Attachment_C_-_PWS_for_TO_01.docx

Attachment C – PWS for Task Order 0001 Assessment of Debt Management Activities

1. Introduction The Office of Chief Financial Officer (OCFO), working with other Department of Education (the 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 internal and external stakeholders with timely, accurate, and relevant information to make decisions. The OCFO is also responsible for developing a sound internal control framework for Department-wide implementation that incorporates relevant elements of enterprise risk management principles. As segment owner of the Financial Management Line of Business (FMLoB), OCFO works with stakeholders from across the Department to ensure information technology investments support effective and efficient financial management business processes and maximize interoperability between financial management and other Department business operations.

In 2013, the Department’s 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 related expenses. At times, some of the funds disbursed must be collected from recipients and that requires program offices to establish debt related activities make the collections.

2. Background The need to collect administrative debt is triggered by 1) the actions of grant-making and other program offices or 2) action or inaction taken by recipients of Department payments. Sources of administrative debt that must be collected includes improper payments, judgments, grantees or employees not meeting terms of agreements, and payments made by the Treasury Judgment Fund. The Department generally collects debt through various methods, including grant and salary offsets, and collections by the Department or Department of Treasury staff. Currently, debt-related business activities at the Department are decentralized, use manual procedures, and are not managed as an end-to-end business process. As a result,

· Information about debt identified by the program offices, referred for collection, collected through offsets (and other means), or not pursued at all is not readily available;

· Program offices manage debt-related activities autonomously although they perform similar activities;

· Technology and applications supporting debt management activities are not consistently available;

· Information related to debt does not flow seamlessly between systems through automated data interchange;

· Record-keeping and maintenance of data needed to track program compliance is often not sufficient to substantiate a debt collection; and

· Information demonstrating that a grantee met the terms and conditions of the grant agreement is not consistently maintained, leading to some improper debt collection actions against people who have properly discharged their responsibility under the terms of the grant.

These conditions raise risks and concerns about the following:

· Non-compliance with debt management laws, regulations, and provisions of grant terms and conditions;

· Inequitable treatment of grant recipients, with collection practices not applied equally among recipients (collections pursued against some, but not others);

· Collection activities taken improperly against grantees who fulfilled their obligations;

· Inaccurate financial records, such as overstated accounts receivable; and

· Potential reputational risk to the Department related to debt management issues.

The OCFO is responsible for collecting debt referred to it by the program offices and therefore, depends on the accuracy of records maintained by those offices. OCFO is moving to a shared service model, where debt is transferred to the Department of Treasury for collection. As such, one of the key objectives of this task order is to help the Department identify opportunities to realign business processes, organizational structure, or operating philosophy/internal policies and to leverage our Oracle financial system capabilities to the maximum extent possible to be more aligned with a shared service provider model.

3. Scope of Services The purpose of this task order is to obtain advisory and assistance services from a highly-qualified contractor team to identify, document, and fully assess all debt-related activities within the Department (except for direct student loans processed by Federal Student Aid – (FSA)) and to make recommendations to better integrate them into well-controlled, efficient, and effective end-to-end business processes, supported by technology. The desired objectives of the task order are 1) to obtain documentation, recommendations, and other related information to enable the Department to take appropriate actions to address deficiencies in current business processes and related controls and 2) to assist the Department in better managing and accounting for debt-related transactions by leveraging the capabilities of our Oracle financial system and utilizing the capabilities of shared service providers. This includes identifying specific methods to leverage automation and integrate business processes from grant award through collection into a seamless, end-to-end debt management process. To accomplish the work required under this task order, the contractor will work with the OCFO and multiple program offices, including the following:

· The OCFO Debt Payment and Management Group (DPMG) and accounts receivable team;

· Grant-making offices, including those that refer debt to OCFO and those that take collection action through other means, such as offsets;

· The Human Capital and Client Services (HCCS) Office for pay-related debt;

· The Office of Inspector General (OIG) for debt generated from audits and investigations including restitution debts;

· The United States Department of Justice (DOJ) Financial Litigation Units– for restitution proof of debt and debt collection activities;

· Office of the Administrative Law Judges and Hearings and Appeals;

· The Office of General Council (OGC) – for debt laws and regulations and ED implementation of them;

· The Office of the Chief Information Officer (OCIO) – for all system-related information, including how data flows between systems, where debt-related data resides, and for cost related data to improve technological support;

· The Financial Improvement and Post Audit Operations Division (FIPAO) - for debts generated from audits and program reviews;

· FSA School Eligibility Channel and the Internal Control Division – for audit and program review related debts;

· Department Grantees - data flow pertaining to debt-related activities and between grant making offices and the grantees; and

· U.S. Department of Treasury – shared services related to collection activities.

