FIMA 15 StdOps Statement of Work 042920 updated.pdf

SOW: National Flood Insurance Program Standard Operations

National Flood Insurance Program

Standard Operations

Draft Statement of Work (SOW)

Award Date: TBD

1. Table of Contents

2. Background

3. Purpose

4. Period of Performance

5. Place of Performance

6. Government Furnished Equipment

7. Personal Identifiable Information Deliverables - Appendix A: Deliverable Table

8. Performance Objectives and Requirements Tasks

Part A: Standard Operations

Task 1. Quality

Task 2. Communications to NFIP Policyholders

Task 3. Records Management

Task 4. Meeting Support

Task 5. Underwriting Support

Task 6. Policy Appeals

Task 7. Claims Operational Support

Task 8. Program Audit

Task 9. Regional Support

Task 10. NFIP Program Guidance

Task 11. Industry Management Support

Task 12. Correspondence Support

Task 13. Reporting Requirements

Task 14. Information Requests

Task 15. Policy Analysis and Program Enhancements

Part B Disaster Support

Task 1. Claims Activities

Task 2. Random Claims Quality Check

Task 3. Adjusting Services

Task 4. Flood Adjuster Registration Management .................. Error! Bookmark not defined.

Task 5. Flood Response Offices

Part C Transition

Task 1. Transition In

Task 2. Transition Out

9. Special Clauses

10. Clauses Incorporated by Reference

2. Background

The Department of Homeland Security (DHS), Federal Emergency Management Agency’s (FEMA) mission is to help people before, during, and after disasters. FEMA accomplishes this mission through the development and execution of the FEMA Strategic Plan.

FEMA’s Strategic Goals are:

1. Build a Culture of Preparedness

2. Ready the Nation for Catastrophic Disasters

3. Reduce the Complexity of FEMA

FEMA focuses on building and developing a culture of preparedness across the country and unifying all levels of community and government into an integrated approach to emergency management. As part of FEMA, FIMA concentrates on increasing the capabilities necessary to reduce loss of life and property by lessening the impact of disasters. FIMA has developed guiding principles that drive decision making.

FIMA’s guiding principles are:

• Emphasize integration and collaboration

• Strive for innovation where needed

• Improve the customer experience

• Improve organizational health

FEMA manages the National Flood Insurance Program (NFIP), which was created by The National Flood Insurance Act of 1968, and a range of related programs designed to reduce future losses to homes, businesses, schools, public buildings, and critical facilities from floods, earthquakes, tornadoes, and other natural disasters. The NFIP aims to reduce disaster suffering by providing affordable insurance to property owners, renters, and businesses as well as encouraging communities to adopt and enforce floodplain management regulations. The NFIP currently serves approximately 5.1 million policies and is aiming to double the number of structures covered by flood insurance by 2022.

Under FIMA, FID’s mission is to provide customer focused flood insurance to help survivors and their communities effectively recover from flood events. The Federal Insurance and Mitigation

Administration (FIMA) is transforming the NFIP to update the products, processes, and procedures that support the program. The risk rating system is being redesigned to leverage industry best practices and current technology to deliver rates that are fairer, easier to understand, and better reflect a property’s unique flood risk. FEMA calls this effort Risk Rating 2.0 and will include updates to rates for all NFIP-insured properties over the next several years. Through these efforts, FEMA’s goal is to make flood insurance significantly easier for agents to price and sell policies, and in turn, help customers better understand their flood risk and the importance of flood insurance.

FIMA also administers the Write Your Own (WYO) program, which enables participating private insurance companies to sell and service the flood insurance product as fiscal agents of the federal government. FIMA also offers policies directly for sale through its NFIP Direct Program. There are approximately 5.1 million NFIP policies in force, with over $1.3 trillion of coverage in force. These policies are sold and serviced through approximately sixty private insurance companies participating in the WYO program, all of whom must report every transaction to the NFIP.

The WYO companies are the primary vehicle for selling, delivering and servicing flood insurance policies, and they are responsible for over 80% of NFIP policies in force. The WYO companies have been invaluable in the NFIP’s effort to increase the flood insurance policy base, increase the geographic distribution of policyholders, improve service to policyholders as well as insurance agents, and enhance the NFIP's ability to settle claims promptly and fairly in post-catastrophe environments.

FEMA is currently soliciting contracts to support the NFIP. NFIP contracts will support the direct sale and servicing of NFIP policies; communications; technology operations, maintenance, and development;

standard business operations (this SOW); and financial reporting. Additional information specific to each contract will be provided through additional industry engagement methods deemed appropriate.

Universal objectives, assumptions, and constraints applicable are provided below and apply to all contracts that support the NFIP.

Universal Objectives:

NFIP Goal 1: The NFIP is growing. As the program works to close the nation’s insurance gap and double the number of structures covered by flood insurance by 2022, support services must scale to meet the workload expected to deliver world-class operations, inclusive of day-to-day, response, and recovery activities.

NFIP Goal 2: The NFIP must make it easier to sign up and maintain flood insurance. From forms, to rating, to the claims process, the NFIP must continue to evolve how it delivers the program to help close the insurance gap and make it easier for citizens and communities to invest in hazard mitigation activities. All providers shall directly contribute to improving the customer experience.

