Q_and_A_Final.pdf

Owner Comment Response Related to Objective 1 on page 5 of the SOO, will the NFIP ultimately be responsible for the final policy language that it adopts, particularly if there is a coverage dispute?

The NFIP will be responsible for the policy language it adopts for the policies it sells.

Objective 1 on page 5 states that “The Contractor will apply relevant legal regulations as well as business and technological developments in policy language to the policy form redesign process.” Will FEMA confirm that all the requirements described in the SOO objectives do not require “legal advice” or “legal counsel” rather advisory services provided by a professional services firm with capabilities in insurance, insurance policy form and form compliance reviews, underwriting, regulatory analysis, and policy form assessment, analysis, and development? Legal advice or legal counsel may constitute an inherently governmental function.

FEMA does not require legal advice or counsel but does expect the offeror to apply an understanding of legal principles in developing policy forms.

If FEMA does not require legal advice and legal counsel as part of this requirement, will FEMA consider updating the SOO objectives as follows: SOO #1: Remove “legal” from the second bullet that currently reads that “The Contractor will apply relevant legal regulations as well as business and technological developments in policy language to the policy form redesign process” to “The Contractor will apply relevant regulations, as well as business and technological developments in policy language to the policy form redesign process”. Please confirm that FEMA is not requesting legal advice or legal counsel as part of this SOO requirement for all objectives

FEMA does not require legal advice or counsel but does expect the offeror to apply an understanding of legal principals in developing policy forms, which would likely requires the skill of an attorney. FEMA will not change the SOO.

Section H.10 KEY PERSONNEL REQUIREMENTS on page 20 states that “It is not required that the Contractor provide personnel with these exact titles, rather the collection of Contractor personnel shall meet the functional requirements consistent with the SOO.” Please confirm that is acceptable to provide an alternative key personnel option for the “Lead Attorney” position that will still possess the relevant skillsets to review the policy forms. We believe that the skillset and experience for "Lead Attorney" position listed in the Key Personnel section can be provided by a “Senior Compliance Analyst” that is still “responsible for all compliance review of policy forms activity of the Risk Rating and Policy Forms Contract, including but not limited to the assessment of the current policy forms, the development of new policy forms, and the testing of the new policy forms. The Senior Compliance Lead would still have significant relevant work experience (over 10 years) working with and developing policy forms." Please confirm this would be acceptable to FEMA.

FEMA has revised the title of the "Lead Attorney" position in the updated SOO dated 11 September 2017. However, the level of legal expertise will be considered.

In pursuing the important goal of a 'plain language' (e.g., understandable) coverage form, is the government willing to allow direct language with respect to 'other insurance' to address issues that are historically frustrating to and not well understood by consumers, such as the first wind vs water issue?

FEMA would consider such language.

Does the government intend that new plain language forms address issues where CRS and flood plain management actions affect multiple loss properties? FEMA intends that the policy forms address all aspects of the NFIP.

Will the government permit the policy language to reflect private sector approaches to multiple loss properties? FEMA can consider such approaches, but cannot commit to adopting them at this time.

Questions related to Objective 1 on page 5 include:

a. Will the NFIP ultimately be responsible for the final policy language that it adopts, particularly if there is a coverage dispute?

b. Coverage under the existing flood policies is fairly limiting and restricted. Are broadening coverage and / or offering higher coverage limits NFIP goals?

c. Is a goal of this Contract to be able to offer policyholders better coverage and more coverage options to choose from even if it is at a higher price?

a. The NFIP will be responsible for the policy language it adopts for the policies it sells. b.

FEMA would like to expand coverage options. FEMA would like to offer higher coverage limits but would need Congressional to do so.

c. FEMA would like to offer better coverage and more coverage options but is sensitive to what consumers would be willing to purchase.

On page 7 under Objective 3, various flood insurance products are listed (i.e., HO-3, Owner occupied homes, including primary, seasonal, and secondary). Questions related to this list of products include:

a. How many policies are currently included within each of the stated products?

b. Are there major variations in the types of policies included within each of the stated products?

c. If there are many policies and / or significant policy variations within each product, is NFIP interested in consolidating or simplifying these policies under the Contract?

a. NFIP has the following forms: Dwelling Form, General Property Form for residential buildings, General Property From for non-residential buildings, and Residential Condominium Building Association Policy. b. The following products are available: Preferred Risk Policy, Newly Mapped Rating, Mortgage Portfolio Protection Policy, Scheduled Building Policy, and Group Flood Insurance Policy.

c. FEMA would like to consolidate and simplify the forms to align with industry standard forms.