Grant-making entities within the Department that have historically referred debt to OCFO are determined by authorized officials within Department Program Offices (POC) as provided in the regulations issued for programs authorized under the Higher Education Act of 1965, as amended, and the General Education Provisions Act. The following five (5) program offices refer the majority of debt for which DPMG establishes receivables:

1. Office of Elementary and Secondary Education

2. Office of Vocational and Adult Education

3. Office of Special Education and Rehabilitative Services

4. Office of English Language Acquisition

5. Impact Aid

4. Requirements The contractor will assist Department staff identify, plan for, and implement changes needed to consolidate and/or streamline business processes, make better use of information technology, strengthen internal controls, provide for greater ad-hoc reporting and analysis capacity, and improve the capability of staff related to their understanding of debt-related activities, data sources for debt-related activities, and methods to improve analysis.

1 Task 1 – Project Management Support – The contractor will provide expert project management support associated with this task order. The contractor will apply generally accepted industry and/or government program/project management standards to manage work-related to completing the deliverables outlined below and to communicate interim progress throughout the performance period of the task order. Activities will include planning and assigning work, integrating the work of government staff and other contractors, tracking and reporting project status using tools such as Gantt charts, project plans and similar documentation, and ensuring all deliverables of completed on time and at a quality level acceptable to designated Department staff.

Task 1 Deliverables:

1.1 Project kickoff meeting – The contractor will conduct an initial project kickoff meeting to plan for and ensure that the contractor and government agree on the requirements of this task order. The contractor will provide the Contracting Officer’s Representative (COR) with an agenda for the initial planning meeting at least three (3) days prior to the meeting.

1.2 Schedule of deliverables – The contractor will provide, at the kickoff meeting, specific calendar dates to meet the deliverable schedule set forth in Section 6. Alternatively, the contractor may propose changes to dates and to consolidate deliverables to reduce duplication. That proposal, however, shall not request a reduction in any of the work called for in this task order. Upon approval by the COR, the revised schedule of deliverables will replace the one included in Section 6 and become binding.

1.3 Meeting minutes - The contractor will provide proposed meeting minutes documenting major decisions made at the kickoff meeting to the COR within two (2) days after the planning meeting. The COR will approve the minutes within two (2) days after receipt.

1.4 Project work plan - The contractor will submit a proposed project work plan to the COR no later than four (4) weeks after the kickoff meeting. The COR has one (1) week to review and provide edits. The work plan will include all key tasks and milestones needed to deliver all task order requirements on time and include metrics to demonstrate interim progress towards final deliverables. The project work plan will be built to ensure timely submission of work products in accordance with the approved schedule of deliverables.

1.5 Weekly status meetings - The contractor will participate in weekly status meetings with the COR and other pertinent Department staff. Status reports shall include a summary of work completed in the last week and what work is planned for the upcoming week. Updates will be provided on the progress being made against all deliverables. Any concerns and/or potential issues that may impact meeting a deliverable date or interim milestone shall be raised immediately at the status meeting for resolution.

2 Task 2 – Document End-to-End Processes. Debt-related activities are performed across multiple organizations in the Department. Initial process mapping has been completed for many key debt-related “as-is” business activities and that documentation will be furnished to the contract team at the kickoff meeting. There are also relevant audit reports pertaining to debt management practices in the Department. The contractor will leverage existing documentation and add to it rather than re-create it. The objective of this task is to identify all key debt-related activities wherever they reside to enable Department staff to gain visibility into what the debt-related activities are, who performs them, and how they are performed. The work required in the remaining tasks is intended to help the Department staff assess how well those activities are being performed and make recommendations to improve them.

Task 2 Deliverables:

2.1 “As-Is” End-to-End process documentation - The contractor will expand existing documentation to ensure that it includes all debt-related Key Business Activities (KBAs), responsible organizations and people (including service providers and external parties) performing the activities, key controls (manual and automated), data and its sources, applicable automated systems/applications, data flow, and dependencies on other Department offices and external organizations. Process documentation will cover debt generated from grants and other types of payments such as civilian payroll, contracts, travel, and other activities where the Department spends federal dollars and is required to collect some funds back. The scope of the task order does not include student loan debt collections that are part of the routine business of FSA, but will include debt that is referred to OCFO and/or Treasury by FSA. 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 debt-related activities.

