Attachment_2_-_Addendum_to_52.212-2_FIAR_FINAL.pdf

RFP FA7014-17-R-5002 Attachment 2

Addendum to 52.212-2 – Evaluation – Commercial Items

1.0 Basis for Contract Award

1.1 This is a performance-price tradeoff source selection conducted in accordance with Federal

Acquisition Regulation (FAR) 12, Commercial Items, as supplemented by the Defense Federal

Acquisition Regulation Supplement (DFARS), and the Air Force Federal Acquisition Regulation

Supplement (AFFARS). These regulations are available electronically at the Air Force (AF)

FARSite, http://farsite.hill.af.mil.

1.2 The Government intends to award a single award Indefinite Delivery/Indefinite Quantity

(IDIQ) and will select the proposal found to be most advantageous to the Government considering IPA certification, OCI Mitigation Plan, technical approach, past performance, and cost/price. The evaluation criteria are divided into three (3) factors: Technical, Past

Performance, and Cost/Price. The tradeoff process for this acquisition will permit a tradeoff between past performance and cost/price for technically acceptable proposals in reaching the contract award decision. The Contract may be awarded to the offeror who is deemed responsible in accordance with the FAR, as supplemented, whose proposal conforms to the solicitation’s requirements (to include all stated terms, conditions, representations, certifications, and all other information required by Addendum to 52.212-1 – Instructions to Offerors – Commercial Item of this solicitation) and is judged, based on the evaluation factors and subfactors to represent the best value to the Government. The Government seeks to award to the offeror who gives the Air

Force the greatest confidence that it will best meet the requirements. This may result in an award to a higher rated, higher priced offeror, where the decision is consistent with the evaluation factors, and the Source Selection Authority (SSA) reasonably determines that performance of the technically acceptable higher priced offeror outweighs the cost difference. The SSA will base the source selection decision on an integrated assessment of proposals against all source selection criteria in the solicitation (described below). While the Government source selection evaluation team and the SSA will strive for maximum objectivity, the source selection process, by its nature, is subjective; and therefore, professional judgment is implicit throughout the entire process.

1.3 This contract is a competitive full and open procurement. The Government intends to award one (1) indefinite delivery/indefinite quantity (ID/IQ) contract as well as task orders 0001-0007.

for the SAF/FM Financial Improvement & Audit Readiness (FIAR). However, the Government reserves the right to make no award at all. This acquisition will result in a Firm Fixed Price

(FFP) contract, with a cost reimbursable line item for travel. The Government will review the proposals for responsiveness. If a proposal is non-responsive then it will not be further evaluated.

1.4 The evaluation will be completed in the following steps:

1.5 Step 1: IPA Certification. The CO will review IPA certifications after submission on 25

September 2017 and the Offeror will be notified within five (5) days of receipt of the IPA certification if they will proceed to Step 2. If the firm does not meet criteria, the proposal will not be evaluated further.

1.6 Step 2: OCI Mitigation Plan. The Government will review the Offeror’s proposed OCI

Mitigation Plan or statement that no OCI exists to determine if there is an OCI. If the CO determines no OCI exists, the offeror will move to step 3. If the CO determines there is an OCI, but it can be mitigated, then the offeror will move to step 3. If the CO determines there is an

OCI that cannot be mitigated, the government will not evaluate any further and the offeror will not continue to step 3. The Government will provide the PCO’s determination of the offeror’s

OCI plan of acceptability or unacceptability in writing.

1.7 Step 3: Evaluate remaining factors. The Government will evaluate technical, past performance, price which includes evaluation of the proposed small business participation plan.

2.0 Correction Potential of Proposals

2.1 The Government intends to award without exchanges. Accordingly, offerors are advised to submit initial proposals that are fully and clearly acceptable without additional information. The

Government will not search for information within the proposal in order to make the proposal acceptable. However, if during the evaluation period, it is determined to be in the best interest of the Government to hold exchanges, a notice will be sent to the offeror.

2.1.1 If exchanges are necessary, the Government will issue Exchange Notices (ENs) as necessary to offerors. ENs will be sent electronically to offerors to ensure complete understanding of any discrepancies. Any necessary page changes to the offeror’s proposals will be obtained prior to concluding exchanges. Throughout the exchange process, the Government will document any changes in ratings and total evaluated cost/price. Offeror responses to ENs and the Proposal Revision Opportunity (PRO) at the conclusions of exchanges will be considered in making the source selection decision. If the offeror’s proposal has been evaluated as acceptable at the time exchanges are closed, any changes or exceptions in the PRO are subject to evaluation and may introduce risk that the offeror’s proposal be determined unacceptable and ineligible for award.

