PBGC01-RP-15-0005.pdf

RFQ IFB RFP

WOMEN-OWNED SMALL BUSINESS

(WOSB) ELIGIBLE UNDER THE WOMEN-OWNED

SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL ITEMS

OFFEROR TO COMPLETE BLOCKS 12, 17, 23, 24, & 30

1. REQUISITION NUMBER PAGE OF

2. CONTRACT NO. 3. AWARD/EFFECTIVE

DATE

4. ORDER NUMBER 5. SOLICITATION NUMBER 6. SOLICITATION ISSUE

DATE

7. FOR SOLICITATION

INFORMATION CALL:

a. NAME b. TELEPHONE NUMBER (No collect calls)

8. OFFER DUE DATE/

LOCAL TIME

9. ISSUED BY

13b. RATING

14. METHOD OF SOLICITATION

CODE

15. DELIVER TO 16. ADMINISTERED BY CODE

18a. PAYMENT WILL BE MADE BY CODEFACILITY

CODE

CODE

TELEPHONE NO.

17b. CHECK IF REMITTANCE IS DIFFERENT AND PUT SUCH ADDRESS IN

OFFER

18b. SUBMIT INVOICES TO ADDRESS SHOWN IN BLOCK 18a UNLESS BLOCK

BELOW IS CHECKED

SEE ADDENDUM

19.

ITEM NO.

20.

SCHEDULE OF SUPPLIES/SERVICES

21.

QUANTITY

22.

UNIT

23.

UNIT PRICE

24.

AMOUNT

(Use Reverse and/or Attach Additional Sheets as Necessary)

25. ACCOUNTING AND APPROPRIATION DATA 26. TOTAL AWARD AMOUNT (For Govt. Use Only)

28. CONTRACTOR IS REQUIRED TO SIGN THIS DOCUMENT AND RETURN

DELIVER ALL ITEMS SET FORTH OR OTHERWISE IDENTIFIED ABOVE AND ON ANY

ADDITIONAL SHEETS SUBJECT TO THE TERMS AND CONDITIONS SPECIFIED

29. AWARD OF CONTRACT: REF.

DATE . YOUR OFFER ON SOLICITATION

(BLOCK 5), INCLUDING ANY ADDITIONS OR CHANGES WHICH ARE

SET FORTH HEREIN, IS ACCEPTED AS TO ITEMS:

30a. SIGNATURE OF OFFEROR/CONTRACTOR

30b. NAME AND TITLE OF SIGNER (Type or print) 30c. DATE SIGNED

31a. UNITED STATES OF AMERICA (SIGNATURE OF CONTRACTING OFFICER)

31b. NAME OF CONTRACTING OFFICER (Type or print) 31c. DATE SIGNED

AUTHORIZED FOR LOCAL REPRODUCTION

PREVIOUS EDITION IS NOT USABLE

STANDARD FORM 1449 (REV. 2/2012)

Prescribed by GSA - FAR (48 CFR) 53.212

COPIES TO ISSUING OFFICE. CONTRACTOR AGREES TO FURNISH AND

OFFER

13a. THIS CONTRACT IS A

RATED ORDER UNDER

DPAS (15 CFR 700)

11. DELIVERY FOR FOB DESTINA-

TION UNLESS BLOCK IS

MARKED

SEE SCHEDULE

12. DISCOUNT TERMS

ARE ARE NOT ATTACHED

ARE ARE NOT ATTACHED

27a. SOLICITATION INCORPORATES BY REFERENCE FAR 52.212-1, 52.212-4. FAR 52.212-3 AND 52.212-5 ARE ATTACHED. ADDENDA

27b. CONTRACT/PURCHASE ORDER INCORPORATES BY REFERENCE FAR 52.212-4. FAR 52.212-5 IS ATTACHED. ADDENDA

17a CONTRACTOR/

OFFEROR.

CODE

8 (A)

SIZE STANDARD:

NAICS:

% FOR:SET ASIDE:UNRESTRICTED OR

SERVICE-DISABLED

VETERAN-OWNED

SMALL BUSINESS

HUBZONE SMALL

BUSINESS

SMALL BUSINESS

10. THIS ACQUISITION IS

EDWOSB

SMALL BUSINESS PROGRAM

STANDARD FORM 1449 (REV. 2/2012) BACK

19.

ITEM NO.

20.

SCHEDULE OF SUPPLIES/SERVICES

21.

QUANTITY

22.

UNIT

23.

UNIT PRICE

24.

AMOUNT

32a. QUANTITY IN COLUMN 21 HAS BEEN

RECEIVED INSPECTED ACCEPTED, AND CONFORMS TO THE CONTRACT, EXCEPT AS NOTED:

41a. I CERTIFY THIS ACCOUNT IS CORRECT AND PROPER FOR PAYMENT

32b. SIGNATURE OF AUTHORIZED GOVERNMENT

REPRESENTATIVE

32c. DATE

41b. SIGNATURE AND TITLE OF CERTIFYING OFFICER 41c. DATE

42a. RECEIVED BY (Print)

42b. RECEIVED AT (Location)

42c. DATE REC'D (YY/MM/DD) 42d. TOTAL CONTAINERS

40. PAID BY

32d. PRINTED NAME AND TITLE OF AUTHORIZED GOVERNMENT

REPRESENTATIVE

32e. MAILING ADDRESS OF AUTHORIZED GOVERNMENT REPRESENTATIVE 32f. TELPHONE NUMBER OF AUTHORZED GOVERNMENT REPRESENTATIVE

32g. E-MAIL OF AUTHORIZED GOVERNMENT REPRESENTATIVE

33. SHIP NUMBER 34. VOUCHER NUMBER 35. AMOUNT VERIFIED

CORRECT FOR

PARTIAL FINAL

37. CHECK NUMBER

38. S/R ACCOUNT NO. 39. S/R VOUCHER NUMBER

36. PAYMENT

COMPLETE PARTIAL FINAL

SCHEDULE Continued

ITEM NO. SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE AMOUNT

PAGE 3 OF 104 PBGC01-RP-15-0005

Post Valuation Administration Support Services 0001 Post Valuation Administration (PVA) support at the

Richmond Heights, OH location. The expected period of performance will be January 21, 2015 - January 20, 2016.

