Attachment_A_-_PWS.docx

Attachment A - Performance Work Statement (PWS)

Department of Education Advisory and Assistance Services For Financial Management and Related Business Process Analysis and Internal Control Work

6/2/2014

SECTION 1: INTRODUCTION

1.1 Background

In 2013, the Department of Education (Department) government workforce totaled approximately 4,200; budgetary resources totaled more than $100 billion; total assets were nearly $1 trillion; and disbursements for grant and loan programs exceeded $200 billion. Most of the Department’s budget authority and disbursements pertain to direct student loans and a myriad of other loan and grant programs. The Department also disburses federal funds for payroll, contracts, interagency agreements, travel, purchase cards, and other purposes. Due to the immense size of financial resources managed relative to the number of government workforce, it is essential that the Department implement and sustain effective, efficient, well-controlled, documented, and expertly managed business processes.

The Office of Chief Financial Officer (OCFO), working with other Department program offices, is responsible for ensuring that staff - using established business processes, internal controls, information technology, and data - collectively deliver program results effectively and efficiently, demonstrate compliance with applicable laws and regulations, and provide stakeholders with timely, accurate, and relevant information to make decisions. OCFO is also responsible for developing a sound internal control framework for Department-wide implementation. As segment owner of the Financial Management Line of Business (FMLoB), OCFO works with stakeholders from across the Department to modernize and enhance the automation supporting business processes. The FMLoB Segment Modernization Plan Goals are as follows:

· Goal 1: Sustain and/or modernize the financial management segment’s integrated hardware, software, and system support

· Goal 2: Optimize utilization of Treasury solutions and shared services (SSP) where feasible[footnoteRef:2] [2: OMB has mandated use of shared services providers for agency financial systems (see OMB Memorandum M-13-08 “Improving Financial Systems through Shared Services,” dated March 25, 2013 (http://www.whitehouse.gov/sites/default/files/omb/memoranda/2013/m-13-08.pdf). The Treasury's Office of Financial Innovation and Transformation will evaluate the Department’s steps to comply with the new directive. ]

· Goal 3: Ensure that IT investments support effective and efficient financial management business processes

· Goal 4: Build analytic capacity to support data-driven decision-making and enhance financial reporting and compliance activities

· Goal 5: Pay Department’s fair share of government-wide costs

· Goal 6: Maximize interoperability between financial Management segment and other Department segments The mission, vision and values of OCFO’s Financial Management Operations (FMO) office are as follows:

Our Mission FMO provides objective financial data and performance information to our stakeholders, promotes sound financial management, and support data-driven decision-making.

Our Vision FMO is an integrated team of talented, accountable professionals who embrace innovation, expertly manage business processes so they are transparent and efficient, and routinely produce timely, accurate, and high-quality products and services that exceed customer expectations.

Our Core Values

· Integrity

· Collaboration and Teamwork

· Respect

· Fairness

· Innovation

· Adaptability

· Stewardship

· Personal Development

Financial management and related business operations in the Department are highly decentralized, with key financial management activities performed outside of OCFO. For example:

· Budget Services performs most budget-related activities including formulation; roll-out; year of execution allocation, execution, and monitoring; credit modeling and related estimates; redistribution of funds; and budget reporting (outside statutory reports). Work done by Budget Services staff drives credit related estimates and disclosures in the financial statements.

· The Department has a relatively substantial information technology portfolio – most of which is managed by the Office of Chief Information Officer (OCIO). OCIO manages and operates financial management and related business systems for the Department, including formulating and executing sustainment costs and enhancement budgets for those systems. OCIO also performs and manages critical financial operations, including: general ledger input and maintenance, disbursements, travel, system security and general/application controls, and interfaces between internal and external systems. Budget formulation and execution of funding should align with the OCFO priorities.

· Risk Management Services (RMS) is responsible for developing grant management policies and identifying and assessing grant-related risks.

· Federal Student Aid (FSA), as a performance-based organization, operates as a semi-autonomous organization within the Department and maintains its own CFO, OCIO, risk management services, and other support staff. Most financial management operations related to student loans are managed by FSA staff.

· Program offices have substantial financial responsibilities related to grants, contracts, human capital, interagency agreements, and related internal controls.

Recent audits and internal assessments of financial management and related business activities indicate that improvements are needed to make underlying business processes more agile, secure, efficient and responsive to customer requirements. Specifically, opportunities exist to: consolidate and/or streamline business processes; make better use of information technology; strengthen internal controls; and improve the capability of the staff to understand financial and performance related data and their ability to perform meaningful analysis and business intelligence and to produce useful, on-demand reports.

