DCPAS_NAF Benefits DRAFT PWS_20211006.pdf

Draft

Defense Human Resources Activity (DHRA)

Alexandria, Virginia

Defense Civilian Personnel Advisory Service (DCPAS)

Performance Work Statement for

Benefits Consultant Services for Department of Defense (DoD) Nonappropriated Fund

(NAF) Health and Retirement Programs

October 6, 2021

1.0. INTRODUCTION The DCPAS NAF Personnel Policy Division requires expert, professional health and retirement benefits consulting and advisory services supporting the

DCPAS staff responsible for DoD NAF health and retirement policies and programs.

2.0. BACKGROUND

2.1. Although DoD NAF employees are Federal employees; most title 5, United States Code, laws that cover civil service employees, do not cover DoD NAF employees unless specifically provided by statute. Different defined benefit and defined contribution retirement plans offered by each of the DoD NAF Component employers cover NAF employees, instead of retirement coverage under the Civil Service Retirement System or the Federal Employees Retirement System. The

Component NAF employer defined benefit programs are governmental plans. NAF employer dollars and employee contributions fund the defined benefit programs. The Pension Benefit

Guarantee Corporation does not insure the NAF defined benefit programs.

2.2. NAF employees are not eligible to participate in the Federal Employees Health Benefits

Program, but instead participate in the DoD-wide NAF Health Benefits Program (HBP). DoD contracts with a third-party administrator (TPA) for access to networks of physicians, hospitals, and dentists, and the processing of medical and dental claims. The DCPAS staff chairs the

Committee that manages and recommends benefits levels, premiums, and policy changes to the

NAF HBP. The DoD Components self-fund most components of the health benefits program.

2.3. The Department’s oversight role requires that DCPAS review the DoD NAF Component employer retirement plan actuarial and independently audited financial reports, monitor funding levels, and assess regulatory and policy compliance. The DCPAS staff is responsible for evaluating HBP Committee recommendations on health benefit levels of coverage, premiums, and program design, as well as for managing the contract with the TPA, which includes monitoring third party contract performance. In order to perform these responsibilities, DCPAS requires consultation and advisory assistance from a health and retirement benefits subject matter experts with experience working with private and public sector benefit plans, including benefit programs covering DoD NAF employees. The current contract for these services will expire on June 28, 2022. Continued consultation and advisory assistance are crucial to the

Department’s efficient and effective management and oversight of NAF benefit policy and programs.

2.4. The DoD has approximately 101,176 NAF employees. The NAF employees work at Defense locations all over the world, supporting our Military Services through resale exchanges and morale, welfare, and recreational services. The employees work in a wide variety of jobs, including sales associates, child caregivers, club managers, laborers, recreation assistants, accounting technicians, and senior executives. The six major DoD NAF Component employers are the Department of the

Army; the Department of the Air Force; the Commander, Navy Installations Command (CNIC);

the U.S. Marine Corps; the Navy Exchange Service Command (NEXCOM); and the Army and

Air Force Exchange Service (AAFES).

2.5. The DoD NAF Component employers offer seven defined benefit plans (AAFES has two), with combined assets of $9.5M, liabilities of $9.5M, which cover over 108,500 members

(employees, annuitants, and survivors). The DoD-wide NAF HBP covers 45,000 employees and retirees, for a total number of participating members of over 77,000, including dependents. The

NAF HBP annual claims exceed $544M.

3.0. SCOPE. The contractor will provide all personnel, management, equipment, and supplies necessary to fulfill the objectives of the Performance Work Statement (PWS).

3.1 The contractor shall provide consultant services for: benefits program strategy, design of benefits programs, and pricing of benefits; private and public sector best practices information and recommendations; regulatory compliance guidance; actuarial analysis and review services;

benefits analysis; benchmarking and assistance in monitoring, evaluating, and auditing vendor third-party administrator performance measurements and contract guarantees for the NAF health benefits program (NAF HBP) contract.

3.2 The contractor shall make recommendations on benefit plan design, administration, regulatory application, compliance, and pricing. Contractor services will include actuarial analysis and review, assessment of contract compliance and performance measurement, vendor evaluation, and auditing assistance.

4.0. REQUIREMENTS The Contractor shall:

4.1. Provide expert consulting services in health and retirement benefits related to private and public sector benefit plans, including benefits programs covering DoD NAF employees.