1.00 LO

Table of Contents

PAGE 4 OF 104 PBGC01-RP-15-0005

SECTION B SUPPLIES OR SERVICES AND PRICES/COSTS

B. 1 Description of Services

B. 2 Pricing Schedule

B. 3 PBGC-44-001 OTHER DIRECT COSTS (MAY 2012)

B. 4 Contract Type

B. 5 PBGC-16 003 CEILING PRICE (FEB 2013)

SECTION C DESCRIPTION/SPECIFICATIONS/WORK STATEMENT

C. 1 Statement of Work

SECTION D PACKAGING AND MARKING

D. 1 PBGC-11 004 PACKAGING AND MARKING (JAN 2012)

SECTION E INSPECTION AND ACCEPTANCE

E. 1 PBGC-46-001 INSPECTION AND ACCEPTANCE OF DELIVERABLES (JAN 2012)

SECTION F DELIVERIES OR PERFORMANCE

F. 1 52.242-15 STOP-WORK ORDER (AUG 1989)

F. 2 PBGC-45 001 GOVERNMENT FURNISHED INFORMATION, ASSISTANCE AND/OR EQUIPMENT (JAN 2012)

F. 3 Government Furnished Property

SECTION G CONTRACT ADMINISTRATION DATA

G. 1 PBGC-32-001 SUBMISSION OF INVOICES (LABOR-HOUR) (JAN 2012)

G. 2 PBGC-42-001 CONTRACTING OFFICER'S REPRESENTATIVE (JAN 2012)

G. 3 PBGC-42-002 OBSERVANCE OF LEGAL HOLIDAYS (JAN 2012)

G. 4 PBGC-32-007 LIMITATION OF FUNDS (SEP 2010)

SECTION H SPECIAL CONTRACT REQUIREMENTS

H. 1 PBGC-00-001 PROFESSIONAL ATTIRE (OCT 2005)

H. 2 PBGC-03-001 CONFIDENTIALITY OF INFORMATION (OCT 2004)

H. 3 PBGC-03-002 ORGANIZATIONAL CONFLICTS OF INTEREST (OCT 2004)

H. 4 PBGC-03-003 SUITABILITY DETERMINATION REQUIREMENTS (JAN 2012)

H. 5 PBGC-04-004 PBGC INFORMATION SECURITY (FEB 2011)

H. 6 PBGC-04-005 PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION (PII) (FEB 2013)

H. 7 PBGC-04-007 MANAGEMENT AND RETENTION OF PBGC RECORDS (SEP 2014)

H. 8 PBGC-09-001 RESTRICTIONS AGAINST DISCLOSURE OF INFORMATION (JAN 2012)

H. 9 PBGC-31-004 AGENCY AWARENESS TRAINING (JAN 2012)

H. 10 PBGC-37-001 KEY PERSONNEL (MAR 2012)

H. 11 PBGC-37-002 EDUCATION AND EXPERIENCE QUALIFICATIONS (JUL 2009)

H. 12 PBGC-39-001 ELECTRONIC AND INFORMATION TECHNOLOGY (OCT 2004)

H. 13 Labor Categories

H. 14 PBGC-15 001 INCORPORATION OF CONTRACTOR'S PROPOSAL (OCT 2004)

H. 15 PBGC-22-001 OVERTIME RATES (JAN 2012)

H. 16 PBGC-31-002 LUNCH PERIOD (FEB 2011)

SECTION I CONTRACT CLAUSES

I. 1 52.212-4 I CONTRACT TERMS AND CONDITIONS--COMMERCIAL ITEMS (MAY 2014)--ALTERNATE I (MAY

2014)

I. 2 52.212-5 CONTRACT TERMS AND CONDITIONS REQUIRED TO IMPLEMENT STATUTES OR EXECUTIVE ORDERS--

COMMERCIAL ITEMS (JULY 2014)

Table of Contents

PAGE 5 OF 104 PBGC01-RP-15-0005

I. 3 52.216-31 TIME-AND-MATERIALS/LABOR-HOUR PROPOSAL REQUIREMENTS -- COMMERCIAL ITEM ACQUISITION

(FEB 2007)

I. 4 52.217-8 OPTION TO EXTEND SERVICES (NOV 1999)

I. 5 52.217-9 OPTION TO EXTEND THE TERM OF THE CONTRACT (MAR 2000)

I. 6 52.232-40 PROVIDING ACCELERATED PAYMENTS TO SMALL BUSINESS SUBCONTRACTORS (DEC 2013)

I. 7 52.244-2 SUBCONTRACTS (OCT 2010)

I. 8 52.225-25 PROHIBITION ON CONTRACTING WITH ENTITIES ENGAGING IN CERTAIN ACTIVITIES OR

TRANSACTIONS RELATING TO IRAN--REPRESENTATION AND CERTIFICATIONS (DEC 2012)

I. 9 52.243-3 CHANGES--TIME-AND-MATERIALS OR LABOR-HOURS (SEP 2000)

SECTION J LIST OF ATTACHMENTS

J. 1 Section J - Attachments

J. 2 SCA Wage Determination - Richmond Heights, OH

SECTION K REPRESENTATIONS, CERTIFICATIONS AND OTHER STATEMENTS OF OFFERORS

K. 1 52.212-3 OFFEROR REPRESENTATIONS AND CERTIFICATIONS--COMMERCIAL ITEMS (MAY 2014)

SECTION L INSTRUCTIONS, CONDITIONS, AND NOTICES TO OFFERORS

L. 1 52.212-1 INSTRUCTIONS TO OFFERORS--COMMERCIAL ITEMS (APR 2014)

L. 2 Instruction to Offerors

L. 3 52.233-2 SERVICE OF PROTEST (SEP 2006)

L. 4 PBGC-15-007 EXPENSES RELATED TO PROPOSAL SUBMISSION (OCT 2004)

L. 5 PBGC-15 011 REFERENCE AND EVALUATION (OCT 2004)

SECTION M EVALUATION FACTORS FOR AWARD

M. 1 Basis for Award

PAGE 6 OF 104 PBGC01-RP-15-0005

SECTION B

SUPPLIES OR SERVICES AND PRICES/COSTS

B. 1 Description of Services

DESCRIPTION OF SERVICES

The Contractor shall provide the necessary Post Valuation Administration services to perform the effort described in Section C, Statement of Work (SOW).

PAGE 7 OF 104 PBGC01-RP-15-0005

B. 2 Pricing Schedule

PRICING SCHEDULE

The price schedule below is inclusive of all Contractor costs (direct and indirect) for performing services outlined in the SOW.

