Attachment_G_DCAS_Vendor_Day_Conference_Presentation_11.18.14.pdf

Data Challenges and Appeals Solution (DCAS)

Vendor Day Conference Request for Proposal #ED-FSA-14-R-0028 New Attachment G

11.18.2014

Notice

1. This is a Pre-Proposal Conference (FAR 52.201);

2. Purpose: exchange information, consistent with procurement integrity requirements (FAR 3.104), to improve your understanding of Government requirements;

3. Remarks and explanations at the conference shall not qualify the terms of the solicitation (informational only);

and

4. Terms of the solicitation and specifications remain unchanged unless the solicitation is amended in writing.

Agenda Introductions 9:30 – 9:35

FSA and Data Challenges & Appeals Solutions

(DCAS) Overview 9:40 – 9:50

Policy Update 9:50 – 10:10

DCAS Operations 10:10 – 10:30

Information Technology Considerations 10:30 – 10:45

Acquisition Strategy 10:45 – 11:00

Break 11:00 – 11:15

Questions and Answer 11:15 – 11:55

Closing Remarks 11:55 – 12:00

FSA Overview A principal office within the U.S. Department of Education, Federal Student Aid:

Designated as a Performance-Based Organization in 1998.

Central role for postsecondary education in the American community

In FY13 delivered $137.6 billion in federal financial student aid to approximately 14 million students attending approximately 6,200 active institutions of postsecondary education

DCAS Overview Data Challenges & Appeals Solution Objectives:

1. Deliver robust and flexible service solution that will support case intake management and workflow processing for:

Cohort Default Rate (CDR) at Institution (iCDR) and Program (pCDR) level;

Gainful Employment (GE) Metrics and Disclosures; and

Other potential areas for data correction.

2. Become successor system to eCDR Appeals application.

3. Leverage industry experience in/knowledge of Title IV servicing.

DCAS Overview (cont’d) Anticipated Implementation Timelines:

1. Debt-to-Earnings (D/E) Metric – by September 1, 2015 for pre-draft and beginning by June 1, 2016 for draft

2. Program Cohort Default Rate (pCDR)/Cohort Default Rate (CDR) – by February 1, 2016

3. Median Earning for Disclosures – by September 1, 2015

4. Completion/Withdrawal Rates, Repayment Rate, & Median Loan Debt for Disclosures – by December 1, 2016

Expect Just-in-Time Delivery of DCAS Case Intake/Case Management Functionality

Cynthia Hammond

Policy Liaison and

Implementation

Policy Update

1. Scorecard

Median debt

2. Ratings, and other transparency efforts

3. Cohort Default Rate

4. Gainful Employment

Final Rule published October 31, 2014 Effective Date is July 1, 2015 Accountability metric o Debt-to-Earnings Annual o Debt-to-Earnings Discretionary o Transition Rates

Disclosures Reporting

Policy Update (cont'd)

1. GE metrics, CDR, and any other potential metrics are calculated by NSLDS and other systems

2. GE Reporting to NSLDS will begin in early 2015

Report all Title IV Students in GE Programs by July 31, Report 2008-2009 through 2013-2014 award years

Programs with Medical and Dental Residencies report 2007-2008 through 2013-2014 award years

Report 2014 – 2015 Award Year by October 1, 2015

Gainful Employment Disclosures

1. Consumer Testing to be conducted to make Disclosure Template as useful as possible

2. pCDR now Disclosure item only - Change from Draft GE Regulation

3. GE Disclosure could include –

Repayment Rate

Completion Rate, and Withdrawal Rate

Median Loan Debt

Median Earnings

Program Cohort Default Rate

CDR and pCDR

1. GE Regulation provides for calculation of Cohort Default Rate (CDR) at the program level

2. Challenge and Appeals timeline for CDR and pCDR are the same; however, only one submission of the challenge/appeal for each loan requiring correction

3. Challenges are submitted on the draft rate and appeals/adjustments are submitted on the official rate

Challenges/Appeals for both CDR and pCDR include –

Incorrect Data Challenge Uncorrected Data Adjustment New Data Adjustment Erroneous Data Appeal Loan Servicing Appeal

Several Challenges/Appeals do not apply to pCDR but must still be done for CDR–

Participation Rate Index Challenge/Appeal Average Rate Appeal Economically Disadvantaged Appeal 30 or Fewer Borrowers Appeals

Katrina Turner Margaret Ayanian

Operations Performance

Management

DCAS Operations

1. Overview of Case Processing – Example of a Pre-Draft Debt-to-

Earnings Challenge

2. Pre-Draft Debt-to-Earnings challenges allow Institution to make corrections to the Completer List of borrowers who completed the GE program during the cohort period.