3 Task 3 – Process Analysis. The contractor will perform a comprehensive review of relevant laws, regulations, and Department policies related to debt management activities to understand the Department’s compliance requirements. The contractor will then assess how debt related activities are conducted in the Department and compare them against the applicable legal and regulatory criteria and suitable Federal best practices and other benchmarks to identify leading practices and opportunities for improvement. The contractor will consider known and suspected issues/concerns by reviewing Inspector General and General Accountability Office (GAO) reviews, internal assessments, and by interviewing relevant staff. Work will be geared towards identifying leading practices as well as deficiencies like the following:

· 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 over-dependency on other offices to perform key financial management activities related to debt collection;

· Use of legacy systems to manage activities that can be integrated into the Oracle financial system;

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

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

Task 3 Deliverables:

3.1 Compendium of laws, regulations, and policies – The contractor will prepare a compendium listing relevant laws, regulations, and policies that pertain to debt management activities in the Department, including legislation that is specific to the Department grant and loan programs. The compendium will include the criteria listed in Section 5 and others identified through independent research, benchmarking against other federal organizations, and from consultation with Department General Counsel and others. The compendium will include any new debt related requirements mandated by the new Office of Management and Budget (OMB) grant “super circular.” The compendium will include a brief summary of why each law, regulation, and/or policy is applicable to the Department in discharging its’ debt management responsibilities and a brief description of what those responsibilities are. The compendium will also include other relevant information related to debt collection, including things such as statutes of limitation for debt collection action and provisions of legislation that restrict the Department’s ability to collect debt.

3.2 Compendium of previously-identified issues covering last 5 years - The contractor will prepare a compendium covering previous audit reports, program reviews, internal control assessments, and other sources identifying known issues related to debt management practices within the Department. The compendium will include known and suspected problems and/or concerns that are either documented or gleaned through interviews with key staff.

3.3 Assessment Report – The contractor will prepare a written report comparing the “as-is” environment within the Department against applicable laws and regulations and other suitable metrics to identify leading practices implemented in the Department as well as areas for improvement such as those listed above. The assessment report will include FY2014 data to baseline the amount of debt identified and collected across all Department programs. Deliverables 3.1 and 3.2 shall be included as appendices in the final assessment report.

4 Task 4 - Process Improvement Recommendations. Using information collected from Tasks 2 and 3, the contractor will provide recommendations for at least three (3) feasible options to address the deficiencies identified in Task 3, to include leveraging leading practices identified. The intent of the recommendations are to create a seamless and integrated end-to-end debt management process that facilitates the seamless flow of debt related activities between offices and systems to allow for efficient and effective debt collection. The process improvement recommendations shall include specific actions to accomplish the following:

· Bring the 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 debt-related activities;

· Improve workflow and performance management with suitable metrics;

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

· Eliminate redundant legacy systems and make maximum use of the Oracle financial management modules;

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

· Improve access to and the quality of financial data;

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

· Remove policy impediments to effective and efficient debt management and collection activities;

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

· Identify methods to obtain debt-related data to perform analytics and improve reporting; and

· Improve the quality of the reports.

Task 4 Deliverables

4.1 Alternatives Analysis (initial report) - The contractor will prepare a written report that includes at least three (3) feasible options to realign work to address the deficiencies or leverage the leading practices identified in Task 3. Options should range from minimal change to current responsibilities of the organizations performing the debt-related activities, to the most efficient organization that may include transferring functions between organizations and shared service organizations, and making maximum use of automation. The contractor will include the pros and cons of each proposed recommendation, as well as potential challenges of each, such as those requiring organizational realignment, shifting work between organizational units, and/or outsourcing the work to a service provider.

4.2 Alternatives analysis (final report) - The contractor will prepare a final report of Deliverable 4.1, incorporating feedback from OCFO and others at the Department related to the feasibility of implementing the various alternatives. The final report will include pertinent summary or detailed level information from work conducted under Tasks 2-3 and 5-10. As deemed appropriate, and with approval of the COR, the final report may consolidate some of the deliverable required under Tasks 5-10 and eliminate the need for separate reports under those deliverables.

4.3 “To Be” documentation - The contractor will provide pro-forma documentation showing how “as-is” processes documented under Task 2 will change under the proposed alternatives. This documentation shall be incorporated into deliverable 4.2. Additionally, for any changes made to current business processes during the task performance period, the contractor will assist in updating the existing documentation to reflect those changes.

