BPM005375 Evaluation Documents.pdf
PDF 3 MB Posted
- Solicitation number
- BPM005375
- Issued by
- Arizona
About this file
This is a Contract Award and Executive Summary document for the Arizona Department of Corrections, Rehabilitation & Reentry's Request for Proposal (RFP) BPM005375 for Electronic Payment Transaction Processing Services. The solicitation was issued electronically on September 7, 2023, with proposals due October 6, 2023. Three offerors submitted proposals: Global Tel*Link Corporation d/b/a ViaPath Technologies, JPay LLC, and Keefe Commissary Network, LLC DBA Access Corrections. The evaluation committee, comprising William Meola (CC ACIS Administrator), Christine White (AR & ITA Manager), and Nan Nesvig (Senior IT Program Manager), conducted initial consensus evaluations on October 23-24, 2023. The evaluation committee recommended contract awards to all three offerors on November 13, 2023, determining that all three proposals were most advantageous to the State based on the evaluation criteria.
The proposals were evaluated on a total of 1,000 possible points across three primary criteria: Scope of Work (550 points), Experience and Capability of Offeror (250 points), and Price/Fees (200 points). ViaPath scored 980 total points (550 Scope of Work, 250 Experience, 199 Price), JPay scored 999 total points (550 Scope of Work, 250 Experience, 199 Price), and Keefe scored 960 total points (550 Scope of Work, 250 Experience, 160 Price). The pricing evaluation utilized a weighted methodology based on 36 priced line items reflecting transaction volumes over a 12-month period, with adjusted scores calculated proportionally to the lowest bidder. The submitted pricing was determined to be fair and reasonable based on adequate price competition. Confidential information determinations were made for both ViaPath and Keefe regarding trade secret materials including cybersecurity compliance reports, IT recovery plans, and financial documents, with designated documents withheld from public disclosure.
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Contract Award and Executive Summary
BPM005375
Electronic Payment Transaction Processing Services
Arizona Department of Corrections, Rehabilitation & Reentry
701 E. Jefferson Street
Phoenix, AZ 85034
Document ID and Title: C317 RFP Contract Award and Executive Summary Determination Revision No.: 1 | Revision Date: 08-22-23 | Page 1 of 2
PROCUREMENT DETERMINATION
RFP Contract Award and Executive Summary
SOLICITATION
No.: BPM005375
Description: Electronic Payment Transaction Processing Services
AUTHORITY
A.R.S. § 41-2534 Competitive sealed proposals; A.A.C. R2-7-C317 Contract Award
EXECUTIVE SUMMARY
DATE EVENT AND DESCRIPTION
Pre-Solicitation Activities
06/14/23 First Procurement Disclosure Statement (PDS) was signed.
08/23/23 Notification sent to the state governmental unit’s employees and the State Procurement Administrator regarding the date of the first PDS.
Solicitation Process
09/07/23 This solicitation was issued electronically via the State’s eProcurement system. An electronic notification was sent to four prospective offerors who were registered in
APP.
09/07/23 The solicitation was formally advertised in the Arizona Republic newspaper in accordance with A.R.S. § 41-2534(C) and A.A.C. R2-7-C301(B).
09/29/23 Solicitation amendment No. 1 was issued to correct two paragraph reference errors in the Scope of Work and to add Attachment 10 – Letter of Insurability.
Evaluation Process
10/06/23, [3:00 PM]
MST
Proposals due. Offers were received from the following:
● Global Tel*Link Corporation d/b/a ViaPath Technologies (ViaPath)
● JPay LLC
● Keefe Commissary Network, LLC DBA Access Corrections (Keefe)
10/23/2023 Process reviewed with evaluation committee members. PDS forms (SPO Forms 110, 120, and 130) signed/updated by evaluation committee members, and offers distributed. Committee members were:
● William Meola, CC ACIS Administrator, Group Supervisor
● Christine White, AR & ITA Manager, Financial Services
● Nan Nesvig, Senior IT Program Manager
10/23/23 Initial Consensus Evaluation of ViaPath’s proposal conducted in accordance with A.A.C. R2-7-C316.