The CLINs identified below indicate the number of hours for each labor category in the Base

Year and each of the Option years.

Base Year – Richmond Heights PVA

January 21, 2015 – January 20, 2016

CLIN

Labor Category

Maximum

Hours

Hourly

Rate

Total

Amount

Optional

(Alternate

Facility)

Hours for

Rate for for

Total Amount

(CLIN and

Optional

CLIN)

0001A Project Manager 2,080 N/A N/A N/A N/A 0001B Assistant Project

Manager

2,080 N/A N/A N/A N/A

0001C Benefits

Supervisor

10,400 0002A 4,160

0001D Team Leader 2,080 N/A N/A N/A N/A

0001E LAN- WAN

Administrator

2,080 N/A N/A N/A N/A

0001F Technical

Support

Assistant –

SCA Occupation

Code: 14042

2,080 N/A N/A N/A N/A

0001G Quality

Review

Analyst

6,240 N/A N/A N/A N/A

0001H Senior Pension

Administrator

31,200 0002B 10,400

0001I Junior Pension

Administrator

58,240 0002C 22,880

0001J Administrative

Support –

SCA Occupation

Code: 01111

24,960 0002D 4,160

Total Estimated Hours 141,440 41,600

0003 Other Direct Costs (ODCs) – Includes postage, paper, other office supplies, and travel as approved by the COR.

NTE $85,000.00

Total Value

Base Year

PAGE 8 OF 104 PBGC01-RP-15-0005

Option Year 1 – Richmond Heights PVA

January 21, 2016 – January 20, 2017 for

Optional

CLIN)

1001A Project

Manager

2,080 N/A N/A N/A N/A

1001B Assistant

Project

Manager

2,080 N/A N/A N/A N/A

1001C Benefits

Supervisor

10,400 1002A 4,160

1001D Team Leader 2,080 N/A N/A N/A N/A

1001E LAN- WAN

Administrator

2,080 N/A N/A N/A N/A

1001F Technical

Support

Assistant –

SCA Occupation

Code: 14042

2,080 N/A N/A N/A N/A

1001G Quality

Review

Analyst

6,240 N/A N/A N/A N/A

1001H Senior Pension

Administrator

31,200 1002B 10,400

1001I Junior Pension

Administrator

58,240 1002C 22,880

1001J Administrative

Support –

SCA Occupation

Code: 01111

24,960 1002D 4,160

Total Estimated Hours 141,440 41,600

1003 Other Direct Costs (ODCs) – Includes postage, paper, other office supplies, and travel as approved by the COR.

NTE $85,000.00

Estimated Total Value

Option Year 1

PAGE 9 OF 104 PBGC01-RP-15-0005

Option Year 2 – Richmond Heights PVA

January 21, 2017 – January 20, 2018 for

Optional

CLIN)

2001A Project

Manager

2,080 N/A N/A N/A N/A

2001B Assistant

Project

Manager

2,080 N/A N/A N/A N/A

2001C Benefits

Supervisor

10,400 2002A 4,160

2001D Team Leader 2,080 N/A N/A N/A N/A

2001E LAN- WAN

Administrator

2,080 N/A N/A N/A N/A

2001F Technical

Support

Assistant –

SCA Occupation

Code: 14042

2,080 N/A N/A N/A N/A

2001G Quality

Review

Analyst

6,240 N/A N/A N/A N/A

2001H Senior Pension

Administrator

31,200 2002B 10,400

2001I Junior Pension

Administrator

58,240 2002C 22,880

2001J Administrative

Support –

SCA Occupation

Code: 01111

24,960 2002D 4,160

Total Estimated Hours 141,440 41,600

2003 Other Direct Costs (ODCs) – Includes postage, paper, other office supplies, and travel as approved by the COR.

NTE $85,000.00

Option Year 2

PAGE 10 OF 104 PBGC01-RP-15-0005

Option Year 3 – Richmond Heights PVA

January 21, 2018 – January 20, 2019 for

Optional

CLIN)

3001A Project

Manager

2,080 N/A N/A N/A N/A

3001B Assistant

Project

Manager

2,080 N/A N/A N/A N/A

3001C Benefits

Supervisor

10,400 3002A 4,160

3001D Team Leader 2,080 N/A N/A N/A N/A

3001E LAN- WAN

Administrator

2,080 N/A N/A N/A N/A

3001F Technical

Support

Assistant –

SCA Occupation

Code: 14042

2,080 N/A N/A N/A N/A

3001G Quality

Review

Analyst

6,240 N/A N/A N/A N/A

3001H Senior Pension

Administrator

31,200 3002B 10,400

3001I Junior Pension

Administrator

58,240 3002C 22,880

3001J Administrative

Support –

SCA Occupation

Code: 01111

24,960 3002D 4,160

Total Estimated Hours 141,440 41,600

3003 Other Direct Costs (ODCs) – Includes postage, paper, other office supplies, and travel as approved by the COR.

NTE $85,000.00

Option Year 3

PAGE 11 OF 104 PBGC01-RP-15-0005

Option Year 4 – Richmond Heights PVA

January 21, 2019 – January 20, 2020 for

Optional

CLIN)

4001A Project

Manager

2,080 N/A N/A N/A N/A

4001B Assistant

Project

Manager

2,080 N/A N/A N/A N/A

4001C Benefits

Supervisor

10,400 4002A 4,160

4001D Team Leader 2,080 N/A N/A N/A N/A

4001E LAN- WAN

Administrator

2,080 N/A N/A N/A N/A

4001F Technical

Support

Assistant –

SCA Occupation

Code: 14042

2,080 N/A N/A N/A N/A

4001G Quality

Review

Analyst

6,240 N/A N/A N/A N/A

4001H Senior Pension

Administrator

31,200 4002B 10,400

4001I Junior Pension

Administrator

58,240 4002C 22,880

4001J Administrative

Support –

SCA Occupation

Code: 01111

24,960 4002D 4,160

Total Estimated Hours 141,440 41,600

4003 Other Direct Costs (ODCs) – Includes postage, paper, other office supplies, and travel as approved by the COR.

NTE $85,000.00

Option Year 4

TOTAL CEILING AMOUNT:

**Exact periods of performance will be finalized at the time of award**

B. 3 PBGC-44-001 OTHER DIRECT COSTS (MAY 2012).

The Contractor shall be reimbursed for the actual cost of other direct costs determined to be allowable in accordance with Part 31 of the Federal Acquisition Regulation and authorized by the Contracting Officer or his designee prior to the contractor incurring the charge.

