Debt Relief Contact Support JNA - Final 10262022.pdf

JUSTIFICATION & APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

Debt Relief Contact Center Surge Support Requirement

1. Identification of Agency and Contracting Activity

United States Department of Education (Department), Federal Student Aid (FSA).

2. Nature/Description of Action Being Approved

On August 24, 2022, the President of the United States (the President) announced targeted debt relief to address the financial harms of the pandemic, a final extension of the pause on federal student loan repayment through December 31, 2022, and proposed changes to other loan forgiveness programs (e.g., income-driven repayment, PSLF changes, etc.) (collectively, Biden-Harris Federal Student Loan Debt Initiative).

To address the surge in calls from the public requesting information and guidance, and the increase in income verification (Debt Relief Contact Center Surge Support) resulting from the Biden-Harris Federal Student Loan Debt Initiative, FSA is conducting a limited-source competition (Solicitation) among existing contract holders within FSA. FSA is utilizing this method because this group of contractors have the following: an existing/approved Authorization to Operate (ATO), available personnel, an ability to plug-in/access various systems, and the base knowledge necessary to begin working on this support services contract immediately.

The Solicitation for this requirement has been sent to FSA’s existing Business Process Operations (BPO) contractors and Accenture Federal Services (Accenture)1. As a result of the pending solicitation, FSA anticipates that a firm fixed-price, limited source contract for Debt Relief Contact Center Surge Support will be awarded to one or more of FSA’s existing BPO contractors and/or Accenture. The contract(s) will be awarded as a six-month contract (a single 3-month Base and three (3) 1-month Options) with an ultimate expiration date of April 2023. The estimated value of the proposed action Base Period is $7,164,186.79 and $7,072,869.00 total for the (3) 1-month Options.

Utilizing this method of procurement ensures FSA will have the resources needed to provide the necessary support services and to handle the surge in public inquires and debt-relief submissions.

1 Accenture is a current contractor on FSA’s system, and had previously provided similar contact center support.

The contract center support was part of Accenture’s original contact, but was removed via modification to transfer contact center support to the BPO contractors.

3. Description of the Services Required to Meet the Agency’s Needs (including the estimated value)

The Debt Relief Contact Center Surge Support contract will provide effective customer support services related to the Biden-Harris Federal Student Loan Debt Initiative which is delivering one-time student loan debt relief to millions of borrowers; helping millions of borrowers prepare to return to repayment after December 31, 2022; and providing other loan forgiveness or discharge, such as income-driven repayment, Public Service Loan Forgiveness (PSLF), and borrower defense to repayment. FSA requires resources and personnel support that already are or can become performance-ready no later than October 11, 2022.

Selected Debt Relief Contact Center Surge Support personnel must be immediately in place while the existing contact centers continue to hire qualified staff to provide long-term support for FSA’s programs. If immediate customer support services are not implemented timely, there is a risk that FSA will not be able to provide debt relief services to otherwise eligible borrowers, failing in its essential purpose.

The Debt Relief Contact Center Surge Support contract scope includes the following elements:

Training FSA anticipates providing training to all successful offerors to ensure consistent handling of work and a common understanding of the targeted debt relief process holistically.

Customer Support Services Provide contact center support in responding to and resolving inquiries related to debt relief and income verification. Support includes, but is not limited to the following types of inquiries listed below:

• General information inquiries related to debt relief

• Inquiries on specific applications

• Form inputs, updates, completions, corrections, and submittals updating

• Application, resources (e.g., FSA ID), services, and technical support

• Fulfillment requests

• Customer screening inquiries which may include eligibility screening

• Scheduling follow-up contacts

Income Verification Process Requirements The successful offerors shall process the allocated income verification.

4. Identification of the Statutory Authority Permitting Other Than Full and Open Competition

This procurement action will be awarded in accordance with FAR 6.302-2 and 41 U.S.C.

3304(a)(2), Unusual and Compelling Urgency. It is anticipated that there will be a temporary surge in calls or inquiries. This procurement will allow FSA to meet its essential mission and provide accurate and timely answers to impacted borrowers. Otherwise, without this short term

(no more than 6 months) support, the Department would face reputational harm, and fail in its essential mission of providing debt relief to otherwise eligible borrowers.

Additionally, the public would be harmed in that the Department will not be able to provide accurate and timely information and guidance to members of the public who are attempting to receive guidance from the Department, resulting in confusion. There is a risk that otherwise eligible borrowers who do not receive such timely, accurate information and guidance regarding the Biden-Harris Federal Student Loan Debt Initiative, will not take the necessary steps to avail themselves of the relief offered.

The award(s) pursuant to this limited source solicitation will allow the BPOs to complete necessary tasks to be able to provide this work long-term. As such, FSA does not anticipate a need to conduct another solicitation to address this scope of work.

5. Demonstration that the Proposed Contractor’s Unique Qualifications or Nature of Acquisition Requires Use of the Authority Cited:

Following the President’s announcement on August 24, 2022, his Administration (Administration) has encouraged everyone who is eligible to file an application for relief.

There are approximately 43 million student loan borrowers in FSA’s portfolio. FSA has the required, relevant income data for approximately 8 million of these borrowers who will automatically get the relief under the Biden-Harris Federal Student Loan Debt Initiative.

For those not automatically processed, the Administration anticipates launching a simple application for relief which will be available in October 2022. The Department expects millions of applications from individuals for whom the Department has no income data.

