Attachment_A_Data_Challenges_Statement_of_Objectives_v4.0.pdf

DATA CHALLENGES AND

APPEALS SOLUTION

STATEMENT OF OBJECTIVES

August 8, 2014

Version 4.0

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Executive Summary

U.S. Department of Education (ED), Federal Student Aid (FSA) has a variety of program metrics that are or will be published on a frequent basis. Current and proposed regulations allow for institutions to challenge and appeal those metrics based on detailed data included in the metric calculation.

FSA currently publishes cohort default rates (CDR) annually. The CDR Regulations allow for multiple data challenge types.

On March 25, 2014, ED published a Notice of Proposed Rulemaking (NPRM) for Gainful

Employment (GE) 79 FR 16426. It is expected that final GE regulations, resulting from this NPRM, will be published no later than November 1, 2014. The new GE Regulations may include provisions that will allow for multiple data challenge types. In addition, there may be additional data adjustment mechanisms that may be needed for institutions as a result of other metrics developed in response to the administration’s transparency initiatives, such as the College

Scorecard.

I. Overview

FSA currently conducts a challenge process in support of the cohort default rate regulations in Subpart N of the Student Assistance General Provisions regulations (34

CFR Part 668).

For the most recent cohort year, 2011, over 357 institutions submitted data challenges on the three year draft CDR. Of the 357 institutional challenges, each submission could range from data challenges on as few as 10 loans to more than 1,000 loans.

With the proposal of new regulations and new metrics for public use, FSA will be responsible for many more data challenges in coming years. The current NPRM for

Gainful Employment was used as a basis to estimate over 300,000 loan level challenges during the first metric calculation year.

FSA has a current intake process that allows institutions to electronically submit data challenges in relation to CDR. Those data challenges are reviewed and resolved on a case-by-case basis by FSA staff. The volume of challenges continues to increase with new regulations and the possibility of additional metrics compounds the issue.

II. Background

The GE initiative is in support of the implementation of proposed new regulations that, when finalized, will apply to all postsecondary institutions that have GE programs. The

Higher Education Act of 1965 (as amended) states that in order to be eligible for

Request for Proposal (RFP) #ED-FSA-14-R-0028 Page 3 of 14 funding under the Title IV programs, an educational program at a non-profit or public institution must lead to a degree (associate, bachelor's, graduate, or professional) or, at all types of institutions, must prepare students for "gainful employment in a recognized occupation". We estimate that there are over 5,000 institutions with GE programs that are currently participating in the Title IV programs for a total of over 64,000 GE programs.

The current Electronic Cohort Default Rate (eCDR) Appeals System supports institution level CDR challenges. Once a challenge is initiated it becomes a case. The platform needs to support large volumes, and interfaces with multiple sources. With the number of data challenges increasing each year and the addition of proposed GE metrics at the program level, the current eCDR Appeals System cannot support the expected volume increase. The eCDR Appeals system maintains information throughout the case's life cycle namely key dates and actions taken by the school and the data providers/managers.

College Scorecards in the U.S. Department of Education’s College Affordability and

Transparency Center (CATC) were designed by the U.S. Department of Education to meet requirements in the Higher Education Opportunity Act and to provide better information to student and parent consumers about college costs. It serves as a central point to several tools that allow users to compare colleges’ tuition and fees, net price, and other characteristics. The CATC is maintained by the Office of Postsecondary

Education with support and technical assistance from the National Center of Education

Statistics and Federal Student Aid.

Unlike GE and CDR, there are currently no data challenges in relation to the CATC;

however, any proposed solution should be robust and adaptable in the event there are future requirements from this or other initiatives.

Goal

To manage a high number of challenges, FSA is looking at solution alternatives that will include a system with workflow capabilities, interfaces with FSA systems and other partner data systems, analytical capabilities for basic checks regarding challenge data, and contracted staffing to assist in resolving challenges within the timeframes indicated in the regulations.

At minimum, any proposed service and/or system solutions shall include:

Electronic intake process for institutions to submit data challenges and appeals, workflow for case resolution to include case processing by contractor staff and case approvals by FSA staff;

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Regular management reporting to FSA management and staff on the number, status of a challenge, and time to resolution statistics;

Automated resolution techniques for simple data challenges and appeals allowing interfaces with FSA’s systems to check for timing differences and data updates as part of the challenge resolution as well as on-going automated processes that would make case processing more efficient;

Routine customer support services for challenge entry and inquiry; and

Capability to transfer any changed data to the calculation system (National Student

Loan Data System (NSLDS)) in order to revise, update, and distribute as final calculations.

