D.5 ATTACHMENT E_TASK ORDER PWS -TASK ORDER.docx

PERFORMANCE WORK STATEMENT

Fiscal Review and Oversight for Grant and Per Diem (GPD) & Support Services for Veteran Families (SSVF) Program(s)

1. Introduction.

Subject to the availability of appropriations, Title 38, U.S.C. §§ 2012 states that the Secretary of VA shall provide (subject to the availability of appropriations) funds to grant recipients or entities eligible to receive a grant that provide supportive services and/or supportive housing to homeless Veterans. By statute, VA may also provide grants to assist community providers in meeting the needs of special populations. Office of Management and Budget (“OMB”) issued the “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Final Rule (Uniform Guidance) on December 26, 2013”, which is referred to as OMB “Super Circular” or “Omni Circular” and is codified at 2 Code of Federal Regulations (CFR) Part 200.

The GPD Program, an essential and critical part of Veterans Health Administration (VHA), is vital for providing safe transitional housing and supportive services for homeless Veterans. The statutory authority for the Grant Per Diem Program is found at title 38 U.S.C. 2044. The implementing regulations are found at title 38 CFR Part 61. The GPD Program has been successful in establishing services for homeless Veterans. Since its inception, the program has grown significantly. Grants have been awarded nationally since 1994. Community-based providers funded under the GPD Program exist in all states, the District of Columbia, Guam, and Puerto Rico. These GPD Programs offer communities a way to assist homeless Veterans with housing and services while assisting VA medical facilities in providing housing or services for Veterans. Program designs are diverse, ranging from congregate living transitional housing projects and apartment style transitional housing, to service centers offering outreach and supportive services.

The statutory authority for the Supportive Services for Veteran Families (SSVF) Program is found at title 38 United States Code (U.S.C.) 2044. The implementing regulations are found at title 38 Code of Federal Regulations (CFR) Part 62. Section 604 of the Veterans’ Mental Health and Other Care Improvements Act of 2008, Public Law 110-387, authorized VA to develop the SSVF Program, which provides supportive services to very low-income Veteran families in/or transitioning to permanent housing. Funds are granted to private non-profit organizations and consumer cooperatives that assist very low-income Veteran families by providing a range of supportive services designed to promote housing stability.

Community-based programs are funded through a national competition in response to a Notice of Fund Availability (NOFA) published in the Federal Register according to rules and regulations and any other funding priorities as announced in NOFA. It is imperative that VA recognize these projects as independent and operating based on designs as put forth (and rated) in the proposal. As VA has no authority to instruct or manage programs, it provides guidance and oversight to ensure operations are in compliance with VA inspection standards and that the program offering the services is the same as was described in the original proposal, or as modified through program scope changes.

VA, the largest provider of treatment and assistance to homeless Veterans in the nation, is committed to rapidly expanding programs to help Veterans who are homeless now and to prevent Veterans from becoming homeless in the future. Homelessness, a significant national problem, has many causes. Homeless individuals are often unemployed, unable to work, or have such low incomes that they cannot afford housing. Some homeless individuals have disabling mental health, substance use, or physical conditions that lead to, or compound, their homeless situation. Homeless families are a growing part of the homeless population in America.

It is anticipated the work will require tasks classified in the following Functional Categories and Capability Areas (select all that apply):

