GSA_SP3_Draft_RFP_Comments.pdf

Comment pertains to

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Cover Letter General All business lines

In reference to the comment on the Cover Letter, "What changes, if any, would be helpful in the current CLINs under each business line as found in Section B", we recommend the addition of a CLINs for Negotiated Interchange. We also recommend the addition of CLINs that allow for offerors to present a price for Fraud Analytics, Data Mining, Case Management. We also recommend a provision is made in the contract for additional CLINs to be created for new services or services like Inter/Intra Government Services which are unclear at this point in the draft RFP.

B.4 and C.3.1

Comment considered. See Sections B.4 Pricing Schedules and C.3.1 Product and Service Offerings in the final RFP for updated requirements.

Cover Letter General All business lines

In reference to the statement on the Cover Letter, "would the ability to price standard transaction refunds be enhanced by including Spend Volume ranges and allowing for a tiered pricing structure? If so, what type of structure would help ensure the Government can compare offers on a level playing field?" We recommend adding Spend Volume ranges to allow for tiered pricing structure would be helpful.

We would recommend tiered structure that allows for either increments of $10M or $50M to support agencies of varying sizes.

B.2 Comment considered. See Section B.2 Pricing Categories in the final RFP for updated requirements.

Cover Letter General All business lines

In reference to the comment on the Cover Letter, "compared to the pricing structure of commercial contracts for similar requirements, how is Section B different or the same?"

Commercial contracts allow for more deductions from Cash advances have been included as part of net charge volume.

Since refunds are a share of interchange, we would request cash advances be deducted from net charge volume.

N/A Comment considered, however, requirements remain unchanged.

Cover Letter General All business lines

In reference to the statement on the Cover Letter that "Many of the requirements in Section C are “not separately priced” as part of Tier 1 and Tier 2 solutions. Are there any requirements in Section C which are unclear as to how they should be priced (separately or not-separately)?" It is unclear how we price Fraud Analytics, Data Mining, Case Management, Tax Reclamation and Intergovernmentals.

Please provide further clarity. We would request the addition of CLINS to accommodate pricing for those CLINS.

B.2, B.4, and C.3.1

Comment considered. See Sections B.2, Pricing Categories, B.4 Pricing Schedules, and C.3.1 Product and Service Offerings in the revised final RFP for changes incorporated.

Cover Letter Section B All business lines

There does not appear to be a Minimum Required Basis Points for ePayables Large Ticket Transactions in the Base Period nor any of the Option Periods (none specified in B.7.1.5, B.7.2.5, B.7.3.5, nor B.7.4.5). ePayables typically see Large Ticket transactions. Would Agencies / Organizations have an interest in additional Tier 2 cardholder benefits for the Travel Business Line, such as 24-hour Roadside Assistance which is offered in the Integrated Business Line? Other potential optional benefits include luggage delay coverage, trip delay coverage, hotel / motel theft reimbursement, and others. It would preferable to pre-define as many Tier 2 optional features as possible to enable valid comparisons of contractors.

B.4, C.1, and C.3.1

EPayables under SP3 has evolved since issuance of the draft. The final RFP will outline the Government's proposed approach to ePayables, to include a definition and changes to the business line and Contract Line Item Number (CLIN) structures. See Sections B.4 Pricing Schedules, C.1 Definitions, and C.3.1 Product and Service Offerings in the final RFP for information.

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Cover Letter Section B All business lines

To be competitive in pricing, the historical performance (especially in regard to speed of pay) is imperative to the simplified refund requirement. The following types of data are most helpful to provide optimum pricing:

• Speed of pay – historical file turn data.

• Account charge off data – number and amount of charged off accounts by business line

• GSA Reports: Payment Performance and Refund Report & Write-Off Report

Also, while it is possible to access SmartPay2 statistics via the GSA website and utilize this data for modeling estimated SP3 distributed (Purchasing, Travel, Integrated, & Fleet) card volumes, anticipated ePayables volumes (or a factor of associated Purchasing Card volume) would be helpful.

B.1.5 and B.2.1.2

Agency-specific information such as speed of pay, account charge off data, and reports at the agency level are all provided at the time of solicitation and competition of task orders by the individual agencies. That data cannot be provided at the master contract level because of the variance in agency / organization size, spend volume, speed of pay, and additional reporting requirements. See Sections B.1.5 Historical Information by Task Order and B.2.1.2 Task Order Level Refunds in the final RFP for updated requirements and information.

Cover Letter Section B All business lines

It does not appear that separate pricing for IBA versus CBA Travel cards is desired. Will offerors have the ability to price IBA versus CBA programs differently given the inherently higher risk associated with IBA / individual liability cards?

B.4 Comment considered. See Section B.4 in the final RFP for changes incorporated.

Cover Letter Section B All business lines

Although spend volume ranges are helpful in pricing, the primary drivers are timeliness of payments (average file turn) and account charge-offs.

Some offerors typically provide tiered pricing to incentivize customers to increase spend on cards whereby the refund / rebate basis points paid increase as the spend increases.

The tiers are based on annual eligible net spend. Assuming a tiered refund / rebate structure, would GSA want card spend for all business lines (card types) aggregated within an Agency / Organization for purposes of determining the eligible spend tier?

