RFI Draft Performance Work Statement.pdf

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Voluntary Education (VolEd) Support Services
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SS20250213RFI
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This is a Performance Work Statement (PWS) for Department of Defense Voluntary Education (VolEd) Support Services, to be executed under the Office of the Under Secretary of Defense for Personnel and Readiness starting January 3, 2025. The PWS outlines requirements for implementing a risk-based institutional compliance program to evaluate approximately 2,700 educational institutions participating in the DoD Tuition Assistance program.

The contractor must provide personnel, equipment, and services to implement the compliance framework, including: a Senior Compliance Specialist, Compliance Analyst, Data Collection/Analysis Lead, and Data Collection Support Analyst. Key tasks include conducting risk-based analyses of institutions, performing web verification research, administering self-assessment surveys, evaluating compliance data, providing feedback to institutions, assessing corrective action plans, and conducting up to five site visits annually. The contract will have a 12-month base period with four 12-month options. The estimated workload requires 7.94 FTEs per year across labor categories. Work will be performed in the National Capital Region, with some travel required. The incumbent contract (HQ003420F0484) was awarded to Guidehouse LLP, with an estimated total value of $14.6 million for the follow-on contract.

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PERFORMANCE WORK STATEMENT (PWS)

Office of the Under Secretary of Defense for Personnel and Readiness (OUSD P&R) Department of Defense Voluntary Education (VolEd) Support Services

January 3, 2025

Part I General Information

1. GENERAL: This is a non-personnel services contract to provide Department of Defense Voluntary Education Support Services (DoD VolEd.). The DoD VolEd Memorandum Of Understanding (MOU) Partnership Institutional Compliance Program (ICP) is a full-scale risk-based compliance program that intends to reduce the overall risks associated with non-compliance facing the DoD VolEd program. The Government shall not exercise any supervision or control over the contract service providers performing the services herein. Such contract service providers shall be accountable solely to the Contractor who, in turn is responsible to the Government.

1.1 Description of Services/Introduction: The contractor shall provide all personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, and other items and non-personal services necessary to perform Voluntary Education Support Services, as defined in this Performance Work Statement (PWS) except for those items specified as government furnished property and services. The contractor shall perform to the standards in this contract.

1.2 Background: In September 2014, the U.S. Government Accountability Office (GAO)1 performed an audit of the performance of a contracted third-party evaluation centered on institutions participating in a DoD TA program. This audit included a review of the 23 evaluations completed in fiscal years 2012 and 2013, the resulting recommendations from these 23 evaluations, and a comparison of the evaluation contract’s execution against the standards and principles established by GAO and the American Evaluation Association (AEA).

According to the GAO, a program evaluation is defined as a systematic study using research methods to collect and analyze data to assess how well a program is working and why. As defined in the GAO Internal Control and Management Evaluation tool, compliance programs must include several key components to improve efficiency and effectiveness of organizations. These include controls on program environment, risk assessment, control activities, communications, and overall monitoring. In addition, a program evaluation should answer specific questions about program performance, assess how to improve program performance, and determine whether program activities have resulted in the desired benefits for program participants or the general public.

Upon completion of the audit, the GAO’s findings were compiled into a Report to Congressional Committees entitled “DOD Education Benefits: Action is Needed to Ensure Evaluations of Postsecondary Schools are Useful.” The GAO determined that the existing third-party assessment did not provide the evaluation information needed by the DoD to evaluate these institutions within the TA program. This lack of information was partly due to the poorly defined assessment areas and goals as well as the lack of an evaluation plan. In addition, the contractor lacked the necessary skills and knowledge to fulfill requirements of the evaluation.

Finally, the completed evaluations often provided results that were only tangentially related to the intended compliance areas and did not include a meaningful sample.

DoD VolEd’s focus on institutional compliance is also an important aspect of the 2015-2020 Strategic Plan. The plan’s vision centers on shaping quality voluntary educational experiences by confronting the unique challenges facing military students, fostering better Service members by emphasizing the role of higher education in military training, and creating better citizens by promoting educational attainment to support their transition into civilian life. This vision is supported by strategic focus areas that promote quality educational opportunities, ensure military student readiness, enable a viable Voluntary Education community & Workforce, and cultivate a culture of organizational effectiveness.