|_|Program & Project Management

|_|Studies and analyses

|_|Medical Supply Chain and Healthcare Logistics Analysis

|_|Business Reqts Development

|_|Data Governance

|_|Supply Chain Management

|_|Strategic Planning

|_|Performance Measurement

|_|Supply Chain Planning

|_|Program Evaluation

|_|Training Development

|_|Inventory Management and Operation

|_|Business Process Reengineering, Improvement and Management

|_|Training Delivery

|_|Supply Chain Optimization

|_|Financial Management Modernization

|_|Quality Management

|_|Policy Management

|X|Internal Financial Controls

|X|Financial Management and Operations

|_|Media Buying

|_|Research and development administrative support

|_|Public Relations Services/Outreach

|_|Human Resources Support

|_|Conference, Events, & Planning Services

|_|Procurement Support to P/PM

|_|Healthcare Related Promotional Materials

|_|Information privacy and records management

|_|Video/Film Production

|_|Revenue operations

2. Scope or Purpose.

The contractor shall support the requirement to conduct Financial and Operational Fitness Assessment (FOFA) reviews for the GPD & SSVF programs. The Contractor shall provide services in support of the grants mission initiatives as described herein to provide financial and operational oversight assistance relevant to Governmental requirements regarding documentation format, routing, retention and related administrative rules. The primary focus of the work is focused on GPD & SSVF internal control program guides, compliance with federal regulations to include 2 CFR 200, 38 CFR Part 61 & 62, IPERIA support and continuous monitoring. This will require data and statistical analysis for FOFA reviews and continuous monitoring. Identifying all sources of funds and expenses for supportive services; determining if costs are allowable in accordance with all applicable OMB regulations, grant regulations and Program Guide; verifying grantee is in compliance with expense thresholds; ensuring compliance with all financial and operational reporting requirements; qualitatively and quantitatively determine if adequate supportive services are being provided (i.e. outreach services, case management services, assisting participants in obtaining VA benefits, and assisting participants in obtaining other government and public benefits), as prescribed by programmatic requirements.

3. Task statement.

1. TASK ONE – GPD & SSVF FOFA PLANNING PHASE (FFP) The Contractor shall provide FOFA planning phase workpapers to include, but not limited to, a summary of the findings with questioned costs, review work papers, and recommendations derived from the applicable work papers.

The GPD & SSVF program office must conduct 76 FOFA field reviews each (152 total) to support this initiative. VA anticipates the field reviews will have an engagement timeline of four weeks per engagement, broken down as follows: five to seven days of planning/preliminary review work; five days of fieldwork; one to two days of post fieldwork analysis; and three to five days to draft and issue a report. The schedule of each review location will be predetermined by OBO, based on one-person review team to complete each review. VA will complete a risk assessment and prepare a schedule and project management plan of 152 reviews. Associates may work on multiple reviews simultaneously. Depending on grantee location and proximity to other grantees, reviews may be combined into a single week or travel event (two day and three-day site visits scheduled for same week/team). The Contractor will not be required to develop an overall review plan/program as OBO will have developed the review program tailored for the GPD & SSVF environment; however, the Contractor will have an opportunity to review and provide suggestions for consideration by OBO.

The Contractor shall revie76w grantees and address internal controls, operational controls, cash management, accounting records and documentation, and compliance with grant agreement terms and conditions. The Contractor shall perform review procedures established by OBO, based on risk and conduct fieldwork at the grantee’s site, depending on the complexity of the data and/or risks identified. Preliminary and Field work shall consist of performing substantive tests by examining financial reports, accounting records, and supporting documents.

During the planning phase, the Contractor shall organize an entrance conference with grantee management to discuss questions about the timeline, prepared by client (PBC) requirements and current progress. In addition, the Contractor shall gain an understanding of GPD & SSVF governing statutes, regulations, official programmatic guidance and other relevant information, by reviewing and assessing the grantee’s previous reporting information, including management replies and review reports, if applicable. The grantee’s information will aid in identifying key preventive and detective controls and assessing any controls that are lacking in the process that may result in unrecorded, inaccurate, untimely and/or fictitious transactions. FOFA reviews are conducted through a combination of remote preparation, document reviews, an on-site review and interviews. The Contractor shall develop a review strategy to define the scope and focus, identifying the following:

1. Additional programs/areas/functions to be reviewed (if necessary);

2. Data or information to be submitted by the grantee prior to monitoring;

3. The names of any participant staff members who will need to be consulted during the reviews;

4. Anticipated staff who will conduct the reviews;

5. Clearly defined areas of responsibilities for each reviewer if more than one staff person will be conducting the reviews;

6. A schedule for carrying out the review tasks and the anticipated time frames.

7. Objectives and review program approval from OBO, GPD & SSVF, and staff.

8. Initiate contact with the Grantee to confirm time and dates of the review(s) and POC for Engagement Letter.

9. Draft the engagement letter and provide to OBO for submission.

10. Coordinate and conduct an entrance conference call with grantee within five (5) days of delivery of engagement letter. If the grantees PBC response is not received by the established due date, the Contractor shall contact the facility via telephone and email to determine the reason for the delay. If no response is received, the Contractor shall elevate the matter to OBO for corrective action.