Contract Award and Executive Summary
Electronic Payment Transaction Processing Services
Arizona Department of Corrections, Rehabilitation & Reentry
701 E. Jefferson Street
Phoenix, AZ 85034
Document ID and Title: C317 RFP Contract Award and Executive Summary Determination Revision No.: 1 | Revision Date: 08-22-23 | Page 2 of 2
10/24/23 Initial Consensus Evaluation of JPay’s and Keefe’s proposals conducted in accordance with A.A.C. R2-7-C316.
10/25/23 Revisions were requested from ViaPath and Keefe, in accordance with A.A.C. R2-7- C315(A).
10/26/23 A Determination regarding Confidentiality was made for ViaPath and Keefe, in accordance with A.A.C. R2-7-103.
11/13/23 Recommendations of award(s) made by Evaluation Committee is as follows:
● Global Tel*Link Corporation d/b/a ViaPath Technologies
● JPay LLC
● Keefe Commissary Network, LLC DBA Access Corrections
CONSENSUS
The proposals were evaluated with a total possible score of 1000 points. The proposals were evaluated based on the following criteria:
1. Scope of Work
2. Experience and Capability of Offeror
3. Price/Fees
DETERMINATION
In accordance with A.R.S. § 41-2534(G) and A.A.C. R2-7-C317(A), the Solicitation shall be awarded to the
Offeror(s) determined to be most advantageous to the State in accordance with the evaluation factors identified in the Request for Proposal; therefore, the evaluation committee recommends the following
Contract Award(s) and the undersigned Procurement Officer concurs:
● Global Tel*Link Corporation d/b/a ViaPath Technologies
● JPay LLC
● Keefe Commissary Network, LLC DBA Access Corrections
In accordance with A.A.C. R2-7-702, the submitted pricing was determined to be fair and reasonable based upon the award of the contract through adequate price competition.
DOCUMENTATION
This determination shall be placed in the Procurement File in the State’s eProcurement System.
Procurement Officer Signature Procurement Officer Title
Procurement Officer Name Date
David Brackney
David Brackney
Sr. Procurement Specialist
11/13/2023
Recommendation for Award
Electronic Payment Transaction Processing Services
Arizona Department of Corrections, Rehabilitation & Reentry
701 E. Jefferson Street
Phoenix, AZ 85034
The members of the evaluation committee have completed their review of the proposals and any subsequent best and final offers received in response to solicitation BPM005375 for Electronic Payment Transaction Processing Services, and have reached a consensus. Based on the detailed evaluation of the individual proposals, it would be in the best interest of the State, to award a contract to:
● Global Tel*Link Corporation d/b/a ViaPath Technologies
● JPay LLC
● Keefe Commissary Network, LLC DBA Access Corrections
As a participating member of the evaluation committee, I agree with the information provided in this document and concur that the consensus scoring is a complete and accurate reflection of the committee’s agreement regarding the evaluation of the proposals received.
Name
Evaluation Committee Member Signature
Date
William B. Meola
Electronic Payment Transaction Processing Services
Arizona Department of Corrections, Rehabilitation & Reentry
701 E. Jefferson Street
Phoenix, AZ 85034
The members of the evaluation committee have completed their review of the proposals and any subsequent best and final offers received in response to solicitation BPM005375 for Electronic Payment Transaction Processing Services, and have reached a consensus. Based on the detailed evaluation of the individual proposals, it would be in the best interest of the State, to award a contract to:
● Global Tel*Link Corporation d/b/a ViaPath Technologies
● JPay LLC
● Keefe Commissary Network, LLC DBA Access Corrections
As a participating member of the evaluation committee, I agree with the information provided in this document and concur that the consensus scoring is a complete and accurate reflection of the committee’s agreement regarding the evaluation of the proposals received.
Name
Evaluation Committee Member Signature
Date
Nan Nesvig
Electronic Payment Transaction Processing Services
Arizona Department of Corrections, Rehabilitation & Reentry
701 E. Jefferson Street
Phoenix, AZ 85034
The members of the evaluation committee have completed their review of the proposals and any subsequent best and final offers received in response to solicitation BPM005375 for Electronic Payment Transaction Processing Services, and have reached a consensus. Based on the detailed evaluation of the individual proposals, it would be in the best interest of the State, to award a contract to:
● Global Tel*Link Corporation d/b/a ViaPath Technologies
● JPay LLC
● Keefe Commissary Network, LLC DBA Access Corrections
As a participating member of the evaluation committee, I agree with the information provided in this document and concur that the consensus scoring is a complete and accurate reflection of the committee’s agreement regarding the evaluation of the proposals received.