The current Cohort Default Rate (CDR) metric is used to determine eligibility of an institution to participate in the Title IV, HEA programs.

As stated in the proposed Gainful Employment regulations, there will be an additional two

(2) independent measures used to determine program eligibility with the implementation dates as follows:

1) Debt-to-Earnings (D/E) Metric - anticipated implementation date to accept, process, resolve, and archive data challenges by September 1, 2015 for pre-draft1 and June 1, 2016 for draft.

2) Program Cohort Default Rate (pCDR)/Cohort Default Rate (CDR) – anticipated implementation date to accept, process, resolve, and archive data challenges and appeals by February 1, 2016.

The proposed regulations will require FSA to calculate additional metrics that will be disclosed to the public. The proposed regulation anticipates calculation and disclosure of a program’s:

1) Median Earning Disclosures - anticipated implementation date to accept, process, resolve, and archive data challenges by September 1, 2015.

2) Completion/Withdrawal Rates - anticipated implementation date to accept, process, resolve, and archive data challenges by December 1, 2016.

3) Repayment Rate - anticipated implementation date to accept, process, resolve, and archive data challenges by December 1, 2016.

4) Median Loan Debt for Disclosures - anticipated implementation date to accept, process, resolve, and archive data challenges by December 1, 2016.

1 Refer to Exhibit 1 on page 13 of this SOO.

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Performance Objectives

Contractor’s Commercial-Off-the-Shelf (COTS) and/or service-based solution shall meet or exceed the following performance objectives and ensure expected outcomes are realized.

Objectives Outcomes

Usability Ease of use capability within workflow framework.

Ability for automated upload of student data sent from schools.

Ability to provide challenge processing support within timeframes mandated by regulation.

Ability for automated upload of challenge data from the calculation system such as NSLDS.

Scalability Ability to process, manage, secure, and store large volume of data.

Ability to manage large user base.

Ability to support tracking of data challenges from submission to resolution.

Ability to scale/provide processing support to align with periods of peak and non-peak workloads.

Flexibility Ability to support new workflows.

Ability to scale to larger data volumes.

Ability to integrate workflow application and case processing labor resources in stable environment (integrated management capability).

Ability to support the addition and revision of analytics to process cases more efficiently.

Ability to be fully staffed in time to support the regulation.

Ability to track additional/new data sets as needed to support business rules for challenges.

Ability to support complex workflows

Ability to support case management for resolution of student-level loan data issues.

Provide methodology to perform each required step for each challenge process.

Support task automation and allow for incremental additions of task automation based on new challenge or data correction additions.

Ability to support processing of challenges to GE, CDR, CATC, College Scorecard, as needed. (see Exhibit 1)

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Objectives Outcomes

Ability to support complex workflows

(continued)

Provide automated workflows that support processing events and system notifications triggered by calendar based events

(such as defined by regulation timelines or business rules).

Ability to present the data for each data challenge (including data from the submitter and associated data from other systems, i.e. data managers/providers) in a manner convenient for use by the case manager/analyst.

Ability to group students within a challenge by data manager.

Ability to automate identification of redundant data (duplicate and repeat data challenges) to enhance quality control.

Access to detailed underlying data

Ability to store data in a transparent format in FSA facilities and/or support daily export of all case-processing data to FSA in a format stipulated by FSA.

Reporting/query capabilities

Ability to support standard and ad-hoc management and staff reporting requirements through unlimited access to data within a flexible IT environment for writing reports.

Ability to support customized data queries to obtain analytical information regarding challenge data.

Provide administrative tools to manage users and workloads.

Ability to produce operational reports regarding challenge processing data, standard and ad hoc versions of report.

Examples include Case Aging Report, Monthly Volumes Report, etc.

Ability to produce production operational reports related to operations and systems performance (such as call center metrics, help desk support, system performance, etc).

Notifications and

Training

Ability to address system notifications leveraging existing or generic workflow framework for processing data challenges.

Ability to provide a set of templates for challenge responses.

Ability to issue email notifications to schools alerting them to status updates, open questions and issues, as well as disposition of their challenges.

Ability to provide communications via email, fax or paper correspondence, ensuring communications are grammatically and syntactically correct.

Provide training materials for any updates, as needed.