2.1.2 Offerors may be asked to clarify certain aspects of their proposal (for example, the relevance of past performance information) or respond to adverse past performance information to which the offeror has not previously had an opportunity to respond.

Adverse past performance is defined as past performance information that supports a less than satisfactory rating on any evaluation element or any unfavorable comments received from sources without a formal rating system.

3.0 Evaluation Factors and Subfactors

3.1 The following evaluation factors and subfactors will be used to evaluate each proposal: Award will be made to the offeror proposing the combination most advantageous to the Government based upon an assessment of the evaluation factors and subfactors described below.

3.1.1 Factor I: Technical

Subfactor 1: Methodology and Approach to Complete PWS Tasks

Subfactor 2: Management Plan

Subfactor 3: Staffing Plan/Recruiting and Retention Plan

Subfactor 4: Transition Plan

3.1.2 Factor II: Past Performance

Subfactor 1: Contract Management History

Subfactor 2: Auditing

Subfactor 3: Audit Advisory

3.1.3 Factor III: Cost/Price

(Including Small Business Participation Plan (SBPP)

3.2 Factor I: Technical

The Government will rate the IDIQ technical proposal at the subfactor level and assign a rating of “Acceptable” or “Unacceptable.” The subfactor ratings will be rolled up into an overall

Technical Factor rating. All subfactors must receive a rating of “Acceptable” in order for the

Technical Factor rating to be found “Acceptable.” If any subfactor is rated as “Unacceptable” then the overall Technical Factor rating will be “Unacceptable.”

Table 1

Rating Description

Acceptable Proposal meets the requirements of the solicitation.

Unacceptable Proposal does not meet the requirements of the solicitation.

3.2.1 Subfactor 1: Methodology and Approach to Complete PWS Tasks at the IDIQ level this subfactor demonstrates an offeror’s understanding, approach, and methodology to complete the required tasks IAW the PWS. The Government will evaluate the offeror’s proposed approach/methodology, understanding of the requirement and associated processes to complete all required tasks IAW PWS requirements.

3.2.2 Subfactor 2: Management Plan at the IDIQ level

This subfactor demonstrates an offeror’s plan to monitor their employees at multiple locations, including subcontractors, to continuously meet the Government’s requirements as outlined in the

PWS. This subfactor will be evaluated based on the Offeror’s sound management plan for oversight of a minimum of 200 FTE’s as a prime contractor or have performed as a subcontractor having managed at least 100 FTE’s.

3.2.3 Subfactor 3: Staffing Plan/Recruiting and Retention Plan

This subfactor demonstrates an offeror’s capability to properly allocate resources in accordance with the PWS and the capability to recruit and retain employees.

At the IDIQ level the Government will evaluate the cross reference matrix (attachment 3) that assigns the proposed labor categories and FTEs to specific PWS task areas. If applicable, the

Government will evaluate any alternate labor categories proposed by the offeror. The technical cross-matrix will be evaluated to assess the offerors full understanding of the requirement for staffing resources and overall management of the entire project and scope.

Task Order: The Government will evaluate the proposed FTEs and labor categories. The

Government will use the TO Request Form (Attachment 5) to assess that the offeror is proposing enough resources to meet the full requirement of the PWS.

The Government will review submitted resumes for all key personnel to show an understanding of the requirement. The Government will evaluate the Offeror’s staffing plan for a solid approach that demonstrates an offeror’s plan to minimize impact on recruiting, and staff and retain. The Offeror shall submit resumes for Key Personnel and identify the attachments

(resumes) as Appendix A.

3.2.4 Subfactor 4: Transition Plan (To include Transition Phase-In Plan and Phase-Out

Plan).