Through this contract, in alignment with their strategic plan, DoD VolEd intends to implement a new risk-based institutional compliance framework and methodology to ensure more rigorous evaluation of the TA program participant institutions and their compliance to the DoD MOU. A well-structured compliance framework will detail the processes necessary to maintain and ensure a participating institution’s compliance to the MOU requirements. A rigorous and sound evaluation program, framework, and methodology are imperative in order to give DoD VolEd insight into how well the TA program is performing and confidence that educational institutions are delivering the intended benefits to the Service members participating in the program.

1.3 Objectives:

The objective of this effort is to provide DoD VolEd support services to the Office of the Under Secretary of Defense for Personnel and Readiness (OUSD P&R) Voluntary Education Programs Office.

The DoD VolEd contract vision is to implement an effective compliance program to enforce adherence to the applicable POE, MOU requirements, and DoD policies and procedures. The institutional compliance program will provide the controls and compliance mechanisms needed to ensure and sustain the quality and value of educational opportunities provided to Service members under the VolEd program. As each Service is responsible for administering the VolEd program, a fully effective VolEd compliance program will include a review of Service-level policies and procedures in addition to oversight of educational institutions. The main objectives of this contract involve implementing the necessary compliance framework, methods, and tools to provide effective oversight of educational institutions receiving TA funds. This program is geared towards correcting the issues and concerns highlighted by the GAO report and findings. The program also aims to achieve DoD VolEd’s strategic business objectives that center on empowering informed service member decision making, shaping meaningful personal and professional pathways, and driving military student success in higher education as stated in the following bullets:

1.3.1. Establish a program that enhances the ability of DoD VolEd to provide military Service members access to high quality education by ensuring educational institutions provide meaningful information about the financial cost and quality of their school, provide high quality academic and student support service, and refrain from abusive and deceptive business practices.

1.3.1.1. Implement a risk-based compliance framework, methodologies, and tools necessary to provide effective oversight of educational institution receiving TA funds

1.3.1.2. Address the issues raised in the GAO Reports on higher education oversight and in Executive Order No. 13607 which established the of Principles of Excellence for educational institutions serving Service members.

1.3.2. Reduce the overall risks facing DoD VolEd that would in any way inhibit their core mission of championing policies, programs, and partnerships that enable access to quality postsecondary educational opportunities.

o 1.3.2.1. Gather, analyze, and report compliance data to relevant stakeholders in a timely and efficient manner and allows for stakeholders to form a plan of action based on results o 1.3.2.2. Support and improve decision making in regard to policy, programs, and partnerships by incorporating the comprehensive data gathered and analyses performed

1.3.3. Build a culture of compliance among all stakeholders in from the DoD, the Services, VA, ED, and the education institutions themselves so that all parties can work together in achieving excellence in education and outcomes for Service members.

o 1.3.3.1. Communicate with students, ESOs, Services, and educational institutions to raise awareness and emphasize the importance of their participation in the ICP by highlighting how their participation will serve to empower themselves and their peers o 1.3.3.2. Continue to promote awareness of compliance as new issues arise, and effectively communicate with and train all stakeholders, especially educational institutions, on the importance and specifics of compliance o 1.3.3.3. Create a long-term sustainable program that utilizes continuous process improvement to anticipate, detect, and deter possible deficiencies in the future before it affects those using TA benefits.

o 1.3.3.4. When, appropriate, revisit overarching policy documents to ensure they remain effective in providing the necessary framework for oversight and compliance enforcement.

1.3.4. As each Service is responsible for administering the VolEd program at the service level, a fully effective VolEd compliance program will include a review of Service-level policies and procedures. This will examine the linkages across the enterprise and ensure that the Service-level VolEd programs are supporting DoD VolEd’s strategic objectives and should be conducted in a manner that is complementary to the ICP.

1.4 Scope: The Department of Defense Voluntary Education (DoD VolEd) MOU Partnership Institutional Compliance Program (ICP) focuses on the approximately 2700 educational institutions approved to participate in the TA program. With the introduction of the ICP, DoD VolEd will initiate a new type of research-based compliance program within the DoD community that includes data collection activities, risk-based analyses, and annual reviews of compliance results across MOU institutions as well as ways to continually improve the program.