PAGE 12 OF 104 PBGC01-RP-15-0005

If Travel and Per Diem are authorized they will be reimbursed in accordance with the Federal Travel Regulation (FTR) in effect at the time the travel is authorized by PBGC. All travel requirements must be met using the most economical form of transportation available and must be scheduled sufficiently in advance to take advantage of offered discount rates unless waived by the Contracting Officer. You may find the FTR at http://www.gsa.gov/ portal/content/104790.

B. 4 Contract Type

PAGE 13 OF 104 PBGC01-RP-15-0005

CONTRACT TYPE

This Government intends to award a Time-and-Materials contract. PBGC reserves the right to convert the contract type from Time-and-Materials to Firm-Fixed-Price via bilateral modification.

B. 5 PBGC-16 003 CEILING PRICE (FEB 2013).

It is anticipated that the total cost to the Government for performance of this contract shall not exceed the ceiling price set forth in Section B for the Base Year Performance Period, and any Option Periods, and the contractor agrees to use its best efforts to perform the work specified

PAGE 14 OF 104 PBGC01-RP-15-0005

in the schedule and all obligations under this contract within the ceiling price. If at any time the contractor has reason to believe that the hourly rate payments and material costs that will accrue in performing this contract in the succeeding 30 days, if added to all other payments and costs previously accrued, will exceed 85 percent of the ceiling price set forth in this clause, the contractor shall notify the Contracting Officer in writing, giving a revised estimate of the total price to the Government for performing this contract, with supporting reasons and documentation.

If, at any time during the performance of this contract, the contractor has reason to believe the total price to the Government for performing this contract will be substantially greater or less than the stated ceiling price the contractor shall notify the Contracting Officer in writing, giving a revised estimate of the total price to the Government for performing this contract, with supporting reasons and documentation. If, at any time during the performance of this contract, the Government has reason to believe the work required in performing this contract will be substantially greater or less than the stated ceiling price, the Contracting Officer will so advise the contractor, giving them the revised estimate of the total amount of effort to be required under this contract. The ceiling price for each contract period is shown in the clause title Price/Cost. The Government shall not be obligated to pay the contractor any amount in excess of the ceiling price, and the contractor will not be obligated to continue performance, if to do so would exceed the ceiling price, unless and until the Contracting Officer notifies the contractor in writing that the ceiling price has been increased and of the new ceiling price of the contract. Once the Contracting Officer increases the ceiling price, any otherwise allowable hours and material costs incurred by the contractor which were in excess of the previous ceiling price before the increase shall be allowable to the same extent as if the hours had been expended or costs incurred after the increase in the ceiling price.

PAGE 15 OF 104 PBGC01-RP-15-0005

SECTION C

DESCRIPTION/SPECIFICATIONS/WORK STATEMENT

C. 1 Statement of Work

SECTION C

DESCRIPTION/SPECIFICATIONS/ STATEMENT OF WORK

C.1 Introduction: The contractor shall provide all personnel, supervision and non-personal services necessary to perform defined pension benefit administration services for the Benefits Administration &

Payment Department (BAPD) of the Pension Benefit Guaranty Corporation (PBGC) as defined in this

Statement of Work Statement (SOW). Except as specified in Section F, the contractor shall provide the required services at PBGC’s established Post Valuation Administration (PVA) Office located at:

26301 Curtis Wright Parkway, Suite 410, Richmond Heights, Ohio 44143

C.2 Background: The Pension Benefit Guaranty Corporation (PBGC), is a Government-owned corporation, established under Title IV of the Employee Retirement Income Security Act (ERISA) of

1974. Background and mission information is available at http://www.pbgc.gov/about/about.html

The Post Valuation Administrator (PVA) serves a vital role in performing almost the vast majority of the administration to participants in PBGC's trusteed plans after benefits have been finalized and a plan closing process is completed. The work of the PVA typically begins with a final review of the plan closing process and defined pension benefit administration services will continue until all benefits are paid under the plan.

PBGC currently pays monthly benefits to approximately 813,000 retirees in over 4,600 terminated plans.

In addition, the agency owes future benefit payments to another 595,000 people who will begin to receive their benefits when they retire. The exact number of plan closings sent or the number of participants who will retire or die cannot be predicted by BAPD. Workloads are impacted by economic conditions in the public sector. A goal of this solicitation is to provide PBGC with enough flexibility within the Post Valuation Administration services to accommodate both the increased and/or decreased workloads.

This contract will support PBGC’s Strategic Goal #2– Paying timely and accurate benefits and supports the following strategic objectives and performance goals:

C.3 Objectives: The primary objective of this contract effort is to provide defined benefit pension administration services to PBGC’s trusteed plans that have moved from “estimated” processing to an ongoing administration status. The Contractor shall provide services which include but are not limited to:

1.3.1 Gathering and maintaining participant data;

1.3.2 Processing benefit payments to eligible participants and beneficiaries;

1.3.3 Processing deceased notifications, address and direct deposit changes;

Strategic Objectives Performance Goals

Promote exceptional customer service to pensioners

Ensure regular monthly benefit payments continue without interruption

Provide accurate and timely benefit calculations

Maintain exemplary customer satisfaction ratings

Continue uninterrupted benefit payments in newly trusteed plans

Approve benefit applications within 45 days

Improve the accuracy, timeliness and completeness of benefit determinations

PAGE 16 OF 104 PBGC01-RP-15-0005

1.3.4 Issuing benefit determination letters;

1.3.5 Maintaining participant documentation;

1.3.6 Handling oral and written inquiries from plan participants;

1.3.7 Performing plan closing;

1.3.8 LAN Administration Support;

1.3.9 Special projects such as; supporting systems testing, data clean-up projects, etc.

C.4 Scope: Under this contract, the contractor shall provide strictly non-personal services and shall work as an independent contractor not subject to the supervision of the government. The Contractor shall be required to work in a collaborative effort with the various divisions within BAPD as well as other contractors that support the mission of the department. The Contractor shall be required to work primarily with BAPD’s Retiree Services Division and other contracted Field Benefit Administration Offices

(FBAs) on plan closing reviews assigned. The TPDs and the FBAs all perform plan closing activities and are responsible for the plan administration prior to the transfer to Post Valuation Administration. The

RSD is responsible for assigning and monitoring the work performed by the Contractor. The RSD will provide technical guidance on specific pension plan provisions and will coordinate with BAPD’s

Actuarial Services Division (ASD) actuarial support on plans assigned to the Post Valuation Contractor.