The Government will evaluate the approach to successfully execute, without mission degradation and successfully credentialing employees at multiple locations within the 45 day transition period. The Government will evaluate the offerors approach and plan for a smooth transition in the turnover of work to/from the incumbent contractor. The Government will evaluate the offerors plan that shall have addressed the following:

a. Key transition personnel

b. Schedule of activities

c. Understanding of current workload and milestones

d. Minimizing disruption to ongoing projects and mitigating any potential disruptions

e. Staffing projects

f. Communication with key stakeholders (e.g., incumbent/successor Offeror management and staff, COR and PCO)

g. Project management reporting and tracking

i. Should demonstrate the management of any program risk to include loss of continuity for the task areas. The Offeror shall provide a robust/well defined mitigation plan that will address any type of risk or unknown risk for the mission.

3.2.4.1 The Government will evaluate the Phase-Out Plan for the approach to include the areas listed above. The plan should address any unforeseen risks, mitigation of the risks, methodologies, areas of staffing

3.3 Factor II: Past Performance

The Past Performance evaluation results in an assessment of the offeror’s probability of meeting the solicitation requirements. The Past Performance factor will receive one of the performance confidence assessments based on the recency, relevancy, and quality assessment ratings per the criteria below. The Past Performance Cross-Reference Matrix will be reviewed but not evaluated for this factor. The matrix is provided to ensure that the Offeror has addressed all areas of the past performance.

3.3.1 The Government will review up to nine (9) total contracts for past performance submitted by the Offeror, minimum of one (1) and maximum of three (3) contracts for Contract Management

History; a minimum of one (1), and maximum of three (3) contracts for Auditing; a minimum of one (1) and a maximum of three (3) contracts for Auditing Support/Advisory. The Offeror may submit the same information for all three performance categories if that information satisfies recent and relevant past performance for all three performance categories. Any submission in excess of the limit will not be considered and only the first nine (9) contracts listed in Volume II will be evaluated.

3.3.2 The past performance evaluation considers each offeror’s demonstrated recent and relevant record of performance in supplying products and services that meet the contract’s requirements.

Performance confidence is assessed at the overall Past Performance factor level after evaluating aspects of the offeror’s recent past performance, focusing on performance that is relevant to the requirement. The Government may consider past performance in the aggregate in addition to on an individual contract basis.

3.3.3 In determining relevancy for individual contracts, consideration will be given to the effort, or portion of the effort, being proposed by the offeror, teaming partner, or subcontractor whose contract is being reviewed and evaluated. The past performance questionnaires (PPQs) and information obtained from other sources will be used to establish the degree of relevancy of past performance. The Government will use the following relevancy definitions when assessing recent, relevant contracts:

3.3.4 Recency Assessment

Recency assessment will apply to all contracts evaluated. An assessment of the past performance information will be made to determine if it is recent. In order to be recent, the contract (or subcontract) must have been performed within the past five (5) years from the date of issuance of this solicitation and for a minimum of a six (6) month period. Past Performance outside this given timeframe will not be evaluated. If performance on the contract occurred within the last five (5) years prior to the RFP's proposal submission deadline, the past performance record will receive a rating of "Recent," otherwise, the past performance record will receive a rating of "Not Recent," and will not receive further evaluation.

3.3.5 Relevancy Assessment

Relevancy will be determined based on the definitions in three performance categories: contract management history, auditing, and audit advisory. All performance categories are equal in importance. Each contract under each performance category will receive a relevancy rating.

3.3.6 Contract Management History: An assessment of the past performance information will be made to determine if it is relevant. To determine relevancy in this performance category, the offeror can submit up to three (3) submissions in this performance category. Each individual contract will receive a relevancy rating. The Government will evaluate the offeror’s relevancy on the management of a large number of FTE’s spread across multiple locations. “Multiple locations can include a number of different locations within the same area and/or varying geographic locations”. In determining the relevancy of effort performed under individual past performance contracts, the Government will only consider the specific effort or portion consistent with that proposed by the prime with any of their teaming partners/subcontractor for their submission. The past performance information obtained from other sources will be used to establish the relevancy of past performance. Submissions for contract management history can be from any type of service contract.

3.3.6.1 A relevancy determination of the Offeror’s past performance will be made based upon the aforementioned considerations. The Government will use the following ratings in Table

3 when assessing the Offeror’s contracts for relevance:

Table 3

Rating Definition

VERY RELEVANT Present/past performance effort involved managing a total of 250 plus FTEs spread across multiple locations on any type of service contract.