11. Review and evaluate internal control processes and procedures.

12. Review fraud risk factors to detect, prevent, or mitigate potential fraud, waste or abuse of federal funds.

13. Review subcontractor agreements, to include a sample of case files, expenses, payroll, and administrative cost review work similar to Grantee review work, if applicable.

14. Analyze general ledger to identify additional unallowable costs, as prescribed in 2 CFR Part 200. The Contractor shall obtain a judgmental sample from the general ledger after eliminating all credits and expenses under $25. A sample of items shall be selected based on a margin of error determined by OBO not to exceed a total sample of 30 to 60 expenses and up to two pay periods for payroll (depending on organizational/staff size).

15. Collaborate with GPD & SSVF Program Office or VA Liaison/Regional Coordinator to obtain background information and current knowledge of outstanding concerns or irregularities associated with the grantee.

16. Review Memorandum of Agreement or Grant Agreement.

17. Confirm adequacy of accounting and internal control directives, segregation of duties and policies and procedures.

18. Review Grant Application and any budget modification information.

19. Determine if grantee has complied with OMB Super Circular requirements by accessing the Federal Audit Clearinghouse.

20. Review of prior year’s Single Audit findings, if applicable.

21. Reconciliation of funds and expenses and determine if they are reasonable, allowable and allocable to source documents for the scope under review. This requires tracing amounts to where differences were identified between the grantee’s financial statements, general ledger, quarterly financial reports, payment and expense invoices, and detailed budget.

22. Verify payroll information through an analysis of timesheets and organizational charts and test additional source documentation for accuracy.

Deliverables:

A. GPD & SSVF FOFA Planning Phase Workpapers

2. TASK TWO – GPD & SSVF FOFA FIELD WORK PHASE (FFP)

During the fieldwork phase, the Contractor shall review case files, conduct interviews, and obtain additional information as necessary and hold an out-brief meeting with grantee management to discuss progress, observations, and findings. The Contractor shall perform the following tasks:

1. Investigate “high risk areas” identified during planning phase.

2. Interview grantee and determine operational fitness of: program goals progress, policies and procedures (P&P), subcontractor management, program management, critical incident response, outreach and eligibility services.

3. Review grantee single audit and related requirements (if applicable).

4. Identify and review all less than arm’s length transactions, if applicable.

5. Review significant modifications in staffing patterns, participants served, programmatic goals and objectives, and reporting requirements.

6. Provide condition, cause, effect and recommendations to improve productivity, cost-effectiveness, quality of work processes, operational business processes, organizational internal controls, and the overall financial and operational position of the organization.

7. Adhere to all Federal Auditing regulations and guidance from OMB, and VA Grant Program Guides.

8. Review grantee SF-425 submissions for completeness and accuracy.

9. Utilize specialized audit and data analysis software (such as TeamMate, Audit Command Language, Microsoft Office and Structured Query Language). Grant offices use these and like tools to research and document data elements required in identifying various risks, controls, and improper or duplicate payments.

10. Educate grantees on requirements associated with executing federal resources, fiscal compliance, and overall risk associated with potential fraud, waste, and abuse.

11. Draft preliminary on-site exit summary highlighting condition, cause, effect and recommendation(s), and including summary of results from off-site review work completed prior to site visit.

12. Present/discuss preliminary exit summary with grantee management prior to completion of on-site review work.

13. Review up to thirty (30) SSVF (SSVF ONLY) case files for, eligibility, recertification, case management, benefit assistance and temporary financial assistance, based on size and risk of the grantee.