1.2 Purpose

The purpose of this procurement is to contract with a qualified contractor capable of assessing the adequacy of the Department’s finance-enabling structures (people, processes, information technology, controls, data, analytics, metrics, policies, and reporting) and making well-researched recommendations to assist the OCFO in building a finance function that aligns with our mission, vision, and values.

1.3 Scope of Work

OCFO seeks to award an advisory and assistance Indefinite Delivery, Indefinite Quantity (IDIQ) contract to a qualified contractor who shall provide high quality financial management support for various financial related studies, quick-turn tasks, business process analyses, internal control assessments and testing, and other activities, as required, to support the OCFO and other offices within the Department in the broad areas of:

· Financial Management and Related Business Process Analysis

· Internal Controls The contractor awarded task orders (TOs) under this IDIQ contract must have expertise and a demonstrated record of success providing advisory and assistance support to federal organizations of the size and complexity of the Department of Education in addressing issues pertaining to the types of work specified below. The scope of the TOs may cover all program offices within the Department.

1.4 Documentation

The contractor shall ensure all required documentation is provided in accordance with applicable Federal or Department regulations/manuals and/or any other specified documentation requirements of individual TOs.

1.5 Security Clearance Requirement

To gain access to the Department’s facilities, programs, and systems the Contractor’s employees and its subcontractor employees are required to obtain a security clearance of no less than 5C level.

1.6 Period of Performance

The contract’s period of performance is expected to last one (1) year with four (4) additional option years. Multiple TOs are expected to be issued during the period of performance of varying timeframes not to exceed 12 months.

SECTION 2: WORK TO BE PERFORMED

2.0 General Business Requirements

The contractor awarded TOs under this IDIQ contract will provide advisory and assistance support and deliverables specified in the individual TOs. In no circumstance will the contractor have final decision authority about any policy, rule or other inherently governmental activity. Final determination and acceptance of all deliverables and work products are exclusively reserved for designated federal employees.

The contractor must collectively possess the experience and capacity to do the type of work called for under this IDIQ contract within an organization of similar size and complexity as the Department of Education. Furthermore, the contractor must perform required tasks as integrated team members (jointly with the Government team, subcontractors, and other contractors as applicable), ensuring an unconstrained flow of information necessary to effectively and efficiently complete TOs requirements within the specified cost and schedule. The type of work anticipated under this IDIQ contract may require the contractor to perform the following types of work.

2.1 Project Management Support. TOs may require the contractor to provide expert project management support pertaining to a single or concurrent TOs. In doing so, the contractor will apply generally accepted industry and/or government program/project management standards to manage work and communicate interim progress throughout the performance period of the TOs. Activities will include: planning and assigning work; integrating work of government staff and other contractors; tracking and reporting project status to government staff using tools such as Gantt charts, project plans and similar documentation; and ensuring all deliverables are completed on time and at an acceptable quality level.

2.2 Financial Management and Related Business Process Management

2.1

2.2.1 Document End-to-End processes. Good business process design is critical to achieving Department program goals and objectives. Many Department business processes are cross-organizational and as such, involve business activities performed by multiple Department offices, FSA, and service providers. Initial process mapping has been completed for many key “as-is” financial and related business activities and will be furnished to the contractor at the start of each TO. The contractor will leverage existing documentation and add to it (based on individual task order requirements) rather than re-create it. The objective of the process documentation is to identify additional details about key activities within the scope of the TO, who performs them, and how they are performed. The contractor will expand existing documentation to ensure that it includes: all Key Business Activities (KBAs) covered by the TO, responsible organizations and people (including service providers and external parties) performing the activities, key controls (manual and automated), data sources, applicable automated systems/applications, data flow, and dependencies on other Department offices and external organizations. The contractor will include all necessary flow diagrams, narratives, and other documents to fully depict “as-is” and/or “to-be” end-to-end processes and parts of processes covering relevant financial management and business activities

2.2.2 Process Analysis. The Department must continuously improve and adapt its business processes to meet new requirements such as shared services, the Data Act, and other changes in the ever changing Federal landscape. The business processes must be effective, efficient and agile enough to respond to change and deliver more accurate and timely information and to support decision making. The contractor will assess end-to-end processes to identify leading practices and potential deficiencies such as:

· Areas of potential non-compliance with Federal laws and regulations and/or Department policies;

· Inefficient, over controlled, overly complex and/or manual processes;

· Missing KBAs and/or essential controls;

· Undefined or ill-defined process ownership responsibilities;

· Workflow and management oversight issues to include insufficient or unsuitable performance metrics to manage and monitor work;

· Lack of access to data, unstructured, or poorly defined data that hinders report preparation, analysis, and/or the ability of OCFO to produce quality work products, including financial reports;

· Over-reliance or dependency on other offices to perform key financial management business activities or to obtain financial management data;

· Resource issues, including staff capabilities and over or under staffing of critical financial related activities; and

· Organizational, legal, or policy impediments impacting the capability of Department staff to efficiently perform KBAs.