NFIP Goal 3: FEMA must reduce the complexity of the NFIP and increase the program’s transparency.

Leveraging process changes, improved communications, and new technology, FEMA must ensure that homeowners have insight, education, and confidence in the entire insurance lifecycle.

NFIP Goal 4: To ready the nation for catastrophic disaster, FEMA must build and sustain long-lasting and mutually beneficial partnerships and coalitions with public and private organizations to leverage capabilities and influence, extending the reach of the NFIP’s mission.

NFIP Goal 5: The NFIP must plan for and implement changes stemming from the reauthorization and other legislative and regulatory changes.

Universal Assumptions and Constraints

• All activities align with Department of Homeland Security/FEMA strategic goals and constraints.

Outreach activities are coordinated, integrated, and consistent with NFIP messaging throughout the program including appropriate advisory focus groups.

• Pivot is the NFIP’s System of Record (SOR).

• FEMA is updating policy forms, and while some will be finalized, not all will be completely in place at the time of contract award.

• Updated rates will be implemented in a phased approach, with new rates going into effect over the next several years.

• The NFIP will continue to operate according to the current authorization and regulations but must ensure flexibility for changes.

• The NFIP will embrace data and fraud analytics to drive better operations through improved oversight, speed, quality, and customer service.

• The NFIP will leverage data analytics and behavioral science to better inform decisions and improve the program’s marketing approach.

• The NFIP will embrace industry-standard customer experience models (online sales, mobile claims through smartphone applications, agents at the contact center, etc.).

• The NFIP will strengthen and expand partnerships—including through incentives.

• Outreach activities are coordinated, integrated, and consistent with NFIP messaging.

• Data security and privacy issues are major focus of the federal Government’s information technology efforts. All program activities must be compliant with the Government Information

Security Reform Act, OMB policies, DHS, and FEMA requirements.

• Solutions must include transition plans detailing how continuity of services will be maintained (e.g., operations of IT systems in various states of health and development, ongoing marketing and sales efforts, program management, etc.)

3. Purpose

The purpose of this Statement of Work (SOW) is to obtain a qualified Contractor, hereinafter referred to as “Contractor”, to support insurance standard business operations, including insurance subject matter expertise, and daily business operations of the NFIP and Federal Insurance Directorate (FID).

The Contractor will be providing support to FEMA and they will be in close coordination with the WYO insurance companies and the NFIP Direct Contractor as they work together to provide the information required by the NFIP. The Contractor will also engage in support activities that include tracking, collecting, disseminating, maintaining, and updating information on the NFIP and the WYO companies.

The Contractor must also establish field offices in the event of a flood disaster per FIMA’s concurrence.

These offices are set up to expedite claims and coordinate WYO activities.

The Contractor must also support NFIP outreach efforts in close coordination with FIMA’s

Communication Contractor.

The work that the Contractor will perform will be UNCLASSIFIED. It should be noted that a substantial amount of data is considered Personally Identifiable Information and must be treated as such.

4. Period of Performance

The period of performance shall be 12 months, with four (4), 12-month option periods.

5. Place of Performance

Contract objectives shall be performed primarily at the Contractor’s site within the National Capital Region. Given the nature of disaster response services and support to FEMA Region offices, some staff will not be located in the NCR. Temporary performance sites may be established in areas impacted by major flood events.

FEMA requires support Monday through Friday, (8:00 AM to 6:00 PM EST) and potentially around the clock during disaster events.

At the request of the COR, the Contractor shall provide at least one (1) person onsite at FEMA Headquarters to facilitate issues, respond to inquiries, and other general coordination.

The Contractor shall provide a daily courier drop off and pick up at FIMA Headquarters. The courier shall meet all Federal, DHS, and FEMA security badging and clearance requirements to facilitate services.

6. Government Furnished Equipment

The Contractor shall furnish all personnel, facilities, equipment, software, material, supplies, and services, except as may be expressly set forth in this SOW as furnished by the Government.

The Contractor will be provided with Government Furnished Equipment (GFE) laptops, to allow direct interface with claims processing and adjusting capabilities of the FEMA system of record, Pivot

To ensure the highest level of protection, all GFE must be imaged by and maintained with a DHS/FEMA certified image. The Contractor shall be responsible for operating and storing all GFE in a secure manner and in accordance with current rules and regulations.

Additionally, the Contractor shall designate a single point of contact for FEMA to work through when assigning or issuing GFE. This individual will be responsible for tracking the whereabouts of all issued

GFE.

The Contractor shall prepare and deliver at least annually or upon request by the Contracting Officer

(CO) or Contracting Officer’s Representative (COR) a detailed list of all GFE.

7. Deliverable Table

All formal deliverables under this contract are listed in Appendix A: Deliverable Table and shall be delivered to FEMA on the designated dates provided. Should any designated dates coincide with a non-business day, the associated deliverable will be due on the next available business day unless otherwise directed by the COR.