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Objectives Outcomes

Notifications and

Training (continued)

Provide system materials and manuals that provide screen shots and technical information for system user guide, to be updated monthly with changes.

Provide additional webinars and training, as needed, to support regulatory initiatives and business enhancements.

Portability of data Ability to support data transparency in a secure and auditable manner.

Ability to accept data challenges and appeals submitted by schools.

Ability to accept data and documentation supporting challenges in various file formats.

Provide for the Department of Education, Federal Student

Aid to retain all rights and control of data.

Ability to support multiple interfaces

Capability in managing existing and/or new interfaces in particular with the calculation system, National Student Loan

Data System (NSLDS).

Provide for bi-directional interface with data calculation provider to receive and send underlying data and data corrections for challenges.

Provide for interoperability with other FSA enterprise systems, such as NSLDS.

Compliance Ability to comply with:

1. FSA’s Project Governance Model (Federal Student Aid

Lifecycle Management Methodology (LMM)), Department of Education technical and security policies.

2. Federal Statutes, Standards and Guidelines for Security such as FISMA 2002, Computer Security Act (1987), Privacy Act (1974), FIPS Pub 199, FIPS Pub 200, FIPS Pub

140-2, NIST SP 800-34, NIST SP 800-18, NIST SP 800-30,

NIST SP 800-37, NIST Pub 800-47, NIST SP 800-50, NIST

SP 800-53, NIST SP 800-88, NIST SP 800-137.

3. OMB Circular A-130 and OMB Circular A-123.

4. 508 Compliance

Assumptions and Constraints

Contractor shall adhere and/or fulfill the following:

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1) GE regulations are expected to be finalized and promulgated by November 1, 2014.

2) Proposed data challenges and appeals solution shall provide an automated bidirectional interface for challenge data elements from the calculation system, (NSLDS).

3) Proposed data challenges and appeals solution shall utilize FSA’s Participation

Management (PM)/ Access & Identification Management System (AIMS), which includes providing a traditional password and Two-Factor Authentication (TFA)

One-time Password (OTP) generated by a registered token device that is in the physical possession of the user.

4) In accordance to Office of Management and budget (OMB) Circular No. A-13, all government websites must be within a specific domain; in this case, it shall be

‘ed.gov’. FSA will register the appropriate domain name and address.

5) Migration of key data elements from eCDR Appeals System into the proposed data challenges and appeals solution.

6) Initial go-live date including successful completion of all training of FSA users shall be by no later than September 1, 2015.

7) Analytic staff support services shall be provided to assist in processing data challenges and appeals including providing technical assistance to FSA staff, schools, and data managers.

8) If existing or new COTS-based solution will not be hosted at the contractor’s facility, it shall be hosted at the government’s Virtual Data Center (VDC).

Place and Period of Performance

It is anticipated that the contractor shall perform the majority of the work at its facility;

however, the contractor may be required to attend meetings in person at FSA’s headquarters located at 830 First Street, NE, Washington, DC, 20202 or participate via conference to discuss project status and other matters.

Base period performance shall commence on the date of award and conclude on February

28, 2015 with anticipated four (4) option periods. Contract term shall not exceed five (5) years.

Option Periods Dates OPT #1 March 1, 2015 through February 28, 2016 OPT #2 March 1, 2016 through February 28, 2017 OPT #3 March 1, 2017 through February 28, 2018 OPT #4 March 1, 2018 through July 31, 2019

Contract Type

This is a hybrid contract on a Fixed Labor-Hour (LH) and Fixed-Unit Priced (FUP) basis.

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Scope of Services

The government expects that the following services will be performed to meet its requirements and objective:

1. Development of general and detailed requirement through stakeholder sessions with key FSA subject matter experts (SMEs) including individuals from NSLDS, eCDR, Policy, Gainful Employment Operations, and other contractors.

2. Review and analysis of relevant artifacts/documentation provided by FSA.

3. Development of detailed design document or solutions user guide including interface control document (ICD) in accordance with FSA standards and based on proposed solution.

4. Development of testing plan and scripts as well as necessary documents in accordance FSA’s Production Readiness Review (PRR) Process Description, version 13, dated July 31, 2013.

5. Development of a training plan and execution of at least four (4) training session either in-person or via internet for all designated FSA users.

6. Production, maintenance, and update of all training materials and training presentations as necessary to ensure that all authorized DCAS users understand the functions and data of the proposed solution.

