Attachment_4_CFPB_Response_to_Offeror_Questions.pdf

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ATTACHMENT 4

CFPB RESPONSE TO OFFEROR QUESTIONS

Bridges to Financial Security

RFP # CFP-14-R-00002

1. Is this a follow-on requirement? If so, could you please provide the incumbent contract number for this opportunity? If not, is this a new requirement?

No, this is not a follow-on requirement. This is a new requirement at CFPB.

2. May we utilize the phone, email and internet to perform the work required in this proposal i.e.

virtual yet national without locations to reduce cost?

Five physical delivery sites at minimum are required, however, Offerors may propose to provide virtual services in addition to the physical delivery sites proposed. An Offeror’s PWS must clearly describe a proposed approach, its benefits, and how it will achieve the SOO, to include at least each Client Objective and each Program Objective listed.

3. Will this contractual agreement go to one organization or several organizations?

CFPB intends to make one award as a result of this RFP, but reserves the right to make multiple awards or no award.

4. If you reserve the right to award multiple organizations, what is the rationale for that decision?

Award to more than one organization may occur based on the best interest of the Government, in consideration of the Performance Work Statements submitted. However, any organization that receives an award must be able to perform all of the work required to achieve the Statement of Objectives (SOO).

5. Is it a requirement that the applying organization currently serves or has measured experience in serving the Disability population?

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It is required that the Offeror (as defined by the RFP Section 4.2 is required to have direct experience working with individuals with disabilities. As stated in the RFP, the term “Offeror” “is defined as the firm, any major subcontractors and any teaming partners.”

6. Relative to deliverables, what are the necessary certifications/credentials of those individuals who will be designated as “financial counselors”?

Please see Section 4.3 the RFP. The trained financial counselor must be appropriately certified by the Social Security Administration as a SSA Benefits Counselor or a comparable certification, or who possesses adequate relevant education and experience.

7. Will the four tasks under Factor 1 receive equal weight in the CFPB’s evaluation of proposals?

Evaluation Factor 1 does not contain any specific tasks. See RFP for detailed submission instructions. The four Task Areas listed in 5.3 were provided for Offeror consideration in forming its proposed PWS and technical approach; the list was not intended to be comprehensive as indicated in the RFP.

8. Can the CFPB clarify how price will be weighed against non-price factors?

As stated in the RFP, non-price factors, when combined, will be considered to be significantly more important than price. Please note that CFPB has provided a current anticipated contract ceiling value of $5,857,343.00 total for the potential five (5) years of performance. Any proposals containing a proposed total price that exceeds the contract ceiling value will not be considered.

9. Pages 31 and 33 of the RFP describe Factor 3 – Past Performance. Can the CFPB confirm that the rating for past performance is based entirely on the past performance questionnaires? In other words, will the CFPB expect or consider write-ups of past projects that are incorporated into the body of the Non-Price Volume?

For Factor 3 – Past Performance, CFPB will consider Past Performance information obtained from outside sources through Past Performance Questionnaires (PPQs) as well as any other relevant past performance information otherwise obtained or known to the Government, however, CFPB will not consider past performance information developed by an Offeror.

10. Can the CFPB estimate the length of time needed to review curricula, tools and materials prior to clearing them for use with clients?

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No, as the length of time needed to review is case specific. However, the Government anticipates that CFPB review time would approximately be within 10 business days upon receipt.

11. Is Adobe PDF an acceptable format in which to submit the non-price and price volumes?

Yes, Offerors may submit proposals using Adobe PDF.

12. Page 72, FAR Clause 52.222-41: If the Service Contract Act does apply, please provide the Wage

Determination.

Applicability of the Service Contract Act (SCA) will depend on the Offeror’s proposal. If applicable, the Service Contract Act (SCA) Wage Determination hourly rates vary based on the locality proposed by the Offeror. In order to determine the Wage Determination, please go to the following site: http://www.wdol.gov/sca.aspx. Select ‘Selecting SCA WDs’ under Service Contract Act and then select the state and county where the services are to be performed, then click Continue. Answer ‘No’ to the following questions and the Wage Determination for that locality will appear below.