The Contractor shall e-mail deliverables to the COR, Alternate COR and the distribution list (as approved by the COR by the due date according to the chart. The Contractor shall also upload the deliverables onto a SharePoint or similar site, as provided by the COR. The due dates of the deliverables are subjected to change. The COR will communicate the changes to the Contractor with advanced notice.

The COR then has 15 business days to review each deliverable and request corrections and/or adjustments from the Contractor before the document is accepted by FEMA.

8. Business Continuity Plan

The Contractor shall prepare and submit a Business Continuity Plan (BCP) to the Government. The BCP

Plan shall be due 15 business days after the date of award, and will be updated on an annual basis. The

BCP shall document Contractor plans and procedures to maintain support during an emergency, including natural disasters and acts of terrorism. The BCP, at a minimum, shall include the following:

• A description of the Contractor’s emergency management procedures and policy

• A description of how the Contractor will account for their employees during an emergency

• How the Contractor will communicate with the Government during emergencies

• A list of primary and alternate Contractor points of contact (telephone numbers & e-mails)

The BCPs shall be activated immediately after determining that an emergency has occurred. It shall be operational within 24 hours of activation or as directed by the Government, and shall be sustainable until the emergency situation is resolved and normal conditions are restored or the contract is terminated, whichever comes first. In case of a life-threatening emergency, the COR shall immediately make contact with the Contractor Project Manager to ascertain the status of any Contractor personnel who were located in Government controlled space affected by the emergency. When any disruption of normal, daily operations occur, the Contractor Project Manager and the COR shall promptly open an effective means of communication and verify:

• Key points of contact (Government and contractor)

• Temporary work locations (alternate office spaces, telework, virtual offices, etc.)

• Means of communication available under the circumstances (e.g. email, webmail, telephone, FAX, courier, etc.)

• Essential Contractor work products expected to be continued, by priority

The Government and Contractor Project Manager shall make use of the resources and tools available to continue contracted functions to the maximum extent possible under emergency circumstances.

Contractors shall obtain approval from the Contracting Officer prior to incurring costs over and above those allowed for under the terms of this contract. Regardless of contract type, and of work location, Contractors performing work in support of authorized tasks within the scope of their contract shall charge those hours accurately in accordance with the terms of this contract.

9. Performance Objectives and Requirements Tasks

Part A: Standard Operations

Task 1. Quality

The Contractor must provide a Project Manager as key personnel. The Project Manager is responsible for managing the activities in this Statement of Work.

The Contractor will provide a Quality Control Plan annually. Quality Control is the monitoring and oversight performed by the Contractor to ensure that work is accomplished in accordance with the terms of the contract. FEMA performs quality control to verify that the Contractor is performing the work required by the contract. The Contractor shall provide services in accordance with the terms of this contract. Elements in the Quality Control Plan shall include, but are not limited to:

• Distribution and storage of deliverables and work products.

• Procedures to ensure compliance with applicable Statutes, Regulations, and policies.

• Quality review processes

• Staffing and capabilities plan.

Task 2. Communications to NFIP Policyholders

The Contractor shall send with each new policy, by mail, and additionally at each annual renewal, the property’s loss history information, as required by the Flood Insurance Reform Act (FIRA), Section 202

(a)(4), the Claims Handbook, as required by FIRA, Section 204, the acknowledgment, as required by FIRA, Section 203, and a cover letter that references these enclosures. The Contractor shall also include notification as required by Homeowners Flood Insurance Affordability Act of 2014 (HFIAA) Section 28.

The Contractor shall send policyholder notices for community actions as directed by FEMA.

The Contractor shall be required to send additional information to policy holders as directed by statute.

The current volume is approximately 6,000,000 mailings per year. This number is expected to increase.

Policyholders’ addresses are available through the NFIP’s System of Record, Pivot.

The Contractor shall implement and maintain electronic record-keeping procedures for the acknowledgement letter to show proof of mailing and receipt or lack of receipt of a policyholder’s signed acknowledgement.

The Government covers all costs for postage, private express delivery, and freight through Smart Link.

The Contractor shall establish and maintain internal controls to assure the security and accounting for all postage, private express delivery, freight, and delivery expenses of the program. The Contractor shall manage postage and express delivery activities to minimize costs to FEMA.

The Contractor shall report to the COR all postal and express delivery expenditures, any unusual or unanticipated expenses, measures being taken, and progress being made to reduce the costs. The

Contractor shall make best efforts to reduce postage, freight, and delivery costs by, for example, preparing mailing lists annually, using the most economic classes of mail, and using all applicable US

Postal Service discounts

Task 3. Records Management

The Contractor shall maintain WYO and NFIP Direct data and information in accordance with FEMA

Manual 5400.2 Records Management Files Maintenance and Records Disposition. The Contractor shall develop FEMA-approved Standard Operating Procedures (SOP) for such activities, and shall, as appropriate, recommend changes to the SOP and to FEMA Records Disposition Schedule. The SOPs are due annually per Appendix A. The media used for record keeping must follow the Federal Records Act, National Archives and Records Administration regulations, and guidance provided by the FEMA Records

Officer.

The Contractor shall maintain documents detailed below and make the copies available to FEMA upon request. The documents must be scanned within thirty days of receipt and retained according to applicable FEMA Records Disposition Schedules.

