ESBD_356196_1713886831449_FNS Handbook 901 v.2.4 (pg 101-250).pdf

2.6 Alignment of Lifecycles 2.0 Lifecycle Management 99

2.6 Alignment of Lifecycles

All lifecycle management frameworks (SDLC, PMLC, ALCM, and DLCM) share a common organization. Aligning them has many benefits, but synchronizing the actual performance of work within the lifecycle frameworks can be complicated. Despite the potential complexity, aligning lifecyles is important. Not only do project activities impact one another from across the lifecycles, but aligning lifecycle activities keep costs down by mitigating the

All lifecycles consist of four broad types of phases. Aligning lifecycles can be accomplished by matching phases of a similar type.

These types of phases include:

1. Plan Establish the objectives and processes necessary to deliver results in accordance with the expected output.

2. Do Implement the plan, execute the process, and make the product. Collect data for charting and analysis in the following steps.

3. Check Study the actual results (measured and collected in Do) and compare against the expected results from the Plan to identify differences.

4. Act If there is a difference from the Plan and the Do activities detected by the Check phase, then the difference needs to be addressed by proceeding through the cycle again to resolve the deviation and establish a new baseline for performance.

Lifecycle Management (LCM) Interactions

Figure 25: PMLC, ALC, SDLC, and DMLC Alignment, below, is a visual representation of how the different phases of each lifecycle, PMLC, ALC, SDLC, DLCM align. The following sections will describe how the lifecycles interact and work together to produce a successful result.

Figure 24: Common Lifecycle Phase Types

2.6 Alignment of Lifecycles 2.0 Lifecycle Management 100

Aligning SDLC and PMLC

The system development process is composed of many complex tasks which must be accomplished in the correct order to produce a successful result. This is why the SDLC is needed. Also, precision and completeness of tasks relies on the structure an SDLC provides. It provides division of responsibilities and collaboration between stakeholders, developers, management, and users. Most projects involving system development include contractor support and specialists in various fields (e.g., software engineers, business analysts, quality control, testing engineers, etc.). The SDLC provides a process for forming clearly defined tasks, defined deliverables, and defined collaborative relationships among the various team members. This is achieved through the SDLC in phases. Where the SDLC focuses on the system being developed as a process, PMLC focuses on the orderly performance of the many activities within the SDLC.

PMLC organizes the SDLC activities into work packages using the WBS. The SDLC processes of Planning, Analysis, Design, Development, Testing, Implementation, and Maintenance & Operation can all be easily organized to align to the project phases of Planning, Execution, and Closure. As previously mentioned, Monitoring and Controlling

The phases of the SDLC generally align with the phases of the project management lifecycle; however, the SDLC phases do not correspond on a one-to-one basis with the project management phases. The degree of alignment varies by the methodology used. The SDLC and PMLC work in conjunction with each other. The PMLC defines how to manage a project and parallels the SDLC. The PMLC describes the tasks that must be completed to produce a product or service. Different project lifecycles exist for specific products and services. However, most processes and deliverables are required for all projects, although in smaller projects they may require less formality and a lower level of effort.

Figure 25: PMLC, ALC, SDLC, and DMLC Alignment

2.6 Alignment of Lifecycles 2.0 Lifecycle Management 101

Aligning ALC to SDLC

The organization of the acquisition lifecycle is similar to that of the system development lifecycle and the project management lifecycle. ALC organizes procurement into a planning and preparation stage (Pre-Award) followed by execution and closure (Award and Post-Award). In an IT procurement, the acquisition activities are tightly coupled to the SDLC. All and operations activities. Once all contract deliverables are accepted, the contract is closed, which is directly related to project closure. SDLC benefits the ALC by allowing the customer to more effectively manage contracts. The SDLC provides a basis for planning and receiving long lead time items during system development. Purchases can be segmented and spread across the SDLC activities in a timely fashion that allows the customer to better manage and mitigate risks. The SDLC provides a means to schedule acquisitions and budget for them across the life of the system. The SDLC benefits individual contracts by establishing a specific schedule of deliverables and identifying the exact scope of work for performance work statements. The SDLC also establishes milestones to effectively manage contractor performance.

Aligning SDLC, ALC, and PMLC to DLC

All of the SDLC, ALC and PMLC activities rely on data and documentation. Managing the data and documents over the duration of these lifecycles should be done with attention and discipline equal to the other activities within each lifecycle model. Data lifecycle management provides a framework that shares a phase orientation with the other lifecycles. All these steps work together to achieve the goal of accountability and all produce myriad documents, records and other information, all of it vital data. That data must be properly maintained to prove adherence to procedure and provide accountability, as well as maintain privacy and security when necessary.

Project managers should ensure data management is incorporated into all of their project activities. This means ensuring the maximum availability of all essential information to support continued competitive acquisitions to support the system over its lifecycle. Simply having the data available is not sufficient if the most current information cannot be efficiently retrieved. The process of data management begins at the very beginning of the PMLC Initiating phase and lasts until after the SDLC disposal phase.