13. Page 85 Key Personal, Contracts Manager: Is the contracts manager equivalent to the contracting officer or the COTR?

The role of the Contract Manager is defined in 6.0 Key Personnel. Note that the Contract Manager is not a government employee, but rather part of the Offeror.

14. What are the CFPB’s small business goals for this procurement? What would result in an acceptable rating?

CFPB does not have small business goals and subgoals to be applied to this specific procurement requirement, however, Offerors should propose to maximize the opportunity for small business participation. As stated in the RFP, the extent of an Offeror’s proposed small business participation “in consideration of the nature of the work required and the Offeror’s proposed approach to performing the work” will be evaluated for acceptability. *Note that CFPB recognizes that given the nature of this work requirement, including the limited scale of this demonstration project and that many of the entities that may serve as a service delivery site do not qualify as a small business for purposes of the small business subcontracting plan factor, that an acceptable level of small business subcontracting may be de minimus or none.

http://www.wdol.gov/sca.aspx

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15. In lieu of a certified small business, would the participation of a small nonprofit be considered toward an acceptable rating for Factor 4?

In general, non-profit organizations are not considered to be small businesses under the Small Business Administration (SBA) standards. So the extent of a non-profit organization’s participation would not count toward small business participation

16. Will the Contractor be required to verify the disability status of demonstration participants? If so, what standard or definition of disability will the Contractor be required to use to verify disability?

Section 1.3 of the RFP provides the parameter under which an Offeror can define disability for the purposes of this procurement. The Offeror may, but is not required to, propose an approach that encompasses the verification of disability.

17. How will the credit scores be obtained for demonstration participants? Should the Contractor include estimated costs of obtaining credit reports for demonstration participants in the proposed budget?

An Offeror should propose a strategy as to how it will obtain participant credit scores in its PWS.

All costs related to the project must be included in an Offeror’s Price Volume.

18. Under Task Area 2, will the Contractor be expected to (be permitted to) conduct direct outreach to individuals who may be eligible for demonstration services to inform them about the availability of the demonstration?

Yes. The Contractor will be permitted to conduct direct outreach.

19. Should the Contractor assume that all data collection necessary to measure demonstration outcomes must be collected under the proposed project?

No. Such data collection may be proposed by an Offeror, but is not a requirement.

20. Will the prime contractor awarded the Bridges to Financial Security: A Multi-Site Demonstration

Project contract, and the subcontractor(s) to the prime contractor, be eligible to bid on potential future procurements to evaluate the Bridges to Financial Security: A Multi-Site Demonstration Project?

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In the case where CFPB issues a solicitation for outcome evaluation services of Bridges to Financial Security, the Contractor will not be precluded from bidding, assuming the contractor does not have any organizational conflicts of interest. Note, however, that eligibility to perform impact evaluation services, if needed, would like be impacted.

21. The deadline for past performance questionnaires (PPQs) in Attachment 2 (stated as January 6, 2014) has passed. What is the deadline for PPQs for this solicitation?

The deadline for submitting Past Performance Questionnaires (PPQs) is February 28, 2014.

Attachment 2 has been amended to reflect this discrepancy.

22. Does CFPB expect there will be a Delivery Site Program Education Lead for each site?

This is subject to the Offeror’s proposed Performance Work Statement (PWS). There is no such requirement.

23. Will CFPB accept bids that propose multi-site supervision by Delivery Site Program Education

Leads?

Yes.

24. What is the nature of the fixed price for this contract in relation to the following statement “CFPB reserves the right to adjust in scale or otherwise refine the program as the CFPB deems appropriate, and any such changes will be considered to be within the scope of this work requirement”? How should the Offeror address potential adjustments and refinements in the Price Model?

The Offeror should not address potential adjustments and refinements in the Price Model.

Project adjustments and refinements having an impact on the contractor’s cost will be negotiated bi-laterally between the contractor and the government after contract award.

25. Are there specific geographic locations that CFPB seeks to service, i.e., major population centers or rural?

No. An Offeror should propose in its technical approach a minimum of 5 delivery site locations and the rationale for the selections.