On page 7 under Objective 3, the SOO states:

“The Contractor will also identify required regulatory changes and assist the government in defining these regulatory changes. The Contractor will provide advisory services if the Government chooses to pursue changing any statutes”

a. Will NFIP please clarify if the advisory services mentioned are included under the firm-fixed pricing?

b. If so, we ask that NFIP please provide additional guidance around their expectations for the advisory service, including an estimate of the level of effort advisory services will be required.

c. If currently NFIP does not know the extent of advisory services that may be required (and the impact on the total level of effort may not be negligible), we respectfully suggest that NFIP consider making these advisory services an option that would be time and materials

a. The offeror should include advisory services in the firm-fixed price offer.

b. FEMA will prepare the regulatory documents but may reach back to the offeror to answer questions or provide clarifications.

c. FEMA will not make these services an option under this contract.

Industry was unable to locate guidance in the RFQ regarding the nature of any potential Organizational Conflict of Interest (OCI) / limitation of future contracting that may arise from an award under this procurement and other concurrent procurements in support of NFIP modernization efforts. Industry requests clarification from the government on this issue.

The Government has no OCI or limitation of future contracting that may arise from an award under this procurement.

In reviewing the scope of this RFP and the scope of other NFIP/PIVOT-related procurements, does FEMA intend for this procurement to serve as the beginning of an overall underwriting transformation program?

This has the potential to significantly change the underwriting process. The actual transformation of the underwriting is not part of the scope of this effort.

Industry requests additional clarification from the government regarding the nature of the relationship/anticipated level of integration between the Risk Rating Redesign Program described in the solicitation and other related procurements in support of NFIP modernization, specifically the target solution for the NFIP/PIVOT program.

The development of the risk rating engine and all other system development work for PIVOT are not covered under this scope of work. However, there may be requirements and inputs needed to support the development of PIVOT as it relates to the rating engine.

Related to section IX of the SOO: Deliverables and Milestone Schedule on page 10, could the acronym “EOD” please be clarified? Entry On Duty Related to the following language on page 20 of the RFP: “It is not required that the Contractor provide personnel with these exact titles, rather the collection of Contractor personnel shall meet the functional requirements consistent with the SOO”. Are we correct in our assumption that the overall team should include the necessary skills and experience as opposed to specific individuals meeting the criteria (e.g., looking for a team with substantial experience developing insurance property policy forms as opposed to an individual with 10 years of property policy form development)? If this is not the case, please provide additional clarity into your expectations for key roles

Key personnel must meet all criteria listed in the Key Personnel section

On page 13 of the draft RFP under “F.2 Period of Performance” NFIP suggests a 12 month base contract period followed by the exercise of up to “three six-month options”. Could NFIP please provide some guidance on the nature of the work and level of effort in the three six-month option periods?

This work is a continuation of the scope in the SOO which allows for flexibility in adding additional period of performance for fluctuations in level of effort and unavoidable delays.

Because of the extremely compressed time allotments between the Question due date and the time for the government to publish Answers, and then for the bidders to incorporate changes to their proposals, would the government consider extending the proposal due date by 1 week? As an additional factor regarding timing, we note that some of our subcontractors and customer references are responding to urgent claims and/or evacuating due to Hurricanes Harvey and Irma.

No

Page 46, does the 30-page limitation include past performance information? No, the page limitation does not include past performance information Page 46 Does the 30-page limit include commitment letters from key personnel? No, the page limitation does not include letters of commitment Please confirm that the government does not want 3 past performance questionnaires for the major subcontractors, as stated on page 49 PPQs for subcontractors will not be evaluated.

Confirmed

Page 48, Section 1- can the contract descriptions be completed as a table? Can non-government contracts be included here as well? Yes, contract descriptions can be completed as a table. Yes, non-government contracts can be included as well but will not be given as much consideration as government contracts.

Page 49, Volume II-Price, (a), what are the Options 1001 and 2001, mentioned in addition to CLIN 0001? Options 1001 and 2001 are the two six-month optional periods of performance that the Government may choose to exercise

Is the government planning to license tsunami catastrophe models? Not at this time, but is willing to explore additional data and modeling sets as the government learns more about needed inputs to the rating methodology

Are only the 50 U.S. states in scope? If not, which additional U.S. territories are in scope? All 50 states and US territories are in scope (anywhere a NFIP policy is offered) On page 9 of the RFP, it states that “the Data Model Expert must have relevant work experience (over 5 years) with catastrophic models (with a strong preference for catastrophic flood models) manipulating and analyzing data output from AIR, RMS, CoreLogic, and/or KatRisk.” Please confirm that the Data Model Expert can have significant catastrophic model experience, including catastrophic flood models, with other relevant catastrophic modelling tools and that FEMA does not require a specific number of years’ experience with AIR, RMS, CoreLogic, and KatRisk.

Yes, that is correct. However, the government will give preference to experience with the catastrophic flood models listed.