4.4 Communication plan - The contractor will develop a communication strategy that includes necessary briefing material and other documents to help government staff define the “to-be” state under the various alternatives and recommendations from deliverables required under Tasks 5-10. Briefing material is intended to help articulate the need for and the value proposition of recommended changes to key decision-makers. The contractor will be expected to actively participate in meetings with senior Department officials to help defend recommendations for process improvement and explain how conclusions were reached. The contractor will provide an initial communication plan within 45 days after task order award and updated that plan every 30 days thereafter to keep it current. Documentation will be adapted to the intended audience that will be briefed.

5 Task 5- Modernize and Enhance Debt-related Automation. Grant making program offices use the G5 grant system and a variety of other manual processes and automated applications to manage debt-related business activities. Work conducted by the OIG indicates that some debt related activities in the grant making offices are not well managed. The OCFO operates and manages its accounts receivable primarily in the Oracle Federal Financial Management System (FMSS) as well as the supplemental Nortridge Loan System (NLS). The debt management and accounts receivable activities in OCFO are currently highly manual, inefficient, and in need of better automated support. There are on-going efforts to automate some of the manual processes and, as of December 2013, new accounts receivable are referred to the Centralized Receivables Service (CRS) through the U.S. Department of the Treasury. Delinquent debts are referred to Treasury through their FedDebt system. The contractor will assist Department staff to leverage existing information technology and identify potential new automated solutions to include:

· Building interfaces between FMSS and Treasury systems;

· Automating manual procedures and data interchange;

· Retiring NLS and leveraging the loan application in the Oracle financial suite of systems;

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

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

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

Task 5 Deliverables:

5.1 Automation modernization and enhancement report (Initial) - The contractor will assess various options about how the Department can fully automate debt-related business activities and make maximum use of electronic data interchange. Preferred options are to make maximum use of existing Department systems and applications or available shared services. The contractor will identify potential solutions to enhancing automation to improve debt-related business activities with a goal of migrating to fewer applications (such as migrating loan management activities from NLS to Oracle), leveraging existing program office applications, and building interfaces between Treasury and Department systems. The contractor will work with OCIO staff and program offices to fully understand the level of effort and potential cost of the transition and sustainment of enhanced automation.

5.2 Automation modernization and enhancement report (Final) – The contractor will provide a final written recommendation report of the study performed in Task 5.1. The final report will include feedback from key stakeholders and relevant outsourcing options (derived from Task 6) to address manual processes and other inefficiencies. The report shall itemize the estimated level of effort and cost of the automation and provide information to support the proposed new investments that is consistent with the way the Department ranks and scores information technology investments. The report will include a specific analysis related to migrating loan management activities from NLS to Oracle and whether that migration makes business sense prior to upgrading to Oracle version 12.

6 Task 6- Optimize Utilization of Treasury and Shared Service Solutions. Consistent with OMB direction, the Department is looking to make greater use of shared services where feasible. The contractor will assist Department staff in assessing options to make maximum use of shared services solutions for debt related activities. Specific support will include things like the following:

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

· Identifying opportunities for the Department to realign its business processes, organizational structure, or operating philosophy and to more fully leverage the capabilities of the core accounting system to be more in line with the shared service provider model;

· Identifying ways to expand the use of electronic payments available under the Treasury shared service solutions that OCFO has already adopted, including better communication with debtors;

· Assessing the Department’s current and shared services plans and making recommendations for improvement;

· Evaluating the existing governance structure and agreements with shared service providers and making recommendations for improvement; and

· Helping to define best practices for governance and provide model service agreements suitable for current or proposed new shared service arrangements.

Task 6 Deliverables:

6.1 Shared services assessment report - The contractor shall assess the current and planned use of shared services for debt management related activities and identify opportunities to improve them. The assessment report will include organizational, policy, or cultural barriers preventing movement to a shared services solution. The report will also compare how the Department currently manages debt-related activities (both manual and automated processes) against how they are managed by shared service providers in an Oracle environment and provide recommendations to better align business processes and make better use of technology. Tasks 6.2 and 6.3 will be incorporated as appendices in this report.

6.2 Governance recommendations report - The contractor will include an assessment of how shared services related to debt management activities are currently being conducted and the quality of any service agreements in use. The contractor will provide a model service agreement for Department consideration covering current and proposed new shared service solutions.