4.1.1. Provide consultation on the design, implementation, and management of health benefit plans covering employees, retirees, and their dependents.

4.1.1.1 Provide expert consulting services related to health care industry regulations and best practices, to include evaluation of the cost effect of changes in benefits, development of short and long-term financial projections for self-insured medical plans, and advise on vendor performance guarantees for customer services and third party administrator programs.

4.1.2. Provide consultation on the design, implementation, management, and oversight of defined benefit and defined contribution retirement plans. The contractor must provide actuarial services, to perform analysis of the NAF Components’ annual valuation reports on their respective governmental pension plans. In addition, expertise is required in applicable generally accepted accounting principles covering pension and retiree medical programs, fiduciary requirements, qualified plan compliance, and Internal Revenue Code error correction procedures for analysis and the production of deliverables.

4.2 Advise on integrated Wellness and Disease Management strategy, for the NAF HBP to increase access to quality healthcare and encourage healthy behaviors while delivering high quality, affordable healthcare. Review and adjust strategy annually.

4.3. Meet via conference call, in-person meetings or an online (video conferencing) platform: (See travel requirements.)

4.3.1. Meet with DCPAS staff and Contracting Officer’s Representative (COR) up to four times annually in each performance year.

4.3.2. Provide appropriate senior-level representative to participate in NAF HBP Committee meetings (up to four, two-day meetings in each performance year).

4.4. Provide benefits consulting services on NAF health and retirement benefits policies and programs and the NAF HBP TPA contract.

4.4.1. Respond to inquiries regarding analysis and recommendations on policy initiatives, laws, regulations, and issues involving health and retirement benefits. Responses may require analysis and recommendations.

4.4.2. Provide benchmark analysis of NAF benefits and total compensation against comparable public and private sector plans and organizations.

4.5. Provide recommendations on NAF HBP annual conventional equivalents and plan design.

4.6. Provide analysis and recommendations regarding the NAF HBP TPA’s annual renewal rates for the Fully Insured Stand-alone Dental Plan and provide data and information to assist with negotiations with the TPA.

4.7. Perform annual Medicare Part D creditable coverage attestation.

4.8. Prior to the start of a new contract year with the NAF HBP TPA, provide analysis and recommendations on the terms of the TPA contract, including performance guarantees and reasonableness of administrative costs.

4.9. Review up to seven actuarial valuation reports in base year and annually in each exercised option year (for six NAF defined benefit retirement plans and one supplemental deferred compensation plan). For each review, provide analysis, a written summary report, and, where necessary, recommendations for action. The written analysis shall also include findings regarding funded levels and other key indicators, actuarial assumptions, and compliance with commonly accepted standards and industry best practices. DCPAS will provide the actuarial valuation reports at varying times throughout the year due to different plan year cycles.

4.10. Provide an annual executive summary of the seven NAF pension plan actuarial valuation reports including review of quality of report content, key findings, and recommendations that are common across the plans. Present the summary via in person meeting, conference call or online platform to the DCPAS NAF Policy staff.

4.11. Lead audits of the NAF HBP TPA’s compliance with contract performance guarantees related to claims processing, prescription drugs, and customer service, with no more than one audit per each performance year. Timing of audit reports will vary.

4.12. Provide a monthly, one-page written progress report. Report must summarize the work performed during the month, problems encountered and proposed solution.

4.13. Participate in a Post-Award Conference and provide written summary of meeting. This meeting provides an introduction between the Contractor personnel and Government personnel who will be involved with the contract and will aid both parties in achieving a clear and mutual understanding of all requirements, and identify and resolve any potential issues. However, this meeting is not a substitute for the contractor’s full understanding of the work requirements at the time of offer submissions, nor is it a time to alter the final agreement arrived at in any negotiations leading to contract award. The Contractor will be prepared to discuss any items requiring clarification and gather information as necessary to support each deliverable and shall submit a written summary of the Post-Award Conference to the COR.

5.0. DELIVERABLES

Deliverable PWS Ref. Delivery Date

Post-award Conference 4.13 Within 15 business days of contract award date

Post-award Conference Summary 4.13 Within 7 business days of the date of the post-award conference.

Written NAF HBP Wellness and

Disease Management strategy.

Review and adjust recommendations upon request.

4.2 Interim or final response not

later than 30 business days from receipt of request.

Analysis and recommendations on retirement and health benefit policy initiatives, laws, regulations and issues. Interim responses must contain estimated date for final response.