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26. The RFP states, “In the last ninety (90) days of any performance period, transition-out/ phase-out activities may be required concurrent with continued implementation.” This statement creates uncertainty that will require Offerors to necessarily include contingency transition activity pricing in their fixed prices for the Base and each Option period. Should Options be exercised, and no transition-out activities/costs be incurred, this approach will result in unnecessarily higher pricing.

Will CFPB include a separate optional CLIN for transition-out/phase out activities for the Base and each Option Period, thereby allowing the CFPB to exercise and incur costs only as needed?

For purposes of completing the Price Model, Offerors are to propose firm-fixed pricing with the assumption that transition-out/phase-out activities will be required only in Option Period 4.

However, one or more option periods may not be exercised, in the Government’s discretion, separate optional CLINs have been included in the pricing information required to encompass transition-out/phase-out activities that may occur in any of the other four performance periods.

27. How does CFPB anticipate reconciling a fixed price and ceiling value for the contract in relation to the minimum hours specified in section 2.4 of the RFP?

There is no need to reconcile these concepts. CFPB has set forth minimum hours of direct service required in the RFP, has set a “maximum ceiling value” for the work to be performed, and anticipates award of a firm-fixed price contract. These concepts are not at odds with each other.

28. If an Offeror includes a strategic partner, are the written letters of commitment required to be submitted with the proposal? Will CFPB exclude these letters from the page count for the Non- Price Volume?

The Offeror must provide a commitment letter for each strategic partner (see Submission Instructions for Factor 2 – Management Approach). Commitment letters will not count toward the page limit for the non-price volume. The solicitation has been amended to reflect this change.

29. Will CFPB provide “the CFPB-approved financial health assessment tool” during the solicitation period to all offerors to ensure offerors are accommodating the use of the tool for Tier 1 intake in our proposal?

No, CFPB will not provide a financial health assessment tool. The awardee must develop or modify a financial health assessment tool, subject to CFPB approval, to be used during the Tier 1 intake phase.

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30. Is the contractor to provide a financial health assessment tool and receive approval from CFPB?

Alternatively, will CFPB provide a tool?

See answer to Question #29.

31. What are the specific educational requirements, licensure, or certifications required for the Delivery Site Program Educational Leads or counselors providing Tier 2 credit education services?

See answer to Question #6.

32. Are there specific accreditations that are required or preferred? What is the process for determining "adequate" experience and education

See answer to Question #6.

33. Are credit reports obtained at no expense to the client to be procured through program funds that are part of the price ceiling (if free reports are not available)?

See answer to Question #17.

34. Will CFPB provide a definition of “person-centered counseling”? Is this term synonymous with

“individualized”?

Person-centered financial counseling includes goal-setting and development of an action plan that incorporates the role of benefits or work incentives in the plan or, conversely, the plan’s potential impact on eligibility for benefits and work incentives. However, CFPB will consider proposals containing an alternative definition. Person-centered financial counseling focuses on the individual circumstances and needs of each customer. Because of the diversity in the PWD population, it is critical that financial counseling programs focus on the individual being served.

35. Does CFPB require services to be provided in-person for any of the Tiers described in the RFP?

See answer to Question #2.

36. Will personalized services delivered with the assistance of teleconferencing technology be acceptable to provide Tiers 1-5 services to participants?

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37. In addition to training as an SSA Benefits counselor, are there specific financial counseling credentials required for counselors providing Tier 4, person-centered financial counseling services for this solicitation?

No. Certification requirements are listed Section 4.3 of the RFP.

38. Will CFPB provide copies and/or lists of all written privacy related requirements for this solicitation in addition to the stated Federal Information Security Management Act of 2002?

See attached copy of CFPB’s privacy policy in Attachment 5.

39. For Offerors with relevant past performance, does CFPB require the Offeror to include for evaluation purposes information about Past Performance contacts in the Non-Price or Price Volume? If required, will this information be excluded from the page limits?

CFPB does not require Offerors to include information about Past Performance contacts.

40. No agency established small business category goals have been identified. Please identify the subcontracting goals for all small business categories to meet the requirements of Evaluation Criteria Factor 4.

See answer to Question #14.