• Section 1316 (Denial of Flood Insurance) documents

• Coastal Barrier Resources Act documents

• Policy Appeal documents

• Claims Appeal documents

• FIRA acknowledgments

• FIRA mailings

• Severe Repetitive Loss and Repetitive Loss documents

• Underwriting documents

• Claims Documents

• Financial Documents

• Others upon request of the Government

Task 4. Meeting Support

The Contractor shall participate, provide subject matter expertise and support for meetings with internal and external stakeholders (insurance agents, lenders, policyholders, adjustment firms, Write Your Own

Companies, etc.) on the NFIP. The Contractor shall identify as a Contractor in all meetings.

The Contractor shall prepare and supply materials, including agenda items, to facilitate communication of NFIP information to these audiences. These items must be approved by the Program Subject Matter

Expert (SME) or COR prior to the meeting. Upon request of FEMA, the Contractor shall provide meeting minutes or general notes within two business days after the meeting.

Task 5. Underwriting Support

The Contractor shall provide an Underwriting Manager as key personnel. The Underwriting Manager must have a minimum of three (3) years of flood insurance experience.

The Contractor shall provide underwriting subject matter expertise and support (utilizing staff with a minimum of three (3) years of experience underwriting flood insurance) to FEMA, the WYO companies, the NFIP Direct, and policyholders, helping ensure that each policy is correctly written and rated.

The Contractor shall receive, resolve, and track underwriting inquiries and coverage problems referred by FEMA, policy holders, agents, WYO companies, State Insurance Departments, and others. For underwriting files where there is a question of coverage involving policy interpretation, the Contractor shall promptly refer them to FEMA through the COR. The Contractor has three (3) business days from the date of receipt to respond to a WYO company or NFIP Direct Contractor inquiry or forward it to FEMA. The Contractor has three (3) business days from receiving FEMA’s response to an inquiry to send it to the WYO Company or NFIP Direct Contractor.

The Contractor shall also provide the following support:

• Technical assistance, as directed by FEMA, to WYO companies and the NFIP Direct Contractor with applying the proper rules and regulations of the NFIP to their policies.

• Providing analysis, support the development, implementation, and communication of the requirements for NFIP rate and rule changes.

• Gather rating and payment information, calculate refunds, perform quality control, and process prior term premium refunds as directed and approved by FEMA, including HFIAA Section 28 provisions, when applicable. The Government will provide payment of the refunds under the

Letter of Credit.

• Respond to NFIP inquiries from a WYO, NFIP Direct, or other NFIP stakeholders.

• Underwriting technical expertise in Operational Reviews. Review NFIP policies for accurate rating and processing to ensure valid documentation and policy information was obtained by the WYO or NFIP Direct.

• Coordinate Coastal Barrier Resource Act (CBRA) eligibility with the U.S. Fish and Wildlife Service and the WYO or NFIP Direct.

• Provide the status of ongoing and completed inquiries and tasks to the NFIP’s Underwriting branch or COR monthly.

The Contractor shall provide support for Special Rating and the Submit for Rate process based on FEMA guidance. The Contractor shall process Submit for Rates. The Contractor shall obtain and validate underwriting policy files from WYO companies and the NFIP Direct Contractor. All necessary documentation must be verified for accuracy and completeness prior to submittal to FEMA for review.

The Contractor shall review and verify that inquiries on new and existing policies are correctly rated. The

Contractor shall follow up on pending new and existing policies and request additional information from the WYO companies or NFIP Direct Contractor, if needed.

Policy Appeals: The Contractor shall support underwriting policy appeals.

Activities include:

• Support the collection and submission of data to substantiate policy appeals, including but not limited to designations of 1316, Coastal Barrier Resource Area, repetitive loss, severe repetitive loss, property address waivers, floodproofing, special rating, preferred risk policy eligibility, leased federal properties, and prior term refunds.

• Review and recommend approval or denial of the policy appeal.

• Coordinate with other FEMA contractors to ensure that the policy appeals are fully adjudicated in a timely manner.

• Implement any adjustments or corrective actions as a result of FEMA’s adjudication of the policy appeal.

Task 6. Appeals

The Contractor shall provide an Appeals Manager as key personnel. The Appeals Manager must have a minimum of three (3) years of flood insurance experience.

Claims Appeals: The Contractor shall support the claims appeals process. Such support includes:

• Provide two teams of specialists:

o One team that supports the triage, insurer response, and examiner determination queues in Pivot. This team should be comprised of at minimum two (2) flood insurance adjusters and examiners, with no less than five (5) years of experience.

o One team that writes appeals decision memos, to be reviewed and approved by

FEMA, in the editorial review queue within Pivot. This team shall be comprised of technical writer capabilities that are experienced in using the issue – rule – analysis – conclusion (IRAC) format.

• Coordinate with other FEMA Contractors to ensure that the policy appeals are fully adjudicated in a timely manner.

• Requesting claims files, uploading the documents and synopses and facilitating the reviews of these files.

• Scheduling calls and meetings with FEMA, policyholders and/or WYO Companies (including the NFIP Direct) about post-decisions.

