Interim Servicing Solution Pre-Solicitation Conference Questions and Answers.pdf
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- Pre-Solicitation Conference Questions and Answers for the Interim Servicing Solution Federal contract opportunity
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- Department of Education
About this file
This document provides the questions and answers from a pre-solicitation conference for the Interim Servicing Solution. The Interim Servicing Solution is an interim contract vehicle to continue federal student loan servicing for the Department of Education as it transitions to its Next Gen environment. The conference addressed questions on requirements, evaluation criteria, pricing templates, and timelines. Offerors can expect the solicitation to be released in October 2020, with proposals due in November and awards made in spring 2021. Pricing templates include sections for system, labor, and fulfillment costs based on servicing 50% of the federal student loan portfolio. The Department of Education will establish performance standards and allocate volume based on those standards. Small business subcontracting requirements will be detailed in the solicitation.
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ID Consolidated Questions Answers
1 Will Disability and 508 Compliance formats be in the ISS scope?
This work is in the scope of this contract; however, initially, this work will be performed leveraging a different vendor. A change order or a task order will be issued to the ISS awardee(s) if FSA determines to migrate this work from another vendor to the ISS awardee(s).
2 Can vendors use the other disability/508 compliance vendors that FSA is already using?
ISS vendors may engage directly with the other disability/508 compliance vendors that FSA is already using.
A) Is it anticipated that BPOs have their own, assigned portfolio?
B) If so, will they have the flexibility to make operational and technology changes to improve customer experience and efficiency?
C) Will the ISS be held accountable for BPO performance related to loans serviced on the ISS’s platform?
A) Once implemented, BPO vendors will manage a unique portfolio of post-disbursement borrower accounts.
B) BPO vendors will not be able to directly make operational or technology changes to the established Next Gen environment. BPO vendors will collaborate with FSA and other designated vendors to share ideas related to potential enhancements/changes needed to improve the experience of customers and/or the efficiency of the enterprise solution consistently across the Next Gen framework.
C) ISS vendors will be responsible for ensuring the continued operations of the solutions leveraged to perform loan servicing by BPO vendors.
4 Is there an opportunity where the current BPOs can do one or more of the optional tasks?
BPOs will be expected to perform all tasks identified under the BPO contract. The ISS awardee(s) are welcome to engage the BPO awardee(s) as teaming partners/subcontractors in performing the tasks identified in the ISS awards.
5 Is it possible to release the pricing information for BPO contracts and will the BPO pricing structure change?
The BPO contracts are currently under protest to the GAO. The BPO contract will not be released during the pendency of the protests.
6 BPO contract terms are three years and the ISS contracts are five years plus five one-year options. Is this an issue for FSA? No, this is not an issue for FSA.
7 Will the ISS vendor be responsible for the cost of providing BPO connectivity into the ISS vendor(s) data centers?
FSA will provide for the connectivity ("lines") between BPOs and ISS vendors if direct connectivity is needed. As covered in the BPO solution, BPOs will continue to be responsible for the connectivity between BPOs and their additional locations.
8 Will BPOs work on one or both ISS Platforms (if two are selected)?
ISS providers need to be prepared to support BPOs working across both platforms. FSA will collaborate with vendors to determine the best configuration post-award.
9 What is the anticipated timeline for moving towards the BPOs? Currently, we cannot provide an exact timeline due to ongoing protests. Once the protests are resolved FSA will issue a task order for BPOs to become performance-ready.
Interim Servicing Solution Pre-Solicitation Conference Questions and Answers Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
Interim Servicing Solution Pre-Solicitation Conference Questions and Answers Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
10 Is FSA planning to keep tasks that are in the BPO contract in the ISS solicitation?
Tasks/activities currently in the ISS contract that are in scope for BPO will transition to BPO once BPOs have been onboard and begin performing servicing-related activities.
11 Are there any other transitions from going to State 1 to State 2 other than plugging in the BPOs? Transitions for ISS will be determined post-award.
12 Should vendors anticipate a similar BPO linkage requirement that was in the EPS solicitation?
ISS vendors shall be prepared to externalize their system such that BPOs can leverage to perform servicing related contact center and back-office processing work.
13 As FSA moves to Transition State 2, is there a vision to change the servicing tasks?
Any changes to the servicing tasks would be made post-award through the Change Management process.