C.5 Performance Period: The period of performance shall be for one (1) Base Year and four (4) one year options commencing on the contract award date. The Period of Performance reads as follows:

Base Year: Contract Award date +12 months

Option 1: 1 year

Option 2: 1 year

Option 3: 1 year

Option 4: 1 year

Phase In: To ensure a smooth transition in the change of work effort, the contractor shall develop a 14 calendar day Phase-In Plan. The Contractor’s Phase-In Plan will describe in detail the transition between outgoing and incoming contractor and how responsibility for services transitions with no interruption in services.

Phase Out: A transition is expected to occur during the last six (6) months of the performance period.

However, the transition period can occur at an earlier date. If the government requires a transition earlier than the end of the performance period, the contractor may have up to six months to complete the transition. The transition time will be dependent on case inventory and the processing stage of cases in the inventory. The Contractor shall fulfill the terms of the contract, resolve issues concerning government property, submit all necessary reports (e.g., technical or progress reports), receive final technical acceptance and submit all necessary financial information at the end of the transition period.

The Government contemplates that at some point during the life of the contract this requirement may transition into the Benefit Administration Support Services (BASS) requirement. The BASS requirement may consolidate current Field Benefit Administration (FBA) offices and services into a single contract whereby the contractor shall provide and maintain the facilities, space, furniture, supplies, support services, and personnel necessary to perform defined benefit pension administration services.

C.6 Quality Control: The contractor shall develop and maintain an effective quality control program to ensure services are performed in accordance with this SOW and BAPD On-Line Procedures Manual

(BAPD Manual). The contractor shall develop and implement procedures to identify, prevent, and ensure

PAGE 17 OF 104 PBGC01-RP-15-0005

non-recurrence of defective services. The contractor’s quality control program is the means by which the contractor assures himself that his work complies with the requirements of the contract. At a minimum, the contractor shall develop quality control procedures that address the areas identified in

Technical Exhibit 1, “Performance Matrix Summary”. After PBGC acceptance of the quality control plan the contractor must receive the contracting officer’s acceptance in writing of any proposed change to the QC system. The contractor’s QC plan must be submitted within 30 days after contract award and must be approved by the COR.

C.7 Performance Matrix Summary: The government shall evaluate the contractor’s performance under this contract in accordance with the Performance Matrix Summary provided in Technical Exhibit

1. This plan is primarily focused on what the government must do to ensure that the contractor has performed in accordance with the performance standards. It defines how the performance standards will be applied, the frequency of surveillance, and the minimum acceptable defect rate(s).

The government reserves the right to change the performance measures and/or performance targets throughout the contract performance period. The government will provide the contractor with a 30 day notice of any changes to the stated performance measures or targets.

C.8 Bilingual Requirement: The contractor shall provide two (2) employees, under any of the labor categories provided with the exception of the Project Manager and Assistant Project Manager, who are fluent in Spanish (reading, writing and speaking) to handle routine and non-routine calls.

Non-routine calls and inquiries from Spanish-speaking participants will be transferred to the PVA

Office from the PBGC Headquarters, Customer Contact Center and FBA Offices. The Contractor shall transfer non-English and non-Spanish speaking participants to the Customer Contact Center.

C.9 Periodic Progress Meetings: The contracting officer, Contracting Officer’s Representative

(COR), and other Government personnel, as appropriate, may meet periodically with the contractor to review the contractor's performance. At these meetings the contracting officer will apprise the contractor of how the government reviews the contractor's performance and the contractor will apprise the Government of problems, if any, being experienced. Appropriate action shall be taken to resolve outstanding issues.

C.10 Contractor Furnished Items and Services

Except for those items specifically stated to be Government furnished property and equipment in Section F, the Contractor shall furnish: a staff that meet or exceed the minimum qualifications as outlined in Section H.

C.11 Project Management and Support Services

C.11.1 The Contractor shall designate the positions of Project Manager, Assistant Project

Manager, and LAN Administrator) as key personnel as required under Section H of this contract. The Contractor shall provide advance notification to the COR (as specified in

Section H) any potential/planned changes in key contract personnel. See Section H regarding additional requirements for Key Personnel. The Contractor shall provide for contract management to effectively plan, perform and control the work of the day-to-day operations of the contract. The project manager and assistant project manager are required

PAGE 18 OF 104 PBGC01-RP-15-0005

to manage the activities performed under this contract, and to ensure effective utilization of resources and coordination of projects with the PBGC

The contractor shall not bill for hours spent performing overhead services, such as preparing payroll, hiring employees, meeting with legal representatives, accountants and benefit providers directly to the contract.

C.11.2 The Contractor shall make provisions acceptable to the PBGC for dealing with unsatisfactory personnel.

C.11.3 The Contractor is responsible for ensuring the quality of all work performed by the staff.

The Contractor is responsible for taking timely corrective action to limit the impact of any problems that may arise.

C.11.4 The Contractor shall provide all other training needed by the staff to perform their duties

(e.g. Microsoft Office skills). The Government will reimburse the contractor as an Other Direct

Costs in those situations in which the government changes its requirements with regards to the use of certain work office software application (e.g. moving to SharePoint or higher levels of Microsoft office). This reimbursement would apply to training of existing staff onboard at the time of contract award. The Government shall not reimburse as an Other Direct Costs for new hires. The contractor shall provide ongoing training to maintain proficiency with systems, and knowledge of procedures and policies, and other related skills.

C.11.5 PBGC Systems: BAPD is interested in using newer technologies and innovative methods to achieve its processing goals that are both efficient and cost effective. To achieve this outcome, the Contractor shall participate in the development process of its new systems to include, but not limited to, transfer of benefit processing knowledge to our developers through requirements gathering sessions, participation in User Acceptance

Testing and ‘Checkpoint” status meetings to discuss problems or issues once a system release has been placed in production.