Aligning SDLC and the APD Process

In any project involving the APD process, the basic SDLC processes must be performed what differs is the timing of their execution. While no two development efforts are alike (and different methodologies may refer to these processes by different names), all projects should progress through the same processes or disciplines:

2.6 Alignment of Lifecycles 2.0 Lifecycle Management 102

System Initiation The business case and proposed solution are re-examined to ensure they are still appropriately defined and address an organizational need. A high-level schedule is developed for subsequent SDLC phases.

Systems Requirements Analysis The needs of the business are captured in as much detail as possible.

System Design Builds on the work performed during systems requirements analysis and results in a translation of the functional requirements into a complete technical solution. The completion of system design marks the point in the project at which the program manager should be able to plan, in detail, all future project phases.

System Construction The project team builds and tests the various modules of the application, including any utilities that will be needed during system acceptance and system implementation.

Documentation and training materials are developed during this phase.

System Acceptance Focuses on system testing and validation by those who will ultimately use the system to execute their daily processes. In addition to confirming the system meets functional expectations; activities also validate all aspects of data conversion and system deployment.

System Implementation The final phase, which includes training, installation of the system in a production mode, and transition of application ownership from the project team to the State agency.

Ultimately, the purpose of the Advance Planning Document is to provide accountability to stakeholders and to ensure proper stewardship of federal funds. Inherent to the APD process are review and approval cycles, as well as required documentation and processes for procurement, project management, security, and testing.

The APD process parallels the SDLC. There are different models and methodologies, but each generally consists of basic steps or stages during which defined IT work products are created or modified. The last phase occurs when the system is disposed of and the task performed is either eliminated or transferred to other systems.

Project means a related set of information technology related tasks, undertaken by a State, to improve the efficiency, economy and effectiveness of administration and/or operation of its human services programs. A project may also be a less comprehensive activity such as enhancements to an existing system, or an upgrade of computer hardware. 7 CFR 277.18(b)

2.7 Lifecycle Management

Summary

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2.7 Lifecycle Management Summary

This chapter has provided a brief overview of all of the lifecycle activities related to an IS project and how they interact with one another.

Systems Development Lifecycle (SDLC) is a phase-based process for;

o Planning, creating, testing, and deploying a system o Maintaining the system, operating the system, and retiring the system (i.e., disposal)

Project Management Lifecycle (PMLC) is phased to provide management control for;

o Initiating, Planning, Executing, Monitoring, Controlling and Closing

Acquisition Lifecycle Management (ACLM) impacts determination of needs, research, development, production, deployment, support and disposal of solutions. It can be broken into three major phases:

o Pre-Award Phase Acquisition Planning, RFP development and Solicitation o Award Phase Source Selection and Award o Post-Award Phase Contract Management and Closeout

Data Lifecycle Management (DLCM) creates processes for proper organization, security and disposal of data that control data storage, access, retention, and destruction

All lifecycle management frameworks (SDLC, PMLC, ALCM, and DLCM) share a common organization o Aligning them has many benefits such as cost control by mitigating the risk of duplicating work

Figure 26: SDLC, PMLC, and APD Integration

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various lifecycles. At a high level, State agencies must prepare for their own internal State clearance and compile the products resulting from the typical SDLC phases into the following key documents:

A Planning APD (PAPD) to address initiation, system concept development, planning, and requirements analysis

An Implementation APD (IAPD) to address design, development, integration and testing, implementation

APD closure and transition to maintenance and operations

3.0 The Advance Planning

Document Process

3.0 The Advance Planning Document Process

Key Points

The information in this section should allow you to understand the following:

What is the process for submitting APDs for FNS review?

What happens to APDs after they are submitted?

What are the different types of APDs and their purpose?

What are the required elements of each type of APD?

Chapter Contents

3.1 Overview of the Advance Planning Document

3.2 The APD Process

Introduction

Preparation & Submission

Review

Disposition

Performing APD Activities

Relationship Between Procurements and the APD Process

APD Closure

Post-Implementation Reviews

Regional Office Fiscal Closure

3.3 APD Information Specific to Program or Project Type

Planning APD

Implementation APD

APD Update

APDU As-Needed

3.0 The Advance Planning

Document Process

Emergency Acquisition Request

3.4 Post-Implementation APDs

3.5 APD Components

Actual Expenditures to Date

Annual APD Update Revised Documents

Alternatives Analysis

Capacity Plan or Study

Changes to the Approved APD

Change Management Plan (WIC EBT)

WIC EBT Clinic Management Plan

Contractor Performance

Conversion or Transition Plan

Cost Allocation Plan

Cost Analysis

Cost Benefit Analysis

Detailed Design Document

Disaster Recovery Plan

EBT Disaster Plan

Executive Summary General Guidelines

Feasibility Study

Functional Requirements Document

General System Design

Pilot and Statewide Expansion Retailer Enablement Plan

Project Management Plan

Project Status

Proposed Budget

3.0 The Advance Planning

Document Process

Quality Management Plan (WIC EBT)

Request for Waiver of Depreciation

Resource Requirements

Risk Management Plan (WIC EBT)