Exclusions to Pre-Draft Debt-to-Earnings include (these are types of allegations) –

Military related deferment status;

In process or approved for Total and Permanent Disability Discharge;

Student was enrolled in another eligible program during the calendar year;

Student completed a higher credentialed undergraduate GE program; or

Student died.

DCAS Operations (cont'd) Processing Steps:

1. Institution accesses DCAS workflow system for purposes of creating a case – DCAS system provides the back-up data file (loan level data) for the completer list.

2. Institution selects the borrower to be excluded from the pre-draft completer listing and enters appropriate information for the challenge including the allegation (reason for challenge). Institution also provides supporting documentation for the allegation.

3. DCAS system tracks the timeliness of the case submission and determines if the pre-draft debt-to-earnings case was submitted before the challenge deadline expired.

4. Case Response Preparer (DCAS Contractor Analyst) and FSA are alerted that a new case has been submitted.

Case Response Preparer (DCAS Contractor Analyst) works the case –

1. Opens the case and reviews the allegation information and supporting documentation.

2. Determination is made if additional information is needed from the Institution or Data Manager.

3. If additional information is needed, Analyst uses the DCAS workflow system to request information from Institution and/or Data Manager.

4. Both Institution and Data Manager are alerted through DCAS workflow system of an information request for the case.

5. Once information is provided, Analyst completes their review of the allegation to determine recommended resolution.

6. Analyst enters the resolution information and submits the case to FSA for final decision.

FSA Case Manager review and decision –

1. DCAS workflow notifies FSA Case Manager of completed case for review.

2. FSA Case Manager reviews the case and determines if they agree/disagree with recommended resolution.

3. If open questions remain, FSA Case Manager uses the DCAS workflow to submit questions and/or requests for clarification back to the Case Response Preparer.

4. FSA Case Manager finalizes the case and sends notifications using DCAS workflow to School and Data Manager of final determination.

5. Final detailed case outcomes (by allegation) are captured by DCAS workflow system and a data file is created to be sent to NSLDS.

Challenge/Appeal Type Allegation Impact Analysis Required Pre-Draft Debt-to-Earnings challenge

Student died Student/borrower to be removed from Completer List.

Review allegation and documentation to determine if evidence supports student died and student/borrower should be removed.

Pre-Draft Debt-to-Earnings challenge

Identifier Conflict Student/borrower to be included on Completer List.

Review identifier conflict information to determine what issues School had in reporting borrower to NSLDS and student/borrower should be included.

Draft Debt-to-Earnings Challenge

Incorrect Median Loan Debt Incorrect student/borrower loan balances identified in GE underlying data.

Review information and documentation to verify if loan balance(s) used in calculation was incorrect.

Determine corrected loan balance to be included.

Data Challenges and Appeals Examples of Allegations and Analysis

DCAS Services, Staffing and Systems must include –

1. Case intake for challenges and appeals submitted by institutions;

2. Workflow capability between Institutions, Data Managers, DCAS Contractor Analyst, and FSA to work cases;

3. Analysis, review and resolution (outcome recommendation) of each case;

4. Submission of completed cases to the Department for final approval;

5. Bi-directional Interface with NSLDS for underlying challenge data and pass back of completed case outcomes;

6. Customer service to support end users (including institutions, data managers, and FSA);

7. Operational and management reporting;

8. Training services; and

9. System solution operations and maintenance services.

Training Services for DCAS

1. Develop and deliver a variety of instructional methods and media for appropriate target audience –

FSA staff

Institutions’ personnel

Data Manager personnel

DCAS Contractor Analysis staff

2. Training methods to include interactive webinars, just-in-time virtual classrooms, instructor lead classroom sessions, etc.

3. Develop and provide core training materials including user guides, manuals, workflow screen shots, job aids, and FAQs.