41. Given the page limitations for the Non-Price and Price Volumes, will CFPB accept an Adobe PDF version of the Offeror’s proposal submission in addition to the Microsoft Office version to avoid potential variations in the way printers read Microsoft Office 2000 files when submitted electronically? Please confirm that Adobe files in PDF format are acceptable for submission of the proposal as they are compatible with Microsoft Office 2000 applications.

Yes, CFPB will accept proposals submitted using Adobe PDF.

42. Is the CFPB’s Service Provider Self-Assessment (Attachment 3) to be submitted by the Offeror with the proposal when submitted? How is the CFPB self-assessment (Attachment 4) that is referenced on p. 91 of the RFP (section 9.3.a) different from the Self-Assessment provided as Attachment 3?

The CFPB Service Provider Self-Assessment is located in Attachment 3. The language in the RFP has been amended to reflect this on page 91.

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43. How should an Offeror address capital expenditures, including equipment, in the Price Model provided by CFPB? Does CFPB assume that all expenditures for adaptive equipment or services to accommodate people with diverse disabilities are included in direct costs?

The Offeror shall provide a detailed price build-up of all direct and other direct costs as part of their proposed firm fixed price per performance period for this requirement. In general, services are considered direct costs and equipment is considered to be other direct costs. An Offeror is to provide a price build-up that encompasses all costs associated with its proposed technical approach.

44. Is there a requirement or expectation that counselors will be full-time equivalent (FTE) or are other configurations acceptable?

No. Full-time equivalent (FTE) counselors are not required. Other configurations are acceptable.

45. The solicitation states that this contract is subject to the Service Contract Act. Will CFPB please provide wage determinations?

See answer to Question #12.

46. Please advise where within the proposal an offeror should include the completed FAR Clause

52.212-3 and other clauses that require completion and submission. Are these items included within the page limitations specified by CFPB for the Non-Price and Price Volumes?

The completed clauses requested in the solicitation are not subject to the page limitation and may be included in the Non-Price Volume or a separate attachment.

47. Please advise if the cover letter and SF1149 will be counted in the page limits and where within the proposal the SF 1449 should be placed.

The SF-1449 may be placed in the Non-Price Volume or may be included as a separate attachment and does not count toward the page limitation.

48. Does CFPB intend to charge the contractor for the cost of the fingerprint check if performed by

CFPB?

CFPB provides the fingerprint card check at no additional cost to the Contractor.

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49. Will CFPB release the questions it received from potential respondents in November 2013 on the draft statement of objectives for Bridges to Financial Security: A Multi-Site Demonstration Project and CFPB’s answers to the questions?

No, CFPB will not be releasing the questions it received in response to the draft Statement of Objectives (SOO) released in November, 2013, given that it is a prior draft and does not reflect the current SOO.

50. On Page 13, Section 3.2 Program Objectives, what is the source of the estimated participation percentage for each tier of the program? If the percentages are based upon estimates suggested through research or other published documentation, would the CFPB please share the source?

The percentage of clients moving through each Tier is based upon government estimates from a variety of research on similar programs.

51. Also on Page 13, Section 3.2, the RFP states that the Performance Work Statement (PWS) “must include a completed table similar to the model table (Table 1)” and “a narrative describing each task/step by Tier (using the table below as a template).” Should the narrative be included in the table or is the narrative separate from the table?

For readability, the narrative should be separate from the table.

52. On Page 14, Section 3.2, the list of baseline data to be collected includes disability. Does the CFPB want to track the specific disability served or simply that the client has a disability? Also, how does the CFPB envision collecting disability data without violating HIPAA and/or other privacy laws?

For the purposes of this procurement, CFPB will only require that the interested participant attest to being qualified to receive services (e.g. having a disability as defined by the RFP in Section 1.3). (Note that the HIPAA only applies to covered entities and, in general, is limited only to information disclosed by doctors, hospitals, pharmacies, and health plans.)

53. On Page 15, Section 4.1 Disability Groups, the RFP states that the “PWS shall provide a comprehensive approach to reach at least three disability populations.” Does the CFPB expect that the Contractor will be able to provide services under this RFP to all disability types listed or just the three populations identified by the Contractor?