4.4 Interim or final response not

later than 30 business days from receipt of request.

Recommendations on NAF HBP annual conventional equivalents and benefits.

4.5 Annually, approximately mid-

June

Deliverable PWS Ref. Delivery Date

Written recommendations, data, and information for NAF HBP

TPA stand-alone dental plan renewal agreement.

4.6 Annually, approximately mid-

June

Written Medicare Part D

Creditable Coverage Attestation.

4.7 By September 30 of each

exercised option year.

Analysis and written recommendations on the terms of

NAF HBP TPA contract.

4.8 Interim or final response not

later than 30 business days from receipt of request.

Written review and analysis of each of the Components’ most recent annual NAF Retirement

Plan valuation reports

4.9 Within 60 business days of

consultant’s receipt of the report from DCPAS.

Executive summary of Retirement

Plan valuation reviews

4.10 Within 30 business days of final

plan review annually

Audit report 4.11 Within 30 business days of conclusion of audit.

Provide a one-page written progress summary report of work performed, problems encountered and proposed solution to problems.

4.12 Monthly

6.0. Reserved

7.0. CONTRACTOR TRAVEL Contractor costs for Government authorized travel for meetings with the NAF HBP are anticipated for this requirement. All travel shall be approved in advance by the COR or CO. Contractor payment claims shall include applicable documentation to support actual costs incurred (e.g. airfare and hotel/lodging receipts). All travel will be in accordance with FAR 31.205-46 and applicable travel regulations (Joint, Federal or Standardized).

No fee or G&A will be allowed, only actual costs will be reimbursed. Failure to provide appropriate documentation may result in a loss of reimbursement of travel expenses.

7.1 The contractor shall attend meetings with the NAF HBP Committee approximately four times a year, for meetings lasting a day and a half to two days each. Number of contractor personnel required to per travel event may vary depending on the purpose of the travel. Locations are to be determined (TBD) and may vary, but recent meetings were in in Dallas, TX; San Antonio, TX; Hartford, CT; Norfolk, VA.

7.2 Other occasional travel may be required to support annual audit requirements and in the support of other PWS task areas. Locations may vary. This travel shall be approved in advance by the COR or CO.

7.3 Contractor travel to the Mark Center/Government facility and/or within the National Capitol

Region for management meetings with DCPAS staff and COR are considered a cost of doing business and will not be reimbursed.

8.0. SECURITY The Contractor will:

NOTE: Security Clearances are not required for access to unclassified data.

8.1 Controlled/Restricted Areas. The Contractor shall be compliant with local procedures for entry to DHRA controlled/restricted areas where Contractor personnel will work.

8.2 Physical Security. The Contractor shall safeguard all Government property and controlled forms provided for Contractor use and adhere to the Government property requirements contained in this contract. At the end of each work day, all Government facilities, equipment and materials shall be secured.

8.3 Pass and Identification Items. The Contractor shall ensure the pass and identification items required for contract performance are obtained for employees and non-government owned vehicles. (Issue of Common Access Card (CAC) and access to Government networks or email is not anticipated for this requirement.)

8.3.1 Comply with HSPD-12 Personal Identity Verification (PIV) issuance requirements, known as the Common Access Card (CAC). Be responsible for obtaining CAC or PIV ready status and submit completed Tier 3 vetting package for processing.

8.3.1.1 All Contractor personnel must obtain/maintain a favorable FBI National Criminal History

Check (fingerprint check).

8.3.1.2 Provide two forms of identification (I-9 document).

8.3.1.3 Personnel must be citizens of the United States.

8.3.1.4 Obtaining CAC or PIV ready status is the responsibility of the contractor. If at any time, any Contractor personnel requiring a CAC is unable to obtain/maintain an adjudicated Tier 3 investigation, the contractor will immediately notify the DHRA Enterprise Operations Center

(DEOC) Security Office and remove such person from performing work under this contract.

8.4 Retrieving Identification Media. The Contractor shall retrieve all identification media, including vehicle passes from employees who depart for any reason before the contract expires;

e.g. terminated for cause, retirement, etc.

8.5 Weapons, Firearms, and Ammunition. Contractor employees are prohibited from possessing weapons, firearms, or ammunition, on themselves or within their contractor-owned vehicle or privately-owned vehicle while on all DHRA installations.