In 2015, DoD VolEd developed an initial framework for the ICP framework as well as a plan for its development and implementation. The ICP framework was designed based upon the best practice methodologies outlined in GAO’s 2012 Designing Evaluations Report. The ICP is designed to provide a continuous and repeatable process to enhance DoD VolEd’s ability to communicate and enforce DoD MOU compliance requirements and results in building a culture of compliance across the DoD VolEd community. The ICP consists of three annual phases that help the compliance program identify and prioritize a risk-based compliance focus, manage the compliance processes to collect and analyze relevant data, and finally evaluate the outcomes to effectively manage risk and identify remediation actions for non-compliance. Figure B1-1 shows the ICP Compliance Framework which is a graphical illustration of the overall ICP components, processes, and methods of the compliance program.

Illustration of the overall ICP components, processes, and methods of the compliance program.

The ICP three-phase process cycle is based on industry and government best practices for compliance programs. Each year, the ICP follows a repeatable, research-based risk management approach to data collection and analysis process that includes three main phases. The process begins with Phase 1: Identify, Prioritize, and Focus, where the institutions for review in that cycle iteration are selected according to a risk-based analysis including VolEd program data, PECS complaint data, and other related institutional data.

The next step, Phase 2: Manage Resources & Processes, Minimize Risk, involves the carrying out of data collection and analysis activities to effectively evaluate the compliance posture of the institutions under review. Phase 3: Evaluate Outcomes is the formalized step at the end of the process for gathering feedback on the evaluation sequence and determining next steps for the evaluated institutions.

1.5 Period of Performance: The period of performance shall be for one (1) Base Period of 12 months and four (4) 12-month option periods. The Period of Performance reads as follows:

1.6 General Information:

1.6.1 Quality Control: The contractor shall develop and maintain an effective quality control program to ensure services are performed in accordance with this PWS. The contractor shall develop and implement procedures to identify, prevent, and ensure non-recurrence of defective services. The contractor’s quality control program is the means by which he assures himself that his work complies with the requirement of the contract. The QCP shall be delivered via electronic mail within 30 days of contract award. Amendments/changes to the QCP shall be delivered to the COR and CO within three business days following any change.

1.6.2 Quality Assurance: The government shall evaluate the contractor’s performance under this contract in accordance with the Quality Assurance Surveillance Plan. This plan is primarily focused on what the Government must do to ensure that the contractor

Figure B1-1: ICP Framework 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).

1.6.3 Recognized Holidays: The contractor is not required to perform service on holidays

New Year’s Day Labor Day Martin Luther King Jr.’s Birthday Columbus Day President’s Day Veteran’s Day Memorial Day Thanksgiving Day Independence Day Christmas Day

1.6.4 Hours of Operation: The contractor is responsible for conducting business, between the WHS core hours of 8:00 AM to 4:30 PM, arriving no earlier than 6:30 AM and departing no later than 6:30 PM Monday thru Friday except Federal holidays or when the Government facility is closed due to local or national emergencies, administrative closings, or similar Government directed facility closings. For other than firm fixed price contracts, the contractor will not be reimbursed when the government facility is closed for the above reasons. The Contractor must at all times maintain an adequate workforce for the uninterrupted performance of all tasks defined within this PWS when the Government facility is not closed for the above reasons.

1.6.5 Place of Performance: The work to be performed under this contract will be performed in a government provided office space in the National Capital Region (NCR). Contractor personnel may be requested to work at the Governments alternate locations during emergencies and emergency exercises. Individual Contractor personnel may be designated as essential personnel to support contingency operations at alternate Government locations during actual emergencies and emergency exercises.

Contractor personnel must obtain and maintain a Pentagon building pass, as well as a Common Access Card (CAC) to access to all Information Technology (IT) systems prior to conducting work on this contract. Contractor personnel must also read and familiarize themselves with all organizational mission statements and charters, organizational structures, operating instructions, Standard Operating Procedures (SOP) and policy.

1.6.6 Type of Contract: The government will award a hybrid contract firm fixed price, Time-and-Material Contract Line Items Numbers (CLINs).

1.6.7 Security Requirements: The Contractor shall comply with all security policies and procedures that apply to DOD and WHS Enterprise Management Directorate. Security procedures shall be made available to Contractor personnel.