B.1.5 and B.2.1.2

Agency-specific information such as speed of pay, account charge off data, and reports at the agency level are all provided at the time of solicitation and competition of task orders by the individual agencies. That data cannot be provided at the master contract level because of the variance in agency / organization size, spend volume, speed of pay, and additional reporting requirements. See Sections B.1.5 and B.2.1.2 of the final RFP for additional information.

Cover Letter Section B All business lines

Our typical refund / rebate pricing schedule is structured as below. Tiers generally are structured in $5MM - $10MM spend ranges.

Annual Dollar Volume Rebates Incentive $30,000,000 and above $20,000,000 to $29,999,999 $15,000,000 to $19,999,999 $10,000,000 to $14,999,999 $5,000,000 to $9,999,999 $2,500,000 to $4,999,999 $0 to $2,499,999

We do not currently consider cash transactions nor reduced interchange transactions that earn less interchange than Large Ticket Transactions eligible to earn a refund / rebate.

We can support quarterly refund / rebate remittances to Agencies / Organizations. With this rebate structure (tiered based on annual spend) and a quarterly refund / rebate payment, a true-up would be performed for determining the payment for the 4th quarter of each fiscal year.

B.2.1.2 Comment considered. See Section B.2.1.2 Task Order Level Refunds in final RFP for changes incorporated.

Cover Letter Section B / Section M ePayables GSA should note that, during the bid process for ePayables programs, contractors will typically request a vendor file from the Agency / Organization Accounts Payable department to perform vendor analysis for purposes of identifying potential spend that can be migrated to card. The methodology used by contractors for such vendor analysis can vary widely and may result in differing estimates of potential ePayables spend and associated refund /rebate potential.

B.4, C.1, and C.3.1

EPayables under SP3 has evolved since issuance of the draft. The final RFP will outline the Government's proposed approach to ePayables, to include a definition and changes to the business line and Contract Line Item Number (CLIN) structures. See Sections B.4 Pricing Schedules, C.1

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Cover Letter Section M All business lines

If there is a test scenario that does not receive at least an acceptable rating during the Live Test Demonstration (LTD), is the Contractor disqualified? If not, what is the lowest rating the Contractor can receive to remain qualified? If a marginal rating is received for the overall LTD rating, is the Contractor disqualified? If not, how long does the Contractor have to correct the deficiencies?

M Comment considered. See Sections L and M for information regarding the evaluation of the Live Test Demonstration (LTD)

Cover Letter Section C - C.2.9

All business lines

The non-generic card design vertical orientation may cause challenges for card personalization (i.e., thermal print of card number and cardholder name required) as well as for merchants and mobile applications. What is the expectation for the volume of agencies that will choose this non-generic card design in light of the potentially higher cost to support thermal printing rather than embossing? We suggest that the Government perhaps makes this card design an option at the Task Order level.

C.3.2 Comment considered, however, the Government requires offerors propose using the card designs found in the RFP;

these are not optional and shall not be re-designed at the task order level.

Cover Letter Section C - C.3.7 & C.3.11.1

All business lines

Government to Government Transactions (C.3.7 & C.3.11.1) is a large and varied requirement that encompasses many types of inter/intra governmental payments. Some can be simple such as interagency payment for printing services, where a charge card can be used, but others are complex and require detailed transactions (like procurement of depot stored end items). Therefore, the agencies/departments have established a payment process (Interagency Purchase Request or Military Interdepartmental Purchase Request) for these procurements. A comprehensive fee structure within the framework of the SmartPay program is difficult to identify and should therefore be a Tier 2 requirement, especially for complex procurements. An option for G2G transactions will impact interchange earn and thus the refund/rebate the contractor can offer. It is also uncertain which CLIN to use to disclose cash advance, and late payment fees.

B.2, B.4, and C.3.1

Comment considered. See Sections B.2, Pricing Categories, B.4 Pricing Schedules, and C.3.1 Product and Service Offerings in the revised final RFP for changes incorporated.

Cover Letter Section C - C.4.4.3

All business lines

Is a custom developed product required? Also please define the internal and external data sources with which this tool must interface.

C.7.4.3 This could be a custom tool or industry tool, depending on the offeror's approach. See Section C.7.4.3 Reporting Requirements in the final RFP for requirements.

Cover Letter Section C - C.6.5

All business lines

Re: Reporting Requirements C.6.5.3.2.e through C.6.5.3.2.k

– is GSA anticipating use of virtual travel cards?

C.3.1 Agencies / organizations may define the need for travel card requirements in accordance with Tier 1 solutions outlined in the general and business-specific requirements.

See Section C.3.1 Tier 1: Required Product and Service Offerings in the final RFP for information.

Cover Letter Section C - C.6.5

All business lines

Re: Reporting Requirements C.6.5.3.2.l – how does the GSA anticipate that ePayables would be used for Fleet purchases?

B.4, C.1, and C.3.1

EPayables under SP3 has evolved since issuance of the draft. The final RFP will outline the Government's proposed approach to ePayables, to include a definition and changes to the business line and Contract Line Item Number (CLIN) structures. See Sections B.4 Pricing Schedules, C.1 Definitions, and C.3.1 Product and Service Offerings in the final RFP for information.