7. Implementation or deployment for final solutions based on the anticipated dates stated in the Goal paragraph.

8. Ongoing operations and maintenance support services including legislative and/or regulatory mandated enhancements.

a) No charge for any solution improvement and/or enhancement that costs

$3,000 or less or requires 100 hours or less to complete, whichever is greater.

b) Proposed solution improvements/enhancements shall be approved using the established FSA Change Request Process. The Contractor shall obtain approval from FSA before analyzing and sizing the proposed system enhancement(s).

c) Once a system enhancement analysis and sizing results have been approved by the FSA and authorized by the Contracting Officer, the

Contractor shall develop and implement the system enhancement.

9. Production and maintenance of a comprehensive record of base solution documentation including releases, patches, and changes that are readily available to

FSA staff as a deliverable against this contract.

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a) Documentation shall be sufficient to allow the transfer of operations and maintenance of the DCAS solution to a third party vendor with no prior knowledge of the system.

b) Consistently use a standards-based documentation format (templates available on FSA’s IT Standards Library website) regularly update the documentation to reflect the current solution architecture and provide detailed information on directory structure, which FSA shall have the right to review for completeness, accuracy, and requirements traceability.

If Federal Student Aid determines that defects in the documentation are material, the contractor shall cure such defects at no additional cost to the Government. The documentation shall provide clear revision information to aid in tracking defect resolution.

10. Analytical and technical services to support data challenge processing by the contractor’s personnel.

11. Ongoing program/project management support services by the contractor’s personnel.

12. Participation and collaboration with FSA staff and other contractors as needed.

Deliverables Schedule

In addition to the deliverables below, the contractor shall propose other relevant deliverables in accordance with the solicitation instructions.

Title/Content Format Due Dates/ Frequency

Updated Project Schedule in accordance with

PMI PMBOK®:

Key task activities (WBS Level 3), Start/end dates (duration), Assigned personnel resource, and Predecessor/successor relationships.

MS Project

Three (3) business days after the project kick-off meeting

Bi-Weekly Status Report:

Planned/completed activities;

Risks/Issues; and Completed work-products/deliverables Meeting minutes.

MS Word 2010 By NLT 2pm on every other Thursday

Baseline Program Management Plan in accordance with PMI PMBOK® and FSA’s LMM

Various TBD

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Title/Content Format Due Dates/ Frequency

Interview session meeting minutes by business unit including a brief summary on commonalities and differences in stakeholder’s input and feedback.

MS Word

TBD

I. Acceptance Criteria for Deliverables

The draft version of these deliverables shall be submitted to the Contracting Officer

(CO) and Contracting Officer’s Representative (COR) via electronic mail.

Government shall review the deliverable to determine that:

It is organized appropriately and written clearly, The information incorporated is accurate, complete, and relevant, It is formatted in either MS Word, MS Project, or Adobe Acrobat, as applicable, and

It adheres to recognized industry (e.g., PMI PMBOK®), government, and/or

Federal Student Aid standards, guidance, and regulations as they related to documentation content, format, quality, and contractual terms in particular

FSA Enterprise Requirements Management User Guide, version 1.03 dated

1/24/2011, tailored FSA Lifecycle Management Methodology (LLM), and other standards published on FSA’s IT Standards Library website as amended.

A deliverable that insufficiently addresses deliverable descriptions, is poorly organized, has poor grammar/spelling, or is incomplete, unclear, or inaccurate will be rejected.

Government shall review each deliverable and provide written notice of acceptance or rejection within ten (10) business days upon receipt.

Upon notice of formal written rejection from FSA’s CO, the contractor shall address all comments/changes and submit a revised deliverable within five (5) business days for the government’s notice.

Staffing and Responsibilities

I. Contractor Staffing and Responsibilities

Any access to necessary facilities, IT systems, and/or data will be based on the contractor’s personnel ability to obtain the requisite security clearance stated in paragraph below.

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Ownership of information and documents prepared in accordance with this contract shall become and remain property of the Federal Student Aid. It is the contractor’s responsibility to ensure system and data security as well as all individual personal data security.

Key Personnel Requirement

The Contractor shall propose key personnel who are committed to this project and available as needed in accordance with the solicitation instructions.

Government anticipates that the staff assigned to provide analytical and technical support services have a minimum of eight (8) years of relevant experience in business/data analytics within the financial lending industry with preference in demonstrated knowledge of or familiarity/experience in Title IV programs.