On pages 45 and 46 of the RFP, it states that the PWS is included in Volume I, and that the page count for Volume I is 30 pages. Please confirm that the PWS does not count towards the Volume I 30-page limit, and that the PWS can be submitted as an Appendix to Volume I. Including the PWS as part of the 30-page limit would not leave much room to describe the technical approach.

The PWS is included in the 30 page limit

The RFP states that “The page limitation for Volume I is 30 pages (front and back, not inclusive of resumes).” May the following be excluded from page count?

- Table of contents

- Cover page

- Title page

- Cover letter

- PWS

- Past performance

- Letters of commitment

- DHS-700-23 (if applicable)

The following may be excluded from the page count:

- Table of contents

- Cover page

- Title page

- Past performance

- Letters of commitment

- DHS-700-23 (if applicable)

Does the government expect to see a single 'base' for with all differentiations addressed via endorsements (to respond to unique risk classification, premium/ rating, etc.)?

No, the government does not have that expectation. The way classification/base rates are defined is still under development.

Does the government intend on having flood coverage having the same 'outcome' from the same/similar event across the nation? This question is relevant due to differences in local insurance statutory provisions and case law and unique state pool structures for specific event types.

At this point of time the NFIP will continue to execute its program under federal regulations and not state regulations.

SOO Objective 2 on page 6, FEMA states that "To complete this Objective, the Contractor shall need to assist FEMA in running the NFIP policyholder data through third party catastrophic flood models. The Contractor shall be expected to analyze and incorporate results from no more than three catastrophic flood models. In addition, the Contractor may be required to analyze and incorporate the NFIP mapping data and historic claims data at the national level. Please see section XI.

Assumptions and Constraints for more information on the catastrophic models." Can FEMA please make these models available now so that we can more properly assess the models and develop our approach to how we will develop processes to run the data through the models?

No. The commercial models that may be used are AIR Touchstone, RMS RiskLink, CoreLogic, and/or KatRisk. They require licensing agreements that make them unable to be shared.

To complete Objective 2, the Contractor is required to assist FEMA in running the NFIP policyholder data through third party catastrophic flood models. The Contractor shall be expected to analyze and incorporate results from no more than three catastrophic flood models. In addition, the Contractor may be required to analyze and incorporate the NFIP mapping data and historic claims data at the national level. Please see section XI. Assumptions and Constraints for more information on the catastrophic models. Can the government provide information on the new risk rating methodology to help offerors understand the effort and complexity of the changes with the new risk rating?

No. The Government does not have information on the new risk rating methodology to share at this time as it is currently being developed.

On page 5 under V: Program Description, the SOO states:

“NFIP is still developing the strategy for the delivery of the policy forms and rates being developed as part of this Contract. This strategy will be mostly developed prior to Contract Award. This may require the Contractor to develop the policy forms and rates using an agile method, where certain policyholder groups would be prioritized and rolled-out in a phased approach”

- Will NFIP please elaborate on what is being developed and clarify potential implications to this Contract (e.g., are we correct in our understanding that this contract does not involve any IT development, even though the “agile method” is usually associated with IT efforts).

The government may choose to focus on developing policy forms and rates for certain policy types (e.g. Homeowners, PRPs, SRLs) or certain geographical areas (e.g. areas with more data) first.

This may allow for a staged roll-out of products to targeted customers. However, this strategy has not yet been defined and may not be the ultimate strategy used. The government is asking Contractors to be agile in their approach and ability to prioritize based on government needs. The IT system development is not part of this scope.

On page 5 under V: Program Description, the SOO states that NFIP will have developed a new Risk Rating and Classification Approach prior to this Contract.

a. When is the new approach (including testing of the approach in two geographical areas) expected to be complete?

b. When is the anticipated start date for performance on this Contract?

c. What impact, if any, might this timing have on the Contractor’s work on the NFIP Risk Rating and Policy Forms effort?

a. The new approach is expected to be complete in January 2018.

b. The start date for performance on the Risk Rating and Classification Support Services Contract has passed. The start date for performance for this NFIP Rating and Policy Forms contract is 1 October 2017. It is understood that there will be dependencies between the two contracts.

c. The Government will maintain oversight of both contracts to ensure that timing of one contract does not impede performance on the other and make contract adjustments as necessary

Page 45 of the RFP states “Volume I shall address the Technical Approach inclusive of the proposed PWS, Key Personnel, Past Performance, Subcontracting Plan and Price, and Solicitation, Offer and Award Documents and Certifications/Representations.” What information related to subcontracting pricing are you seeking given that pricing information should not be included in the technical volume?