Because borrowers will want to apply before loans return to repayment—particularly true for those who expect full debt relief—it is expected that many of these applications will arrive between the time of application launch and November 15, 2022. This increase in applications will translate to immediate work for the Department’s contact center/back-office processing solutions who will need to handle applications requiring immediate manual intervention. Once a borrower completes the application, they can expect relief within 4-6 weeks.

Since the President’s announcement, the Department has been inundated with calls from student loan borrowers seeking guidance and information about the impacts of the Biden- Harris Federal Student Loan Debt Initiative. The use of authority 6.302-2 (Unusual and compelling urgency) is the most relevant authority for this immediate action. Without the use of this authority, the Department will not be able to effectively handle the volume of customer interactions (e.g., calls, chats, and emails) and processing necessary to meet the public’s needs in an expeditious manner.

FSA identified Accenture and the BPO contractors as the limited sources that could perform the requirements. The limited sources identified have unique qualifications in that they recently performed comparable scope or are currently performing comparable scope. The limited sources also have the capacity to meet the immediate need of the Government.

FSA is striving to deliver on the promise of the Biden-Harris Federal Student Loan Debt Initiative. This effort provides once-in-a-generation relief to millions of borrowers, enabling up to $20,000 in loan cancellation per borrower per eligibility criteria. To deliver on the President’s commitment to America, FSA and its vendors are engaging in multiple efforts to execute the promises of the Debt Relief Initiative in a highly compressed timeframe.

Given the stated importance of the work, FSA has already evaluated all vendor work and paused or canceled lower priority projects to enable FSA and vendor resources to focus on delivering the Debt Relief Initiative. If FSA does not proceed with the award(s), FSA and/or its agents will:

a) Not be able to effectively handle the volume of customer interactions (e.g., calls, chats, emails) and provide needed information to borrowers;

b) Not be able to process debt relief actions timely for otherwise eligible borrowers;

c) Suffer significant injury by failing to provide services to the public that are a part of the core mission;

d) Be inundated with a volume of work that cannot be completed timely; thereby creating a risk that unqualified employees may inadvertently give false information to a borrower, resulting in potential litigation costs to the Department; and

e) Experience mission failure if otherwise eligible, timely Debt Relief applications are not processed before the payment pause expires on December 31, 2022.

The Department anticipates an increase in contact center support associated with each application and without additional capacity that is immediately available, the Department will not be able to handle the call volume and will fail to meet the core mission. The Department is not able to conduct a full and open competition due to the urgent nature of the requirement;

FSA had limited ability to engage with vendors prior to the announcement; and therefore, did not have sufficient time to develop a solicitation or request for quotation to conduct full and open competition. The cost and time of running a full and open competition and getting various sources up to speed would be harm to the Government, as well as loss of public trust.

6. Description of Efforts Made to Ensure That Offerors are Solicited from as Many Potential Sources as is Practicable

The BPO contractors have this scope of work in their contracts. Although, the contact center scope was recently removed from Accenture’s contract and transitioned to the BPO contractors, Accenture still has the immediate capability as its technical capabilities have not been decommissioned.

The Department has issued the Solicitation to the BPO contractors and Accenture. If Accenture receives an award pursuant to the Solicitation, the Department will issue a modification against the Accenture contract if they are a successful offeror. If a BPO contactor receives an award pursuant to the Solicitation, a task order will be issued to the BPO contractor(s) against their Indefinite Delivery Indefinite Quantity (IDIQ) contract.

The BPO contractors and Accenture are the only available resources to do the work within the timeframe required. The identified vendors are familiar with FSA programs and systems. They also meet the system and security requirements including:

a) An ATO to include necessary equipment needed to operate under this effort

b) An ability to access the necessary systems/applications

c) Personnel that can be cleared and training-certified (e.g. performance-ready) by

10/11/2022.

7. Determination of Anticipated Price Reasonableness

The CO will make the final determination after review of this limited competitive action as well as other contact center contracts and GSA schedule prices for proposed labor categories for similar services. This immediate action will result in a firm fixed price contract (i.e., a supplemental agreement and/or new task order award against an existing ED/FSA contract vehicle). The limited source competitors will provide a price for labor and other direct costs.

The CO will determine whether the proposed prices/costs, to include all options, are fair and reasonable.

8. Description of Market Research Conducted

FSA conducted market research by reviewing data and information internally available to the Government to determine the potential sources of additional capacity. FSA determined that the two likely sources of additional capacity were Accenture under the TIVOD contract and the BPO contractors under the current BPO IDIQ contracts.

9. List of Interested Sources for Debt Relief Contact Support Contract

• Accenture Federal Services

• BPO Contractors:

o EdFinancial Services o F.H. Cann & Associates o Maximus Federal Services o Missouri Higher Education Loan Authority

10. Actions to Promote Future Competition

After the 3-to-6-month period of performance, FSA anticipates that the work under this award(s) will transition to the BPO contractors’ existing IDIQ contract(s). We therefore do not anticipate a need for a future competition.

11. Program Office Certification of Accuracy and Completeness

This is to certify that the portions of this justification developed by the undersigned program office personnel, including supporting information and data verifying the Government’s minimum needs, schedule requirements and other rationale for other than full and open competition, are accurate and complete.

Christian Lee Odom, Director Federal Student Aid, Next Gen FSA Program Office

Date

12. Acquisitions Office Certification of Accuracy and Completeness

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Carolyn S. Dickens, Contracting Officer Federal Student Aid, Acquisitions Directorate

13. Approving Official’s Signature

Approved:

Bradley Bumgarner/Executive Director On Behalf of the Competition Advocate Federal Student Aid, Acquisitions Directorate