Schedule of Activities, Milestones, and Deliverables

Security Plan

State Agency / Contractor Assurances (WIC EBT)

Test Plan

Training Plan

Transmittal Letter

3.6 Summary

Chapter Acronyms APD Advance Planning Document

APDU Advance Planning Document Update

CBA Cost Benefit Analysis

EAR Emergency Acquisition Request

EBT Electronic Benefits Transfer

FFP Federal financial participation

IAPD Implementation Advance Planning Document

IAPDU Implementation APDU

MOU Memorandum of Understanding

PAPD Planning Advance Planning Document

PAPDU Planning APDU

RFP Request for Proposal

SDLC Systems Development Life Cycle

SOW Statement of Work

3.1 Overview of the Advance

Planning Document

3.0 The Advance Planning

Document Process

3.1 Overview of the Advance Planning Document

State agencies may receive federal funding to develop, acquire, and/or implement Information Systems (IS) that support the operation of FNS programs. State agencies are required to submit an Advance Planning Document (APD) to FNS in order to obtain prior approval to receive or utilize federal funding for IS supporting these programs.

the design, development, implementation, and operation of an information system (IS) supporting SNAP, WIC programs, and related EBT systems. The system must meet Federal, State, and user needs in an efficient, comprehensive, and cost-effective manner. The APD records information for the planning and implementation of the IS that is reviewed by FNS through the APD process.

APDs are designed to:

Establish system and program performance goals in terms of projected costs and benefits Provide the budget basis for securing Federal financial participation (FFP) for the State agency SNAP or a grant for the WIC State Agency

The APD is comprised of several documents resulting from activities related to the Systems Development Lifecycle (SDLC). The APD process is not the same as the SDLC, but is closely associated with it. Where the SDLC focuses on system planning, development, and implementation, the APD focuses on documenting these SDLC activities.

In addition to gaining FNS approval for FFP or other associated funding for IS projects, the APD is also used as a means for FNS review and oversight of IS projects. The APD enables FNS to fulfill its stewardship responsibilities for FFP. Where chapter 1.0 Getting Started with the Advance Planning Document (APD) Process provides a general overview of the APD process, this chapter focuses on the specific elements of the different APDs and the process for submitting and obtaining approval for APDs.

For definitions of terms used in this handbook please see appendix A1 Acronyms and Glossary of Terms.

3.2 The APD Process 3.0 The Advance Planning

Document Process

3.2 The APD Process

Introduction

In general, the APD process is the same for each FNS program (i.e., SNAP and WIC). Likewise, most of the APDs follow a common process, differing in the specific APD contents and how these are reviewed based on the res implementing IS in advance of carrying them out and incurring costs. The differences between APDs are based on specific requirements and nuances for each FNS program that alter the APD contents and process slightly. This section explains the common processes for preparation, submission, review, and disposition for each type of APD. Specific details for each APD will be explained in section 3.3 APD Information Specific to Program or Project Type.

implementation, and operation of an IS supporting SNAP, WIC, and related EBT systems. It is a period of communication and cooperative oversight between the State agency and FNS lasting the duration of the project.

Submission is determined by relevant thresholds for APD documents and procurement documents. State agencies may not execute contracts or obligate funds without this approval.

HOW TO USE THIS CHAPTER

Chapter 1.0 Getting Started with the Advance Planning Document (APD) Process and chapter 3.0 The Advance Planning Document Process must be used together. Determining the need to submit an APD is described in Chapter 1. Chapter 3 describes the common process details for all APD types and the specific details for each APD type. This chapter also explains the details of the process for preparation, submission, review, decisions related to each APD, and APD closure.

1. Read the APD common process (section 3.2 The APD Process and all sub-sections) to understand the general process requirements for APDs.

2. Read the specific information for the APD you are preparing in the appropriate sub-section of section 3.3 APD Information Specific to Program or Project Type

3. Each type of APD has specific required documentation components. Refer to section

The APD process focuses on areas of SNAP and WIC program functionality that may benefit from IT solutions.

using program resources, improving federal reporting and accountability, and achieving local agency efficiencies using IS to support SNAP, WIC, and related EBT systems. Planning and implementation using FFP is constrained by allowable costs, budget, and staffing levels. In addition to these, planning takes into consideration maintenance and security issues, compatibility with other existing or anticipated State projects, procurement rules, contractual terms, and transitioning costs from development to operations. FNS reserves the right to be included in planning and project meetings as appropriate. This chapter explains in more detail the purpose, document requirements, preparation, and submission for each type of APD.

3.2.1.1 The General APD Process

The APD process is a series of successive steps through which a State agency can meet federal oversight requirements. The APD process has eight basic steps that are the same for PAPDs and IAPDs.