C.12 Basic Benefit Administration Services: The contractor shall provide participant focused benefit administration services in support of BAPD’s trusteed plans. For all tasks outlined, the contractor shall follow the policies and procedures outlined in the BAPD

Manual. Periodically, BAPD will publish interim guidance to procedures via email notification and on its Portal until the BAPD Manual is updated. The contractor shall consult with RSD for technical guidance and assistance. Any deviations from the BAPD

Manual must be approved by the PBGC designee and clearly documented in the appropriate file.

C.12.1 Gathering and Maintaining Participant Data: The Contractor shall assist in maintaining accurate participant information received through oral and written correspondence which may be obtained to clarify and expand on participant data obtained from plan and administration files.

C.13 Processing Benefit Payments to Eligible Participants and Beneficiaries: The Contractor shall review and process new retirement applications and process applicable benefit adjustments in

PAGE 19 OF 104 PBGC01-RP-15-0005

accordance with the BAPD Operations Manual and performance measure targets. The Contractor shall process all benefit payments in accordance with BAPD’s published Benefit Payment schedule.

C.13.1 Application Process: The Contractor shall process all applications received by mail, fax and electronically through MyPBA. All applications deemed completed for eligible participants and beneficiaries’ payments should be processed timely.

C.13.2 Benefit Estimates: The Contractor shall provide benefit estimates to participants upon request.

C.13.3 Woodwork Participants: The Contractor shall research and process woodwork participants who claim possible entitlement to a benefit from a particular plan who is not included in the final valuation.

C.13.4 Missing Benefit Payments: The Contractor shall coordinate stop payments on missing benefit checks with PBGC’s paying agent, and, where applicable initiate re-issuance of benefit payments.

C.13.5 Unlocatable Participants: The Contractor shall coordinate with the designated government representative to initiate the search.

C.14 Process Participant Information Changes: The Contractor shall process participant information changes such as:

Electronic direct deposits

Bank Changes

Address changes

Death notices

Income Verifications

Social Security Earnings Request

C.15 Distributing Benefit Determination Letters: The Contractor shall work with the designated government representatives to schedule and distribute Benefit Determination letters advising participants of their benefits under a plan and, if applicable, benefit statements with an explanation before rejecting any claims.

Process Benefit Adjustments: The Contractor shall process benefit changes, such as:

Step downs, temporary supplements, pop ups, and disabilities;

Final benefit adjustments (change payment from estimate to final status) within 90 days after the expiration of the appeal period, to include the implementation of recoupment/recoveries/special checks and updates to Spectrum.

As authorized by PBGC, adjust participants’ benefits shortly after trusteeship to PBGC’s estimated amounts, when necessary.

C.16 Appeals: The Contractor shall support appeals process such as referrals from appeals (RFAs) and the timely implementation of appeal decisions.

C.17 Maintaining Participant Documentation: The Contractor shall process all participant documents received from customer inquiries received by mail (date/time stamped receipt), fax, or

PAGE 20 OF 104 PBGC01-RP-15-0005

email. All participant records must be properly indexed and scanned/converted into IPS. The contractor shall coordinate with the TPD the scanning of any documents that are in a format other than paper (e.g. microfiche).

C.18 Oral and Written Inquiries: The Contractor shall respond to all inquiries from participants and other interested parties, except for sensitive correspondence. The contractor shall field and response to calls from participants as needed. The Contractor shall document all inquiries and responses, which includes the scanning/imaging of all written correspondence. The Contractor shall response to written inquiries in writing on PBGC letterhead (with the appropriate logo) and signed as PBGC’s authorized representative.

C.19 Plan Closing: The Contractor shall review the Plan Closing documents submitted by the federal staff or other contractor field benefit administration offices. The contractor shall determine if the plan closing documents are acceptable based on the criteria established in the BAPD Procedures Manual. For those documents not considered acceptable, the contractor shall notify the RSD federal designated representative.

C.20 Special Projects: Participate in and support BAPD projects such as the Communities of

Practice, process improvement events, participant meetings, conferences, ad hoc projects, etc.

Provide requirements for new and updated systems and performs user acceptance testing.

C.21 LAN Administration Support: The contractor shall perform on premise hardware/software support for the PVA staff. The contractor shall coordinate with facilities personnel for facilities support requirements, e.g. HVAC and power problems and perform forms troubleshooting at the desktop operations level and on application issues, which could involve working with Tier 2 & 3 support.

Performs installation and moving of equipment. The contractor shall also perform on-site validation of

IT equipment operations. The contractor shall perform asset management by validating status and location of on-site IT equipment and provides updates to COR and PBGC's IT Asset Manager.

The LAN Support shall also include running reports and database queries in support of the office processing activities.

C.22 Other Requirements: Information and Telecommunications: Contractor staff must take the mandatory Annual Security Awareness Training offered by the PBGC. Newly hired employees after contract award will be required to take the Initial Security Orientation Course within 30 days of being hired. This orientation course will be offered by way of a web-based tutorial.

Contractor personnel are required to abide by PBGC’s Directive (see Clause PBGC 04-004) on the

Use of Information Technology Resources and Safeguarding Information.

C.23 Continuity of Operations Planning (COOP): The PBGC will provide specific guidance to the Contractor regarding COOP. The Contractor may be requested to support PBGC in two of its

COOP testing exercises. PBGC will provide up to two weeks advance notification of the timing of any planned COOP activities. The Contractor will be required to do the following:

Provide an updated succession and delegation orders for the COOP Plan quarterly

Provide quarterly COOP contact list (to be provided to COR)

C.24 PBGC Agency Audits: The contractor shall be required to support any audit/review activity relating to the work performed under this contract. All work performed under this contract is subject to review and inspection and/or audit by the PBGC and other entities. PBGC will conduct

PAGE 21 OF 104 PBGC01-RP-15-0005

the following review on a regular basis, but shall not be limited to any of the following:

COR site visits

PVA Performance Review

Compliance Reviews

PBGC Financial Audits

Audits conducted by PBGC’s Inspector General

Audits conducted by the Government Accountability Office (GAO)

If any parties other than PBGC express the need to visit the contractor's site, the Contractor shall coordinate the visit with the COR. The contractor shall also coordinate with the PBGC in responding to documentation and information requests.

The Contractor shall designate an individual, at the Senior Pension Administrator labor category or above, who can be trained by the PBGC to be responsible for processing the following:

Qualified Domestic Relations Orders (QDROS), Powers of Attorney (POAs) and

Guardianships.