Cover Letter Section C -- C.6.5 ePayables ePayables (C.6.5 pgs. 225-227) requirements are vague and undefined. Since this category is evolving, processes and technology are expected to grow substantially resulting in new (and as yet undefined) potential opportunities for contract spend. Since ePayables is expected to be a future spend opportunity but resulting in substantially reduced interchange revenue, will the Government establish ePayables as a Tier 2 fee based offering?

B.4, C.1, and C.3.1

EPayables under SP3 has evolved since issuance of the draft. The final RFP will outline the Government's proposed approach to ePayables, to include a definition and changes to the business line and Contract Line Item Number (CLIN) structures. See Sections B.4 Pricing Schedules, C.1

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Cover Letter Section C.4.4.3

All business lines

Fraud Analytics (C.4.4.3 pgs. 142-143) are normally the purview of the associations and banks. In this section the requirements toggle between fraud detection during transaction processing and analytics to detect misuse/abuse by cardholders. In addition, the integration of the fraud analytic tools with the EAS will entail development of both the tools and require EAS enhancements to enable real-time approval/rejection of non-qualifying transactions by the A/OPC or GSA staff. Net result – increased development costs will equal lower basis points (bp) for refunds to GSA/Agencies. One alternative is to incorporate fraud analytic requirements into data warehouse, data mining, or reporting sections.

For clarification, is GSA asking that an Agency have the ability to interrogate merchant authorization requests via the Card Association network and participate in real-time decisioning to approve or decline the transaction?

C.7.4.3 Requirements remain unchanged. Fraud analytics needs to be integrated within the EAS of the contractor. See Section C.7.4.3 of the final RFP for information.

Section B - Pricing Schedule

B.1 (moved from Section B to H.12)

All business lines

There are numerous statements throughout the RFP that indicate the contractor must provide all Tier 1 Services and all services in section C. However, figure 5 on page 18 indicates bidders may compete selectively on the lines of business. Can you please clarify if contractors must bid on all Lines of Business or if they have the option of bidding separately? If contractors may bid selectively on the lines of business, can you more explicitly clarify which products fall in the lines of business? (also applies to B.2, C.2.3, C.2.6, and B.6.1)

B.2, B.4, and C.3.1

See Sections B.2 Pricing Categories, B.4 Pricing Schedules, and C.3.1 Tier 1: Required Product and Service Offerings in the final RFP for clarifications.

Section B - Pricing Schedule

B.1.1 All business lines

Under GSA SmartPay 2, Contractors are calculating the IFF based on charge volume and then deduct that from the refund. Can you please further explanation as the draft RFP differs from the current process.

B.3.3 Please note that the terms "Industrial Funding Fee" and "IFF" have been changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. The draft RFP removed separate refunds/rebates for charge volume and productivity, as was found under GSA SmartPay 2. For GSA SmartPay 3, CAF is deducted from gross refunds and remitted directly to GSA by the Contractor. See Section B.3.3 of the final RFP for information on the calculation of refunds.

Section B - Pricing Schedule

B.1.1 All business lines

In reference to the description for IFF, "The Contractor shall deduct the GSA Industrial Funding Fee (IFF) from the net charge volume for the sales refund" under paragraph 2, this does not align with the example illustrated under Section B.3.1. Can you confirm which scenario the Contractor shall use: the description in Section B.1.1 or the example in Section B.3.1?

B.3.3 Please note that the terms "Industrial Funding Fee" and "IFF" have been changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. See Section B.3.3. Calculation of Refunds in the final RFP for updated refund examples.

Section B - Pricing Schedule

B.3 ePayables Suggest GSA carry-over similar language from Smart Pay 2, Section B.4.5 related to Non-Interchange Transactions with the option to negotiate the IFF based on the type of ePayables solution being offered.

B.3.2 and G.1

Please note that the terms "Industrial Funding Fee" and "IFF" have been changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. Comment considered, however, requirements remain unchanged.

The CAF, as outlined in the final RFP by business line and product / service offering, is the minimum acceptable to the Government. See Sections B.3.2 GSA Contract Access Fee (CAF) and G.1 GSA Contract Access Fee (CAF) in the final RFP for information.

Section B - Pricing Schedule

B.3.1 All business lines

Contractors typically have standard billing cycle start and end dates. Customers have the ability to choose which billing cycle they want to be on when presented with their options. Customers do not have the ability to choose their own cycle start and end dates. Standard commercial cycles are monthly (calendar), weekly, or daily. Also see section C.2.11, as this comment applies there.

B.3 Comment considered. See Section B.3 Refunds:

Calculation, Payments, and Remittance, in the final RFP for updates.

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Section B - Pricing Schedule

B.3.1.1 All business lines

Does the Contractor need to provide daily convenience check spend reports and daily gross credit losses reports?

B.3.3 and C.7.3

For the purposes of the calculation, the Contractor needs to provide the amounts used for the calculation; see Section B.3.3 in the final RFP. However, this information may be required as part of specific reports outlined in Section C.7.3, Reporting Requirements, of the final RFP.

Section B - Pricing Schedule

B.3.1.1 Fleet Can you please define "credit losses?" Is it what is defined as a "Credit" in Section C.1 Definitions?