Deliverables:

A. GPD & SSVF FOFA Fieldwork Phase Exit Summary

3. TASK THREE – GPD & SSVF FOFA REVIEW REPORTS (FFP)

During the Reporting phase of the review process, the Contractor shall develop a review report summarizing the review results. The Contractor shall perform the following tasks:

1. Develop the draft review report using the predetermined format as provided by VA.

2. Ensure draft review report includes:

a. Executive Brief

b. Questioned Cost

c. Table of Contents

d. Results (to include: Condition, Criteria, Cause, Effect, and Recommendation(s))

e. Grantee Background

f. Scope and Methodology

g. Sampling Methodology

During the reporting phase, the Contractor shall provide the GPD & SSVF FOFA draft report to the Government within five (5) business days after completion of fieldwork. The Contractor shall provide a final report within five (5) business days after the Government provides feedback. OBO will then forward the final report to the GPD & SSVF Grant Program Office for official records and distribution to the applicable parties.

Deliverables:

A. GPD & SSVF FOFA Draft Report B. GPD & SSVF FOFA Final Report

4. Delivery Schedule. [Complete the table below based on deliverables defined above]

76 GPD

76 SSVF

24 GPD Options 24 SSVF Options 6 Within 30 days of kick-off. The remaining evenly spaced for the remainder of period of performance.

76 GPD

76 SSVF

24 GPD Options 24 SSVF Options

NLT 15 days following completion of task 1

76 GPD

76 SSVF

24 GPD Options 24 SSVF Options

NLT 5 days following completion of task 2

B. GPD & SSVF FOFA Final Report

76 GPD

76 SSVF

24 GPD Options 24 SSVF Options NLT 5 days following completion of draft report (3A)

5. Period of Performance.

The period of performance (PoP) shall be 1 year base period with 4 year options.

Any work at the Government site shall not take place on Federal holidays or weekends unless directed by the Contracting Officer (CO).

The Contractor shall be available during the Grants Program Office hours of 8:00 AM (Eastern) to 5:00 PM (Eastern), Monday through Friday. The Contractor shall ensure that FOFA review site visits are coordinated with the site Point of Contact and shall work that site’s normal working hours or as agreed with the point of contact for the specific FOFA review.

There are ten (10) Federal holidays set by law (USC Title 5 Section 6103) that VA follows:

Under current definitions, four are set by date:

If any of the above falls on a Saturday, then Friday shall be observed as a holiday. Similarly, if one falls on a Sunday, then Monday shall be observed as a holiday. The other six are set by a day of the week and month:

6. Type of Contract.

Firm-Fixed Price (FFP)

7. Place of Performance.

Tasks under this PWS shall be performed at Contractor facilities (CONUS). Work may be performed at remote grantee locations with prior concurrence from the Contracting Officer’s Representative (COR). The Contractor shall identify the Contractor’s place of performance in its proposal.

8. Travel.

Travel must be pre-approved by the CO and COR and in accordance with Federal Travel Regulations. Each Contractor invoice must include copies of all receipts that support the travel costs claimed in the invoice. Local travel within a 50-mile radius from the Contractor’s facility is considered the cost of doing business and will not be reimbursed. This includes travel, subsistence, and associated labor charges for travel time. Travel performed for personal convenience and daily travel to and from work at the Contractor’s facility will not be reimbursed. General and administrative expenses will also not be reimbursed.

The total estimated number of trips in support of this effort is 76 GPD & 76 SSVF grantee site visits during the base period plus option years. Each grantee site visit trip will require two or three days on-site. The locations for the 152 trips are provided in the project priority listing and are subject to change. All sites are located in the continental United States. Historically, based on the tentative schedule, three contracting review teams composed of two personnel are required per scheduled review or one person teams to lessen the burden on travel. OBO reserves the right to modify the location of the site visits as needed.