• Implement any adjustments or corrective actions as a result of FEMA’s adjudication of the policy appeal.

• Monitor and report on policyholders with active appeals who file suit.

• Review and recommend approval or denial to FEMA of the policy appeal. FEMA makes the final determination.

• Support in developing and maintaining a repository in SharePoint or FEMA folder of completed decision memos, with metadata/tags for ease of reference and ability to quickly recall through a search.

• Support the collection and submission of data to substantiate policy appeals including but not limited to designations of 1316, Coastal Barrier Resource Area, repetitive loss, severe repetitive loss, property address waivers, floodproofing, special rating, preferred risk policy eligibility, leased federal properties, and prior term refunds.

• Support the implementation of a Flood Insurance Appeals web portal for policyholders that enables policyholders to Directly enter their appeals into Pivot and learn in real-time whether their appeal meets the eligibility requirements (e.g., within 60 days of denial; copy of denial letter included, etc.).

• Support the maintenance of the FEMA Appeals email inboxes, including logging and responding to status requests from policyholders, when appropriate. There are currently two inboxes.

• Support the training of WYOs and NFIP Direct contractor, upon their receiving access to the Pivot Appeals application.

Claims Appeal claim file and synopsis requests to WYOs and the NFIP Direct must be complete within one business day of receipt and assignment in Pivot. A final draft decision memo must be delivered to FEMA within 21 calendar days after assignment in the Editorial Review queue.

Task 7. Claims Operational Support

The Contractor shall provide an Claims Manager as key personnel. The Claims Manager must have a minimum of three (3) years of experience of processing flood claims.

The Contractor shall provide support for claims processing to NFIP stakeholders to ensure the proper collection of accurate claims information for all claims.

The Contractor shall provide experienced flood insurance claims personnel to respond to and support FEMA, the WYO companies, the NFIP Direct Contractor and other NFIP stakeholders in the implementation of the NFIP.

The Contractor shall provide personnel with two different levels of claims experience. One level must have a minimum of one (1) year flood insurance claims experience. The next level must have a minimum of three (3) years of flood insurance claims experience and three (3) years of commercial insurance claims.

General Adjusters (GAs): The Contractor shall provide a minimum of eight (8) full time General Adjusters with NFIP flood insurance claims experience to support reinspections, correspondences and other NFIP Program inquiries/issues. The Government covers travel for reinspections through Smart Link.

The General Adjusters are required to be claims professionals, have correct authorization with an active Flood Control Numbers (FCN), have appropriate NFIP flood insurance claims experience to expertly address difficult technical claims issues with policyholders and their representatives and have the computer and software skills necessary to perform the duties. The General Adjusters must demonstrate excellent customer service skills and written and verbal communication skills

The Contractor shall provide General Adjusters with two (2) different types and levels of experience:

• A minimum of 3 GAs shall have at least five (5) years of experience in providing general adjusting for residential flood claims estimating.

for commercial flood claims estimating.

NFIP General Adjusters may be required to travel extensively in the USA, and the U.S. Territories.

Flood Adjuster Registration Management: The Contractor shall obtain information regarding adjusters seeking NFIP registration or annual reregistration from the NFIP training Contractor. The Contractor shall transition in from the NFIP training Contractor information (dates, names, etc.) regarding adjusters seeking NFIP registration or annual reregistration. The Contractor shall use this information to track the adjuster’s training, which is a prerequisite for NFIP registration and reregistration, distribute adjuster authorization documentation with FCN cards, and maintain historical records. The Contractor must maintain a list of active adjusting companies and training plans from all Flood Adjuster Capacity Program

(FACP) WYO approved adjusting companies. FEMA requires all registered adjusters to reregister annually to ensure that information in the database or SharePoint is current for every registered adjuster. All Adjuster registration and status must be uploaded to SharePoint.

Collection of Claims Information: The Contractor shall be the focal point for the collection of information about coverage issues, policy interpretation, severity questions, and all other claims matters. If the issue is critical or time sensitive, the issue shall be referred to FEMA within 24 hours of determination of such.

Otherwise, the Contractor shall process all claims information and subsequently notify FEMA of issues encountered and all actions taken by the Contractor within 7 business days.

Increased Cost of Compliance (ICC) Reporting: The Contractor shall maintain a log of all claims reported where the policyholder consents to the assignment of the ICC claim payment. The Contractor shall obtain a copy of the Assignment of Increased Cost of Compliance and supporting documentation to be disseminated to the appropriate WYO carrier or the NFIP Direct Contractor.

Claims Operation Reviews: The Contractor shall provide NFIP subject matter experts into support

Operation Reviews. FEMA will provide capabilities of the SMEs prior to the Reviews.

Special Claims Projects: As requested of the COR, the Contractor shall support special claims projects and ad-hoc analyses. The projects may involve an in-depth review of claims files and field surveys of specifically identified areas (e.g. condominiums, ICC, repetitive loss, subrogation, CBRA, etc.).