B.3.3 and C.1

See updated information in Section B.3.3 Calculation of Refunds in the final RFP. See the updated definition for "Gross Credit Loss" in Section C.1 Definitions of the final

RFP.

Section B - Pricing Schedule

B.3.1.1 Fleet Please better define credits and adjustments and provide examples of each.

B.3.3 and C.1

See updated information in Section B.3.3 Calculation of Refunds in the final RFP. See new definition for "Adjustment" and updated definition for "Credit" in Section C.1 Definitions of the final RFP.

Section B - Pricing Schedule

B.3.1.1 All Business Lines

This section identifies that GSA IFF can be up to 6.5 basis points. At what point in time will GSA make a decision on the base period IFF and option periods as well? What factors would cause GSA to change the IFF mid contract?

Will GSA IFF be different for different organizations?

B.3.2 and G.1

Please note that the terms "Industrial Funding Fee" and "IFF" have changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. The Center for Charge Card Management (CCCM) will evaluate the CAF amounts and notify parties as outlined in Section G.1 GSA Contract Access Fee (CAF) of the final RFP. CAF will not vary by agency/organization.

Section B - Pricing Schedule

B.3.1.1 All business lines

Regarding calculation of Sales Refunds does the word "determine" entail that the Contractor will have to disclose net charge volume on a daily basis to the Agencies?

B.3 See Section B.3, Refunds: Calculation, Payments, and Remittance in the final RFP for updated information.

Section B - Pricing Schedule

B.3.2.1 All business lines

Can you comment/clarify why the quarterly refund schedule has been changed from October of each year in SmartPay 2, to November in SmartPay 3? It appears all other months remained the same.

B.3.1 Comment considered. See Section B.3.1, Frequency of Refund Remittance in the final RFP for updates.

Section B - Pricing Schedule

B.3.2.1 All business lines

Is November 15th a change from the current process?

Contractors are using October 15th for the Fiscal Year.

B.3.1 Comment considered. See Section B.3.1, Frequency of Refund Remittance in the final RFP for updates.

Section B - Pricing Schedule

B.3.3 ePayables Can you please clarify the following sentence: "The Contractor shall remit and deduct 2 basis points of gross sales refunds for ePayables or 6 cents per transaction for ePayables transactions for the GSA IFF." Are you stating the contractor will choose how they pay the IFF on ePayables?

B.3.2 and G.1

Please note that the terms "Industrial Funding Fee" and "IFF" have been changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. Comment considered, however, requirements remain unchanged.

Depending on the structure of the ePayables solution, we anticipate that either method (bps against gross refunds or per transaction) could be used. Structuring the pricing schedule this way allows the Government to outline it's minimum required refund in the event either method is proposed under a given solution, and CAF should be paid in accordance with the method awarded at the task order level. Offerors must propose both pricing methods at the master contract level.

Section B - Pricing Schedule

B.3.3 All business lines

Can the GSA please clarify what is driving a separate GSA IFF for ePayables product?

B.3.2 and G.1

Please note that the terms "Industrial Funding Fee" and "IFF" have been changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. A separate CAF for ePayables product and service offerings was developed to account for the lower rate of interchange generated by these types of solutions.

Section B - Pricing Schedule

B.3.3 All Business Lines

Question: If the IFF increases, how is the increase funded?

Will the issuers be expected to cover the costs of this increase?

B.3.2 and G.1

Please note that the terms "Industrial Funding Fee" and "IFF" have changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. The Contract Access Fee (CAF) is calculated against net charge volume, then deducted from gross refunds. This calculation remains constant regardless of the rate at which the CAF is set.

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Section B - Pricing Schedule

B.3.3 All business lines

GSA Industrial Funding Fee (IFF): GSA reserves the right to unilaterally adjust IFF basis points for the duration of the Master Contract. If a Contractor’s internal cost of funds increases, yet the IFF rate is not increased by GSA, is the Contractor expected to cover the expense of their increased funds cost?

B.3.2 and G.1

Please note that the terms "Industrial Funding Fee" and "IFF" have changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. The Contract Access Fee (CAF) is not a tool for Contractors to recover internal cost of funds. Contractors must negotiate refund rates at the task order level that take into consideration possible increases in their costs over the life of the contract. CAF is paid to GSA using the calculations found in B.3.3. These calculations remain constant regardless of the rate at which the CAF is set. See Sections B.3.2 and G.1 in the final RFP for information.

Section B - Pricing Schedule

B.3.3 All business lines

Will there by any variation on IFF calculations by agencies? B.3.2 and G.1

Please note that the terms "Industrial Funding Fee" and "IFF" have changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. CAF will not vary by agency/organization.

Section B - Pricing Schedule

B.4 All Business Lines

Pg 16 Pricing for Base and Option Yrs: Question: Is there a possibility that transactions can occur during the Transitional Period? If so, how is the decision made regarding the start and end dates for the Transitional Period? How do contractors price for transactions that occur during the Transitional Period?

C.2.2 and H.11

See Sections C.2.2 Transition and H.11 Transition to GSA SmartPay 3 of the final RFP for information.