8.6 Controlled Unclassified Information Requirements for DoD Contractors. The following procedures will be used to protect Controlled Unclassified Information (CUI) documents and materials:

8.6.1 HANDLING: Access to CUI material shall be limited to those employees needing the material to perform their duties. The CUI marking is assigned to documents and material created by a DoD User Agency. CUI is not a classification, but requires extra precautions to ensure it properly safeguarded and disseminated and is not released to the public without government authorization.

8.6.2 MARKING: Mark unclassified documents containing CUI: “CUI" at the top and bottom of each page, include the CUI warning box, and the CUI Designation Indicator Block as required in DoDI 5200.48. In a classified document:

8.6.2.1 Mark individual paragraph containing only CUI, but not classified material by placing

“(CUI)" at the beginning of the portion.

8.6.2.3 If the document or material contains CUI under the category of Controlled Technical

Information (CTI), use of distribution statements is required. See DoDI 5200.48.

8.6.2.5 Mark other records such as computer print outs, photographs, films, tapes, or slides in accordance with DoDI 5200.48 so the receiver or viewer knows the it contains CUI material.

8.6.2.6 Mark a message containing material in accordance with DoDI 5200.48. Unclassified messages containing CUI material must show the abbreviation (CUI) before the text begins.

8.6.2.7 Ensure documents transmitting CUI material call attention to any attachments containing

CUI.

8.6.2.8 CUI material released to a contractor by a DoD user agency must have the following statement on the front page or cover:

“THIS DOCUMENT CONTAINS CUI MATERIAL AND MUST BE REVIEWED BY A

GOVERNMENT REPRESENTATIVE UNDER THE REQUIREMENTS OF DODI 5200.48,

DODI 5230.09, and DODI 5230.29.”

8.6.3 STORAGE: During normal duty hours, place CUI material in an out-of-sight location if your work area is accessible to persons who do not have an authorized government purpose for access to the material. After normal duty hours, store CUI material to prevent unauthorized access. File with other unclassified records in unlocked files or desks when internal building security is provided and the file is marked as CUI. When there is no internal security, locked buildings or rooms usually provide adequate after hours protection. For additional protection, store CUI material in locked containers such as file cabinets, desks, or bookcases. Expenditure of funds for security containers or closed areas solely for the protection of CUI material is prohibited.

8.6.4 TRANSMISSION: CUI documents and materials may be transmitted via first class mail, parcel post or for bulky shipments-fourth class mail. Within the CONUS discussion of CUI material on the telephone is authorized if necessary for the performance of the contract and no alternative is available. Electronic transmission of CUI (voice, data, or facsimile) should be by approved secure communications systems whenever practical. If there is a fax transmission, the sender must ensure the intended receiver is available to receive it or a cover sheet will be used to allow carrying it to the final recipient to avoid unauthorized disclosure of the CUI.

8.6.5 RELEASE: CUI material shall not be released outside of the contractor’s facility except to the representative of DoD or DHRA.

8.6.6 DESTRUCTION: When the CUI material no longer meets the threshold for safeguarding and dissemination, it shall be immediately decontrolled, be processed through the records management process, and destroyed by the approved methods identified in DoDI 5200.48 precluding its disclosure to unauthorized individuals by rendering it unreadable, indecipherable, and irrecoverable.

8.7 Reporting Requirements. Contractor personnel shall report to an appropriate authority any information or circumstances of which they are aware may pose a threat to the security of

DOD personnel, Contractor personnel, resources, and classified or unclassified defense information.

8.8 Key Control/Access Badge Control. The Contractor shall establish and implement methods of making sure all keys/badges issued to the Contractor by the Government are not lost or misplaced and are not used by unauthorized persons. The Contractor shall not duplicate any keys issued by the Government.

8.9.1 Prohibited Use. The Contractor shall prohibit the use of keys, issued by the Government, by any persons other than the Contractor’s employees and the opening of locked areas by

Contractor employees to permit entrance of persons other than Contractor employees engaged in performance of contract work requirements in those areas.

8.10 Lock Combinations. The Contractor shall control access to all government provided lock combinations to preclude unauthorized entry. The Contractor is not authorized to record lock combinations without written approval by the COR. Records with written combinations to authorized secure storage containers, secure storage rooms, or certified vaults, shall be marked and safeguarded at the highest classification level as the classified material maintained inside the approved containers.