1.6.7.1 Physical Security: The contractor shall be responsible for safeguarding all government equipment, information and property provided for contractor use. At the close of each work period, government facilities, equipment, and materials shall be secured.

1.6.7.2 Lock Combinations. The Contractor shall establish and implement methods of ensuring that all lock combinations are not revealed to unauthorized persons. The Contractor shall ensure that lock combinations are changed when personnel that having access to the combinations no longer have a need to know such combinations. These procedures shall be included in the Contractor’s Quality Control Plan.

1.6.7.3 Key Control: The Contractor shall establish and implement methods of making sure all keys/key cards issued to the Contractor by the Government are not lost or misplaced and are not used by unauthorized persons. NOTE: All references to keys include key cards. No keys issued to the Contractor by the Government shall be duplicated. The Contractor shall develop procedures covering key control that shall be included in the Quality Control Plan. Such procedures shall include turn-in of any issued keys by personnel who no longer require access to locked areas. The Contractor shall immediately report any occurrences of lost or duplicate keys/key cards to the Contracting Officer.

1.6.7.3.1. In the event keys, other than master keys, are lost or duplicated, the Contractor shall, upon direction of the Contracting Officer, re-key or replace the affected lock or locks; however, the Government, at its option, may replace the affected lock or locks or perform re-keying. When the replacement of locks or re-keying is performed by the Government, the total cost of re-keying or the replacement of the lock or locks shall be deducted from the monthly payment due the Contractor. In the event a master key is lost or duplicated, all locks and keys for that system shall be replaced by the Government and the total cost deducted from the monthly payment due the Contractor.

1.6.7.3.2. The Contractor shall prohibit the use of Government issued keys/key cards by any persons other than the Contractor’s employees. The Contractor shall prohibit the opening of locked areas by Contractor employees to permit entrance of persons other than Contractor employees engaged in the performance of assigned work in those areas, or personnel authorized entrance by the Contracting Officer.

1.6.8. Contractor Manpower Reporting:

(a) The Contractor shall report all Contractor labor hours (including subcontractor labor hours) required for performance of services provided under this contract via a secure data collection site. The Contractor is required to completely fill in all required data fields using the following web address: http://www.ecmra.mil/.

(b) There are four separate ECMRA tools at the ECMRA website: Army, Air Force, Navy, and All Other Defense Components. The appropriate ECMRA reporting tool to use is determined by the requiring activity being supported by the service. The Contractor shall use the “All Other Defense Components” tool unless otherwise directed by the Contracting Officer’s Representative or Contracting Officer.

(c) Reporting inputs will be for the labor executed during each Government fiscal year (FY), which runs October 1 through September 30. While inputs may be reported any time during the FY, all data shall be reported no later than October 31 of each calendar year. The Contractor shall completely fill in all required data fields. The Contractor shall enter initial data into the appropriate ECMRA tool to establish the basic contract record no later than 15 business days after receipt of contract award or contract modification incorporating this clause. The Contractor shall notify the Contracting Officer when the basic contract record has been established in the appropriate ECMRA tool.

(d) Contractors may direct technical questions to the help desk at: http://www.ecmra.mil.

[Reference: DPAP memorandum of 28 November 2012, “Enterprise-wide Contractor Manpower Reporting]

1.6.9 Post Award Conference/Periodic Progress Meetings: The Contractor agrees to attend any post award conference convened by the contracting activity or contract administration office in accordance with Federal Acquisition Regulation Subpart 42.5. The contracting officer, Contracting Officers 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 views 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. These meetings shall be at no additional cost to the government.

1.6.10 Contracting Officer Representative (COR): The (COR) will be identified by separate letter. The COR monitors all technical aspects of the contract and assists in contract administration The COR is authorized to perform the following functions: assure that the Contractor performs the technical requirements of the contract: perform inspections necessary in connection with contract performance: maintain written and oral communications with the Contractor concerning technical aspects of the contract: issue written interpretations of technical requirements, including Government drawings, designs, specifications: monitor Contractor's performance and notifies both the Contracting Officer and Contractor of any deficiencies; coordinate availability of government furnished property, and provide site entry of Contractor personnel. A letter of designation issued to the COR, a copy of which is sent to the Contractor, states the responsibilities and limitations of the COR, especially with regard to changes in cost or price, estimates or changes in delivery dates. The COR is not authorized to change any of the terms and conditions of the resulting order.