2.2.3 Process Improvement Recommendations. Once issues (both positive and negative) are identified through a thorough analysis of “as-is” business processes, the contractor will make written recommendations to improve the selected processes through multiple feasible options for potential a future “to-be” state. The contractor will assist Department staff plan, coordinate, report, monitor and follow-up activities related to process improvements. The contractor will develop necessary business cases, briefing material, communication plans, and other documents needed to help government staff define the “to-be” state of end-to-end business processes/activities and to articulate to decision makers the need for and the value proposition of recommended changes. The contractor will benchmark best practices and apply applicable frameworks and standards to help the Department build to the best possible solution. Recommendations for process improvement are intended to:

· Bring Department into compliance with relevant laws and regulations;

· Eliminate inefficiencies and non-value added KBAs, such as manual, over-controlled, and overly complicated processes;

· Add missing KBAs or essential internal controls;

· Define roles and responsibilities of each office involved in the KBAs;

· Improve workflow and performance management with suitable metrics;

· Streamline, simplify, standardize, consolidate, and/or shift workload between organizations and/or within business units;

· Standardize common business processes, to the extent, feasible, through consolidation of activities and automation;

· Align business processes to the best practices that exist in the Federal government or suitable private industry models;

· Improve access to and the quality of financial data;

· Better utilize or increase staff productivity training and/or more efficient workflow;

· Remove policy and/or organizational impediments to effective and efficient financial management activities;

· Improve the quality of work products to increase customer satisfaction;

· Identify methods to obtain data to needed to perform analytics and improve reporting; and

· Improve the quality of the reports.

2.2.4 Modernize and Enhance FM Automation. In accordance with the FMLoB segment modernization plan, the Department intends to integrate information technologies to support comprehensive management of business processes and activities. The contractor will assist Department staff in:

· Building interfaces between Department and Treasury systems;

· Automating manual procedures and data interchange;

· Identifying and building the capacity to meet the requirements of the Data Act pertaining to all types of ED disbursements;

· Leveraging other Department-owned software and applications to improve and/or standardize financial management and related business activities;

· Identifying other tools used by other Federal agencies that can be implemented at Department; and

· Leveraging knowledge management and records management tools to move paper records into digital format.

2.2.5 Optimize Utilization of Treasury and Shared Service Solutions. In accordance with OMB direction, the Department plans to consider whether shared services solutions are feasible to meet Department financial management and other business objectives. The contractor will assist the Department in exploring opportunities do things such as:

· Supporting on-going efforts to either upgrade to Oracle financials version 12 or to migrate to a shared service provider in accordance with the OMB/Treasury OFIT requirements;

· Identifying potential business process, policy, system, and/or organizational impediments that may impact realizing the intended benefits of shared service solutions;

· Identifying opportunities for the Department to realign and/or standardize its business processes, organizational structure, or operating philosophy/internal policies to be more in line with the best practices of existing shared service providers or an applicable best practice model in industry;

· Assessing ED’s current and planned use of shared services and making recommendations for improvement; and

· Evaluating the existing governance structure and service agreements (i.e. Memorandums of Understanding or MOUs) with shared service providers against applicable best practices and making recommendations for improvement.

2.2.6 Policy and Procedures. OCFO intends to create an integrated set of internal policies and procedures that align with end-to-end process documentation, ensure compliance with applicable laws and regulations, and enhance transparency and knowledge management over key business processes. The contractor will assist the Department staff:

· Identify areas where Department directives and other internal policies and procedures do not comply with applicable Federal laws and/or regulations and make recommendations for improvement;

· Identify potential legal or regulatory impediments contained in Department internal policies and procedures precluding effective and/or efficient financial operations and make recommendations to address them;

· Ensure that OCFO policies and procedures align with the end-to-end process mapping documents; and

· Identify opportunities to leverage technology to best align and integrate policy, process, system, and controls documentation within a Knowledge Management or related automated tool.