14 Is FSA expecting a formal third party to do a CMMI review?
FSA has modified its position on this requirement and will not require CMMI Level 3 certification at the time of award. Please see the solicitation for the new requirement to be implemented within 12 months of award.
Does the Department see a concern that there is a potential conflict of interest if the ISS vendor is a current BPO awardee, and thus would be performing work under both contracts?
At this time, the Government does not detect any organizational conflicts that cannot be mitigated. Per the solicitation, any proposal response that may have a potential conflict of interest must include a mitigation plan.
16 Is there an inherent conflict with separation of the platform and servicing?
There was not an inherent conflict in separating out the system components from the personnel resources performing contact center and back office processing components. As an organization, the vision is to migrate towards enterprise solutions that can be leveraged across the organization and realize economies of scale and other efficiencies. An ISS awardee(s) may also be a BPO awardee, and if that offeror believes there is or may be a conflict of interest, then, in accordance with the solicitation provisions, they shall submit that notation and mitigation plan with their ISS proposal.
In the slides for the Pre-Solicitation conference, FSA used the term “recompete” of the existing TIVAS and NFP work, and later in commentary, FSA referred to a “free and open competition.” Can FSA provide clarity?
The ISS Solicitation will be a full and open competition. FSA has contracts expiring and cannot have a disruption to Servicing. This is a “recompete” for those services currently provided by the TIVAS and NFPs. FSA emphasizes “solution” because ISS is more than a system; it also involves people and fulfillment. Ultimately, FSA needs a solution to continue servicing borrowers with minimal disruption.
Is there an anticipated timeline for integrating ISS and BPOs with DCC? What dependencies should the ISS bidders assume with regard to the Digital Customer Care (DCC) Solution?
The BPO awards are under protest at the GAO, so no timeline is available at this time. There are no immediate dependencies on DCC that ISS bidders should assume. Necessary integrations will be made post-award as part of a Change Management process.
Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
19 What disaster recovery standards does FSA foresee for systems and operations? Please review the ISS Solicitation, once released, for the Disaster Recovery requirements.
A) What is the relationship between this and the EPS solution?
B) Is all that work in the ISS?
A) There is no relationship between the EPS solicitation and the ISS solicitation. The ISS solicitation is basically a recompete of the current Servicing work being done by the current Servicing contractors.
B) If this question is asking if all the requirements of the EPS solicitation are in the ISS solicitation, then the answer is no.
21 Can FSA provide any insight on what proposal evaluation criteria are being considered? Evaluation criteria will be shared with all via the solicitation.
23 Is FSA anticipating that the ISS vendors convert to an FSA brand?
This is a not a day one requirement. Any changes required by FSA will be handled through the Change Management process.
24 How will value added concepts be handled?
FSA welcomes all value added concepts either with the offerors proposals or post-award. The solicitation will identify the relevant evaluation factors for proposal submissions, and any post-award value added concepts will be handled through the contract administration process.
Will there be a requirement for the historical paper supporting documentation to move from its current provider / location to the ISS provider(s)? Will the ISS provider be responsible for the cost of moving and warehousing this paper?
Yes, there are requirements for moving and storing historical paper documentation. The execution of this work will be determined post-award through the Change Management process so no costs should be included in the offeror's proposal related to this work.
26 Can FSA identify which specific FAR clauses related to IP Ownership are going to be applicable?
Please review the ISS Solicitation once released to see what, if any, clauses related to IP Rights are required.
Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
In the IRPE, there was a data segregation comment about FSA does not expect that segregation to be in place at go-live. Can FSA clarify this? Is a blended experience allowed in having ED and private loans on the website (not data comingling)?
The ISS Solution must meet all applicable federal security requirements, including those relating to data segregation. To the extent a contracted solution does not meet any of these requirements, the authorizing official will make a risk-based determination as part of the ATO process. Depending on the specific circumstances, technologies, and compensating controls, the authorizing official may allow a plan of actions and milestones (POAM) to be put in place to take future corrective actions.
Private loans are not allowed on an ISS contractor web site deployed in support of ISS. During the Initial State, offerors may propose solutions consistent with their current capabilities as long as the loan types are part of the Title IV programs. Please note that the Government defines commercial, or private loans, as those loans in which the Government has no interest. This definition means Title IV loans are considered part of the Government loan process.