9.0. GOVERNMENT FURNISHED PROPERTY/EQUIPMENT/INFORMATION

(GFP/GFE/GFI). N/A

10.0. PLACE OF PERFORMANCE.

Work performance will occur at the contractor’s site.

11.0. QUALITY CONTROL

The contractor will implement and maintain a Quality Control Plan (QCP) to ensure work performed conforms to the scope of work and meets the requirements under this PWS. The QCP will, at a minimum provide a method for performing inspections; identifying, correcting and preventing problems/defective service; addressing customer complaints, and improving the quality of services over the life of the contract.

12.0. QUALITY ASSURANCE

12.1. The Government reserves the right to perform inspections and surveillance to evaluate the

Contractor’s compliance to the contract terms and performance of the requirements in the PWS.

The Government will make every effort to ensure that the surveillance methods described below occur in an objective, fair, and consistent manner.

12.1.1. Periodic Surveillance. This action occurs when the COR or other Government official observes a deficiency. Examples include evidence from accidents, incidents, or delays.

Regardless of where in the line-of-duty the COR observes contractual procedures not being followed, there is an obligation to document and report the deficiency to the Contracting Officer.

12.1.2. Customer Complaint Surveillance. This action is instituted when the COR receives a complaint from a stakeholder regarding contractor service. The COR will obtain the complaint in writing and then conduct an investigation to determine its validity. If the complaint is deemed valid, the COR will immediately notify the Contracting Officer for action. The COR will notify both the Contract Manager and the complainant of the Government’s response to their complaint.

12.2. Contract Discrepancy Report (CDR). In the event of unsatisfactory contractor performance, the COR or CO will issue a CDR that will explain the circumstances and findings concerning the incomplete or unsatisfactory service. The contractor will acknowledge receipt of the CDR and respond in writing as to how they will correct the unacceptable performance and avoid a recurrence. The Government will review the contractor's corrective action response to determine acceptability and will use any completed CDR as part of an overall evaluation of Contractor performance when determining present or future contractual actions.

13.0. ORGANIZATIONAL CONFLICTS OF INTEREST

The Contractor acknowledges that it is familiar with FAR Subpart 9.5, Organizational and

Consultant Conflicts of Interest, and agrees to avoid, neutralize or mitigate such conflicts of interest in accordance with the principles set forth in the FAR. If the performance requires the

Contractor (to include subcontractors) to supply technical support related to systems or projects with which the Contractor is already directly concerned, either by prime or subcontract, the

Contractor will immediately inform the Contracting Officer. If there is a conflict of interest, the

PWS may be withdrawn. The Contractor will not undertake performance of any PWS requirement, that requires technical support regarding such systems until notice, is given, and the Contracting

Officer issues written consent to proceed.

14.0 APPLICABLE DOCUMENTS

Document Web link DoD Instruction (DoDI) 8500.1, Cybersecurity http://www.dtic.mil/whs/directives/corres/pdf/850001_2014.pdf

15.0 PERFORMANCE REQUIREMENT SUMMARY (PRS)

15.1 Purpose. The PRS lists performance objectives for the required services the Government will surveil. The absence of any contract requirement from the PRS shall not detract from its enforceability nor limit the rights or remedies of the Government under any other provision of the contract including the clauses entitled “Inspection of Services”, “Inspection”, or “Default” in the contract.

15.2 Components. The PRS states the performance objective (required service), and threshold

(performance standard, accept and reject points (if applicable)) in either a qualitative or quantitative fashion for each critical success factor.

Performance Objective

PWS paragraph

Performance Standard/Acceptable Quality Level

Provide benefits consulting services on NAF health and retirement benefits policies and programs and the NAF HBP TPA contract

Deliverable:

Interim or final response

4.4 Performance is acceptable when:

a) 100% of deliverable requirements are met and received on time

AND

b) critical information is accurate

Perform actuarial analysis of the NAF Components/

Defined Benefit Plan annual valuation reports

Written review and analysis reports

4.9 Performance is acceptable when:

a) 100% of deliverable requirements are met and received on time

AND

b) critical information is accurate

Lead audits of the NAF

HBP TPA/s compliance with contract performance guarantees

4.11 Performance is acceptable when:

a) 100% of deliverable requirements are met and received on time

AND

b) critical information is accurate http://www.dtic.mil/whs/directives/corres/pdf/850001_2014.pdf

Audit report

16. Mandatory Training Requirements for Contractor:

N/A