Name
Evaluation Committee Member Signature
Date
Christine White
Confidentiality Determination
Electronic Payment Transaction Processing Services
Arizona Department of Corrections, Rehabilitation & Reentry
701 E. Jefferson Street
Phoenix, AZ 85034
Document ID and Title: 103(C) Confidential Information Determination Revision No.: 0 | Revision Date: 02-06-23 | Page 1 of 2
PROCUREMENT DETERMINATION
Confidential Information
REFERENCE
No.: BPM005375
Description: Electronic Payment Transaction Processing Services
AUTHORITY
A.R.S. § 41-2540(B) Responsibility of bidders and offerors; A.A.C. R2-7-103 Confidential Information
DETERMINATION
In accordance with A.A.C. R2-7-103(C), it is determined that:
● The following designated information, submitted by Keefe Commissary Network, LLC DBA Access Corrections (Keefe), is confidential and the agency chief procurement officer shall not disclose the information except to those individuals deemed by the agency chief procurement officer to have a legitimate state interest:
■ Confidential – Supplement – Attachment D – TKC Holdings- IT Recovery Plan v2.0 Executive Summary
■ Confidential – Supplement – Attachment E – Fraud Prevention Overview
– FINAL
■ Confidential – Supplement – Attachment F – Financials provided to AZ
DOC
● The following designated information submitted by Keefe is not confidential:
■ N/A
All other information submitted by Keefe is not confidential and will be released as public record upon contract award.
If the Department receives a public records request to disclose the confidential documents, Keefe will be notified and will be expected to defend against public disclosure. The Department is requesting Keefe to provide written confirmation stating if such a request is made, Keefe will
Arizona Department of Corrections, Rehabilitation & Reentry
Document ID and Title: 103(C) Confidential Information Determination Revision No.: 0 | Revision Date: 02-06-23 | Page 2 of 2 defend against public disclosure. Please provide your written confirmation in a formal letter regarding this information no later than November 2, 2023 via email to dbrackney@azadc.gov.
BASIS
The above documents determined to be confidential appear to meet the standard for “trade secret” information as described in A.A.C. R2-7-101(51).
NOTICE
In accordance with A.A.C. R2-7-103(D), if Keefe wishes to request a review of this determination by the State Procurement Administrator (SPA), the request must be received no later than 3:00 pm MST (Arizona time) on November 2, 2023. The request shall be sent to SPOCompliance@azdoa.gov, on behalf of the SPA.
DOCUMENTATION
This determination shall be placed in the procurement file or contract file.
_______________________________ _Chief Procurement Officer_________ Procurement Officer Signature Procurement Officer Title
__Kerry Wells_____________________ _10/26/23____ Procurement Officer Name Date mailto:SPOCompliance@azdoa.gov
Arizona Department of Corrections, Rehabilitation & Reentry
PROCUREMENT DETERMINATION
Confidential Information
REFERENCE
No.: BPM005375
Description: Electronic Payment Transaction Processing Services
AUTHORITY
A.R.S. § 41-2540(B) Responsibility of bidders and offerors; A.A.C. R2-7-103 Confidential Information
DETERMINATION
In accordance with A.A.C. R2-7-103(C), it is determined that:
● The following designated information, submitted by Global Tel*Link d/b/a ViaPath
Technologies (ViaPath), is confidential and the agency chief procurement officer shall not disclose the information except to those individuals deemed by the agency chief procurement officer to have a legitimate state interest:
■ Confidential – Supplement – ViaPath NIST 800 53 Cybersecurity
Framework Command System Compliance Report
■ Confidential – Supplement – ViaPath System and Organization Controls
SOC 2 Type 2 Report
● The following designated information submitted by ViaPath is not confidential:
■ Confidential – Supplement – ViaPath PCI DSS Certification
All other information submitted by ViaPath is not confidential and will be released as public record upon contract award.
If the Department receives a public records request to disclose the confidential documents, ViaPath will be notified and will be expected to defend against public disclosure. The Department is requesting ViaPath to provide written confirmation stating if such a request is made, ViaPath will defend against public disclosure. Please provide your written confirmation in a formal letter regarding this information no later than November 2, 2023 via email to dbrackney@azadc.gov.
mailto:dbrackney@azadc.gov
Arizona Department of Corrections, Rehabilitation & Reentry
BASIS
The above documents determined to be confidential appear to contain “trade secret” information as described in A.A.C. R2-7-101(51), whereas the document determined not confidential does not appear to meet the same standard.