6.3 Pro-forma process documentation – The contractor will provide pro-forma process documentation showing how “as-is” business processes documented under Task 2 will change under the proposed alternatives.

7 Task 7 –Debt Management Policies and Procedures. The contractor will assist Department staff in assessing current debt management policies and procedures and provide recommendations for improvement. Specifically, the contractor shall

· Identify any changes to debt related activities that may impact the Department as a result of implementation of the new grant “super-circular”;

· Identify areas where Department policies and procedures do not comply with applicable Federal laws and regulations identified in deliverable 3.1 and make recommendations to address them;

· Identify potential legal or regulatory impediments to effective and/or efficient debt collection and make recommendations to address them; and

· Determine if OCFO policies and procedures align with the end-to-end process mapping documents and adequately address the debt related activities performed by OCFO.

Task 7 Deliverables:

5.1 Evaluation of compliance report - The contractor will assess key provisions of relevant laws, regulations, and policies identified in deliverable 3.1 and determine areas of potential conflicts between existing Department policies and applicable Federal laws and regulations. That assessment will include an assessment of the new OMB grant “super circular” to determine if there is any potential impact on Department debt related activities that may result from implementing the circular. The contractor will prepare a written report of its evaluation, findings, and recommendations.

5.2 Evaluation of OCFO policies report – The contractor will assess OCFO policies to determine if they are consistent with OCFO debt related responsibilities. The contractor will prepare a written report of its evaluation, findings, and recommendations. The intent of OCFO is to have desk procedures that align with the detailed process flow and are integrated to the extent feasible with current software. The contractor will identify any gaps in OCFO procedures and provide specific recommendations for closing those gaps.

8 Task 8 - Workforce analytics. The contractor will perform workforce-related analytic work to assist Department staff in determining the following:

· Number of staff and appropriate skill and grade level required to perform debt-related KBAs effectively and efficiently;

· Determine the full range of skills and training needed to perform debt management functions effectively in the “to-be” OCFO environment that is more highly automated and is expected to perform complex financial analysis;

· Suitable performance objectives and measurable performance metrics to evaluate OCFO staff performance on their debt management related work;

· Opportunities to combine, consolidate, and streamline OCFO debt-related activities to make them as efficient as possible; and

· Potential staff savings that may be realized through implementation of recommendations in Tasks 3 -7.

Task 8 Deliverables:

8.1 Recommend staffing model – The contractor will provide recommendations for appropriate OCFO staffing models detailing the estimated staff and skill level associated with performing the proposed options developed under the other tasks in this task order. The contractor will include recommended grade structure, skill sets, and training requirements for the Department staff performing debt-related activities. The contractor will also include recommendations related to suitable performance standards and metrics to appropriately measure and rate staff conducting debt related activities within OCFO.

8.2 Analysis of manpower savings - The contractor will provide a report detailing estimated manpower savings associated with recommendations for process improvements, increased automation, and expanded use of shared service solutions developed under Tasks 3-7. If recommendations require increased resources to address deficiencies (such as to do things that had not been done previously), the report will include estimated savings from a revised baseline of fully compliant operations. The purpose of this report is to support a business case for investing in information technology to improve debt management activities and/or moving to shared service solutions.

9 Task 9 – Enhance Financial Reporting. The contractor will assess OCFO report compilation methods and the accuracy of information included in the Department’s debt reports, such as the Treasury Report on Receivables (TROR) and Annual Financial Report (AFR). The contractor will also review Treasury scorecards and other applicable metrics to identify methods to improve. Additionally, the contractor will compare disclosures in the AFR against suitable benchmarks to improve the quality of AFR disclosures.

Task 9 Deliverables:

9.1 Assessment of debt reporting – The contractor will assess the efficiency of ED’s current practices for compiling debt-related reports and evaluate the completeness and accuracy of the reported information. Based on that assessment, the contractor will provide a written report with recommendations for improvement. The report will include ways to improve the way reports are compiled and the completeness and accuracy of information reported. The report will also identify ways to improve on other debt-related products including Treasury scorecards. The report will also include a description of the benchmarking performed against other federal organizations to assess the quality of the disclosures in the AFR about Department debt-related activities. Based on those benchmarks, the contractor will provide recommendations to improve debt related disclosures in the AFR.