These include:

1. Prepare the APD (State agency)

2. Submit the APD to FNS (State agency)

3. Review the APD (FNS)

4. Notify State agency of decision (i.e., approve or disapprove) (FNS)

5. Conduct procurements when applicable (State agency)

6. Perform activities described in APD (e.g., planning or implementation) (State agency)

7. Provide annual APD updates as appropriate (State agency)

8. Close the APD when the activities described in the APD are complete (FNS and State agency)

Figure 27 provides an overview of the APD processes. Typically, the activities conducted after a PAPD is approved will lead to the creation of an IAPD as shown in Figure 27. An APD approval means FFP is approved for conducting the activities described in the APD. PAPD funding is used for planning only. IAPD funding is used for implementation only. When planning and implementation activities exceed one year, the State agency must provide FNS with an annual APD Update (APDU). The APDU is one of the requirements for continued funding.

See chapter 1.0 Getting Started with the Advance Planning Document (APD) Process for the applicable thresholds for determining submission requirements for each type of APD.

Figure 27: Overview of PAPD and IAPD Processes

When the activities described in the approved APD are completed, the APD is closed using a final APDU. At this point the system enters the M&O phase of the SDLC. See section 3.4 Post-Implementation APDs for more information of APD activities during the M&O phase.

State agencies are urged to communicate with FNS early and often when undertaking an IS project to verify information required and avoid disallowances. Retroactive approvals are granted only in the most extreme circumstances. Poor planning or communication is not considered valid reasons for retroactive approval of expenditures.

State agencies must be able to properly follow the APD process, regardless of the size of the project or procurement (e.g., enhancement, upgrade, interim, or full-scale projects), and submit the appropriate documentation based on funding thresholds.

See chapter 1.0 Getting Started with the Advance Planning Document (APD) Process for (section 1.5.1).

See chapter 4.0 Procurement for the applicable thresholds for determining submission requirements for RFPs and contracts (section 4.3.1).

3.2.1.2 Relationship of APD Process to SDLC

The APD process parallels the SDLC for developing IS through multiple phases of investigation of initial requirements through analysis, design, implementation, operations, maintenance, and disposal. The APD process is designed to be flexible and adaptable to different system design methodologies (e.g., waterfall, incremental, or iterative) and operational management strategies.

Figure 28 illustrates the major SDLC activities corresponding to the PAPD and IAPD over the course of a typical IS project.

APD.

The APD process in Figure 28 assumes all APD activities are approved.

See chapter 2.0 Lifecycle Management for details on the relationships between the SDLC, the APD process, and development methodologies.

Figure 28: Major SDLC Activities Related to the APD Process

Preparation & Submission

3.2.2.1 Preparation

The documentation required for each APD varies by type of APD and program. To receive approval and subsequent funding, all documentation must be present and include sufficient content to allow FNS to make an informed decision on the APD request. Complete information and good communication among partners expedites review. Because the contents of each type of APD varies, documentation requirements and preparation of each is described later in this chapter in the appropriate section for that type of APD.

Planning APD o Preparation see sections 3.3.1.3 PAPD Documentation Requirements and 3.3.1.4 Preparing the

PAPD

o Submission see section 3.3.1.5 Submitting the PAPD

Implementation APD o Preparation see sections 3.3.2.3 IAPD Documentation Requirements and 3.3.2.7 Preparing the

IAPD

o Submission see section 3.3.2.8 Submitting the IAPD

APD Update o Preparation see sections 3.3.3.3 APDU Documentation Requirements and 3.3.3.4 Preparing the

APDU

o Submission see section 3.3.3.5 Submitting the APDU

APDU As-Needed o Preparation see sections 3.3.4.3 APDU As-Needed Documentation Requirements and 3.3.4.4

Preparing the APDU As-Needed o Submission see section 3.3.4.5 Submitting the APDU As-Needed

Emergency Acquisition Request (EAR) o Preparation see sections 3.3.5.3 EAR Required Documentation and 3.3.5.4 Preparing the EAR o Submission see section 3.3.5.5 Submitting the EAR

FFP payments may be disallowed if FNS finds that any approved system project fails to comply with the criteria, requirements, or other specifications described in the approved APD or APD Update.

The State agency must prepare for its own internal State clearance and State-level regulatory compliance for IS projects in addition to complying with federal regulatory requirements. (See appendix A2 Regulations for a listing of applicable general federal policies and guidance, as well as those for each program.) The Planning APD and the Implementation APD are the two key documents that must be submitted based on dollar threshold submission requirements. (See 1.5 Determining the Need for an APD.)

3.2.2.2 Submission

The State agency prepares and submits all APDs to FNS electronically, including a scanned copy of a transmittal letter signed by an official authorized to commit State resources.

When a project involves multiple federal partners, one combined APD is developed. The State agency is required to submit the APD separately to each agency that is providing FFP. The State Agency should ensure that all FNS required content is included in the combined APD.

Before preparing the APD, the State agency should also consult with the internal State IT oversight department to determine whether any additional documents or procedures are suffice.

State agencies need not format documents exactly as described in this handbook to receive FNS approval.

APD in any standard, professional format. FNS review may be facilitated by the State agency providing a cross-walk or document map to the FNS required APD content.

The electronic submission should be sent to the appropriate FNS Regional Office, with a copy to the appropriate State Systems Office analyst, if known. See the FNS website for the State Systems Office and RO contact list (http://www.fns.usda.gov/apd/contacts-and-stakeholders).