1.6.11 Labor Categories and Key Personnel:

1.6.11.1 The personnel listed below are considered key personnel to the work being performed under this contract. During the first 180 calendar days of performance, the contractor shall make no substitutions of personnel without the approval of the Contracting Officer, unless illness, death, or termination of employment necessitates the substitution. The contractor shall notify the COR and Contracting Officer as soon as possible after the occurrence of any of these events and provide the information required below;

After the initial 180 calendar day period, the contractor may quote a substitution. The contractor shall (1) notify the Contracting Officer in writing of any quoted substitution at least 30 days in advance of the quoted substitution unless extenuating circumstances exist (see above paragraph). (2) provide a detailed explanation of the circumstances necessitating the quoted substitutions, complete resumes for the quoted substitutes, and any additional information requested by the Contracting Officer. (3) The Contractor shall, prior to making any substitution permanent, demonstrate to the satisfaction of the Contracting Officer, that the qualifications of the quoted substitute personnel is equal to or better than the qualifications of the personnel originally identified for the position. The Contracting Officer will notify the contractor within 15 calendar days after receipt of all required information of the decision on d http://www.ecmra.mil/ http://www.ecmra.mil/ substitutions. The Contractor shall make no diversion without the Contracting Officer's written consent; provided that the Contracting Officer may ratify in writing the quoted change, and that ratification shall constitute the Contracting Officer's consent required by this document.

The contractor shall provide the following qualified key personnel under this contract, and price each labor category as it could be applied to the PWS Part 5.

One (1) Consultant Manager III (Senior Compliance Specialist) – Shall have a relevant bachelor’s degree or professional certification and minimum 12 years related experience. The Consultant Manager shall have experience in the design and implementation of program evaluation and compliance methodologies within a regulatory environment. The Consultant Manager will be responsible for the following: Leading compliance, data-gathering, and risk-based analysis.

Providing direction and supervision to team members responsible for compliance activities, data collection and analysis.

Serving as the project team’s internal compliance expert and supports quality assurance of the compliance processes and deliverables. Coordinating compliance activities with the program manager, client, and stakeholders who can include Service representatives and higher education administrators. Leading inspection and audit activities, to include on-site inspections of higher education institutions.

One (1) Consultant I (Compliance Analyst) – Shall have a relevant bachelor’s degree or professional certification and a minimum 1 year’s related experience. The Consultant I will be responsible for the following: Supporting activities and research associated with compliance and governing rules, regulations, policies and applicable data for more senior team members. Conducting Internet and document research, manages team databases and knowledge repositories, takes notes during meetings, drafts process flow diagrams, contributes to compliance analysis and reporting, and other deliverables.

One (1) Senior Consultant II (Data Collection and Analysis Lead) – Shall have a relevant bachelor’s degree and a minimum of 5 years of related experience. The Senior Consultant II will be responsible for the following: Leading data collection and analysis activities required to support the compliance program requirements. Designs and implements methods to support data collection and analysis, to include database development and knowledge repositories. Providing direction and supervision for business analysts. Leading and managing the implementation of data collection and analysis activities, to include on-line surveys and assessment tools. Consolidating and presenting compliance data and information for more senior team members and the client. Responsible for data management and data quality assurance to ensure the accuracy and validity of compliance analysis.

One (1) Consultant II (Data Collection and Analysis Support (Business Analyst)) – Shall have a bachelor’s degree and at least 1 year of relevant experience. The Consultant II will be responsible for the following: Assisting and providing project team members with routine data gathering, data mining and research activities, organizes data and project documents, and assists program manager and other team members in project administration and support activities.

Performing web-based research, compliance analysis, and documentation of findings.

1.6.11.2. Special Qualifications: Contractor personnel will be required to sign a Non-Disclosure Agreement (NDA), located as an attachment under the contract, and provide copies to the COR within five days after contract award.

1.6.12 Identification of Contractor Employees: All contract personnel attending meetings, answering Government telephones, and working in other situations where their contractor status is not obvious to third parties are required to identify themselves as such to avoid creating an impression in the minds of members of the public that they are Government officials. They must also ensure that all documents or reports produced by contractors are suitably marked as contractor products or that contractor participation is appropriately disclosed. Contractor personnel will be required to obtain, use, and display a Common Access Card in the performance of this service.