RELEVANT Present/past performance effort involved managing a total of 200 to 249 FTEs spread across multiple locations on any type of service contract

SOMEWHAT RELEVANT Present/past performance effort involved managing a total of 150 to 199 FTEs spread across multiple locations on any type of service contract

NOT RELEVANT Present/past performance effort involved managing a total of 149 or less FTEs spread across multiple locations on any type of service contract

3.3.7 Performance of Auditing: An assessment of the past performance information will be made to determine if it is relevant. To determine relevancy in this performance category, the offeror can submit up to three (3) submissions in this performance category. Each individual contract will receive a relevancy rating. In determining the relevancy of effort performed under individual past performance contracts, the Government will only consider the specific effort or portion consistent with that proposed by the prime. The past performance information obtained from other sources will be used to establish the relevancy of past performance. Relevancy ratings for past performance will be determined by audit that are the same or similar to the budget and percentage of work.

3.3.7.1 A relevancy determination of the Offeror’s past performance will be made based upon the aforementioned considerations. The Government will use the following relevancy ratings in table 4 when assessing the Offeror’s contracts for relevance:

Table 4

VERY RELEVANT Past/Present performance on audit contracts for entities with an annual budget greater than $60B performing 51% or more of the required effort

RELEVANT Past/Present performance on audit contracts entities with an annual budget between $35 - $59B performing 40-50% of the required effort

SOMEWHAT RELEVANT Past/Present performance on audit contracts entities with an annual budget between $10 - $34B performing 30-39% of the required effort

NOT RELEVANT Past/Present performance on audit contracts for entities with an annual budget less than $10B performing 20% or less of the required effort

3.3.8 Performance of Audit Advisory: An assessment of the past performance information will be made to determine if it is relevant. To determine relevancy in this performance category, the offeror can submit up to three (3) submissions in this performance category. Each individual contract will receive a relevancy rating. In determining the relevancy of effort performed under individual past performance contracts, the Government will only consider the specific effort or portion consistent with that proposed by the prime. The past performance information obtained from other sources will be used to establish the relevancy of past performance. Relevancy ratings for audit advisory past performance will be determined by audit advisory that are the same or similar to the requirements in the PWS with an emphasis on the budget, percentage of work and number of tasks supported in the submitted effort.

3.3.8.1 A relevancy determination of the Offeror’s past performance will be made based upon the aforementioned considerations. The Government will use the relevancy ratings in table 5 when assessing the Offeror’s contracts for relevance.

Table 5

VERY RELEVANT Past/Present performance on audit advisory contracts for federal entities with an annual budget greater than $60B doing 7-8 tasks found in the PWS and in which they are performing 51% or more of the required effort

RELEVANT Past/Present performance on audit advisory contracts for federal entities with an annual budget between $35 - $59B doing 5-6 tasks found in the PWS and in which they are performing 40-50% of the required effort

SOMEWHAT RELEVANT Past/Present performance on audit advisory contracts for federal entities with an annual budget between $10 - $34B doing

3-4 tasks found in the PWS and in which they are performing 30-39% of the required effort.

NOT RELEVANT Past/Present performance on audit advisory contracts for any entity with an annual budget less than $10B doing 2 or less tasks found in the PWS and in which they are performing 29% or less of the required effort

3.3.9 Performance Quality Assessment

Each submission in the three performance categories will receive a quality assessment rating based on table 6. A quality assessment of the past performance information will be made to determine the quality of the performance for each of the references. Each submission will receiving an individual rating.

Table 6

Rating Description

Acceptable During the contract period, the contractor’s performance is meeting (or met) all contract requirements and consistently exceeding (exceeded) many. Very few, if any, minor problems encountered.

Contractor provided immediate and effective correction action.

Unacceptable During the contract period, the contractor’s performance is failing (or failed) to meet contract requirements. Serious problems encountered and required corrective actions, were either ineffective or non-existent. Extensive customer oversight and involvement was (or is) required.

3.3.9.1 The performance quality assessment may result in positive or adverse findings.

“Adverse” is defined as past performance information that supports a less than

"Satisfactory" rating on any evaluation element. For adverse information identified, the evaluation will consider the number and severity of the problem(s), the mitigating circumstances, and the effectiveness of corrective actions that have resulted in sustained improvements. The Government will not use negative quality assessments against the

Offeror until the Offeror has had a chance to address the findings made, either prior to the

RFP submission if time permits or during the course of this evaluation. The Government may enter into communications with the Offeror regarding adverse past performance information to which the Offeror has not previously had an opportunity to comment.