C.25 Applicable Documents

The Contractor shall perform the services set forth in the SOW in accordance with the BAPD On-

Line Manual that includes PBGC’s Policy Manual and Bulletins (BAPD Manual) The Contractor will also perform services in accordance with documented procedures contained on PBGC’s Portal for certain case processing activities and in accordance with Interim Guidance that is released periodically through e-mail notification. In addition, the contractor shall perform Tier 1 LAN

Administration Support in accordance with the OIT Standard Operating Procedures for Service

Desk Support, provided upon award.

C.26 Performance Requirements

This acquisition directly supports the mission and goals of PBGC by providing the highest caliber professional pension benefit administration services support. The following measurable activities are aligned with PBGC Strategic Objectives and include:

Activity 1: Participant Services

Activity 2: Case processing support services

Activity 3: Customer Service

Activity 4: Special Projects

Specific services, performance standards and Government monitoring methods and/or

“scorecards” are contained in the performance-based contracting matrix that follows. It should be noted, that BAPD continuously strives to provide exceptional and timely service to its plan participants. As such, the stated target levels for the performance measures outlined may be adjusted at the beginning of each option year to meet the departmental goals and objectives.

Changes to the performance targets will be communicated to the contractor 30 days prior to implementation.

C.27 Reporting Requirements:

PAGE 22 OF 104 PBGC01-RP-15-0005

C.27.1 Monthly Management Report: The Contractor shall submit a monthly status report identifying all significant activities issues, and events that might impact established workplan target dates.

All reports are due to the COR and designated government representative by the fifth (5th) workday after the end of the month.

C.27.2 Monthly Burn Report: The Contractor shall submit to the COR a monthly cost report showing actual labor costs and other costs. Additionally, this report shall provide labor hours per labor category, labor costs per labor category and rate. This report shall be submitted to the COR by the tenth (10 th

) of current month.

C27.3 Other Reports: Contractor shall provide other reports as required/requested by the

COR or designated government representative.

C.27.4 Overtime: Overtime will be paid at the same rate as regular time, except for those labor categories indicated in Section B. All overtime must be pre-approved by the COR. The Contractor shall provide the COR with all projected overtime for the month in their Monthly Management

Report.

C.27.5 Contractor Staff Listing: The contractor shall submit to the COR by the last business day of the month a cumulative listing of employees that are onboard and who have terminated during the fiscal year.

C.28 Alternate Facility (Washington, DC Metropolitan Area): The Government at its discretion reserves the right to exercise the optional CLIN which includes a having work conducted under this contract at an alternate facility. PBGC may have additional

PVA work conducted at an alternate facility outside of the Richmond Heights Office. The government will coordinate this requirement in advance with the contractor. The hours and staff required are included in the Pricing Schedule included in Section B.

C.29 Contractor Performance Report (Scorecard)

The COR will be responsible for meeting frequently with the contractor to address problems and issues as they arise. On a quarterly basis, the Management Coordination Division (MCD), of BAPD in coordination with the COR will issue a performance report for the performance measures outlined in the attached matrix. The scorecard will indicate those performance measures in which the contractor has met has or exceeded the established targets. The contractor shall have 10 calendar days after the scorecard is issued to concur with the evaluation provided and to provide a corrective action plan for deficiencies noted to both the COR and MCD Supervisor. Any disputed information presented in the scorecard should be communicated to both the COR and MCD

Supervisor. . An adjusted scorecard will be issued to reflect any agreements reached on the disputed information within 10 calendar days of the agreement. The MCD Manager will act as mediator to resolve any disputes.

PAGE 23 OF 104 PBGC01-RP-15-0005

TECHNICAL EXHIBIT 1

Performance Matrix Summary

Required Services Performance

Standards

AQL Monitoring

Method

Activity 1: Retiree/Beneficiary Administration

Strategic Goal: Pay benefits on time and accurately

Strategic Objective: Ensure regular monthly benefit payments continue without interruption

Performance Goal: Approve completed benefit applications within 45 days

1.1

Review and process new retirement applications:

New retirement applications are processed timely so that participants receive their benefit payments.

Supported by the following tasks:

Utilizing the Actuarial Tool to calculate the benefit at the actual retirement date and form of benefit if available.

Processing Actuarial Support Requests “ASRs” where a change in data is required.

Processing Power of Attorney and Durable Power of Attorney

Participant locator services

Participants not included in the valuation:

Researching participant eligibility

Social security earnings investigations

Process off-cycle checks

Resolve Trial Balance Variances

87% of eligible applications are processed within 45 days of receipt by

PBGC’s document management center.

90% of eligible applications are processed within 60 days of receipt by

PBGC’s document management center.

100% of Trial Balance

Variances are resolved within the specified timeframes (based on date in published check schedule)

No deviation

Cognos

Cognos

Report issued by

RSD Benefit

Payment

Branch after each Trial

Balance cycle.

PAGE 24 OF 104 PBGC01-RP-15-0005

Standards

AQL Monitoring

Method

1.2

Authorization of monthly benefits:

Monthly benefits are authorized accurately and properly reflected in PRISM/SPECTRUM.

Conduct the following payee data reviews o Form of benefit o Participant status

Notify participant

Reconcile PRISM/SPECTRUM data

Process participant benefit changes, such as Joint and

Survivor, remaining certain periods, adjusted recoupments, step downs, supplemental, popups, disability

Process participant information changes such as:

Electronic direct deposits

Address changes

Bank changes

Date of birth

Death processing

Coordinate stop payments on missing benefit checks and deceased participants

Process recoupment and recoveries

Process QDRO’s

Process Trial Balance Variances

98% of benefit authorizations processed are completed accurately.

Participant information changes are processed in accordance with the

BAPD Operations

Manual.

Monthly

MCD will pull a sample of transactions authorized for the month and review for quality based on established checklist.

Activity 2: Participant Services

Strategic Goal: Pay benefits on time and accurately

Strategic Objective: Provide accurate and timely benefit calculations

Performance Goal: Maintain exemplary customer service

2.1

Plan Closing: Plans are closed with less than 5% critical errors; BDLs are corrected and benefit adjustments have been made.

Review and accept

85% of the plans within 60 days and

70% within 30 days.

No deviation without

RSD Management approval.

Any deviations

Any plan closing rejected will be evaluated by the RSD

PAGE 25 OF 104 PBGC01-RP-15-0005

Standards

AQL Monitoring

Method

Review of plan closing completed by the TPD or FBA to verify the following:

All audits are complete and imaged

Participants are reconciled between the actuarial valuation and the Spectrum Database.