2.2.7 Key Performance Indicators (KPIs) and Metrics. OCFO seeks to develop well-controlled business processes that are managed and performance tracked using KPIs and other suitable metrics. The metrics are intended to inform OCFO leadership and stakeholders, monitor and allocate work, identify potential bottlenecks, promote sound financial management, support data-driven decision making, and related activities. The contractor will assist the Department staff as follows:

· Identifying opportunities to integrate pertinent KPIs and other metrics into the workflow of key business processes to help monitor performance;

· Benchmarking current performance against federal standards and best practices;

· Identifying opportunities to leverage technology to support performance management; and

· Helping to align FM operations to achieve the goals of the Government Performance Results Modernization Act (GPRMA) and align with the Department’s Strategic Plan, and underlying goals and objectives.

2.2.8 Workforce analytics. OCFO has made it a priority to build staff capabilities to help achieve its vision of an integrated team that embraces innovation and expertly manage business processes that routinely produce timely, accurate, and high-quality products and services. The contractor will perform workforce analytic tasks to assist Department staff in:

· Identifying unnecessary steps or inefficient work methods;

· Identifying the most efficient methods to perform key KBAs;

· Determining the number of staff and the appropriate skills and grade level required to perform KBAs effectively and efficiently;

· Identifying key positions and at risk of staff loss through attrition and developing strategies to address them;

· Determining the full range of skills needed to perform effectively in a more highly automated and complex “to-be” OCFO environment;

· Building a comprehensive career ladder progression plan that includes staff development and training plans to prepare staff for more complex financial management tasks; and

· Recommending suitable performance requirements and measurements for use in evaluating staff performance commensurate with grade.

2.2.9 Data Analytics. The OCFO intends to build staff capacity to perform significantly more complex financial analysis to support decision making. The contractor will support Department staff by:

· Identifying analytic requirements of OCFO internal and external stakeholders through customer surveys, benchmarking, and other means;

· Benchmarking other Federal organizations to identify leading practices related to performing financial analysis and using business intelligence tools;

· Determining the data required to perform analysis across all major financial management business processes and sources and methods of data extraction;

· Performing specific data analytic related tasks and helping to transition the work to OCFO staff;

· Identifying appropriate tools and methods of performing financial analyses, to include making maximum use of existing Department analytic tools used by other offices or organizations; and

· Determining how best to leverage the resources, data, and people from other Department offices (such as OCIO and RMS), automated systems, and from shared service providers to support financial analysis requirements.

2.2.10 Enhance Financial Reporting. The OCFO intends to build the capacity to routinely produce timely, accurate, and high-quality financial reports and other products that exceed customer expectations. The contractor will assist Department staff by:

· Taking an inventory of all financial reports mandated by external stakeholders, requested by internal stakeholders, or otherwise routinely produced by the OCFO and determining why the reports are being produced and who consumes them;

· Determining the financial reports produced by other Department offices, including OCIO and Budget Services;

· Determining if any of the reports should no longer be produced or can be consolidated or modified to provide more useful information;

· Assessing the efficiency of the processes used to compile reports and the accuracy of data reported;

· Through benchmarking, customer surveys, and other suitable methods, develop of listing of the current reports that should be sustained, other types of reports typically produced by OCFOs across the federal government and should be produced by the ED OCFO staff, and reports Department customers indicated that they want or need;

· Determining the data sources and most efficient compilation methods to producing reports, including expanding the capacity of the staff to obtain the data and increase their capacity to produce ad-hoc reports across the multiple financial management business processes;

· Helping to improve the quality of the form, content and disclosures in the Annual Financial Report (AFR) and other statutory financial reports; and

· Improving results reflected in Treasury and other internal or external dashboards and scorecards.

2.3 Internal Controls

Consistent with requirements of the Federal Managers’ Integrity Act (FMFIA) of 1982, Federal Financial Management Improvement Act (FFMIA) of 1996, OMB Circular A-123, and other relevant criteria, the contractor shall assist Department staff to build, sustain and manage a sound Department-wide internal control framework. That framework should incorporate key aspects of Enterprise Risk Management (ERM) concepts derived from applicable commercial and federal models.