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An Offeror’s PWS should include an approach to reach at least three disability populations, defined by the Offeror; the list provided is for illustrative purposes only.

54. On Page 21, Task Area 1: Curriculum Development, “review, repair, and rebuild credit” is listed as one of the areas of personal financial education that must be included in the customized curriculum. There are varying definitions of the term “credit repair” and what activities qualify thereunder. Could the CFPB please explain what it means by “credit repair”?

The RFP reference to credit repair encompasses the contractor identifying and assisting clients in the correction of credit report errors. The RFP’s reference to credit repair does not encompass anything broader, such as a proposed plan for debt reduction or the creation of a debt repayment plan.

55. The RFP states that the contractor must develop technologically appropriate outreach content.

Could the CFPB please provide standards or clarify the definition of “technologically appropriate outreach content”?

There is no set standard or definition. Appropriate content is dependent on an Offeror’s proposed approach to working with various disability populations.

56. Does the CFPB expect contractors to use items such as “apps for mobile devices, customization for digital readers, or transcripts for radio programs” or are these just suggestions?

No. These were simply given as examples.

57. Could the CFPB please share content or design standards from the CFPB Design Style Guide that could impact the materials and content selected for the project?

The CFPB Design Style Guide will be provided to the contractor after contract award.

58. Are there any best practices or standards in the CFPB Design Style Guide that could be shared now as respondents are identifying materials and content to include in the project?

See answer to Question #57.

59. On Page 22, Task Area 3: Financial Education and Service Integration, “review of consumer credit file” is listed as one of the items to be included in the Financial Health Assessment.

However, on Page 17, a review of the consumer’s credit report and/or score is listed as a Tier 2

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activity. Since Tier 1 clients are not required to participate in Tier 2, could the CFPB please clarify what is meant by “review client credit file” in the Tier 1 Financial Health Assessment and how it is different from the Tier 2 credit report review?

The review of the “consumer credit file” should provide baseline data for the financial health assessment, while the review of the consumer’s credit report in Tier 2 should provide a more in-depth review, individualized credit education, and recommendations for improving one’s credit score.

60. On Page 32, Proposal Submission Instructions, the due date given for the Past Performance

Questionnaire (PPQ) is February 28, 2014. However, the PPQ form lists a due date of January 6, 2014. Could you please confirm the due date for PPQ submissions?

The deadline for submitting Past Performance Questionnaires (PPQs) is February 28, 2014.

Attachment 2 has been amended to reflect this discrepancy.

61. Some in the disabled community are well-served via technological solutions that work well remotely. Would the CFPB be open to the use of such solutions as part of this project?

See answer to Question #2.

62. Is the CFPB open to the potential for overlap and synergies between this RFP and the recent financial coaching RFP, especially for disabled veterans?

No. These are separate and independent pilot programs.

63. Does the CFPB have a working definition of individuals with disabilities “transitioning to work”?

No. The intent is that services provided through the Bridges To Financial Stability would be for individuals who are receiving services that would lead to employment. Those services are individualized for the person receiving them.

64. May individuals self-identify as a person with a disability, transitioning to work or in the workforce? Will other documentation be required? If so, what documentation?

See answer to Question #16.

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65. Could the CFPB direct the application to the financial education research used to inform the feasibility of serving/counseling/collecting outcome data for the 3,200 low income working people a year?

Our research was based on comparable financial education programs.

66. What research was used to project the percentages quoted on how participants will move between

Tiers?

See answer to question #65.

67. Can the order of the tiers be changed or reconfigured?

Yes. CFPB will consider a PWS that includes an approach in which the tiers are reconfigured or different from those provided in the RFP.

68. Must services be delivered in person?

69. May targeted individuals enter service delivery at any tier? Or must it be tier one?

Yes. Participants can enter the program at any tier.

70. Does the total number served per year represent a duplicated or unduplicated count? Do the proposed target numbers for each year constitute exclusively new consumers or may it include repeat customers?

The total number encompasses only new consumers. Repeat consumers may be served but should not be counted toward meeting the minimum program objectives.