Subrogation and Discovery: The Contractor will support the Office of Chief Counsel (OCC) and the DHS

Office of the Inspector General (OIG)with FEMA’s Subrogation and Discovery Response initiatives by conducting special subrogation claims projects and analyses involving but not limited to:

• Appearing as witnesses for hearings, proceedings, or depositions, investigatory assistance, retention of expert witnesses or retention of outside counsel, etc. in the time frame communicated by OCC.

• Performing claim reviews and litigation discovery assistance

• Collecting and maintain information on all Cause of Loss and Subrogation Reporting forms submitted by WYOs and NFIP Direct

• Performing field investigations to identify and target subrogation prospects,

• Requesting claims and underwriting files from WYOs and NFIP Direct

• Support other ad hoc claims analyses and subrogation initiatives as required

The Contractor may be required to perform this task on site (FEMA Headquarters).

Claims Reinspections: Under FEMA direction, the Contractor shall plan, implement, and manage the NFIP Claims Reinspection process. There are three routine categories of reinspections: Congressional, Appeals, and Special Assists.

Major Functions for Claims Re-inspections:

• The Contractor is required to have NFIP authorized General Adjusters make on-site property re-inspections; one General Adjuster is required at each reinspection.

• Adjuster Preliminary Damage Assessment (APDA): The Contractor shall collect APDA forms via email and enter necessary data into the SOR for reports used by community floodplain management and FEMA.

• The Contractor shall analyze and summarize the results of the re-inspections, including identifying trends, overpayments and underpayments, etc. The Contractor shall provide a quarterly report on reinspection activities to FEMA. FEMA must approve the format of these reports.

• The Contractor shall maintain a detailed database in SharePoint of the re-inspections and the associated findings.

• The Contractor shall provide feedback to FEMA, the WYO companies, and the NFIP Direct Contractor on claims matters arising from re-inspections, including repeated issues and trends.

• The Contractor shall support FEMA by reviewing and investigating losses through claim file reviews or re-inspections.

• The General Adjusters shall record and report their findings on the reinspection form, which must be completed in full and signed by both the WYO company representative and the NFIP General Adjuster indicating agreement with the findings.

• The reinspection form should include if there was an under/over payment

Task 8. Program Audit

The Contractor shall furnish all pertinent files, records, documentation, procedures, data, and any other information which is in its possession that may be required by any governmental organization and requested of FEMA. Similarly, files, records, reports, data, other information, and assistance shall be furnished to the FEMA Office of Chief Counsel (OCC) for initiation or defense of litigation, or in connection with any other action or proceeding. FEMA will initiate all relevant requests of the Contractor and the Contractor shall furnish these materials within the due date provided.

The Contractor shall support audits in all functional areas including the annual external fiscal year audit that covers select aspects of the business processes described in this SOW. The Contractor shall establish internal audit activities for underwriting and claims analyses to assure the integrity of WYO underwriting and claims data and reporting.

Task 9. Regional Support

The Contractor shall provide support for all ten FEMA Regional Offices on flood insurance inquiries and issues. The Contractor may be required to sit within one of the Regional Offices or FEMA Joint Field

Offices (JFO) with COR approval. The Contractor shall identify as a FEMA/NFIP Contractor in all meetings.

The Contractor shall provide support for the following activities:

• Assist stakeholders (policyholders, insurance agents, community officials, realtors, condominiums associations) with flood insurance issues and questions.

• Attend by phone or webinar quarterly meetings with NFIP headquarters and weekly meetings with FEMA Regional staff

• Attend various trainings and conferences, upon COR approval, to understand the latest trends and efforts to support flood insurance activities

• Brief insurance agents, realtors, local officials and other stakeholders after flood events in coordination with the Regional Insurance Specialist and other FEMA disaster response activity including Joint Field Offices.

• Conduct outreach to NFIP stakeholders, including the real estate community, condominium associations, homeowners’ associations, etc.

• Coordinate disaster activities with headquarters NFIP disaster management team and Regional disaster response activities

• Participate in conferences, town hall, public forums and other events

• Participate in FEMA Regional Office meetings as requested

• Participate in one Flood Smart 101 webinar to gain understanding of national resources/materials available

• Post-Disaster NFIP activities including promoting NFIP participation through local officials and assisting at disaster response offices

• Provide data and data analysis to the FEMA Regional Offices in responding to Congressional inquiries

• Research and address FEMA Regional Office inquiries via phone, email or written correspondence

• Research and address inquiries as directed by FEMA

• Respond to FEMA’s flood related website inquiries

• Support Community Rating System (CRS) activities in local communities in coordination with FIMA and other regional stakeholders

Task 10. NFIP Program Support

The Contractor shall provide subject matter expertise, technical editing, proofreading, graphics and formatting support with final production of NFIP documents. Other contractors may be the lead for development and delivery of some deliverables. Such documents include:

• Flood Insurance Manual

• NFIP Claims Manual

• WYO Arrangement

• NFIP Financial Control Plan

• Any other written products as requested by the government and approved by the COR.

The Contractor shall provide support for the following:

• Supporting the development and maintenance of operating forms, manuals, and other required publications, including bilingual materials, in accordance with all applicable Government regulations.

• Creating manuals, technical bulletins, and other materials as designated or required, and review material for accuracy and consistency.

