by subsection (e) to the extent the Secretary determines appropriate for the effective and efficient operation of the plan.” According to DHAR there are about 100,000 eligible TDP beneficiaries in OCONUS areas,2 The TDP program includes several features for beneficiaries OCONUS including:

Designation of Command Sponsored Beneficiaries that receive beneficial cost sharing and balance payments;

Command‐sponsored OCONUS members have no cost‐share for any service except for prosthodontic, major restorative, implant services, and orthodontic care, all of which are cost shared at 50%;

In TDP, the Contractor is responsible for paying an OCONUS provider all owed amounts, and the Contractor’s insurance payment to the provider (dentist) is based on its allowed amount. Beneficiaries or select providers (TRICARE preferred dentists) submit dental claims to the TDP Contractor. The Contractor directly bills DHA for the difference between the allowed amount (minus cost‐share) and the billed amount. The enrollee pays the applicable cost‐shares.

V. Requirements for TDP to FEDVIP transition Transition of uniformed services families, reservists, reservist families and survivors in the future population for the FEDVIP program will require ongoing verification through receipt of information from DEERS. OPM intends for the source of FEDVIP eligibility for the uniformed services population to be the Defense Enrollment Eligibility Reporting System (DEERS). This will require the interface with the DEERS system.

Administering premium subsidies for sub‐populations. As described above, under TDP separate sub‐ populations receive different subsidies. Reservists and Active Duty family premiums are subsidized at 60% and survivors are subsidized at 100%.

Administering Changes in Plans and Subsidy Status. Active duty service members and their families often change location. A change in location may require a change in plan since not all FEDVIP Carriers are National/International. Also, when a reservist is called to active duty their status and account would be frozen. Premium subsidies would not be received for the reservists. The now active duty family would be eligible for premium subsidy. When a reservist returns from active duty, the eligibility for subsidy would be reversed.

Separate payment streams. Under TDP, their contractor combines the premiums received from sponsors with the subsidy payments from the Defense Health Agency.

Separate enrollment of Reservists and their Families. As described above, TDP Reservists who are sponsors are required to enroll separately from their dependents because the statute requires a separate plan for Reserve sponsors and dependents. Reservists are also eligible for a subsidy while their families are not.

VI. GENERAL CONTRACTUAL REQUIREMENTS

All prime contractors and subcontractors are required to be SAM registered.

The prime and all subcontractors must be compliant with Section 889(a)(1)(B) of the John S.

McCain National Defense Authorization Act.

The prime and all subcontractor firms must by physically operating from within the 50 United States and the District of Columbia.

All employees of the prime and ALL subcontractors must be physically located within the 50 United States and the District of Columbia.

The prime contractor, regardless of business size, must handle all management and oversight tasks themselves, using their own employees’ labor.

If the RFP is set aside for small business, any small business prime contractors are required to perform at least 50% of the work under the contract using their own employees’ labor.

VII. Quality Assurance Surveillance Plan (QASP) and Requirements Traceability Matrix (RTM) See the draft Quality Assurance Surveillance Plan and Requirements Traceability Matrix for a list of BENEFEDS requirements.

VIII. Response Requirements This Request for Information (RFI) is for market research purposes only and IS NOT A REQUEST FOR PROPOSAL (RFP) nor does it restrict the Government as to its ultimate acquisition approach. The Government will not reimburse respondents for any costs incurred in preparation of a response to this Notice.

IX. Response Instructions All responses to this Notice must be in Microsoft Word or Adobe Portable Document Format (PDF).

Your cover letter should, at a minimum, include the RFI Number, company name, company address, contact person (name, title, phone number and email address), DUNS number, and your company’s business size standard classification relative to North American Industry Classification System (NAICS) code 524292 – Third Party Administration of Insurance and Pension Funds for this requirement.

Please limit responses to no more than twenty‐five (25) single‐spaced pages.

You should not include proprietary information in your response. We will not return responses to this Notice.

In order that we may determine the feasibility (or non‐feasibility) of using a small business set‐ aside for the future solicitation, as well as determine whether our intended performance timeframes are adequate, please address the following in your response:

1. Company history offering enrollment, payroll, and premium administration services for insurance benefits carriers and contractors. Please include any experience working with e‐payroll and annuity providers.

2. Description of all the types of services currently being provided by your company.

3. Description of your company’s experience working with healthcare, dental, vision plans or other benefits.

4. Description of the company’s ability to support over five million Federal employees, annuitants, and eligible family members.

5. Your company’s current staffing level and your ability to provide staffing at a level adequate to support the volume of participants.

6. Your company’s need to subcontract to provide adequate skills and staffing to perform this requirement, and your ability to do so in compliance with the General Contractual Requirements stated in Section VI above.

7. Descriptions of the company’s experience with enrollment and eligibility requirements as they relate to health and dental insurance and the Internal Revenue Code, Section 125 (Cafeteria Plans)?

8. Explanation as to whether the company currently has a premium administration system that provides the required functionality? If not, how soon could the company stand up and operate a premium administration system that provides the required functionality? Please provide an estimate of the start‐up and cost associated with this process.

9. Explanation as to whether the company currently has an enrollment website/portal that provides the required functionality. If not, how soon could the company stand up and operate an enrollment website that provides the required functionality?

10. Explanation as to whether the company currently has a call center that meets the stated requirements? If not, how soon could the company stand up and operate a call center that meets the stated requirements?

11. Does your organization have experience introducing a new eligible population to an existing benefit program? If so, please describe.

12. Does your organization have any experience interfacing with eligibility systems such as DEERS? If yes, please describe your approach and the challenges experienced in establishing such connections.

13. Does your organization have experience in administering an employer/agency benefits subsidy? If yes, please briefly describe how the subsidies are processed and reconciled.

Please include in your discussion how retroactive corrections are administered.

14. Describe your organization’s ability to manage plan year enrollment changes and the ability to change premium payment assignment from the primary enrollee to their eligible dependents.

15. Please briefly describe any experience your organization may have in the administration of premium subsidies for a population with similar characteristics and the potential of changes in plan and enrollment status.

16. Do you have any experience in receiving enrollee subsidy benefit payments from the

Defense Health Agency or other government agencies? If yes, please briefly describe the controls that are required for administration of the funds that are received.

17. What is the process to ensure timely payments of full premiums under similar circumstances?

18. Does your organization have any experience in administering enrollments for employee/sponsors separately from their family? If yes, what are the challenges that you’ve experienced.

Additionally, industry is welcome to provide comment / feedback on the draft QASP and RTM as well as submit a list of questions that the Government should ensure are addressed in the forthcoming PWS or other documents in order to provide greater clarity when the RFP is released. Please be advised that any questions /comments presented during the RFI phase will not be answered back to individual respondents.

X. Response Submission and Due Date All responses to this RFI shall be submitted electronically by email to the following Contract Specialist:

Name: Shireen Belanger Title: Contract Specialist Email: Shireen.Belanger@opm.gov

The Request for Information closing date is as specified in the BetaSAM notice. Responses received after the closing date may not be considered.

XI. Additional information Please note that the collection of this information does not obligate the U.S. Government to the incorporation of solicited comments in any future procurement actions, nor does it obligate the Government to procure any services or products related to this notice.

Responses to this Notice do not affect a potential offeror’s ability to respond to any future solicitations, which may or may not follow. Participation is purely voluntary. Submitting a response to the RFI does not provide you an advantage in the eventual RFP. Not submitting a response to the RFI will not affect the evaluation of a proposal in response to the RFP.

The Government will not provide reimbursement for any information that may be submitted in response to this notice. Respondents are solely responsible for all expenses related to this notice.