Section B - Pricing Schedule

B.4 All Business Lines

There are ambiguities/contradictions in the transitional and transactional period of performance. Please provide clarification on whether an agency will be able to transact prior to the expiration of their existing SP2 task order period of performance. Also, as written, it appears the transition period can extend beyond the first date of transactional period of performance for SP3. If so, what is the contracting mechanism to keep the agency with their SP2 provider past the SP2 expiration date.

F.1 See Section F.1, GSA SmartPay Contract Period of Performance, in the final RFP for clarification on the transitional and transactional periods for GSA SmartPay 3.

Section B - Pricing Schedule

B.6.1 All business lines

Figure 5 breaks out fleet separately, but elsewhere integrated is defined as including fleet. Is there an option to offer integrated without also offering fleet? Options 3, 5, and 7 do not otherwise include fleet as a stand-alone business line, although the definition for Integrated in C.1 includes fleet. Please clarify whether the Integrated card program must include fleet cards when the Contractor is bidding on Pricing Options #3, #5, and/or #7.

B.4, C.1, and C.2.1

See Section B.4 Pricing Schedules, in the final RFP for updated proposal options. See Section C.1 Definitions, in the final RFP for the definition of an Integrated Card. See Section C.2.1.4 Integrated Business Line Scope of Work, in the final RFP for information about associated requirements.

Section B - Pricing Schedule

B.6.1 All Business Lines

If an agency receives only one bid above the minimum for each pricing grouping will it be allowed to resubmit its task order with a different grouping to attract more offers?

B.4 See Section B.4 Pricing Schedules, in the final RFP for updated proposal options. Any such determination for task order competitions will be at the discretion of the agency/organization level Contracting Officer under the policies of that agency/organization.

Section B - Pricing Schedule

B.7 Fleet Convenience check management is more geared towards a purchase or travel card program. Please review and clarify if this is a true fleet card program need to be managed through an EAS. We have not encountered this need in the fleet card industry. We would ask that it be removed, or made optional.

B.4 and C.3.1

See Section B.4 Pricing Schedules, in the final RFP for updated contract line items by business line. See Section C.3.1.Product and Service Offerings, in the final RFP for updated information and tables depicting the business lines under which each Tier 1 or Tier 2 product / service offering fall.

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Section B - Pricing Schedule

B.7.1.1 All business lines

Regarding the terms in Section B.7.1.1. can the following CLINs be added to the list of fees a Contractor can include in its pricing offer:

- Cardholder Annual Fee

- Cash Advance Charge from Teller

- Late Payment Charge

- Purchase Finance Charge

- Foreign Transaction Fee

- Return Payment Fee

- Implementation Fee

- Implementation and Training Fee

- File Integration and Reporting Fee

- Custom File Development Fee

- Custom Card Design Fee

- Convenience Checks Stop Payment

- Card Special Handling Fee

- Statement Fee

- Telephone Payment Fee

- Statement and Receipt Copy Fee

B.2, B.4 and C.3.3.16

Comment considered, however, requirement remains unchanged. Section C.2.10.10, Fees, in the draft RFP stated that "No payment solution fees...shall apply to the GSA SmartPay Program accounts, unless otherwise specified herein." In the final RFP, see Sections B.2 Pricing Categories, B.4 Pricing Schedules, and C.3.3.16 Fees, for information.

Section B - Pricing Schedule

B.7.1.4 Fleet CLIN 0003: There is not a "large ticket treatment" in closed-loop card solutions with regards to refunds/rebates to customers. The size of the transactions simply do not vary a great deal, as they are narrowed in scope; transactions over $1,000 are rare. The rebate/refund given to customers is typically the same for a $500 transaction as it is for a $25 transaction. Recommend the large-ticket treatment not be required for closed-loop card solutions, as this only applies to open loop solutions.

B.2, B.4, and C.3.1

Comment considered, however, requirements remain unchanged. While this may not be applicable in a closed-loop system, should the card be used at a merchant that does not accept the closed-loop solution, the transaction is processed using open-loop system and as such, merchants may determine a transaction to be a "large ticket transaction". See Sections B.2 Pricing Categories, B.4 Pricing Schedules, and C.3.1 Product and Service Offerings for information.

Section B - Pricing Schedule

B.7.1.4 Fleet Is there IFF payment due to GSA on Tier 2 products? B.3.2 and G.1

Please note that the terms "Industrial Funding Fee" and "IFF" have changed to "Contract Access Fee" and "CAF" in the final RFP as a result of the Transactional Data Reporting rule issued by GSA in June 2016. There is no distinction in the application of CAF between Tier 1 and Tier 2 products; CAF is applied against the net charge volume of all products / services and deducted from gross refunds. See Sections B.3.2 and G.1 in the final RFP for information on calculating and remitting CAF to GSA.

Section B - Pricing Schedule

B.7.1.5 ePayables Epayables: There are commercially available ePayables solutions in the market that are not fully integrated with an ERP and require human intervention on one or both ends of the transaction. These solutions (like virtual accounts) provide a benefit to users and should be identified as an offering under the ePayables section.

B.4, C.1, and C.3.1

Comment considered. See Section B.4 Pricing Schedules, in the final RFP for revised proposal options and pricing tables. See Section C.1 Definitions, of the final RFP for updated definitions of ePayables solutions from those outlined in the draft RFP. See Section C.3.1 Product and Service Offerings, for additional informational related to ePayables solutions.