• Developing text, tables, and graphics for the periodic revisions of NFIP documents

• Ensuring all materials sent to GPO are fully compliant with all FEMA, DHS and GPO rules and regulations.

• Ensure all web-versions of materials created are compliant with Section 508 of the Rehabilitation Act before they are published.

• Identify trends and issues and propose strategies to address them in program documentation.

• Maintain and update underwriting forms (Application, Endorsement, Cancellation forms), manuals (Flood Insurance Manual and Specific Rating Guidelines

• Translate complex technical material into simple, clear explanations or instructions.

• Providing SME to the NFIP. The SME is required to review documents or language for accuracy, participate in meetings, provide recommendations, etc.

The Contractor shall ensure that artifacts have no spelling, grammatical, or punctuation errors and are precise, concise, and reflect agency values, clear writing and exemplary professionalism. Peer reviews and proofreading are required to ensure consistent and accurate information. Some materials developed require significant concurrence from many program offices within FEMA and may require multiple revisions.

In addition, the Contractor shall provide 508 Compliance management to make the documents compliant and remedy any problems that may arise. The Contractor shall coordinate with the COR timelines for delivery that include sufficient time to accommodate significant FEMA and other reviews and allow for the Contractor to ensure 508 compliance.

The Contractor shall maintain Microsoft Office Specialist (MOS) Expert certifications, Microsoft Publisher certification, Adobe Certified Expert (ACE) certifications, or equivalents. The Contractor shall provide editing support, including a write-editor and a line editor to ensure that the products meet government standards of writing in plain English language and are consistent with the U.S. Government Publishing Office (GPO) Style Manual.

The forms, manuals and publications tasks shall be done in coordination with FEMA’s Printing Officer, Forms Management Officer, and Information Officers, and consistent with their guidance. These objectives should also be consistent with the Paperwork Reduction Act of 1995 and implementing OMB Regulation 5 C.F.R 1320, the Joint Committee on Printing Regulations, and U.S. Government Publishing Office regulations.

Task 11. Industry Management Support

The Contractor shall provide an Industry Manager as key personnel.

The Contractor shall provide technical expertise in supporting WYO oversight including but not limited to:

• Coordinating Coastal Barrier Resource Act eligibility with the U.S. Fish and Wildlife Service and the WYO or NFIP DIRECT.

• Drafting response for incoming FEMA Underwriting correspondence. This includes obtaining and validating the information from the WYO or NFIP Direct, drafting the response, and providing the draft to FEMA.

• Providing technical assistance to WYO companies and the NFIP Direct Contractor with applying the proper rules and regulations of the NFIP to their books of business.

• Responding to NFIP inquiries from a WYO, NFIP Direct, or other NFIP stakeholders.

• Gathering rating and refund information, validating refunds, and processing prior term refunds of premiums when applicable. The Government covers the actual payments through Smart Link.

• Preparing WYO Arrangement Packages and preparing and reviewing reports on WYO company compliance with FEMA requirements

• Processing and providing quality control oversight for Prior Term Refunds of premium requests when applicable

• Reviewing, recommending approval and processing Preferred Risk Policy (PRP), CBRA Properties, Leased Federal Properties, 1316 Properties and Severe Repetitive Loss (SRL) Properties appeals for resolution by FEMA.

• Supporting analysis, development, implementation, and communication of the requirements for NFIP Program and Rate and Rule changes

• Tracking the statuses of WYOs, name changes, onboarding, off boarding, etc.

• Weekly provide a dashboard with the inventory of each daily task and the oldest receipt date.

Financial Strength Ratings: The contractor will support the analysis of the potential use of multiple financial strength rating companies and grades by the WYO. The contractor will gather information on cross-industry use of financial strength ratings, current federal use practices, differences in major financial strength ratings, and the credibility of rating sources. The analysis will at a minimum focus on financial strength ratings of A.M. Best, Demotech, S&P, Moody's, and Fitch. The contractor will provide FEMA with a status update on the analysis at least once every two weeks.

Task 12. Correspondence Support

The Contractor shall provide support for the correspondence that is required to meet stakeholder needs. This support consists of establishing documented procedures for handling all correspondence, fielding the originating requests, requesting and obtaining the appropriate information and synopsis from the WYO or NFIP Direct, creating appropriate responses for the request and maintaining logs of all correspondence activity.

The Contractor shall respond to technical claims and underwriting inquiries and review the grammar and technical content of the draft responses prior to forwarding them to FEMA. The Contractor shall develop and use FEMA-approved templates as guides.

The Contractor shall draft responses with no spelling, grammatical, or punctuation errors and are precise, concise and reflect agency values, clear writing and exemplary customer service.

The Contractor shall implement, document, maintain detailed procedures for handling of all NFIP related correspondence which includes processing and drafting responses for all incoming and outgoing correspondence for FEMA approval. The Contractor shall perform quality assurance and deliver timely performance of all correspondence tasks.

The Contractor shall track the life cycle of the claim correspondence, e.g. notifications of incoming correspondence, notification of all activity, track correspondence status, etc.