71. Please provide additional clarification of the CFPB’s definition of a written financial plan.

A written financial plan is unique to the participant. An Offeror should propose in its PWS an approach to working with clients to identify financial goals within the context of other services and/or benefits received. The financial plan should reflect these goals, with identified action steps and milestones.

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72. Do all sites need to provide all of the Tiers of service?

No, the exact tiers and the order in which they are laid out in the RFP are not required. The CFPB will consider other approaches proposed by Offerors. However, the services provided in at least the five (5) minimum service delivery sites must be consistent across those delivery sites;

the services provided in additional or virtual delivery sites may vary.

73. Will the contractor develop a new Financial Health Assessment tool or be expected to utilize and modify a CFPB tool?

See answer to Question #29.

74. We understand that Tiers 3 and 4 must be made available to any individual, regardless of whether they have completed the previous tiers. But as this relates to the completion ratios, how will individuals who did not complete previous tiers be counted? If they join at Tier 3 and continue to Tier 4, can they be counted as part of the required 60% conversion from Tier 3 – Tier 4? Or do the completion ratios assume a single pool of participants (i.e., of the 3200 that are initially counted as completing Tier 1, 85% of those same participants must go to Tier 2, then 75% of those same participants must go to Tier 3, etc.)

There is no requirement for conversion between any of the tiers. The numbers provided is simply a government estimate. The estimate was not based on a single pool of participants as some may not move through the tier successively.

75. Please provide additional clarification of the CFPB’s definition of “group” education.

Basic financial education topics, such as money management, understanding credit, or consumer protection, provided in a group setting.

76. What are considered to be transition out/phase out activities? (p. 11) “In the last ninety (90) days of any performance period, transition-out/phase-out activities may be required concurrent with continued implementation.”

Transition out/phase out activities account for general project wind-down activities and/or transfer activities to a successor contractor, including the transfer and/or destruction of any data developed under the contract.

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77. How much notice will the CFPB provide if they do not intend to exercise the option for periods 1, 2, 3, or 4? If the CFPB chooses to discontinue services, is the contractor required to provide continuation of services to enrolled participants past the current period?

CFPB will not be obligated to provide notice of its intent to not exercise an Option Period, however, CFPB will work in good faith with the awardee to provide notice as soon as practicable.

The Contractor will not be required to provide continuation of services beyond the final contract performance period.

78. Should the proposal document be single-spaced or double-spaced?

CFPB does not have a preference to whether proposals are single-spaced or double-spaced.

79. Based on responses to questions, will the due date be extended?

CFPB currently does not anticipate changing the proposal submission due date.

80. Can the order of the tiers be changed? For example can individuals start with a person center plan since individuals can skip tiers?

See answer to Question #72.

81. The percentage of individuals returning to the next tier appears very high and is contradictory to my personal experience. I am wondering how the percentages of the tiers were determine, is there new research available that shows an increase rate of follow thru for individuals with disabilities and financial counseling?

See answers to Questions #50 and #74.

82. Currently nationwide there are limited number of individuals who are trained/certified in providing financial education to individuals with disabilities. There are not enough certified Benefits Planners/CWICs to provide benefits planning to SSA beneficiaries in most states. This is compounded by the fact that many benefits planners do not provide information on financial issues and literacy. It appears that the RFP has made the assumption that there are readily available qualified people to provide the service. Is CFPB willing to allow grantees time to train individuals to provide the service and rethink this qualification.

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In its PWS, the Offeror should propose a plan to ensure that appropriately trained staff is available and utilized. (Note this is a procurement action, not a grant or cooperative agreement).

83. I am hopeful that there may be a possible extended submission date with this RFP. Is that a possibility?

The CFPB currently does not anticipate changing the proposal submission due date.

84. In the service delivery concept section (4.3) you describe four tiers of program services. Is their flexibility in the order in which participants may progress through the tiers? For example, could they have group financial education, then the financial health assessment, then credit education and person-centered financial counseling? May we propose alternatives within the RFP response?

See answers to #67 and #72.

85. Does the Tier 1 intake have to be performed by a counselor, or could that be done by another trained staff member?

Tier 1 intake may be performed by any staff person with the appropriate training.