NOTICE
In accordance with A.A.C. R2-7-103(D), if ViaPath wishes to request a review of this determination by the State Procurement Administrator (SPA), the request must be received no later than 3:00 pm MST (Arizona time) on November 2, 2023. The request shall be sent to SPOCompliance@azdoa.gov, on behalf of the SPA.
DOCUMENTATION
This determination shall be placed in the procurement file or contract file.
Chief Procurement Officer Procurement Officer Signature Procurement Officer Title
Kerry Wells 10/26/23 Procurement Officer Name Date mailto:SPOCompliance@azdoa.gov
ViaPath (GTL) Keefe Jpay
SELECTION CRITERIA:
1. Scope of Work
2. Experience and Capability
3. Price/Fees
TOTAL POSSIBLE POINTS
Scope of Work Evaluation
Points
Rating
Points
(0 - 2)
Score / Comments
Rating
Points
(0 - 2)
Score / Comments
Rating
Points
(0 - 2)
Score / Comments
Section 1 Introduction Not Scored Not Scored Not Scored
Section 2 Task Not Scored Not Scored Not Scored
Section 3 Definitions Not Scored Not Scored Not Scored
Section 4.1 Purpose Not Scored Not Scored Not Scored
Section 4.2 Background Not Scored Not Scored Not Scored
Section 4.3 Schedule Pass Pass/Fail Pass Pass/Fail Pass Pass/Fail
Section 4.4 Utilization of Contractor's Services Pass Pass/Fail Pass Pass/Fail Pass Pass/Fail
Section 4.5.1 Costs and Revenue Pass Pass/Fail Pass Pass/Fail Pass Pass/Fail
Section 4.5.2 Minimum Requirements Pass Pass/Fail Pass Pass/Fail Pass Pass/Fail
60 60 60
2 Meets requirements 2 Meets requirements 2 Meets requirements
Section 4.5.4 Data and Network Access/Security
40 40 40
2 Meets requirements 2 Meets requirements 2 Meets requirements
40 40 40
2 Meets requirements 2 Meets requirements 2 Meets requirements
40 40 40
2 Meets requirements 2 Meets requirements 2 Meets requirements
40 40 40
2 Meets requirements - no subcontractors 2 Meets requirements 2 Meets requirements
20 40 40
Offeror performs annual internal testing and identified its 3rd party testing provider, but did not provide enough details to allow for a more complete evaluation of its testing process.
2 Meets requirements 2 Meets requirements
Section 4.5.5 Access and Types/Methods of Payment
30 30 30
2 Meets requirements 2 Meets requirements 2 Meets requirements
30 30 30
2 Meets requirements 2 Meets requirements 2 Meets requirements
30 30 30
2 Meets requirements 2 Meets requirements 2 Meets requirements
Evaluation Tool for Request for Proposals BPM005375 (ADCRR No 23-132-28)
2 = 100% of total available points - Meets Requirements
Offeror Identification
Available Points
Scoring Guidelines: Scoring for all rated criteria can be scored from a minimum of 0 points to a maximum of 2 points.
1 = 50% of total available points - Partially Meets Requirements
0 = 0% of total available points - Does Not Meet Requirements, no response, or does not provide enough information to evaluate (Note: During the evaluation process, some criteria may given an initial "0" and subsequently changed contingent upon clarification, revision, and or negotiations.)