The Contractor shall provide reports on the nature of correspondence, sources (e.g... White House, Congress, State Officials, agents, insured etc.) trends, (e.g. Geographic and programmatic) and timeliness of problem resolution and responses. The Contractor shall have the ability to upload to SharePoint and electronically deliver to FEMA complete files that are too large to send via email. The Contractor should be prepared to accommodate correspondence procedural changes due to significant disasters, changes to internal FEMA correspondence processes, or other issues.

Correspondence Support Deadlines:

• The Contractor shall respond to inquiries from FEMA regarding the status of correspondence in writing or by telephone within one business day o Controlled Correspondence: a finalized draft response must be delivered to FEMA within five (5) business days from date of receipt, with an acknowledgement letter sent within one business day of receipt off initial inquiry. Controlled correspondence is defined as Congressional, White House, and DHS correspondence.

o Uncontrolled Correspondence: a finalized copy to FEMA, within ten (10) business days from date of receipt. Uncontrolled correspondence is defined as general correspondence.

Task 13. Reporting Requirements

Reporting requirements shall be subjected to regular review for duplication and utility by the Contractor.

FEMA shall examine all reporting requests to determine the most expeditious and economical manner in to satisfy the requirements. These requirements shall apply to all reports, for WYO Companies and the NFIP Direct Contractor’s operations, including those reports generated for internal use by the Contractor as well as those provided FEMA and NFIP stakeholder use. Technical reports, designs identifying source data and calculations performed within reports shall be delivered to the COR when scheduled or requested.

All reports generated from the SOR shall be usable in multiple formats to fully support all NFIP stakeholders who are granted access to program data through FEMA authorization.

Task 14. Information Requests

The Contractor shall be responsible for providing assistance to FEMA HQ and Regions, Auditors, WYO

Companies, other NFIP Contractors and others as identified by FEMA with each stakeholder’s report requirements.

The Contractor shall coordinate with FEMA staff and respond to all inquiries from FEMA’s Flood Smart website or a similar site. Inquiries include questions from FEMA’s Ask the Expert page on https://www.fema.gov/ask-expert.

The Contractor shall draft reports or responses to Freedom of Information Act (FOIA) requests, Congressional inquiries, or other requests. The Contractor shall use existing routine reports or on-call reporting whenever possible to ensure the economy, responsiveness and integrity of the information provided.

Task 15. Policy Analysis and Program Enhancements

The Contractor will provide insurance subject matter expertise to the various branches in the Federal

Insurance Directorate to support policy analysis and program enhancement efforts. The support may include efforts to update programmatic statues and regulations, implement affordability programs, update policy forms, develop and implement process improvements to capitalize on evolving technology, updating web content with accurate and relevant information, and other potential changes.

https://www.fema.gov/ask-expert

Part B Disaster Support (The Government is currently looking for innovative ways to incorporate disaster support operations, offerors are encouraged to provide feedback)

Part B Disaster Support, which includes labor and activities, is authorized and paid through a Smart Link account. All expenditures must be approved by the COR.

The Contractor is required to provide capable surge staff, different from the standard operational staff, to support the following activities:

Task 1. Claims Activities

The Contractor shall recommend to FEMA that a Flood Event Designation Number (EDN), formerly known as Flood Insurance Claim Office (FICO) number, is required to track all ensuing claims of severe flooding events. Once approved by FEMA, the Contractor shall designate an EDN for the event. The Contractor must disseminate a bulletin to the WYO Principal Coordinators and the NFIP Direct Contractor advising of the EDN(s), affected states, and the dates of loss.

At the direction of FEMA, the Contractor shall identify as Contractors and participate in community meetings, town halls, etc.

The Contractor shall prepare, draft, provide technical edits, seek concurrence, and disseminate relevant bulletins. Bulletins shall be uploaded to an NFIP related website per COR direction.

Task 2. Random Claims Quality Check

During a flood event, FEMA implements a fourth reinspection type (Random Claims Quality Check/RCQC) The Contractor shall plan, implement and manage the NFIP Claims RCQC process. Similar to the major functions of a routine reinspection, the Contractor is shall:

• Analyze and summarize the results of the re-inspection, including identifying trends, overpayments and underpayments, etc.

• The Contractor shall maintain a detailed database, in SharePoint, of the re-inspections and the associated findings.

• The Contractor shall provide feedback to FEMA, the WYO companies, and the NFIP Direct Contractor on claims matters arising from re-inspections, including repeated issues and trends.

• The Contractor shall support FEMA by reviewing and investigating losses through claim file reviews or re-inspections.

• The General Adjusters shall record and report their findings on the reinspection form, which must be completed in full and signed by both the WYO company representative and the NFIP General Adjuster indicating agreement with the findings.

• The reinspection form should include if there was an under/over payment.

Task 3. Adjusting Services

Separately from the eight full time General Adjusters, the Contractor shall have the capability to increase the numbers of General Adjusters to support RCQC, flood related inquiries/issues, workshops, damage assessments, and other related activities during a flood event.

The General Adjusters are required to be claims professionals, have correct authorization with an active Flood Control Numbers (FCN), have appropriate NFIP flood insurance claims experience to expertly address difficult technical claims issues with policyholders and their representatives and have the computer and software skills necessary to perform the…