In the event a project originally estimated to cost less than the $6 million threshold for SNAP or $500,000 for WIC encounters changes in prices or scope that increase the costs to exceed these thresholds, the State agency must submit an APD to FNS for approval of the entire project, not just the portion over the threshold. In such a circumstance, the State agency should work with FNS to ensure that all information requirements of the APD are met prior to submitting the APD for approval. This will assist FNS in reviewing and making an approval determination and obviate or shorten any project slowdown during the approval process.

Review

3.2.3.1 APD Reviews in General

In general, when FNS reviews APDs, it seeks to ascertain the program benefits and overall process improvements to be obtained through the proposed IS. FNS review typically addresses the following questions:

1. Who is/are the requesting State agency(ies)?

2. What is the purpose of the project?

3. Which Federal/State programs are involved/affected?

4. How will the project be conducted (contractor support, in-house, combination)?

5. Will the project involve any lease/purchase of software/hardware, etc.)?

6. Which State and federal funding agencies are involved?

7. What is the projected cost of the project, and is the cost reasonable and necessary?

8. What are the benefits of the project to the affected program(s)?

The FNS HB901 provides guidance for USDA APD processes ONLY. It does not provide guidance for APD requirements for other Federal agencies, such as DHHS, who may also be providing Federal financial participation.

For SNAP EBT, FNS approves the RFP and negotiated contract prior to the State incurring any costs. Under the new contract, the State must submit the IAPD to FNS for review and approval, one copy each to the RO and SSO. Failure to complete this step will jeopardize FNS

FFP.

9. Will the project benefits support the costs (Cost Benefit Analysis (CBA))?

10. What is the project schedule?

11. Does the budget reflect all allowable costs (staff time, training, equipment, travel, testing, etc.)?

Figure 29 summarizes the overall FNS review process. The process assumes the State agency will start with planning activities that require a PAPD, even though there are some circumstances when this is not the case. The process. The process assumes the PAPD will lead to successful planning activities that will generate continuation of the process into the implementation phase that requires an IAP represents each type of APD (e.g., PAPD, IAPD, APDU, APDU As- Needed, or EAR), again depending on where the applicable timelines (see section 3.2.3, including all sub- ion to applicable to each type of APD (PAPD and IAPD) when appropriate. The PAPD is closed sometime near the beginning of the implementation, commonly after the IAPD is approved. The IAPD is closed when implementation is completed and FNS has approved system roll-out.

3.2.3.2 APD Evaluation in General

When reviewing the APD (PAPD or IAPD), FNS follows several steps before deciding to approve or disapprove the

Examines the transmittal letter to ensure that it is signed by an appropriate project sponsor with the authority to commit state resources

Notifies the State agency of receipt of the document(s) Conducts a preliminary review of the document for completeness

Figure 29: General FNS Review Process

Evaluates whether the document adequately addresses IT technical and security issues, cost and benefit issues, Federal/State procurement regulations, and program needs assessment by meeting the following review criteria:

o Describes planning activities that justify the costs involved or that are otherwise consistent with the objectives of FNS programs o Identifies key stakeholders in the planning process and explains how relationships with other programs or organizations will be considered o Demonstrates availability of funds, resources, and skills to conduct the proposal in a satisfactory manner o Reflects an itemized planning budget by federal fiscal year and quarter and identifies the sources and amounts of federal and non-federal funding and the basis for the allocation of costs among the sources o Includes proposed cost allocation, if applicable o Describes the scope of the appropriate planning activities that meet the identified project objectives and needs Notifies the State agency if more information is needed or changes are required Notifies the State agency if documentation is missing or incomplete Coordinates comments and requests for information between financial, and program entities at different organizational levels at FNS, as needed

Meets with the State agency on all negotiable matters Provides technical assistance to the State agency, as appropriate and necessary Notifies the State agency of APD closure (PAPD or IAPD) after it has successfully completed all APD activities

State agencies are encouraged to work closely with FNS to facilitate document review and funding approval in a timely fashion. States may also request that FNS performs reviews in parallel with their internal State reviews, its reviews as soon as possible. Good communication between parties can serve to facilitate the review process.

In reviewing the IAPD, FNS will focus on successful project management (see chapter 7.0 Project Management) to ensure the IAPD provides a project plan the State agency can follow for a successful implementation. Identification and management of risks are key elements FNS looks for in the project plan.

3.2.3.3 FNS APD Review Timeframes

Document review timeframes are defined for all APDs and associated documents submitted to FNS. With the exception of the EAR8 and WIC EBT PAPDs, FNS has 60 days to review a document It is important that both and approve, disapprove, or request additional information. The clock stops when FNS communicates to the State agency the approval, disapproval, or a request for additional information. If FNS requests additional information, the clock starts another 60-day review cycle when FNS receives the State response.

FNS strives to review all documents in less than the allotted 60 days. State agencies are asked to consult with FNS as frequently as needed to address FNS questions and comments in a timely manner. FNS views the APD process

The review period for Emergency Acquisition Requests is 14 days, not 60 days.