3.3.10 Performance Confidence Assessment

As a result of the recency, relevancy, and quality ratings in all three performance categories, offerors will receive an integrated performance confidence assessment rating. Although the past performance evaluation focuses on performance that is relevant to the Technical subfactors and cost/price factor, the resulting performance confidence assessment rating is made at the factor level and represents an overall evaluation of contractor performance. Offerors without a record of recent

/ relevant past performance or for whom information on past performance is so sparse that no meaningful confidence assessment rating can be reasonably assigned will not be evaluated favorably or unfavorably on past performance and, as a result, will receive an “Unknown

Confidence” rating for the Past Performance factor.

More recent performance will have a greater impact on the Performance Confidence Assessment than less recent or relevant effort. A strong record of relevant past performance may be considered more advantageous to the Government than an “Unknown Confidence” rating. Likewise, a more relevant past performance record may receive a higher confidence rating and be considered more favorably than a less relevant record of favorable performance.

The performance confidence assessment may result in positive or adverse findings. Adverse is defined as past performance information that supports a less than satisfactory rating on any evaluation element or any unfavorable comment received from sources without a formal rating system. For adverse information identified, the evaluation will consider the number and severity of the problem(s), mitigating circumstances, and the effectiveness of corrective actions that have resulted in sustained improvements. Process changes will only be considered when objectively measurable improvements in performance have been demonstrated. The Government will use the following performance confidence ratings when assessing recent, relevant efforts

Table 7

Performance Confidence Assessment

Rating Description

Substantial Confidence

Based on the offeror’s recent, relevant, and quality ratings in all three performance categories, the Government has a high expectation that the offeror will successfully perform the required effort.

Satisfactory Confidence

Based on the offeror’s recent, relevant, and quality ratings in all three performance categories, the Government has a reasonable expectation that the offeror will successfully perform the required effort.

Limited Confidence

Based on the offeror’s recent, relevant, and quality ratings in all three performance categories, the Government has a low expectation that the offeror will successfully perform the required effort.

No Confidence

Based on the offeror’s recent, relevant, and quality ratings in all three performance categories, the Government has no expectation that the offeror will be able to successfully perform the required effort.

Unknown Confidence

(Neutral)

No recent, relevant, or quality performance record is available or the offeror's performance record is so sparse that no meaningful confidence assessment rating can be reasonably assigned.

3.4 Factor III: Cost/Price

3.4.1 The offeror’s Cost/Price proposal will be evaluated for award purposes based upon the proposed prices in the IDIQ Pricing Sheet (Attachment 4) being fair and reasonable pricing, along with a realistic PECP. Cost/Price will also be evaluated for the total proposed cost/price for Task Orders 1-8 (Attachments 5a to 5h) to ensure consistency with the IDIQ. The Government reserves the right to eliminate a proposal from further evaluation due to evaluated prices that are unfair or unreasonable.

3.4.2 IDIQ Level:

3.4.2.1. IDIQ Pricing Sheet (Attachment 4) will be evaluated for fairness and reasonableness. The IDIQ Pricing Sheet (Attachment 4) will be incorporated into the contract and utilized for pricing for future task orders.

Reasonableness: Comparison of proposed cost/prices received in response to this solicitation is the preferred and intended price analysis technique. Other techniques and procedures found in FAR 15.404-1, if deemed necessary and reasonable, may be used to ensure a fair, reasonable, and balanced cost/price.

3.4.2.2 PECP Realism Analysis. The Government will evaluate the Offeror’s and PECP for realism in accordance with FAR Provision 52.222-46 - Evaluation of Compensation for Professional Employees (Feb 1993). For the PECP to be realistic, the compensation plan(s) will be evaluated to determine if the compensation level proposed is unrealistically low IAW the scope and effort of the PWS. The analysis will be based on labor rates in the Washington, D.C. area. The Government may utilize Government civilian rates, similar contract labor rates, salary.com, other similar or relevant websites, or anything else it deems appropriate or beneficial in its evaluation of realism. Failure to comply with the requirements in FAR Provision 52.222-46 may constitute sufficient cause to justify rejection of the proposal.