In 2014, the OCFO developed a high level framework for Internal Controls over Financial Reporting (ICOFR). That strategy focused initially on identifying significant end-to-end business processes that underlie the amounts reported on the financial statements and identifying key controls, determining where those controls reside, and identifying who manages them. As indicated previously, the Department’s financial and related business operations are highly decentralized, with critical financial management functions managed and performed outside of the OCFO. Accordingly, key financial controls have been designed, built, and put in operation by offices outside of OCFO. However, the OCFO is required to assist the Secretary of Education assert on the effectiveness of controls over financial reporting. As such, the OCFO must build a more robust internal control framework that accounts for the decentralized organizational structure of the Department and its dispersed financial management functions. The type of work to be performed is outlined below.

2.3.1 Build an Overall Internal Control Framework. The OCFO intends to build a comprehensive internal control framework that considers: the size and scope of Department operations (including FSA), the organizational structure and management culture of ED, level of automation, and other relevant factors. The internal control framework shall be aligned with, to the extent possible, applicable ERM concepts adopted by the federal government and/or benchmarked against applicable industry standards. Because ERM has not been fully embraced within the Department and not mandated within the Federal government, work will be geared towards making incremental progress towards building an internal control structure that fully integrates with a Department-wide ERM model should one be developed and considers ERM concepts in assessing risks in the relevant financial management business processes. Tasks in this area include:

· Development of a controls framework that incorporates ERM concepts such as the Committee of Sponsoring Organizations of the Treadway Commission (COSO) and International Organization of Standardization (ISO) standards, and/or applicable federal standards and identifying enterprise risks applicable to financial management and related business practices;

· Assessment of recent OMB and other work related to ERM, including requirements incorporated in OMB Circulars and GAO publications;

· Alignment of Department business processes with those established by FSA at a high level to better integrate and align business processes and controls within a Department-wide framework; and

· Development and implementation of change management strategies.

2.3.2 Align Internal Controls to Process Maps. The contractor will assist Department staff in ensuring that end-to-end process documentation and narratives pertaining to the financial management and related business processes adequately identify all relevant internal controls. The contractor will validate the completeness of the controls by mapping them to key financial events that trigger financial transactions reported in the financial statements or that support key estimates or other disclosures. Tasks in this area include production of a controls catalog listing that defines key controls and provides relevant information about each control.

2.3.3 Risk Assessments. The contractor will assist Department staff determine the enterprise risk factors, financial reports, materiality thresholds, and related factors to assess the risk of significant financial statement accounts and their underlying business processes. Risk assessments will consider both qualitative and quantitative factors. The contractor will perform a risk analysis of all key financial management controls in the Department (except FSA), including an analysis of planning materiality levels and recommend the priority and frequency of testing. As part of the assessment, the contractor will gain an understanding of the control environment of the Department, the decentralized FM functions, and related risk factors that may impact financial reporting. The contractor may be required to:

· Coordinate (to the extent practicable) with the Office of the Inspector General (OIG) and their external auditor on matters pertaining to internal controls;

· Work with the internal controls team at FSA to align work to the extent possible; and

· Engage the Department’s senior leadership and management in discussions about risk and risk mitigation strategies.

2.3.4 Assessments of Control Design. Key internal controls concepts include things such as authorization, segregation of duties, application controls, and auditability. The contractor will assist Department staff in improving the design of such controls, with emphasis on making them more effective and efficient, based on preventing negative events as opposed to detecting them after the fact, and leveraging technology, such as continuous monitoring techniques, to the maximum extent practical. The contractor will assess control design against applicable standards and/or benchmarks and provide recommendations for improvement. TOs will include things such as:

· Identifying potential duplication, overlap, or missing controls or where there are concerns associated with the organizational placement of responsibility for a key financial control;

· Identifying ways to automated controls, to the extent possible; and

· Identifying poorly designed or documented controls that may jeopardize Department’s ability to operate in a timely, efficient manner and may result in such negative consequences as:

· loss of assets and resources;

· intentional errors, illegal acts, or unauthorized use of resources;

· unintentional errors, inefficiency, or waste;

· mismanagement;

· loss of consumer confidence;

· erroneous reporting of information;

· failure of the Department to meet and certainly exceed management objectives;

· failure to follow management decisions and policies;

· failure to meet regulatory requirements; and

· reportable conditions identified in outside audits and reviews.

2.3.5 Controls Testing. Testing internal controls is intended to collect sufficient, competent evidence to provide reasonable assurance that the controls are in place and working as intended. The contractor will take a risk based approach to testing and create and/or validate existing test plans to test internal controls over financial reporting that meet the guidelines provided in OMB Circular A-123, Appendix A and other applicable standards. Testing areas may include:

· Manual controls,

· General computer application controls,

· Computer application controls,

· Credit modeling and other accounting/budget estimates,

· Journal Voucher and other accounting adjustments,

· Formula and discretionary grant compliance,

· Testing for compliance with other applicable laws and regulations, including improper payments.