The review period for WIC EBT Planning APDs is 30 days, not 60 days.

Figure 30: APD Review Clock as a Federal/State partnership and strives to implement a team effort in fulfilling the requirements of the process.

Figure 30 illustrates how the APD Review Clock is applied by FNS.

Table 7 is a sample timetable that presents a timeline using the full 60 days provided for document review and approval for both APDs and procurement documents. State agencies that provide complete required information can minimize the review period because key documents would be approvable with few or no revisions.

Table 7: APD Federal Review Sample Timetable

Process Step Expected Completion Date Approval/Recommended

Time Period (when applicable)Month Year

Planning Phase (24 months)

SA submits Planning APD to FNS January year 1

PAPD approved by FNS March year 1 60 days

SA submits Planning RFP to FNS March year 1

Planning RFP approved by FNS May year 1 60 days

SA releases Planning RFP June year 1 90 days

Proposals evaluated/selection made September year 1 30 days

SA submits contract to FNS October year 1

Contract approved by FNS December year 1 60 days

PAPDU submitted January year 2

Contract signed February year 2

PAPDU approved by FNS March year 2 60 days

Planning phase begins (contractor-on-board)

March year 2

Planning phase completed (one year for planning activities)

February year 3

PAPD Closure (submit final PAPDU) February year 3 60 days

PAPD Closed (final PAPDU approved by FNS)

April year 3 As needed

Implementation Phase (12 months to contractor-on-board)

SA submits IAPD to FNS October year 2

Table 7: APD Federal Review Sample Timetable

Process Step Expected Completion Date Approval/Recommended

Time Period (when applicable)Month Year

IAPD approved by FNS December year 2 60 days

SA submits Implementation RFP to FNS December year 2

RFP approved by FNS February year 3 60 days

SA releases Implementation RFP March year 3

Proposals due from bidders May year 3 at least 90 days

Proposals evaluated/selection made August year 3

SA submits contract to FNS November year 3

Contract approved by FNS February year 4 60 days

Contract signed May year 4

SA begins implementation activities November year 4

SA submits IAPDU to FNS October year n

IAPDU approved by FNS December year n 60 days

IAPD Closure (submit final IAPDU) Month year n

IAPD Closed (final IAPDU approved by FNS)

Month year n As needed

Total Estimated Time Before Beginning Implementation Activities: 34 months (Does not account for simultaneous or iterative activities)

Disposition

After FNS reviews APD documents, including additional information that may have been requested, a decision will be made and provided to the State agency in writing. There are two possible decision outcomes: approved and disapproved.

3.2.4.1 Approval Decision

Approvals for APD documents and funding requests are issued by FNS Regional Offices (RO). The State Systems Office (SSO) works closely with the ROs and coordinates the APD process for FNS. APD coordination related to

WIC EBT delivery methods is handled by the RO WIC Program directly. Centralized coordination promotes the consistent application of policy and procedures across regions and provides an opportunity for enhanced customer service.

If approval is granted for an APD, FNS will notify the State agency and include one of the following conditions of approval:

General - Related to availability of federal funds and compliance with FNS regulations Specific - Funding might be approved for a specific time period or incrementally based on satisfying specific conditions, such as submitting additional documents requested by FNS

Some examples of specific conditions that FNS could require include the following:

Due to high risk or funding conditions for a project, monthly progress reports are required Specific contractor deliverables must be shared with FNS

3.2.4.2 Disapproval Decision

FNS may disapprove a project plan if it determines that one of the following conditions occurs:

Cost, scope, or methodology proposed are not feasible Analysis conducted by the State agency was insufficient and did not result in a valid outcome Procurement proposed or conducted was not allowable

Any planning or implementation costs incurred prior to APD approval will remain the responsibility of the State agency. No retroactive approval will be granted.

Approval of planning activities does not guarantee approval of FFP for implementation activities.

FNS rarely disapproves a project plan completely. Whenever possible, FNS will work with a State agency to identify and remedy possible concerns throughout the planning phase or help the State adjust the plan to reach approval.

3.2.4.3 Provisional Approval in SNAP

Provisional approval is in effect if a SNAP State agency does not receive approval, disapproval, or a request for additional information within 60 days of receipt of the FNS acknowledgment. This would not, however, exempt a State from meeting all other federal requirements that pertain to the acquisition of IS equipment and services.

Such requirements remain subject to federal audit and review. FNS will make every effort to respond to State agencies within the targeted review periods.

Performing APD Activities

Assuming the APD (i.e., PAPD or IAPD as appropriate) is approved, the State agency proceeds with the SDLC activities. If contractor services are required, the State agency prepares and submits the Request for Proposal (RFP). FNS reviews the RFP and notifies the State agency if more information is needed. FNS approves or denies the RFP and informs the State agency of the decision. Figure 31 depicts the general RFP and contract review process.