As part of the ATO process, and with the implementation of the requirements for MTIPS and TIC, a technical/security design review of the proposed system design of a "blended experience" will need to be completed before FSA can provide an answer regarding the user experience. However all federal requirements must be satisfied which includes, but is not limited to, all loan types must be Title IV loans, all loan data must be presented on an ed.gov web site, and all data must pass through the government security process within the TIC and MTIPS requirements.
In the IRPE document, Section 5.3 – Performance Testing: on what volume should the offeror base its performance testing response? Should it be based on 50% of the current portfolio size with the assumption of 2 ISS vendor awards? When is the initial performance test required to be submitted: at initial proposal submission;, X days from award; other?
Performance testing should be performed on 100% of the one-half of the total portfolio volume.
The initial tests are required as part of the offeror's proposal.
Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
Please clarify when and what should be provided in each of the IRPE table columns by section. There are some sections in the IRPE where the table columns are not clear or seem to be inapplicable. I.e. Section 2.1 asks for a list of additional software. What should be included in the columns titled “If no, time required to meet this requirement” and “Artifacts”?
FSA will provide detailed instructions to complete the IRPE as part of the solicitation. The artifacts column are for additional documents that can be used to answer the request.
30 The ISS Cybersecurity and IRPE standards, will these look the same for BPOs?
The solutions being solicited for under ISS and BPO are different, so offerors should anticipate different Cybersecurity and IRPE standards.
31 Provided there are two ISS awardee(s), will the initial allocation of accounts be 50/50? Initial allocation is expected to be as close to 50/50 as reasonably possible.
32 What are the ISS requirements for call center and back-office processing?
This procurement is a recompete of the current work being done for Servicing. The requirements for Call Center and Back-office processing are the same as they are now and detailed requirements will be in the solicitation.
33 What is the total solution expectation for the ISS Call Management System?
On Day 1, ISS Servicers will use their existing technical backbone. Any changes to that solution will be made through the Change Management process.
A) Will ISS utilize processes and technology (i.e. existing letters, account servicing strategies) or will FSA provide approved processes and technology (i.e. correspondence, system triggers, strategies).
B) Will ISS be enabled to develop additional processes or technology?
C) Will one ISS servicer be required to share best-practices with the other ISS servicer?
A) The requirements for Servicing are not changing and will be part of the solicitation package.
The requirements explain what must be done and the offerors will propose how they will meet these requirements
B) See Question 24 response.
C) Best practices shall be shared with FSA and FSA will decide if a best practice needs to become a requirement change.
35 What hours of operation does FSA anticipate? Are there any geographic or time-zone requirements? The hours of operation will be stated in the ISS Solicitation.
Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
36 How long will Transition State 1 last?
For FSA, it is important to make sure the customer experience is cared for and data integrity is sound while also caring for the timelines and milestones of legacy contracts. FSA will be requesting offerors’ thoughts and plans on loan migration and mitigating factors. Timelines for transitions states will be defined after award.
37 Are there any other key milestones for ISS besides solicitation release, award, and legacy contract expirations?
FSA has not established specific solution milestones; any additional details will be provided in the solicitation.
Is the vendor responsible for securing the appropriate staffing whether internal or subcontracting to manage the volumes that come with award?
Yes. The vendors are responsible for all staff that are needed to fulfill the requirements for servicing.
39 Will ISS providers service using their own scripts and processes?
Yes. This is a recompete for existing servicing. Any changes will be done through a Change Request (CR) process.
What are the timeframes for the ISS Solicitation and will FSA propose a common award date in the solicitation that offerors should use?
It is anticipated that the ISS Solicitation will be released in October with an award date in Spring 2021. Please refer to the ISS Solicitation once released for important dates and milestones.
41 Does FSA view ISS as a temporary service?
ISS is an interim solution to continue servicing for our borrowers. The word "solution" is used because there are 3 main components: system, staffing, and fulfillment. ISS will evolve over time and allow FSA to move forward with the Next Gen vision.
42 What are the Loan Migration requirements and timeline?
FSA is drafting a migration plan but will ask for vendor input on process and duration.
Customer experience and data integrity will be a priority when determining sequencing. More details around the loans and customers will be included in the solicitation.
43 Would FSA like to receive data from small business servicers for future solicitations?
Small business servicers are welcome to respond to all solicitations, including this full and open competition.
44 Which NAICS code will the solicitation be under? It is anticipated that the NAICS Code will be 522390 Other Activities Related to Credit Intermediation.