Section B - Pricing Schedule

B.7.3.5 ePayables Pg 38, Epayables Option Period 2: Question: Footnote 44 states "Contractor may offer minimum basis points level that is higher than the required 20 basis points minimum";

however the table states that 15 bps is the minimum. Which is correct?

B.4 See Section B.4 Pricing Schedules, for updated information on the minimum basis points required under ePayables product and service offerings.

Section B - Pricing Schedule

General All business lines

The RFP does not state the exact rebate structure. Will there be a base rebate amount and also a speed-to-pay type incentive? There is also reference to a "tiered approach" in the cover letter; please describe the structure.

B.2.1.2 and B.4

The draft RFP removed separate refunds/rebates for charge volume and productivity, as was found under GSA SmartPay 2. See Sections B.2.1.2 Task Order Level Refunds, and B.4 Pricing Schedules, in the final RFP for information on what is allowable in terms of refund/rebate structures at the task order level.

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Section C - Statement of Work

C 4.1 All business lines

Must EAS requirements that an ordering agency wants to impose in a task order pursuant to Section C.4.1 of the RFP be mutually agreed with the Contractor (as the changes provision in FAR 52.212-4(c) indicates), or can they be unilaterally imposed by the agency?

What limits, if any, are there on the type or scope of requirements that an ordering agency can include in a task order pursuant to Section C.4.1 of the draft RFP?

C.7.1 and H.12.11.2

Agencies/organizations will outline any additional requirements in their task order request requirements documents. It is up to the Offerors to propose and the Offerors and agencies / organizations to negotiate refunds at the task order level based on the agency/organization-specific requirements. Agencies/organizations are not authorized to include requirements that contradict or fall outside the Statement of Work found in the GSA SmartPay 3 Master Contract. However, they are authorized to include agency-specific requirements that compliment the Master Contract requirements. See Sections C.7.1 Electronic Access System and H.12.11.2, Tailored Task Order Process, in the final RFP for additional information.

Section C - Statement of Work

C.1 All business lines

Please define "EAS" as it relates to the scope of this contract. Is it inclusive of all contractor's systems offered?

Or is the RFP only referring to a contractor's account and card management EAS?

C.1 and C.7.1

See Sections C.1 Definitions, and C.7.1 Electronic Access System, in the final RFP for information.

Section C - Statement of Work

C.1 ePayables Suggested addition: ePayables may include non-interchange fee based payment products with designated Smart Pay 3 ePayable Providers. These non-interchange fee based products would operate outside of card networks for payment transfers.

B.4, C.1 and C.3.1

Comment considered. EPayables under SP3 has evolved since issuance of the draft. The final RFP will outline the Government's proposed approach to ePayables, to include a definition and changes to the business line and Contract Line Item Number (CLIN) structures. See Sections B.4 Pricing Schedules, C.1 Definitions, and C.3.1 Product and Service Offerings in the final RFP for information.

Section C - Statement of Work

C.1 ePayables Suggested addition Definition: Interchange Transaction:

Transactions processed through traditional transaction channels (e.g. traditional network [MC, Visa] based interchange structure).

N/A This terminology is not used within the confines of the GSA SmartPay 3 requirements. Requirements remain unchanged.

Section C - Statement of Work

C.1 ePayables Suggested addition: ePayables may include non-interchange fee based products that may utilize ACH to disburse payments along with an e-Remit statement to exchange funds and data associated with payment.

B.4, C.1, and C.3.1

EPayables under SP3 has evolved since issuance of the draft. The final RFP will outline the Government's proposed approach to ePayables, to include a definition and changes to the business line and Contract Line Item Number (CLIN) structures. See Sections B.4 Pricing Schedules, C.1 Definitions, and C.3.1 Product and Service Offerings in the final RFP for information.

Section C - Statement of Work

C.1 ePayables Suggest adding a definition for "Non-Interchange Transaction: Transactions process through alternate transaction channels (ACH, wire, etc.)"

C.1 See Section C.1 Definitions in the final RFP for a definition of "Non-Interchange Based Transactions".

Section C - Statement of Work

C.1 All business lines

In regards to Net Charge Volume, please define further "merchant credits."

C.1 See Section C.1 Definitions in the final RFP for a definition of "Merchant Credit".

Section C - Statement of Work

C.1 Fleet In regards to Net Charge Volume, some card issuers can net taxes as a part of transaction processing (based on Level III data capture). In this instance does "net charge volume" mean the "sale amount net of tax", or "gross of tax"?

B.3.3 For all business lines, "net charge volume" includes ALL transactional spend. See Sections B.3.3 Calculation of Refunds, in the final RFP for information.

Section C - Statement of Work

C.1 Fleet Merchant Category Codes (MCCs) may not be relevant in a closed-loop environment. Closed-loops use identifiers sometimes called product category or product class controls. Suggest that any MCC-related requirements not be applicable to closed loop solutions.

C throughout

See Section C throughout the final RFP for updates related to the applicability and use of Merchant Category Codes (MCC) to closed-loop environments.

Section C - Statement of Work

C.1 All business lines

In reference to the definition of "Closing Date": It is stated as specific to Individually Billed Accounts (IBAs) in the RFP.