Relationship Between Procurements and the APD Process

Many planning and implementation projects involve procuring contractor services, equipment, software, or all of these. The costs of these procurements are part of the total project costs used for determining whether an APD is required. If procurement is needed, the RFP and contracts resulting from the RFP must be submitted for review and approval prior to the issuance of the RFP or the execution of the contract. States may submit RFPs simultaneously with APDs. States may submit the draft contract prior to the release date of the RFP. Changes (i.e., amendments) to existing contracts may also need FNS review and approval. Like the APD, this is based on the potential dollar value of the contract or amendment. While related to APD thresholds, the need for FNS RFP and contract review determination is separate from APD thresholds. Also, the thresholds are different for competitive and non-competitive procurements.

Provisional approval does not apply to WIC.

Once the procurement activities are completed and a contract is ready to be executed, the State agency follows the same process as for the RFP. The State agency prepares and submits the contract. FNS reviews the contract and notifies the State agency if more information is needed. FNS approves or denies the contract and informs the State agency of the decision. Once contractors are on board, the appropriate activities begin. Annual APDUs are submitted accordingly until the activities in the APD are completed.

Figure 31: RFP and Contract Process Review

Because the activities described in each type of APD are different, performance of the specific activities is described in the APD type descriptions later in this chapter.

Planning APD see section 3.3.1.6 Implementation APD see section 3.3.2.9 APD Update see section 3.3.3.6 APDU As-Needed see section 3.3.4.6 Emergency Acquisition Request (EAR) see section 3.3.5.6

APD Closure

When all APD activities have been completed, the State agency provides a final APDU (i.e., Planning APDU or Implementation APDU) to advise FNS that all APD activities have been completed. Closing a PAPD or an IAPD entails confirming that the project objectives have been met and determining the actual costs incurred. The recommended timeframe for submitting the final IAPDU is after a post-implementation review is conducted or at the end of the system warranty period. The final APDU includes the final budget showing actual costs. Official closure of the APD must occur to document the end of the approved activities, the actual costs incurred, and to begin the process to close-out FNS funding activities. FNS notifies the State agency of APD closure in writing.

FNS requires submission of final documentation to validate all aspects of the project prior to closure. FNS verifies that the State agency has successfully completed all APD activities and notifies the State agency of APD closure.

Since the closure process may include document review as well as on-site review(s), the standard FNS 60 day review timeframe does not apply. To close out a PAPD or an IAPD, the State must submit the information as shown in Table 8.

Table 8: Closure Documentation Requirements

Documents PAPD IAPD

Transmittal Letter (3.5.33)

Final project plan showing all work complete

Final summary of work complete

Final budget showing all expenditures by line item by federal fiscal year and quarter

Final cost allocation across all contributing entities (if applicable)

List of all deliverables and payments made to contractors or State IT staff

Description of the goals met by the project and any deviations from the last approved APDU

Table 8: Closure Documentation Requirements

Documents PAPD IAPD Description of any problems encountered during system development and implementation and their resolutions

Description of any outstanding issues and how these will be resolved (these should be minor or closure cannot occur)

Estimate of annual operating costs for the new system

Documentation of any post-implementation reviews or reports conducted by the State or contractors, if available

If projects become dormant (display no activity for a substantial period of time) or are abandoned (no longer being conducted by the State agency) before they attain the goals set forth in the APD, FNS will contact the State to determine if a need still exists for the project. FNS may close the APD at its own discretion, terminate funding availability, and recover any unused funds owed, as applicable to each program. FNS will make every effort to close an APD only when the project has been completed or when there is mutual agreement with the State agency.

Post-Implementation Reviews

Before closing the IAPD, FNS may conduct a post-implementation review of costs and system functionality once the system is fully operational statewide.9 A critical reason for the post-implementation review is to ensure that the system is reviewed and evaluated before the warranty period expires. After implementation, a State agency may have a limited time to identify any problems or shortcomings with the system and to get them fixed during the warranty period.

The post-implementation review typically occurs approximately 6 months after system deployment statewide to accommodate the initial user learning curve. FNS may conduct an onsite post-implementation review to ensure the State accomplished the goals stated in its APD. This review encompasses the program, technical, security, and financial aspects of the system. FNS will require submission of a final Implementation APDU to update all aspects of the project.

-implementation review may include verifying the following:

Program policy is correctly implemented by the system The system reflects the specified system requirements as approved in the IAPD

The system satisfies requirements in the areas of accountability, management, user training, documentation, security, and use of automated tools

3.3 APD Information Specific to

Program or Project Type

3.0 The Advance Planning

Document Process

The information systems equipment and services are being properly used in meeting objectives described in the IAPD, and accurate equipment inventory records exist as required by 2 CFR 200.313(a)(1)-Title and Use of Equipment by Non-Federal Entities10

The actual costs of the project and any significant divergence from the cost estimates in the most recently approved APDU

The cost allocation methodology was complied with and all charges made were for eligible costs All aspects of the system have been validated before the warranty period expires

The financial management (FM) portion of the review is often conducted separately as part of the planned FM reviews of State agencies conducted by FNS Regional Offices.

FNS will prepare a detailed report of its findings and submit the report to the State agency within 60 days of the review. The State agency has 45 days from the date of receipt of the review findings to inform FNS of its proposed corrective actions, if required.