There will be three (3) potential service levels of testing provided in TOs issued under this IDIQ contract:

Testing levels

“Bronze”

· Minimum testing; Higher risk processes will be selected based on results of Risk Assessment. Testing will consist primarily of interviews and walk through procedures, with some additional procedures for high risk controls.

2.3.6 Corrective Action Plans. The contractor will assist Department staff in preparing corrective action plans to remedy identified deficiencies and to help build a more automated and robust internal controls program, with particular attention paid to strengthening the five interrelated components of internal control:

· Control Environment: The control environment sets the tone of an organization, influencing the control consciousness of its people. Control environment factors include the integrity, ethical values, and competence of the organization’s people; management’s philosophy and operating style; the way management assigns authority and responsibility, and organizes and develops its human resources; and the attention and direction provided by the board of visitors.

· Risk Assessment: Every organization faces a variety of business risks from external and internal sources that must be assessed. A precondition to risk assessment is establishment of objectives, linked at different levels and internally consistent. Risk assessment is the identification and analysis of relevant risks that may prevent the achievement of established objectives.

· Control Activities: Control activities include policies and procedures implemented by management to ensure management directives are carried out to meet organizational objectives. They are designed to address risks that could prevent achieving the organization’s objectives. Control activities occur throughout the organization, at all levels and in all functions. Each department is unique, and only the most basic of control activities are specifically outlined in university policy and procedures. The department head is responsible for identifying other appropriate control activities to address the unique risks to which his or her department may be exposed.

· Information and Communication: Pertinent information must be identified, captured, and communicated in a form and time frame that enables people to carry out their responsibilities. Effective communication also must occur in a broader sense, flowing down, across, and up the organizational structure. All personnel must have a means of communicating significant information upstream. The Department must also effectively communicate with external parties, such OMB and Treasury.

· Monitoring: Effective monitoring is a process that assesses the quality of the system’s performance over time. It includes the regular management and supervisory activities as well as separate evaluations by central units, Internal Audit, or other independent parties.

· Corrective action plans: Corrective action plans will be developed in response to deficiencies or improvement opportunities identified through process analysis, internal control testing, and/or external audit.

2.3.7 Statement of Assurance Process. In accordance with OMB Circular A-123, agencies must report annually on internal control through management assurance statements. The quality of those reports depends on the level of reviews and accuracy of reporting done at the program office level. The contractor will assist Department staff to:

· Help program offices to understand what responsibility they have for key financial management and related business activity controls;

· Consolidate input from multiple process owners throughout the Department needed to provide reasonable assurance that internal controls over financial reporting are in place and operating effectively;

· Provide recommendations to improve the quality of the information provided by the program offices, to include modified statement of assurance letters and more reliance on external audits and other reviews;

· Assist Department staff in producing the annual Statement of Assurance with respect to Internal Controls over Financial Reporting, included in the Department’s Annual Financial Report (AFR); and

· Provide recommendations to improve disclosures in the AFR.

2.4 Deliverables

2.4.1 Format. The contractor must complete deliverables in the approved format and provide them to the Program Manager and COR. Required deliverables shall be specified in individual TOs; however, the content of all deliverables shall be clear, concise, complete, accurate and relevant; void of spelling and mathematical calculation errors; and grammatically correct. The contractor will prepare a work plan to include dates of completion for PM/COR approval.

· Regularly Scheduled Deliverables:

· Weekly activity and work status report

· Non- regularly Scheduled Deliverables:

· Ad hoc reports as requested by management within one week of request. If the report cannot be produced within one week, it must be provided within a reasonable time as determined by management

· All deliverables must be completed by the end of the performance period If the government requests the contractor to use specific templates, logos, branding or other formats in deliverables required to be submitted, the government is responsible for providing these items to the contractor.

SECTION 3: STAFFING AND RESPONSIBILITIES

3.1 Government

3.1.1 Government Staffing

The project and all individual TOs will be overseen by the DCFO for financial management and a designated Contracting Officer’s Representative (COR). These Federal resources will be responsible for managing and coordinating all activities across the Department.

The Department’s business units have identified resources to serve as technical experts and business process representatives to facilitate documentation and assessment efforts, and to represent the business units in making decisions and approving work products.