4. Provide revisions and updates to all training materials for each phased in implementation and regulatory updates.

Mike Fillinch

Enterprise Data Services Director

Technology Office

Information Technology Considerations Solution Hosting - Vendor Hosting vs. FSA Hosting factors:

1. Speed to implement

2. Security

3. Service

4. LMM Applicability

5. Total Cost of Ownership

IT Considerations - VDC

1. Mainframe Services includes hardware and server-side software hosting, data backup and restoration, operations and administration, and other general support services.

2. Non-mainframe Server Services includes hardware and server-side software hosting, data backup and restoration, operations and administration, and other general support services.

3. Middleware Administration and Support includes implementing configurations, establishing and maintaining configuration and system parameters, executing processes for the proper maintenance and functioning of the business and web applications residing in this layer on mainframes and non-mainframe servers.

4. System Level Database Administration and Support includes technical and administrative work in the management of FSA databases through the planning, design, configuring, implementation & operation of database systems; planning & implementing database expansions;

reorganizations and/or conversions; developing and implementing backup and recovery procedures; and establishing and administering database policies.

IT Considerations - VDC (cont'd)

5. Storage services includes establishing, reporting, and optimizing storage environments to include storage array networks, tapes, non-tape media, and optical devices.

This service includes management of media for receiving data into applications from external sources, for backup and recovery, and housing of media to meet regulatory requirements.

6. Custodian of Software Licenses includes managing and tracking all server and software licenses for applications residing at the VDC, regardless of whether the VDC, Federal Student Aid or an application developer acquired the license.

IT Considerations – Network

All new telecommunications procurements (telephone & data) must be ordered through FSA’s GSA NETWORX procurement team.

IT Considerations – VDC Network Services

1. Network Managed Services includes the provision, monitoring and management of networks that connect two or more separate facilities spanning a geographic area larger than a campus or metropolitan area. Network managed services, dedicated Internet connections, broadband (DSL/cable modem) Internet connections, Internet-based Virtual Private Networks and dial-up connections.

2. DHCP/DNS Services includes the provisioning, monitoring and managing all aspects of DHCP/DNS services supporting the Federal Student Aid applications and systems at the Contractor site(s).

3. Internet Communication Services includes all aspects of providing and maintaining connection of the Federal

Student Aid applications and systems to the public Internet.

IT Considerations - Network Services at the VDC

4. Virtual Private Network Services includes the provision, monitoring and management for remote users to securely connect to the VDC over the public Internet; includes dedicated site-to-site VPN connectivity on a shared public IP network; requires industry-based/Internet-based standards for security to create and preserve privacy, data integrity and authenticity.

5. Application Acceleration Services includes the temporary storage and caching of web objects (web pages or components such as JSPs, servlets, and beans that contain presentation logic) and the routing and distribution of applications to reduce bandwidth consumption, server load and latency of web requests, as necessary (e.g.

Akamai and INTERNAP).

IT Considerations - Development

Any and all code development must be produced in compliance with FSA’s Lifecycle Management Methodology (LMM) structure.

IT Considerations - Software

All new COTS software procurements must be ordered through FSA Acquisitions Group, Software Team.

IT Considerations – Security

1. Compliance with all Federal laws, regulations, and policies

2. Personnel Security

3. Physical Security

4. Cyber Security

5. Personally Identifiable Information (PII)

6. Authority to Operate (ATO)

IT Considerations – Other

1. Testing Services

2. Independent Verification and Validation (IV&V)

3. Performance Testing – Peak Processing

4. Auditing and Audit Support

Dega Hussen

DCAS Contracting Officer

FSA Acquisitions Group

Acquisition Strategy: Key Facts

1. Unrestricted (Full & Open Competition) pursuant to FAR

Part 12

2. NAICS Code Standard: 541519 (Other Computer Related Services)

3. Evaluation Factors: Past Performance, Performance Work Statement, and Pricing

4. Base Period - six (6) months

5. Options - anticipated three (3) one-year option periods and one (1) eighteen-months (total contract term not-to-exceed five (5) years)

Acquisition Strategy: Key Facts (cont'd) Organizational Conflict of Interest (OCI)

1. Existence of a set of circumstances in which a contractor may be unable to render impartial advice to the government; have impaired objectivity in performing work; and/or obtain an unfair advantage

2. Each offeror makes a determination whether actual or potential OCI exist

If yes, Mitigation Plan containing proposed response strategy

If no, Statement outlining the process undertaken to reach this determination

Q&A

Closing Remarks