3.4.3 Task Order Level:

3.4.3.1. Task Order Request Form (Attachment 5a-g) will be evaluated for fairness and reasonableness. The total evaluated cost/price (TEP) will consist of the sum of the Firm

Fixed Price (FFP) (Off-Site Labor) plus Travel for each of the Task Orders (Estimated

Travel cost is provided in the cost/pricing worksheets). Each task order is for a one (1) base year plus four (4) option years.

3.5 Small Business Participation Plan (SBPP)

The Government will evaluate the Offerors Small Business Participation Plan to determine whether it is acceptable or unacceptable, using the ratings and descriptions outlined in the table 2 below:

Table 2:

3.5.1 The Government will evaluate the extent of participation of small businesses to include service-disabled veteran-owned small business (SDVOSB) concerns, Woman-owned small business (WOSB) concerns, and veteran-owned small business (VOSB) concerns in performance of the contract.

3.5.2 The Government will evaluate the narrative information on how requirements for this effort were developed and if they are realistic. The Government will also evaluate offerors explanations for why targets cannot be met (if applicable).

3.5.1 This requirement is met when the total proposed of small business participation is

25% of the total workshare cost/price of this requirement broken down among the three

(3) social economic categories outlined below. The 3% goals for SDVOSB, WOSB and

VOSB are included in the overall small business target of 25% for the workload.

Small Business Category Target 25%

Service Disabled Veteran Owned Small Business

(SDVOSB)

3%

Woman Owned Small Business (WOSB) 3%

Veteran Owned Small Business (VOSB) 3%

3.5.2 The Government shall evaluate the total combined percentage of work to be performed by both large and small businesses (include the percentage of work to be performed both by Prime and Subcontractors) as outlined below:

3.5.2.1 Example: If Prime proposed a price of $1,000,000 (including all options), and small business(es) will provide $250,000 in services/supplies as a prime or subcontractors, the % planned for small business is 25%; and 75% for large business equaling 100%.

Table 3

Total Contract Value (TCV)

(Including Options, etc.):

N/A

Dollar Value of your participation as a Prime Contractor:

N/A

Small Business Participation Ratings

Rating Definition

Acceptable Proposal meets the minimum requirements of the solicitation.

Unacceptable Proposal does not meet the minimum requirements of the solicitation.

Total Percentage and Dollar

Value Planned for Large

Business(es):

Total Percentage and Dollar

Value Planned for Small

Business(es):

TOTAL % * $

* Note: When combined, Large and Small Business totals must equal 100%.

3.5.2.2 The Government shall evaluate the total percentage of participation to be performed by each type of subcategory small business. An Offeror that qualifies as a small business shall include its prime Contractor dollars in calculating its proposed percentage goals in all of the small business categories that it qualifies for. The percentage of work performed by small businesses that qualify in multiple small business categories may be counted in each category.

Table 4

Small Business Category % of TCV Dollar Value

Small Disadvantaged Business % * $

Woman Owned Small Business % * $

Veteran Owned Small Business % * $

Service Disabled Veteran Owned

SB

TOTAL % * $

* NOTE: The sum of all the percentages need not equal 100% as individual subcontractors may be counted towards more than one category. All percentages shall use TOTAL CONTRACT VALUE as a baseline.

3.5.3 This requirement is not met when the Small Business Participation Plan (SBPP) does not meet the minimum of the following:

3.5.3.1 Provides narrative information that does not adequately explain how requirements for this specific effort were developed and why they are realistic, to include failing to adequately explain why any targets cannot be met.

3.5.3.2 Simply reflects the goals stated in its comprehensive subcontracting plans approved under DFARS 252.219-7004, or a company / division-wide commercial subcontracting plan and does not address the requirements of this specific effort.

3.5.3.3 The offeror proposes a target of less than three percent (3%) for service-disabled veteran owned small businesses concerns, women-owned small business concerns or small business concerns, even if other small business targets are met.

3.6 The offeror’s Small Business Participation Plan (SBPP) will be incorporated into and become part of the contract.

4. Award

The Source Selection Authority (SSA) shall select the source whose proposal offers the best value to the Government in accordance with the established criteria in this Evaluation Criteria.

Trade-offs may be utilized to award to the best-value source based on a comparative assessment of proposals in accordance with the established criteria and with consideration of the recommendations and minority opinions presented to the SSA.