3.1.2 Government ownership of information

Ownership of information and documents prepared in accordance with this contract shall become and remain property of the government. The safeguarding of all the Department’s systems and data as well as all employee personal property security is the responsibility of the Contractor. The contractor will provide all completed work related to TOs under this contractor to the designated Department officials in the format prescribed.

3.2 Contractor

3.2.1 Contractor Staffing and Qualifications

OCFO requires expert assistance related to financial policy and procedures, research and analysis, business process improvements, financial statement analysis, financial reporting support, and other related efforts. It is essential that the contractor work collaboratively with Department staff, its subcontractors, and other contract teams to facilitate the free flow of information.

Work pursuant to TOs issued under this IDIQ contract requires that the contract team has knowledge about government business processes, especially pertaining to grants, loans, contracting, personnel, leases, and interagency agreements. Additionally, the Department is highly dependent on automation and as such, the contractor s must have experience working in a highly automated environment, and be familiar with the capabilities of Oracle financials. All proposed staff should have strong Federal financial management knowledge and experience in areas outlined in this PWS and the individual TOs. Requisite skills include a strong understanding of federal financial management laws and regulations, federal proprietary and budgetary accounting, financial reporting, federal system requirements, and internal control requirements. Requisite skills also include demonstrated proficiency in federal financial statement audits, financial analysis, system testing, and internal control reviews.

The contractor shall have a demonstrated core competency in project management with the proven ability to manage large, complex engagements. Other team or functional leads shall have demonstrated core competencies in the areas for which they are responsible, including experience with financial business process engineering and expertise in internal control requirements at the Federal government level.

The contractor shall include a staffing structure and organizational matrix detailing proposed team roles and responsibilities by PWS tasks, with qualifications of proposed staff. The plan shall identify key personnel at the project or Program Management Office (PMO) level, at the quality control manager level, at the team lead/manager level for all teams, and for subject matter experts.

3.2.2 Contractor Staff Responsibilities

The staffing plan shall define the roles and responsibilities for the contractor staff and shall include details of the work to be performed by the proposed labor category.

The Contractor shall submit eQIP initiation forms for all proposed and new staff to the COR by 10am on the 1st business day after contract award. Upon notification from the COR, the Contractor staff shall complete the Security Clearance package on-line via eQIP (http://www.opm.gov/e-qip/)) and submit all signature pages, fingerprint cards, EDNET forms, Account Request Forms to the COR within 8 business hours. The Contractor shall email confirmation to the COR and Program Manager by 5pm on the day the security requirements are completed that certifies that:

a. The eQIP initiation form was submitted to the COR by 9am on the 1st business day AND The Security Clearance package was electronically completed via eQIP and all signature pages and Account Request Forms were submitted to the COR within 8 business hours of notification from the COR.

b. The Contractor shall complete the Department’s required training when notified to do so by the COR. The Contractor shall complete the Department’s annual IT Security Awareness and Privacy training.

3.2.3 Other

3.2.3.1 Status Meetings

Status meetings between the Contractor and Program Manager and/or COR will be held on weekly basis or as required by individual TOs. At least one business day (24 hours) in advance of each status meeting, the Contractor shall provide a proposed written briefing agenda to the Program Manager, preferably via e-mail. At a minimum, the agenda shall include the following:

· The time, date, and location of the meeting;

· The results of work performed since the last status meeting;

· Outstanding documentation requests;

· Problem areas/potential delays; and

· Planned areas/work to be completed by the next status meeting.

3.2.3.2 Progress Reports

Progress reports shall be provided electronically in Microsoft Word to the FMO Project Manager, COR, and Contracting Officer every Wednesday beginning one week after the date of award, or as specified in the individual TOs. The report shall contain all relevant activity completed in the previous week and work planned in the upcoming week. The report shall contain a section of accomplishments by task, planned activities by task, project risks, status of deliverables by task including delivery dates and completion status. Any concerns and/or potential issues that may impact meeting a deliverable date or interim milestone should be raised immediately at the status meeting for resolution.

3.2.3.2 Communication

The contractor shall anticipate having to coordinate, collaborate and effectively communicate with multiple Department stakeholders and other interested parties. The contractor will be encouraged to apply high quality teaming practices and openly, honestly and accurately communicate and actively working to build and maintain trust, with other Department team members and interested parties.

3.2.3.4 Compliance with ED IT Security Policy

Please see Appendix B.

SECTION 4: Laws and Regulations

4.1 Basic Requirement. It is expected that the contract team will possess expert knowledge of all pertinent laws and regulations pertaining to Federal government financial management operations, including those pertaining to performance management and financial management systems. Additionally, the contractor will be expected to research and identify specific laws and regulations that pertain to the Department of Education and/or relate to requirements in the specific task orders.