Regional Office Fiscal Closure

Once FNS has determined a project may be closed from an APD standpoint, the APD will be referred to the FNS RO for fiscal closure. The FNS RO will compare expenditures reported in the annual APDU with reported expenditures for IS development from both of the following forms:

Form FNS 798: WIC Financial Management and Participation Report Form SF-425/778: Financial Status Report with addendum

Any differences are to be examined and reconciled. There should be no significant differences between expenditures reported on the FNS 798 or SF 425/778 and those reported in the annual APDU. Reconciled expenditures should be compared with the approved APD budget to determine if budget revisions are required.

In addition, the FNS RO should examine that the State has complied with the requirement to submit an APDU-As Needed with revised budget projections. The FNS RO must notify the designated SSO representative of any inconsistencies or inaccuracies in project budgets that cannot be reconciled. Otherwise, the SSO should be notified when the budget is reconciled and send a closure letter to the State agency.

3.3 APD Information Specific to Program or Project Type

Now that the general APD process has been described, this section describes the purpose and specific content of each type of APD along with unique preparation and submission requirements. It also describes the activities the State agency will perform as described in each type of APD once the APD is approved.

3.0 The Advance Planning

Document Process

Planning APD

3.3.1.1 Purpose of PAPD

The Planning APD is a brief document (usually 6 10 pages) describing the plan of action to accomplish the planning activities for an IS project supporting certification, eligibility, or related EBT systems. It documents necessary planning for a State agency to determine the need for, feasibility of, and projected costs and benefits of an IS equipment or services acquisition. It includes a brief explanation for procuring IS equipment and/or services and developing information necessary to carry out the planning process and prepare an Implementation APD. A State agency must use a PAPD to declare its assurance that the system will meet program requirements; request prior approval; and obtain a commitment for federal funding from FNS to plan major system development efforts, enhancements, or upgrades.

The planning process, describes the planning activities to be done, and explains how the State agency will manage the activities. It also describes the project purpose and goals. Submission and approval of a PAPD is required before a State agency begins to incur planning costs for system development efforts, system enhancements, or upgrades.

Therefore, it is important to consult with FNS before initiating any planning activities.

Should the State agency decide to expand the scope of planning activities after the PAPD has been approved, an

FNS- -

3.3.1.2 Related SDLC Activities for PAPD

After the PAPD is approved, the State agency will begin planning SDLC activities. These include requirements definition, a feasibility study including alternatives analysis, and a Cost Benefit Analysis (CBA). The purpose of these activities is to evaluate the existing system and its business practices, define the future system business requirements, identify feasible solutions, assess systems acquisition methodologies, and prepare the Implementation APD.

Planning activities can vary by State agency, with the primary aim of developing a viable Implementation plan suitable for the specific State agency program and operational environment. Among the typical planning activities, a State agency will conduct an evaluation of changes to the State IS. Planning should consider possible

3.0 The Advance Planning

Document Process replacement of the current system and assess State agency and local operational and policy changes. Planning should identify resource needs and determine the State or contractual resources necessary to implement and operate the system. The State agency may also use the planning period to explore specific approaches and technologies with critical stakeholders such as retail vendors, State and local staff, and technology staff. FNS recognizes that State agencies often start the planning process with a specific technology in mind. The focus of the planning activity is to perform activities and make decisions, as well as develop supporting information, that will be presented in the IAPD. The last step of the planning phase is the preparation of an IAPD, which is submitted to FNS for approval.

It is incumbent upon the State agency to notify FNS when the State legislature approves funding to support major IS initiatives that will affect program administration. Examples of State legislature activities that could impact program initiatives include deadlines for overhauling the system interfaces or organizational restructuring of the State agency that includes the program. This will provide FNS ample time to assess the magnitude and possible policy implications that a change from the legacy system may present. Information on any mandate, requirement, deadline, or funding from the legislature that is driving a project should be included in the submission. Please see section 3.2 The APD Process or 7 CFR 277.18.(d)(2)11 for details of the PAPD process in its entirety.

3.3.1.3 PAPD Documentation Requirements

PAPDs are usually short, simple, and concise documents. Because of the nature of PAPDs, the required documentation tends to be a single narrative stand-alone document with attachments that include an initial planning phase schedule, an estimated budget, and a preliminary cost allocation plan. However, this varies depending on the complexity of the planning activities being undertaken. Consult with FNS for guidance and samples of the required PAPD documents, as needed.

The components required when submitting a PAPD are outlined in Table 9. For detailed descriptions of each required document, refer to section 3.5 APD Components.

For SNAP EBT, A PAPD is only required if the State agency is exploring new technology or expects to incur excessive planning costs. Otherwise, a PAPD for SNAP EBT is not required.

3.0 The Advance Planning

Document Process

Table 9: PAPD Documentation Requirements

Document Components SNAP SNAP EBT WIC WIC EBT

Transmittal Letter (See 3.5.33) n/a

Executive Summary (See 3.5.16) n/a

Schedule…