"Closing Date" is a term applicable to IBAs and Centrally Billed Accounts (CBAs). Please clarify why it is only used for IBAs in the draft RFP.

C.1 See Section C.1 Definitions in the final RFP for an updated definition of "Closing Date".

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Section C - Statement of Work

C.1 All Business Lines

Association is no longer an accurate term for the networks providing services to the banks such as setting of interchange. Networks are publicly traded companies. PCI is a council. EMV Co is a company. Neither would be member owned associations. Recommended deleting the term.

C.1 See Section C.1 Definitions in the final RFP for an updated definition of "Association".

Section C - Statement of Work

C.2 All business lines

Related to Fraud Analytics, in the definitions section, "External Fraudulent Activity" is defined as “an act of misuse and/or abuse for GSA SmartPay account payment”, "Fraud" is defined as “an act of corruption or attempt to cheat Federal Government” and "Fraudulent Activity" is defined as “The use of government payment solutions not sanctioned, not authorized.” It appears that the use of these terms are not consistent with how they are defined in the Fraud Analytics section of the RFP and our understanding is that this section is only refering misuse and abuse. In the commercial card industry, external fraud is defined as third party fraud. The role of managing third party fraud along with the liability is assumed by the issuer. Since the banks are wholly responsible for 3rd party fraud, we are assuming throughout this document, any reference to fraud throughout the RFP is in reference misuse and abuse, not fraud.

Please confirm that this understanding is correct.

C.1, C.3.3.13, and C.7.4.3

See Section C.1 Definitions in the final RFP for updated definitions. See Section C.3.3.13 Liability in the final RFP for information regarding liability for external fraud. See Section C.7.4.3 Fraud Analytics in the final RFP for necessary fraud analytic capabilities / tools required under GSA SmartPay 3.

Section C - Statement of Work

C.2.10.11 All business lines

We would ask that you allow contractors to charge a foreign currency conversion fee of some percentage, and that it not be waived altogether. This is a standard business practice, and was allowed in SmartPay 2.

C.3.3.16.2 Comment considered, however, requirement remains unchanged. This is a change from GSA SmartPay 2 to GSA SmartPay 3. See Section C.3.3.16.2 Foreign Currency Conversion in the final RFP for information.

Section C - Statement of Work

C.2.10.12 All business lines

Delinquency control cannot be regulated by the Contractors.

The requirement has a bullet ‘Implementing regulations/guidance’. Will GSA consider revising that requirement to clarify that the contractor is required to "implement government regulations/guidance?"

C.3.3.10 Comment considered, however, requirement remains unchanged. Section C.2.10.12 of the draft RFP stated that "The Contractor shall assist GSA and agencies/organizations with the monitoring of delinquency in accordance with regulations and policies outlined in P.L.

112-194 and OMB Circular A-123, Appendix B..." See Section C.3.3.10 Delinquency Control in the final RFP for this language which was retained from the draft RFP.

Section C - Statement of Work

C.2.10.13 All business lines

Regarding the account type being referenced, do these suspension procedures apply to the CBA, the cardholder/charge account or both?

C.3.3.11 See Section C.3.3.11 Suspension Procedures in the final RFP for information and clarification.

Section C - Statement of Work

C.2.10.14 All business lines

The requirement states: “Credit information shall not be referred to credit reporting agencies for Travel CBAs. Any and all disclosure of credit information shall begin only after the account has been suspended twice during a 12-month period or the account is past due for undisputed amounts and the suspension procedure requirements have been met.” These two sentences appear contradictory. If travel CBAs will not be referred to credit reporting agencies why does the second sentence allow for disclosure of credit information under the two specified conditions?

C.3.3.11 and C.3.3.12

See Sections C.3.3.11 Suspension Procedures and C.3.3.12 Cancellation Procedures in the final RFP for information and clarification.

Section C - Statement of Work

C.2.10.14 All business lines

The requirement states that the Contractor shall notify the A/OPC of transactions that are processed on cancelled cards more than 90 days after the account has been closed.

To clarify if EAS is an acceptable data source/tool for A/OPC notification, is notification via the EAS acceptable?

Is email notification preferred?

C.3.3.12 See Section C.3.3.12 Cancellation Procedures in the final RFP for information and clarification.

Section C - Statement of Work

C.2.10.2 All business lines

Viewing statement and making payments on-line: GSA is requesting that the Contractor assist agencies with establishing on-line or mobile access to their account to view statements and make payments. When GSA says ‘on-line’ is it referencing the EAS?

C.3.3.1 See Section C.3.3.1 Account Set-Up, subparagraph g), in the final RFP. Subparagraph g) is a reference to assisting account holders with set up for access to statements and ability to make mobile payments through the banks interface for account holders. "Online" does not mean

"EAS".

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C.2.10.2 All business lines

The account set-up process includes an email from the Contractor to the account holder. GSA is requesting that the Contractor accept program forms electronically, including but not limited to processing account applications, with a subsequent email on how to sign up for online account access via email. This crosses multiple ‘types of systems’ that may not be interrelated. What is GSA’s ultimate goal with this requirement?