4.1.1 Key Laws and Regulations. The following list contains many of the key provisions of Federal laws and regulations that will be relevant to the task orders.

General Laws

· AntiDeficiency Act (codified as amended in 31 , U.S.C. 1341, 1342, 1351, 1517).

· Prompt Payment Act (codified as amended in 31 U.S.C. 3901-3907)

· Pay and Allowance System for Civilian Employees as provided primarily in Chapter 51-59 of title 5, United States Code

· Federal Credit Reform Act of 1990, Pub. L. No. 101508, 104 Stat. 1388610 (codified in various sections of 2 U.S.C.)

· Provisions Governing Claims of the United States Government as provided primarily in sections 3711-3720E of Title 31, United States Code (including provisions of the Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321-1358, which also is codified in various sections of 5 U.S.C., 18 U.S.C., 26 U.S.C., 28 U.S.C., 31 U.S.C., 42 U.S.C.)

Based on materiality levels established for the FY13 audit of the Department’s annual financial statements, the external audit firm, using the General Compliance Checklist in the GAO/PCIE FAM §802, determined that the following general laws were significant to ED and FSA:

· Federal Credit Reform Act of 1990, Pub. L. No. 101508, 104 Stat. 1388610 (codified in various sections of 2 U.S.C.)

· Provisions Governing Claims of the United States Government as provided primarily in sections 3711-3720E of Title 31, United States Code (including provisions of the Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321-1358, which also is codified in various sections of 5 U.S.C., 18 U.S.C., 26 U.S.C., 28 U.S.C., 31 U.S.C., 42 U.S.C.)

· Elementary and Secondary Education Act (ESAE)

· Higher Education Act (HEA) including Amendments of 1992, 1993 and 1998.

· Title 34 CFR Parts 74-86 and 97-99 Education Department General Administrative Regulations (EDGAR)

· American Recovery and Reinvestment Act

· Title I Improving the Academic Achievement of Disadvantaged

· Title II Americans with Disabilities Act

· Title III Strengthening Institutions

· Title IV Federal Student Assistance Programs Additional laws that are relevant by reference in OMB Bulletin No. 07-04 or other documents that 1) ED is required to comply with and 2) where noncompliance with these identified laws could have a direct and material effect on the financial statements include:

· Government Performance and Results Act of 1993

· Government Management Reform Act of 1994

· Clinger-Cohen Act of 1996 (see the FFMIA and EDP audit programs)

· OMB Circular A-127 – Financial Management Systems

· Federal Managers Financial Integrity Act of 1982

· Federal Financial Management Improvement Act of 1996 (FFMIA)

· Federal Information Security Management Act of 2002

· Improper Payments Information Act of 2002

· Cash Management Improvement Act of 1990

· Single Audit Act

· Pay and Allowance System for Civilian Employees as provided primarily in Chapters 51-59 of Title 5, United States Code.

Appendix A

In 2014, the Department identified eight (8) significant business processes that underlie the financial statements:

Payroll processing

Personnel hiring and terminating

Payroll reconciliation

Appendix B

Compliance with ED IT Security Policy The contractor, and all sub-contractors, shall comply with the Department of Education’s IT security policy requirements, specifically those set forth in the ‘Handbook for Information Assurance Security Policy (OCIO-01)’, and other applicable procedures and guidance. The contractor, and all sub-contractors, shall develop and implement management, operational and technical security controls to assure required levels of protection for information systems. The contractor, and all sub-contractors, shall further comply with all applicable Federal IT security requirements including, but not limited to, the Federal Information Security Management Act (FISMA) of 2002, Office of Management and Budget (OMB) Circular A-130 Appendix III, Homeland Security Presidential Directives (HSPD), the National Institute of Standards and Technology (NIST) standards and guidance, and the Federal Risk and Authorization Management Program (FedRAMP) requirements and guidance.

These security requirements include, but are not limited to, the successful Security Authorization (SA) of the system (includes commercially owned and operated systems managed by the commercial vendor and its sub-contractors, supporting Department programs, contracts, and projects); obtaining a full Authority to Operate (ATO) before being granted operational status; performance of annual self-assessments of security controls; annual Contingency Plan testing; performance of periodic vulnerability scans; updating all information system security documentation as changes occur; and other continuous monitoring activities, which may include, mapping, penetration and other intrusive scanning.