10 Task 10 - Internal Control Work. The contractor will assist Department staff in ensuring that end-to-end debt management process documentation and narratives adequately identify and describe all key internal controls relevant to the debt related activities. As part of that work, the contractor will consider relevant risks from an enterprise perspective that should be considered in conducting debt related activities. Tasks in this area include the following:

· Identifying key internal controls related to debt management activities;

· Identifying enterprise risk pertaining to debt related activities and conduct a risk assessments of the controls designed to mitigate those risks;

· Evaluating the design efficiency and effectiveness of controls and determine methods to streamline and/or strengthen controls and to align controls to risk;

· Developing plans to test controls at the gold, silver, and bronze levels described in the Performance Work Statement (PWS); and

· Identifying opportunities to implement real-time debt management process monitoring and/or implement continuous monitoring tools to improve the effectiveness of controls over debt related activities.

Task 10 Deliverables:

10.1 Controls listing - The contractor will identify all key controls related to debt management activities that the Department either does or should do. The contractor will ensure that the process documentation prepared under Task 2 includes all the key controls.

10.2 Controls assessment report- Leveraging documentation created in Tasks 3 and 4, the contractor will conduct a full assessment of the design of the key debt-related controls against applicable benchmark and standards and document all deficiencies noted. Deliverable will include recommendations to correct the deficiencies, to include adding or eliminating controls, improving the effectiveness of controls, and otherwise strengthening the controls.

10.3 Risk assessment report – The contractor will provide a risk assessment of key controls pertaining to debt management activities from an enterprise perspective. The assessment will rank the controls based on their significance/impact and provide updates to for the overall OCFO risk assessment pertaining to internal controls over financial reporting.

10.4 Proposed test plans – The contractor will provide a proposed test plan covering key controls related to debt management activities. Test plans will provide recommendations for gold, silver, and bronze testing in accordance with their definitions in the PWS.

5. Applicable Documents

5.1 Legislative Authority: As required under deliverable 3.1, the contractor is required to perform a comprehensive review of all relevant laws, regulations, and policies pertaining to debt management activities performed or required by Department staff. Some key provisions follow.

5.1.1 The Federal Claims Collections Standards (implementing the Federal Claims Collection Act, 31 USC, section 3711 require agencies all debts arising out of activities of, or referred, or transferred for collection to that agency. Other 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.) Federal Credit Reform Act of 1990, Pub. L. No. 101508, 104 Stat. 1388610 (codified in various sections of 2 U.S.C.)

5.1.2 The legislative authorities which directly impact each program are 34 CFR Part 386 (RSA), 34 CFR Part 611 (TQE), ACS Department Handbook for Processing Salary Overpayments, OM-04 (SOP), No Child Left Behind Act of 2001, Title VII, Part A (OIE), 34 CFR, Part 304 (SEP), Higher Education Act (HEA), Section 428L (CLAARP), and HEA, Title VII, Part B (EBS).

5.1.3 Additional authority in grant management can be found in EDGAR, 34 CFR 74-99. The legislative authorities for the overall debt management can be found in the Federal Claims Collection Standards (FCCS), Debt Collection Improvement Act of 1996 (DCIA), and the ACS Department Handbook for Accounts Receivables Requirements, OCFO-02.

5.2 Assumption/Constraint

5.2.1 The contractor shall adhere to the institute of electrical and electronic engineers (IEEE) definition for Software maintenance.

5.2.2 Information systems shall be developed in accordance with the ED Lifecycle Management Framework (LCM), ACS-OCIO 1-106.

5.3 Security Clearance:

5.3.1 The contractor shall have or shall obtain a 6C security clearance for this contract. A level 6C security clearance is required for contractors who have access to sensitive information, computer systems or restricted areas where the risk and magnitude of damage that could be done is high. The screening for a 6C employee may include a review of completed security forms, a credit check, a records check and a file check. A background investigation is required for a level 6C security clearance.

5.4 Government-furnished Property and Services:

5.4.1 The government will provide key staff from both DPMG and the Internal Controls group to team with the contractor to facilitate progress. The contractor will have electronic access to all existing pertinent documentation

5.5 .Government-furnished Information:

5.5.1 The government will furnish additional information to the contractor to inform their work, including the FM Line of Business Segment Modernization Plan, “as is” process maps and control documentation, test plans.

6. DELIVERABLES. In accordance with deliverable 1.2, the contractor may propose reasonable changes to deliverable dates shown below and may propose the consolidation of deliverables to reduce duplication. In no case, however, will the contractor propose a reduction in work. Agreement on changes to the schedule and on which deliverables will be consolidated will become binding on the contractor under deliverable 1.2 and be the basis for the project work plan called for in Task 1.4.