1.6.13 Contractor Travel: The Contractor shall be reimbursed for actual allowable, allocable and reasonable travel cost incurred during performance efforts in accordance with FAR 31.205-46. The contractor shall provide a written request at least ten (10) business days in advance for travel to the COR prior to finalizing any travel arrangements. All travel with 75 miles of the National Capital Region is included in the price of this contract. Travel shall be addressed as a Time & Materials item. The contractor will be required to travel outside of NCR at a minimum two times per-year. The estimated cost of travel per trip is $2,000, and the overall cost for travel will be identified under the contract travel CLINs. Request for approval of cost in excess of maximum per diem rates shall be in accordance with the procedures contained in FAR 31.205-46(a)(3) and must be submitted to the KO for final approval prior to commencement of travel. The contractor will be reimbursed for actual, allowable, allocable, and reasonable Other Direct Charges when approved in advance by the TM and COR.

1.6.14 Other Direct Costs: This category includes travel (outlined in 1.6.13), reproduction, and shipping expenses associated with training activities and visits to contractor facilities.

1.6.15 Data Rights: The contractor shall provide Data Rights information in accordance with DFARS 252.227-7013.

The contractor agrees to assume responsibility for protecting the confidentiality of Government records, which is not considered public information. Each contractor or employee of the contractor to who information may be made available or disclosed shall be notified in writing by the contractor that such information may be disclosed only for purposes and to the extent authorized herein.

The contractor shall not release any information related to this contract to the public, media or other unauthorized persons or organizations unless the Government has conducted the appropriate security review and granted written approval (e.g., posting information to a public website).

1.6.16 Organizational Conflict of Interest: Contractor and subcontractor personnel performing work under this contract may receive, have access to or participate in the development of proprietary or source selection information (e.g., cost or pricing information, budget information or analyses, specifications or work statements, etc.) or perform evaluation services which may create a current or subsequent Organizational Conflict of Interests (OCI) as defined in FAR Subpart 9.5. The Contractor shall notify the Contracting Officer immediately whenever it becomes aware that such access or participation may result in any actual or potential OCI and shall promptly submit a plan to the Contracting Officer to avoid or mitigate any such OCI. The Contractor’s mitigation plan will be determined to be acceptable solely at the discretion of the Contracting Officer and in the event the Contracting Officer unilaterally determines that any such OCI cannot be satisfactorily avoided or mitigated, the Contracting Officer may affect other remedies as he or she deems necessary, including prohibiting the Contractor from participation in subsequent contracted requirements which may be affected by the OCI.

1.6.17 Phase in Period: To minimize any decreases in productivity and to prevent any possible lapse in services, the contractor shall have personnel on board, during the 14-calendar day phase-in. During the phase in period, the Contractor shall become familiar with performance requirements in order to commence full performance of services on the contract start date for the PWS task areas described in Section 5.

1.6.17.1 The Contractor shall follow its Phase in plan submitted as part of their proposal and keep the Government fully informed of status throughout the Phase in period. Throughout the phase-in it is essential that attention be given to minimize interruptions or delays to work in progress that would impact the mission. The Contractor must plan for the transfer of work control, delineating the method for processing and assigning tasks during the phase-in periods.

o Phase-in: The Contractor shall submit a detailed phase-in plan to include start-up activities that may be required to transition to full operational capability upon conclusion of the transition period.

The Contractor shall:

o Provide a detailed transition methodology in logical sequence to ensure a smooth transition of all tasks/subtasks of the contract without interruption or degradation of service levels;

o Provide a timeline for completion of the phase in; and o Identify associated risks and issues and risk mitigation strategies that show how the contractor intent to transition.

1.6.18 Contract Management: The contractor shall establish clear organizational lines of authority and responsibility to ensure effective management of the resources assigned to this requirement. The contractor must maintain continuity between the support operation at P&R (currently the Pentagon) and the contractor corporate offices.

The contractor shall establish processes and assign appropriate resources to effectively administer this contract. The contractor shall respond to Government requests for contractual actions in a timely fashion. The contractor shall have a single point of contact between the Government and contractor personnel assigned to support this contract. The contractor shall assign work effort and maintain proper and accurate time keeping records of personnel assigned to work on this requirement.