C.3.3.1 As stated in the draft RFP requirements, once the applicant submits an online application form, should they be approved for an account, the Government requires that the applicant be provided an email with account set up information. See Section C.3.3.1. Account Set-Up in the final RFP for information and clarification.

Section C - Statement of Work

C.2.10.3 All business lines

The stated card issuance delivery shipping timeline is tight for international card delivery; item b) 10-14 calendar days for international addresses is not feasible in all cases. Will the Government consider easing the stringency of that requirement?

C.3.3.2 See Section C.3.3.2 Card Issuance and Delivery in the final RFP for updated requirements.

Section C - Statement of Work

C.2.10.3 All business lines

Card replacement timeline does not consider Contractor operations and the Processor cutoff times and schedules.

Item e) Process and mail replacement cards within 2 calendar days does not take into account operational cut-off times, and the Processor scheduling impacts on weekends and holidays. Would GSA consider noting such exceptions to the deadlines?

C.3.3.2 See Section C.3.3.2 Card Issuance and Delivery in the final RFP for updated requirements.

Section C - Statement of Work

C.2.10.4 Fleet Please remove the requirement that the agency can tell the contractor who to use for a mail carrier. This should be up to the contractor to negotiate themselves at their discretion. If an agency wants to use a particular carrier for their own reasons, they should pay for it through their own carrier account number.

C.3.3.2 See Section C.3.3.2 Card Issuance and Delivery in the final RFP for updated requirements.

Section C - Statement of Work

C.2.10.6 All business lines

Verification and tracking of card delivery requires all parties (sender and recipient) to be engaged and accountable.. The GSA requirement puts the verification of receipt of every charge card on the Contractor. Will the Government mandate that agencies cooperate and assist the Contractor and Processor with validating card delivery status?

Secondly, does cardholder activation not suffice to verify successful card delivery?

C.3.3.2.2 See Section C.3.3.2.2 Verification of Card Receipt in the final RFP for updated requirements.

Section C - Statement of Work

C.2.10.6 Fleet With regards to the requirement of verification of card receipt, would providing to the agencies a report of overnight tracking numbers of card shipments to the agencies meet the requirement? Or do you want the agencies to call in and activate their cards? This is not typical with a closed-loop solution; cards are typically shipped in an active state.

C.3.3.2.2 See Section C.3.3.2.2 Verification of Card Receipt in the final RFP for updated requirements.

Section C - Statement of Work

C.2.10.7 Fleet Must prefixes be unique for each individual account by agency or is the requirement for one assigned prefix that is unique to all agencies participating in a particular line of business?

C.3.3.6 The requirement is to provide prefixes not for individual customers, but to help identify government users within the GSA SmartPay Program. See Section C.3.3.6 Account Number in the final RFP for information.

Section C - Statement of Work

C.2.10.9 All business lines

Liability for fraudulent activity: Given that GSA will only assume liability for external fraud, do you anticipate invoking a Liability Waiver with the contractor for internal / employee fraud?

C.3.3.13 As stated in Section C.2.10.9 Liability of the draft RFP, and Section C.3.3.13 Liability of the final RFP, the Government will not assume liability for external fraud. See Section C.3.3.13 Liability and associated subsections in the final RFP for information related to Contractor liability.

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C.2.10.9 All business lines

This requirement does not encourage agencies to work toward minimizing losses. Will the Government consider revising the requirement for external fraud liability to require the agency A/OPC and cardholder to cooperate with the Contractor to minimize losses with minimal impact to the cardholder.

C.3.3.13 As stated in Section C.2.10.9 Liability of the draft RFP, and Section C.3.3.13 Liability of the final RFP, the Government will not assume liability for external fraudulent activity. See Section C.3.3.13 Liability and associated subsections in the final RFP for information related to Contractor liability.

In accordance with OMB Circular A-123 Appendix B, agencies must establish risk management processes to mitigate risks of fraud, abuse, and misuse. Agencies will leverage Contractor and Network existing fraud analytics capabilities to assist these efforts. The GSA SmartPay 3 Master Contract is not a vehicle to hold agencies accountable for external fraud.

Section C - Statement of Work

C.2.10.9, C.2.10.9.1, C.6.2.1.4.7, and C.6.3.1.5.5

All Business Lines

As written, GSA expects the issuer to accept liability on all charges not authorized by the cardholder. Issuers are held to dispute processes set forth by the Brands in determing liability. Requirements will need to be rewritten to include cardholder responsibilities in disputing unauthorized transactions in all sections.

C.3.3.13 As stated in Section C.2.10.9 Liability of the draft RFP, and Section C.3.3.13 Liability of the final RFP, the Government will not assume liability for external fraudulent activity. See Section C.3.3.13 Liability and associated subsections in the final RFP for information related to Contractor liability.

In accordance with OMB Circular A-123 Appendix B, agencies must establish risk management processes to mitigate risks of fraud, abuse, and misuse. Agencies will leverage Contractor and Network existing fraud analytics capabilities to assist these efforts. The GSA SmartPay 3 Master Contract is not a vehicle to hold agencies accountable for external fraud.

Section C - Statement of Work

C.2.10.9.1 Liability - 74

All Business Lines

This section indicates the government only accepts liability for employee fraud not external fraud on CBA accounts.

Does this mean the government does not expect to have to follow a dispute process to avoid liability for external…