Based on a sample the participant BDLs are accurate and complete.

Plan closing report and critical error reports have been correct or noted as uncorrectable in the memo.

Plan closing memo is accurate and complete.

Assure that benefit adjustments have been completed.

Log, track and report on all Plan Closing Reviews.

95% of sampled plan closing reviews are determined accurate and complete upon initial review.

should be noted in contractor’s monthly status report

No deviation.

federal staff for concurrence.

BAPD staff will perform at least quarterly a sample review of the plan closing reviews completed for compliance with BAPD procedures.

Activity 3: Customer Service Strategic Goal: Pay benefits on time and accurately

3.1

Provide high quality customer service.

Responding to participants written and oral communications

Responding to requests from the Problem Resolution

Office

Responding to FOIA requests

Responding to Congressional inquiries

Processing income verifications

Health Coverage Tax Credit Coordination and support

Process benefit estimates

Process woodwork participants. A woodwork person can be defined as one who claims possible entitlement to a benefit from a particular plan who has not been included in the final valuation.

95% of tested closed participant inquiries have been adequately resolved.

Customer Call

Quality Assurance score must maintain a score of

80% after 1 st months of the 1 st contract year.

Quarterly, RSD COR will review a sample of closed service request in

CRM.

Independent contractor report provided monthly on results of call monitoring.

PAGE 26 OF 104 PBGC01-RP-15-0005

Standards

AQL Monitoring

Method

Activity 4: Other Special Projects

Strategic Goal: Pay benefits on time and accurately

4.1

Conduct special projects related to plan or participant benefit administration to facilitate participant services and/or to streamline PBGC operations, to include such activities as:

Systems requirement support, including user acceptance testing

Data clean up/conversion

Communities of practice

Participate in PBGC training and train the trainer, such as new systems, policy updates

Audit support for both PBGC internal and external auditors.

Process improvement initiatives

Rotational policy support

Wrap up work associated with legacy pre PVA status cases at the PVA site. Includes all processing steps through Plan Closing.

Activities completed within agreed upon periods and approved by COR.

No deviation without

COR approval

The contractor shall report in their

Monthly

Management

Report any special projects undertaken and the outcomes.

PAGE 27 OF 104 PBGC01-RP-15-0005

TECHNICAL EXHIBIT 2

Deliverables Schedule

Deliverable Frequency # of Copies Medium/Format Submit To

1. Quality Control Plan

30 days after contract award

Microsoft word document

COR

2. PICS Employee certification

Quarterly based on call announcement

N/A Via email PICS Coordinator, cc to COR

3. Monthly Management

Report 5th workday after end of month

1 Submitted through the Word

COR and designated government representatives

4. Monthly Burn Report 10th workday after end of month

1 Excel Spreadsheet submitted electronically.

COR and designated government representative

5. COOP Succession and

Delegation order.

Order

Quarterly

Template format in word

COR, with cc to COR Coordinator

6. COOP Employee Listing Quarterly 1 Excel Spreadsheet COR

7. MCD Scorecard

Concurrence

10 calendar days 1 Via email MCD Supervisor & COR

Coordinator with cc: to the COR

8. Corrective Action Plan. 10 calendar days 1 Via email using established template

COR

9. Monthly performance report

5" workday after the end of each month

1 Via email and or

Portal/Share Point

COR & COR Coordinator

PAGE 28 OF 104 PBGC01-RP-15-0005

TECHNICAL EXHIBIT 3

Staffing Plan

Staffing Level: 67 employees

Number of Plans: 4,136 cases

Number of Participants: 1.5 million participants

Outgoing Letters FY14 172,310

Applications Processed – FY14 20,142

Death Processing FY 14 31,827

CRM Incoming Calls FY14 119,649

CRM Outgoing Calls FY14 6,002

Plan Closing Reviews 83

PAGE 29 OF 104 PBGC01-RP-15-0005

SECTION D

PACKAGING AND MARKING

D. 1 PBGC-11 004 PACKAGING AND MARKING (JAN 2012).

The Contractor is responsible for the cost of all packing, packaging and mailing in accordance with the best commercial practices. All information submitted to the Contracting Officer or the COR must be clearly marked with the company name, the PBGC contract number, and identification of the item.

PAGE 30 OF 104 PBGC01-RP-15-0005

SECTION E

INSPECTION AND ACCEPTANCE

E. 1 PBGC-46-001 INSPECTION AND ACCEPTANCE OF DELIVERABLES (JAN 2012).

All deliverable items are to be furnished to the Contracting Officer's Representative (COR) or to PBGC personnel designated by the COR to receive a specific deliverable.

PBGC's receipt of a deliverable does not constitute acceptance by the Government. Final acceptance of any reports or other deliverable items required under this contract will be made in writing and may only be made by the COR or Contracting Officer.

PAGE 31 OF 104 PBGC01-RP-15-0005

SECTION F

DELIVERIES OR PERFORMANCE

F. 1 52.242-15 STOP-WORK ORDER (AUG 1989)

(a) The Contracting Officer may, at any time, by written order to the Contractor, require the Contractor to stop all, or any part, of the work called for by this contract for a period of 90 days after the order is delivered to the Contractor, and for any further period to which the parties may agree. The order shall be specifically identified as a stop-work order issued under this clause.

Upon receipt of the order, the Contractor shall immediately comply with its terms and take all reasonable steps to minimize the incurrence of costs allocable to the work covered by the order during the period of work stoppage. Within a period of 90 days after a stop-work is delivered to the Contractor, or within any extension of that period to which the parties shall have agreed, the Contracting Officer shall either--

(1) Cancel the stop-work order; or

(2) Terminate the work covered by the order as provided in the Default, or the Termination for Convenience of the Government, clause of this contract.

(b) If a stop-work order issued under this clause is canceled or the period of the order or any extension thereof expires, the Contractor shall resume work. The Contracting Officer shall make an equitable adjustment in the delivery schedule or contract price, or both, and the contract shall be modified, in writing, accordingly, if--

(1) The stop-work order results in an increase in the time required for, or in the Contractor`s cost properly allocable to, the performance of any part of this contract; and

(2) The Contractor asserts its right to the adjustment within 30 days after the end of the period of work stoppage; provided, that, if the Contracting Officer decides the facts justify the action, the Contracting Officer may receive and act upon the claim submitted at any time before…