76 SSVF

9. Material Other Direct Costs.

None

10. Government-Furnished Information, Equipment, and Facilities.

The Government has multiple remote access solutions available to include Citrix Access Gateway (CAG), Site-to-Site Virtual Private Network (VPN), and RESCUE VPN. The contractors are required to provide their own laptops and accessories. However, when necessary, the Government will furnish desktops or laptops, for use by the Contractor to access VA networks, systems, or applications to meet the requirements of this PWS. The overarching goal is to determine the most cost-effective approach to providing needed access to the VA environment coupled with the need to ensure proper Change Management principles are followed. Contractor personnel shall adhere to all VA system access requirements for on-site and remote users in accordance with VA standards, local security regulations, policies and rules of behavior. GFE shall be approved by the COR and Program Manager on a case-by-case basis prior to issuance.

Other than what is listed above, the Government will not provide IT accessories including but not limited to cell phones, Mobile Wi-Fi hotspots/wireless access points, additional or specialized keyboards or mice, laptop bags, extra charging cables, extra Personal Identity Verification card readers, peripheral devices, or additional Random Access Memory (RAM). The Contractor is responsible for providing these types of IT accessories in support of this effort as necessary and any VA installation required for these IT accessories shall be coordinated with the COR.

11. Key Personnel.

All personnel performing work shall possess expertise in the disciplines and technical areas as related to the tasks in the PWS to include Federal Finance, Accounting, Financial Systems, and as well as experience in financial statement audit, audit remediation, and audit readiness. The Contractor shall provide the titles, and a description of the duties of key personnel to be assigned to these tasks.

The Key Personnel positions required are as follows and shall possess the following minimum qualifications:

The Senior Auditor shall have a minimum of three (3) years of experience implementing, managing, and supporting relevant projects. Minimum education includes a bachelor’s degree in accounting or business.

The Staff Auditor shall have a minimum of two (2) years of experience implementing, managing, and supporting relevant projects. Minimum education includes a bachelor’s degree in accounting or business.

Submitted resumes are to be redacted to prevent disclosure of personally identifiable information (PII). Examples of PII include but are not limited to names, addresses, phone numbers, social security numbers, and birthdays/dates. For those individuals proposed as Key Personnel who are not current employees of the contractor, a signed redacted letter of intent will be required. Submitted signed letter (s) of intent are to be redacted to prevent disclosure of PII. The Key Personnel positions and redacted resumes of individuals who shall fill the key personnel positions shall be included as an attachment to the contract in Section D upon award.

During the first 90 days of performance, the Contractor shall not replace or substitute Key Personnel who the Contractor proposed pre-award unless the replacement is necessitated by illness, death, or termination of employment. The Contractor shall notify the Contracting Officer within 15 calendar days after the occurrence of any of these events and provide a detailed explanation of the circumstances necessitating the proposed substitution and shall demonstrate that the proposed replacement personnel are of at least substantially equal ability and qualifications as the individual originally proposed for that position. The proposed replacement personnel shall be approved by the CO and COR prior to final determination.

After the initial 90 days, any personnel the Contractor offers as substitutes for the above identified key personnel positions shall have the ability and qualifications equal to or better than the key personnel which are being replaced and shall meet or exceed the qualifications designated for that Key Personnel position. If any change to a key personnel position becomes necessary, the Contractor shall immediately notify the VA PM and COR in writing, but whenever possible Contractor shall notify the VA PM of substitutions in personnel in writing 30 calendar days prior to making any change in key personnel, and provide a detailed explanation of the circumstances necessitating the proposed substitution and shall demonstrate that the proposed replacement personnel are of at least substantially equal ability and qualifications as the individual originally proposed for that position and that the proposed replacement meets or exceeds the qualifications designated for that Key Personnel position.

The Contractor agrees that it has a contractual obligation to mitigate the consequences of the loss of Key Personnel and shall promptly secure any necessary replacements in accordance with this PWS section in order to avoid any interruption in contract performance by that Key Personnel. Failure to replace a Key Personnel pursuant to this requirement shall be considered a condition endangering contract performance and shall provide grounds for default termination.

12. Task Order Quality Assurance Surveillance Plan (QASP).

Deliverable or Requirement Performance Standard Surveillance Method Outcome

100% inspection. The TO COR will review Services for timeliness according to criteria established in this TO and/or the Project Initiation Agreement.

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