Section 4.5.5.1 - Internet Website/Portal
Section 4.5.5.2 - Telephone
Section 4.5.5.3 - Walk-in Storefront
Global Tel*Link (ViaPath
Technologies)
(GTL)
Section 4.5.3 Transaction Reporting (4.5.3.1 - 4.5.3.2.21)
Section 4.5.4.1.1 Unauthorized Access/Theft
- include copy of PCI DSS compliance certificate
Section 4.5.4.1.2. Disaster Protection/Recovery
Section 4.5.4.1.3. Cyberattack Protection and Recovery
Section 4.5.4.1.4. Subcontractor Vulnerability
Section 4.5.4.1.5. Penetration Testing
Jpay, LLC Keefe Commissary Network, LLC dba Access Corrections
ViaPath (GTL) Keefe JpayOfferor Identification
Available Points 30 30 30
2 Meets requirements 2 Meets requirements 2 Meets requirements
80 80 80
2 Meets requirements 2 Meets requirements 2 Meets requirements
30 30 30
2 Meets requirements 2 Meets requirements 2 Meets requirements
30 30 30
2 Meets requirements 2 Meets requirements 2 Meets requirements
30 30 30
2 Meets requirements 2 Meets requirements 2 Meets requirements
Section 4.5.10 Miscellaneous Provisions (4.5.10.1 - 4.5.10.2) Not Scored Not Scored Not Scored
Section 4.5.11 Stipulated Requirements for Contractors Not Scored Not Scored Not Scored
Total Points for Scope of Work 550 530 550 550
Section 4.6 Experience and Qualifications Evaluation
Points
Rating
Points Score / Comments
Rating
Points Score / Comments
Rating
Points Score / Comments
150 150 150
2 Meets requirements 2 Meets requirements 2 Meets requirements
100 100 100
2 Meets requirements 2 Meets requirements 2 Meets requirements
Total Points for Experience & Capabilities 250 250 250 250
Price/Fees Evaluation
Points Score / Comments Score / Comments Score / Comments
200 199 160
Total Points for Fees 200 200 199 160
980 999 960
I AGREE WITH THE ABOVE SCORING AND COMMENTS SHOWN ABOVE:
William Meola Signature
Nan Nesvig Signature
Section 4.5.8 Customer Service (4.5.8.1 - 4.5.8.2) 30
Section 4.6.2 Experience and References
Section 4.6.1 Experience and Capability
Section 4.5.6 Search, Mapping and Data Mining (Subsection
4.5.6.1 - 4.5.6.1.3.3)
Each of the 36 priced line items were given a weighting factor based upon the number of transactions for that line item over a recent 12-month period. That weighting factor was multiplied Offeror's price to arrive at an adjusted score. The offer with the lowest total adjusted score received all 200 possible points. Other offers were awarded points proportional to the quotient of the lowest adjusted score divided by theirs.
OFFEROR'S TOTAL POINTS FOR ALL CRITERIA
Section 4.5.5.4 - Mobile Payment Platform/Application 30
Section 4.5.7 System Upgrade/Outage/Breach (4.5.7.1 -
4.5.7.4)
Section 4.5.9 Deployment, Contract Expiration/Termination and Decommissioning (4.5.9.1 - 4.5.9.2.4)
Christine White Signature
DBRACKNEY
Stamp
Fee Evaluation - BPM005375 - Electronic Payment Transaction Processing Services
Inmate Trust Account Deposits % of All # Transactions
Payment in recent Weighting APP Weighted APP Weighted APP Weighted APP Weighted
Internet Transactions Transactions 12-mo. Period Factor Fees Fees Fees Fees Fees Fees Fees Fees
$1.00 - $20.00 4.254% 29,367 0.04254 0.95 0.040 0.95 0.040 0.95 0.040 0.95 0.040
$20.01 - $30.00 4.496% 31,039 0.04496 1.45 0.065 1.45 0.065 2.35 0.106 1.45 0.065
$30.01 - $40.00 3.391% 23,410 0.03391 1.89 0.064 1.89 0.064 2.85 0.097 1.95 0.066