Documentation that subcontractor pricing has been determined fair and reasonable

Currently the NAICs code for the Prime for this solicitation is 524298 and the SBA limit is $15 million. Does the NAICs code small business size dollar and employee size limitation apply to the small business in the subcontracting plan requirement? If so, could the NAICs code be changed to 525990 Other Financial Vehicles with a limit of $32.5? This NAICs code covers insurance policy and business matters such as flood insurance and also covers the aspect of risk modeling and predictive modeling required in this solicitation. Several highly qualified small businesses will be excluded from subcontracting if the current NAICs code and limit holds for subcontractors

For this requirement this NAICS code 524298 is the most applicable and cannot be changed based on the needs of the Program Office. For a subcontract, the prime contractor—not the government—decides what NAICS code (and corresponding size standard) applies.

Attachment 4 DHS Form 700-23 requires the small business subcontractor goals to be shown as a percentage of total subcontracting dollars, which would be calculated as the ratio of small business subcontract dollars to total small and large business subcontract dollars. However, page 18 Subcontracting plan expresses the small business goal of 39% as a percentage of total contract value, which would include dollars to the prime company as well. Which is the correct way to measure the small business goal of 39% under the RFP?

Please use DHS 700-23 form when calculating the percentage of work allocated to your small business contractor.

Because the additional time between proposal due date and contract start date may allow us to add additional value to the government by adding more subcontractors to our plan, may the contractor submit a plan without identifying all the subcontractors? For example, as in the DHS Subcontracting Plan Review Checklist E.2, we could list the sources of where we will search for subcontractors and perhaps identify some contenders. Would that be sufficient, or must the proposal identify all the exact subcontractors we plan to use on the project?

The proposal must identify all the exact subcontractors that will be used on this requirement.

Page 48, factor 3, how is "major subcontractor" defined in terms of providing past performance examples? Is it "subcontractors who will be providing critical hardware/services or whose subcontract is at least 50% of the total proposed price" as stated on page 49?

It will be all subcontractors who will be providing critical hardware/services or whose subcontract is at least 50% of the total proposed price

Page 2, the Price/Cost schedule shall be developed based on the attached Statement of Objectives. Is this referring to the draft SOO dated June 22, 2017, Section C of the RFP dated September 5, 2017, or some other document?

No, the SOO dated September 11, 2017 should be used.

Page 2, the Price/Cost schedule shall be submitted in Excel form. Is there a particular format or template that is required? If so, please provide it. No, there is no template.

Please confirm that a complete GSA solution is not required, and offerors are not required to show schedule labor categories quoted, number of hours quoted for each labor category, and quoted labor rates.

A GSA solution is not required. Offerors are required to show labor categories quoted, number of hours quoted for each labor category, and labor rates in order to help the Government determine the appropriateness of the labor and scope as well as determine price fair and reasonable.

On page 47 of the RFP, it states that a minimum of two Past Performances are required. However, on page 49 of the RFP, it states that a minimum of three Past Performance Questionnaires are required. Please confirm that only two Past Performances and two Past Performance Questionnaires are required.

A minimum of 2 past performances and 2 past performance questionnaires are required. A maximum of 4 past performances and 4 past performance questionnaires are allowed.

The RFP states: “Volume I - shall address Technical Approach inclusive of the proposed PWS, Key Personnel, Past Performance, Subcontracting Plan and Price, and Solicitation, Offer and Award Documents and Certifications/Representations.” Please confirm it is the Government’s intent to include price information in the Price Volume only?

Confirmed

The RFP requires the offeror submit a small business subcontracting plan in accordance with the requirements identified in the Department of Homeland Security Subcontracting Plan Review Checklist (DHS Form 700-23 see Attachment 4). Please clarify whether offerors are required to develop their own subcontracting plan for submission as a part of their proposal response or complete and submit DHS Form 700-23 or both. Additionally, as the Small Business Subcontracting plan includes price information, please confirm it should be included in the Price Volume and the Small Business Participation Plan should be included in the Technical Volume

The offeror is required to develop their own subcontracting plan for submission as part of their proposal repsonse and submit DHS form 700-23. The Small Business Subcontracting plan pricing information should be included in the Price Volume and the Small Business Participation Plan should be included in the Technical Volume.

The requirements for the Title Page and the Cover page are identical. What is the difference between a Cover Page and a Title Page? Please use either a Title Page or a Cover Page. They are the same.

The RFQ requires offerors submit two separate volumes using standard, 12-point minimum font size in Arial or Times New Roman. Would the Government consider reducing the font size to 10-point?

No

Given the model validation tasks requirement, under the National Flood Insurance Program (NFIP) Risk Rating and Classification Support Services, Solicitation # HSFE20-17-Q-0016, there appears to be a organization conflict of interest (OCI) related to impaired objectivity and unequal access to information. As such, please confirm that Prime Contractor, Milliman, has an OCI issue that cannot be mitigated, and is precluded from bidding on this new requirement.

The Prime Contractor for the National Flood Insurance Program (NFIP) Risk Rating and Classification Support Services does have a conflict of interest and is unable to compete on this procurement.

Questions and Answers