45 How does ISS relate to OPS and the overall Next Gen Strategy?
ISS is an interim solution to continue servicing for our borrowers. ISS will evolve over time and allow FSA to move forward with the Next Gen vision. Also see Question 46 response.
46 Will OPS be awarded from the two ISS vendors? The Government anticipates OPS to be a full and open competition.
47 Is Perkins in scope? Perkins is not in scope.
Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
48 Will the ISS vendors both be required to do the optional work such as specialty services?
All ISS vendors are expected to perform all optional tasks / specialty work or have an implementation plan to be able to perform all optional work within the base period of performance. FSA will issue task orders to perform the work based upon its needs. See the ISS solicitation for full details.
The Digital engagement section in the SOW refers to the portal providing access to TPD, TEACH, PSLF, FSA Image Repository, Decommissioned Servicer Data and Legacy Consolidation Support information. If there are two ISS vendors selected, will both vendors be required to demonstrate this capability for all of these programs on their partner portal, even if they do not service or provide that core ISS system functionality?
ISS offerors need to be able to demonstrate this capability as part of the proposal process. The proposal should speak to each of the solicitation's requirements and make the assumption that a partner portal will be required to support the capabilities listed (e.g. providing access to TPD, TEACH, PSLF, et cetera).
50 Will there be a timing requirement for Past Performance? The timeframe will be published in the ISS Solicitation.
51 When would PCAs fall off the state, during the transitional or final state? FSA cannot answer this at this time.
52 Are the Performance SLAs intended to be unilateral or negotiated?
The intent is unilateral. FSA wants vendors to be able to comply with performance metrics. If there are clarifying questions there will be an opportunity to submit a question once the solicitation is posted.
53 The Performance Measures template mentions KPIs but none are listed. Does FSA have standard KPIs in mind?
Currently, there are no defined KPIs. FSA mentioned KPIs as they could be introduced in the future, but those KPIs would not carry any of the financial penalties or disincentives, but rather would be used for incremental evaluation of areas.
54 Would the future KPIs count towards performance factors that would lead to allocation?
They could but there have not been any discussions on this so far. Allocations would be based on SLAs.
55 Is FSA set on the SLAs and weighting? Yes, FSA has spent a lot of time looking at the SLAs and rationalizing those.
56 Has FSA considered an earn back on SLAs? FSA will not consider an earn back.
57 When is performance testing required and is it part of the solicitation response? The initial tests are required as part of the offeror's proposal.
Should pricing be for up to 50% of the portfolio or 100% of the portfolio? If both, can the template be updated for tiered pricing for Section B?
The pricing is on 50% of the portfolio. Sections A, B, and C were set up to see cost differences between system, labor, and fulfillment costs.
Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
On Line 40-41 in the Pricing Template, there is a line item that covers licensing fees that allow BPO providers to access back-office processing tools and tools needed for calls. How should offerors address this in order to not double charge?
FSA is looking for the costs to be separated. FSA understands that from the time of ISS award, the successful offerors would provide all the services as-is today (e.g., connectivity for the ISS awardee'(s) agents). Once BPOs are stood up and ready to be plugged in, this contract would provide the system (where the accounts would reside), the fulfillment activities, and the access for BPOs to use the tools that agents use today. The top three sections on the Pricing Template (A, B, C) are the common pricing components at the time of award. When the BPOs are plugged in, it is expected that the people doing the back-office processing and calls will ramp down. FSA added those lines for BPO to make sure those weren't in Section B of Technology Pricing. Specialty costing is separate.
60 Has FSA considered adding a BPO Implementation line in the Pricing Template?
No. ISS vendors will be expected to have the capability to externalize their system such that an external contact center/ vendor could leverage the solution to perform servicing-related contact center and back-office work.
61 How should vendors price the DCC integration? This will be done through the Change Management process, so no pricing is required.
62 The pricing template states use for inbound calls. What about outbound calls? The document will be updated to state both inbound and outbound calls.
If offerors come in with additional pricing in their responses, how will FSA make sure there is a level playing field for evaluation?
The evaluation factors and methodology will be identified in the solicitation.
64 How will specialty pricing by evaluated and compared between offerors? The evaluation factors and methodology will be identified in the solicitation.
FSA indicates that TPD borrowers “will NOT be separated from the main costing per borrower, therefore ongoing costs for TPD should be part of the cost per borrower by borrower status”.