$40.01 and up 22.871% 157,878 0.22871 4.95 1.132 4.95 1.132 5.85 1.338 4.95 1.132
Mobile App Transactions
$1.00 - $20.00 7.537% 52,026 0.07537 0.95 0.072 0.95 0.072 0.95 0.072 0.95 0.072
$20.01 - $30.00 6.590% 45,490 0.06590 1.45 0.096 1.45 0.096 2.35 0.155 1.45 0.096
$30.01 - $40.00 5.407% 37,322 0.05407 1.89 0.102 1.89 0.102 2.85 0.154 1.95 0.105
$40.01 and up 30.723% 212,084 0.30723 4.95 1.521 4.95 1.521 5.85 1.797 4.95 1.521
Telephonic Transactions
$1.00 - $20.00 0.463% 3,194 0.00463 0.95 0.004 0.95 0.004 0.95 0.004 0.95 0.004
$20.01 - $30.00 0.578% 3,992 0.00578 1.45 0.008 1.45 0.008 2.35 0.014 1.45 0.008
$30.01 - $40.00 0.511% 3,529 0.00511 1.89 0.010 1.89 0.010 2.85 0.015 1.95 0.010
$40.01 and up 3.949% 27,262 0.03949 4.95 0.195 4.95 0.195 5.85 0.231 5.50 0.217
Store Front Transactions
$1.00 - $20.00 0.232% 1,600 0.00232 2.50 0.006 4.50 0.010 0.95 0.002 2.50 0.006
$20.01 - $30.00 0.434% 2,998 0.00434 2.50 0.011 4.50 0.020 2.35 0.010 2.50 0.011
$30.01 - $40.00 0.434% 2,994 0.00434 2.50 0.011 4.50 0.020 2.85 0.012 2.50 0.011
$40.01 and up 4.165% 28,749 0.04165 2.50 0.104 4.50 0.187 5.85 0.244 2.50 0.104
Community Corrections Payments
Internet Transactions
$1.00 - $20.00 0.012% 80 0.00012 0.95 0.000 0.95 0.000 0.95 0.000 0.95 0.000
$20.01 - $30.00 0.009% 64 0.00009 1.45 0.000 1.45 0.000 2.35 0.000 1.45 0.000
$30.01 - $40.00 0.009% 60 0.00009 1.89 0.000 1.89 0.000 2.85 0.000 1.95 0.000
$40.01 and up 0.657% 4,538 0.00657 4.95 0.033 4.95 0.033 5.85 0.038 4.95 0.033
Mobile App Transactions
$1.00 - $20.00 0.010% 71 0.00010 0.95 0.000 0.95 0.000 0.95 0.000 0.95 0.000
$20.01 - $30.00 0.010% 67 0.00010 1.45 0.000 1.45 0.000 2.35 0.000 1.45 0.000
$30.01 - $40.00 0.011% 73 0.00011 1.89 0.000 1.89 0.000 2.85 0.000 1.95 0.000
$40.01 and up 0.513% 3,540 0.00513 4.95 0.025 4.95 0.025 5.85 0.030 4.95 0.025
Telephonic Transactions
$1.00 - $20.00 0.003% 24 0.00003 0.95 0.000 0.95 0.000 0.95 0.000 0.95 0.000
$20.01 - $30.00 0.019% 133 0.00019 1.45 0.000 1.45 0.000 2.35 0.000 1.45 0.000
$30.01 - $40.00 0.001% 8 0.00001 1.89 0.000 1.89 0.000 2.85 0.000 1.95 0.000
$40.01 and up 0.220% 1,522 0.00220 4.95 0.011 4.95 0.011 5.85 0.013 5.50 0.012
Store Front Transactions
$1.00 - $20.00 0.008% 52 0.00008 2.50 0.000 4.50 0.000 0.95 0.000 2.50 0.000
$20.01 - $30.00 0.005% 32 0.00005 2.50 0.000 4.50 0.000 2.35 0.000 2.50 0.000
$30.01 - $40.00 0.006% 41 0.00006 2.50 0.000 4.50 0.000 2.85 0.000 2.50 0.000
$40.01 and up 0.515% 3,558 0.00515 2.50 0.013 4.50 0.023 5.85 0.030 2.50 0.013
$25 Background Check/Visitation Transactions
1.937% 13,374 0.01937 1.00 0.019 1.00 0.019 0.95 0.018 0.00 0.000
0.001% 4 0.00001 1.00 0.000 1.00 0.000 0.95 0.000 0.00 0.000
0.019% 134 0.00019 1.00 0.000 1.00 0.000 0.95 0.000 0.00 0.000
Store Front Transactions 0.000% 0 0.00000 2.50 0.000 4.50 0.000 0.95 0.000 0.00 0.000
Totals 100.000% 690,309 1.00000 80.94 3.544 98.94 3.660 99.80 4.423 76.90 3.553
Raw Score Adj. Score Raw Score Adj. Score Raw Score Adj. Score Raw Score Adj. Score
200 160 199
Internet
Mobile Apps
Telephone
Offer #1 Offer #2 Offer #3
ViaPath (using
CheckFreePay for
Storefront
Transactions)
Jpay (using MoneyGram for Storefront
Transactions)
Keefe (using InComm for
Storefront Transactions)
Offer #1 (modified)
ViaPath (using Western
Union for Storefront
Transactions)
Total Points Not separately used on
Evaluation Tool
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