Applicable References and Standard

a. Subpart M and Subpart N of Section 668 of the Code of Federal Regulations.

b. Subpart A of section 668 of the Code of Federal Regulations for reporting and disclosure requirements.

c. Additional default prevention and management information available on ifap.ed.gov.

d. Gainful Employment (GE) Information Resources website.

e. NSLDS User Guide for reporting GE data.

f. GE Operations Manual.

g. White House College Scorecard.

h. FSA Information Technology (IT) Standards Library.

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&rgn=div5&view=text&node=34:3.1.3.1.34&idno=34#34:3.1.3.1.34.13 http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&rgn=div5&view=text&node=34:3.1.3.1.34&idno=34#34:3.1.3.1.34.14 http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&rgn=div5&view=text&node=34:3.1.3.1.34&idno=34#34:3.1.3.1.34.1.39.6 http://www.ifap.ed.gov/DefaultManagement/DefaultManagement.html http://www.ifap.ed.gov/GainfulEmploymentInfo/GEResources.html http://ifap.ed.gov/nsldsmaterials/attachments/NSLDSGainfulEmploymentUserGuide.pdf https://www.ifap.ed.gov/GainfulEmploymentOperationsManual/GainfulEmploymentOperationsManual.html http://www.whitehouse.gov/issues/education/higher-education/college-score-card https://studentaid.ed.gov/about/contracting-info/it-standards

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Exhibit 1: Examples of Data Challenges

Type Description Pre-Draft Debt-to-Earnings (D/E) and Median Earnings to Disclosure Challenges

Allows institutions to add or remove students from the Completer List. The Completer List is provided to the Social Security Administration to obtain mean/median earnings information used in calculating D/E measures and used in disclosures.

Draft Debt-to-Earnings (D/E) Challenge

- Annual Earnings

Allows institutions to challenge the draft Debt-to-Earnings Annual Earnings rate. The Annual D/E rate is the percentage of a GE program’s annual loan payment compared to the annual earnings of the students included in the calculation.

Draft Debt-to-Earnings (D/E) Challenge

– Discretionary Earnings

Allows institutions to challenge the draft Debt-to-Earnings Discretionary Earnings rate. The Discretionary D/E rate is the percentage of a GE program’s annual loan payment compared to the discretionary income of the students included in the calculation.

Transitional Period – Draft Debt-to- Earnings (D/E) – Challenge (Applies to both Annual and Discretionary D/E rate)

Allows institutions to challenge draft transitional D/E rates for a GE program failing or in the zone. For any of the first 4 award years for which D/E rates are calculated, a transitional D/E rate is calculated using the median loan debt of students included in the calculation during the most recently completed award year prior to the calculation of the D/E rates.

Draft CDR and pCDR – Incorrect Data Challenge (IDC)

Allows institutions to challenge default date information on individual borrower records.

Draft CDR and pCDR – Participation Rate Index Challenge (PRI)

Allows institutions to challenge loss of eligibility (applies to sanctioned schools only).

Final CDR and pCDR – Uncorrected Data Adjustment (UDA)

Allows institutions to challenge default date information on individual borrower records.

Final CDR and pCDR – New Data Adjustment (NDA) Appeal

Allows institutions to challenge default date information on individual borrower records.

Final CDR and pCDR – Erroneous Data Appeal

Allows institutions to challenge default date information on individual borrower records.

Final CDR and pCDR – Loan Servicing Appeal

Allows institutions to challenge their rate for loans improperly serviced for cohort default purposes.

Final CDR and pCDR – Economically Disadvantaged Appeal (EDA)

Allows institutions to challenge their CDR for low-income rate purposes.

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Type Description Final CDR and pCDR – Participation Rate Index Appeal

Allows institutions to challenge loss of eligibility (applies to sanctioned schools only).

Final CDR and pCDR – Average Rate Appeal

Allows institutions to challenge their CDR for average rate purposes.

Final CDR and pCDR – 30 or Fewer Borrowers Appeal

Allows institutions to challenge their rate for fewer than 30 borrowers over three most recent cohorts.

Draft Disclosures Challenge to Repayment Rate

Allows institutions to challenge loan level information on individual borrower records used for the calculation of repayment rate.

Draft Disclosures Challenge to Completion Rate

Allows institutions to challenge completion rate information on individual student records.

Draft Disclosures Challenge to Withdrawal Rate

Allows institutions to challenge withdrawal rate information on individual student records.