Where does the application cost fall into the pricing model?
Which status should be used for TPD per borrower cost?
Processing TPD applications is the same as other discharges so no separate pricing is required. Once a TPD application is approved the borrower's loans are discharged and a waiting period begins. The vendors will receive the "cost per borrower" that is listed in the system section of the template.
66 Does FSA anticipate having a Q&A after the posting of the solicitation? Yes.
67 Will FSA consolidate and share the Q&A with meeting participants? Yes. This information will be posted via www.beta.sam.gov.
Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
68 Is FSA planning to share any other draft versions of the ISS solicitation? Not at this time. The final documents will be released as part of the ISS Solicitation.
Please clarify what should be provided in the Artifacts column and under what circumstances? For example, is it only provided when the requirement is met and is it proof that the requirement is met?
FSA is working on the final requirements and may remove this column. The final ISS Solicitation will have the final requirements and detailed instructions.
70 Will the IRPE be part of the solicitation Yes, the IRPE will be part of the ISS Solicitation.
71 What is the expected solicitation response time for bidders (from RFP posting to initial proposal submission)?
Once the ISS Solicitation is released the due dates will be established in the solicitation. It is anticipated that the ISS Solicitation will be released in October and proposals will be due in November.
The ISS Pre-Conference only discussed the IRPE, Requirements Gap Spreadsheet and the Pricing template. Will the RFP require other proposal volumes/elements? If so, what are they?
Yes, please review the ISS Solicitation once its released.
73 Is FSA envisioning a reuse of the existing ATOs? FSA cannot address the specifics because there are too many variables with existing systems versus new or updated systems that may be proposed as part of the ISS solution.
74 Would it be possible for a TIVAS ATO to be transferred to another vendor? No.
Statement on Small Business Goals: Consider counting second tier subs (i.e., subs of subs) towards Small Business Goals due to the technical nature of work
Please review the ISS Solicitation once released for all Small Business related information.
Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
We understand that small business utilization goals will be provided in the solicitation. In the BPO procurement, to achieve prescribed small business utilization goals, an offeror expected to outsource 60-70% of operational staff to small businesses.
Does FSA anticipate providing differentiated goals based on revenue type (operational vs technology)? Should we expect to have small business goals driven by total revenue (like BPO) or as a percent of overall outsourced spend (like EPS)?
Wil the Small Business utilization goals be based off a % of total contract value or % of subcontracted work
Please review the ISS Solicitation once released for all Small Business related information.
77 Will FSA be setting aside portions of ISS for Small Businesses or HUBZone and Disabled Vet contractors? Please review the ISS Solicitation once released for all Small Business related information.
Which Fiscal Year's small business goals will FSA be using, FY20 or FY21 and will they be similar to BPO's small business goals?
Please review the ISS Solicitation once released for all Small Business related information.
None of the not-for-profit servicers have systems, so it will be critical to have them on team(s). Because they are not considered small businesses, adding them to a team will impact the ability to achieve aggressive small business targets. Will FSA consider this when setting the small business outsourcing targets?
Please review the ISS Solicitation once released for all Small Business related information. Not-for-profits entities may create a for-profit entity to be eligible for Small Business targets.
81 Can FSA provide clarity around small business requirements? Please review the ISS Solicitation once released for all Small Business related information.
Two of the current servicers have loans with two of the possible ISS candidates. Would there be an opportunity for either to remain a federal servicer if their current system provider is also selected as an ISS vendor?
The Title IV Additional Servicers and Not-For-Profit contracts expire and no additional optional ordering periods are available under those contracts. The Government encourages all ISS offerors to engage with all experienced and knowledgeable entities in preparing its proposal response.
Federal Student Aid would like to note that to the extent there are any conflicts between the Q&As and information provided during the Interim Servicing Solution Pre-Solicitation Conference, the written responses will supersede.
83 Is there any concern with teaming with BPO vendor(s)?
No. FSA's goal is to achieve the Next Gen vision. Offerors can team with anyone they wish to deliver on the requirements. If an offeror believes there is, or may be, a conflict of interest then, in accordance with the solicitation, they shall submit that notation and mitigation plan with their ISS proposal.
84 Is FSA expecting to allow or disallow exclusive teaming agreements? FSA is not allowing exclusive teaming or subcontracting agreements.
Q&A Consolidated
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