1.6.19 Subcontractor Management: The contractor shall be responsible for any subcontract management necessary to integrate work performed on this requirement and shall be responsible and accountable for subcontractor performance on this requirement. The prime contractor shall manage work distribution to ensure there are no OCI considerations. Contractors may add subcontractors to their team after notification to the KO and/or TM and COR. It is the responsibility of the awardee to check subcontractors CAGE Code status and are not debarred from working on federal contracts.

PART 2

DEFINITIONS & ACRONYMS

2. DEFINITIONS AND ACRONYMS:

2.1. DEFINITIONS:

2.1.1. CONTRACTOR. A supplier or vendor awarded a contract to provide specific supplies or service to the government. The term used in this contract refers to the prime.

2.1.2. CONTRACTING OFFICER. A person with authority to enter into, administer, and or terminate contracts, and make related determinations and findings on behalf of the government. Note: The only individual who can legally bind the government.

2.1.3. CONTRACTING OFFICER'S REPRESENTATIVE (COR). An employee of the U.S. Government appointed by the contracting officer to administer the contract. Such appointment shall be in writing and shall state the scope of authority and limitations. This individual has authority to provide technical direction to the Contractor as long as that direction is within the scope of the contract, does not constitute a change, and has no funding implications. This individual does NOT have authority to change the terms and conditions of the contract.

2.1.4. DEFECTIVE SERVICE. A service output that does not meet the standard of performance associated with the Performance Work Statement.

2.1.5. DELIVERABLE. Anything that can be physically delivered but may include non-manufactured things such as meeting minutes or reports.

2.1.6. KEY PERSONNEL. Contractor personnel that are evaluated in a source selection process and that may be required to be used in the performance of a contract by the Key Personnel listed in the PWS. When key personnel are used as an evaluation factor in best value procurement, an offer can be rejected if it does not have a firm commitment from the persons that are listed in the proposal.

2.1.7. PHYSICAL SECURITY. Actions that prevent the loss or damage of Government property.

2.1.8. QUALITY ASSURANCE. The government procedures to verify that services being performed by the Contractor are performed according to acceptable standards.

2.1.9. QUALITY ASSURANCE Surveillance Plan (QASP). An organized written document specifying the surveillance methodology to be used for surveillance of contractor performance.

2.1.10. QUALITY CONTROL. All necessary measures taken by the Contractor to assure that the quality of an end product or service shall meet contract requirements.

2.1.11. SUBCONTRACTOR. One that enters into a contract with a prime contractor. The Government does not have privity of contract with the subcontractor.

2.1.12. WORKDAY. The number of hours per day the Contractor provides services in accordance with the contract.

2.1.12. WORK WEEK. Monday through Friday, unless specified otherwise.

2.2. ACRONYMS:

CFR Code of Federal Regulations COR Contracting Officer Representative DD Form 254 Department of Defense Contract Security Classification Specification DOD Department of Defense EM Enterprise Management Directorate FAR Federal Acquisition Regulation KO Contracting Officer

OCI Organizational Conflict of Interest ODC Other Direct Costs PIPO Phase In/Phase Out POC Point of Contact PRS Performance Requirements Summary PWS Performance Work Statement QA Quality Assurance QAP Quality Assurance Program QASP Quality Assurance Surveillance Plan QC Quality Control QCP Quality Control Program TE Technical Exhibit TPOC Technical Point of Contact WHS Washington Headquarters Services

PART 3

GOVERNMENT FURNISHED PROPERTY, EQUIPMENT, AND SERVICES

3. GOVERNMENT FURNISHED ITEMS AND SERVICES:

3.1 Government Responsibilities and Furnished Information

3.1.1 Government Responsibilities

• Review and approve all POAMs, plans, methods, processes, surrounding this effort prior to the commencement of work.

• Assist contractor with scheduling an initial project kick off meeting with stakeholders.

• Ensure the appropriate DoD and government personnel participate in the kick-off meeting and program review processes.

• Provide the contractor with applicable policies, plans, and studies regarding voluntary education and compliance measures.

• Assist the contractor with policy clarification when needed.

• Provide access to DoD and Service specific liaisons to facilitate data gathering.

• Serve as the primary liaison with internal and external stakeholder groups for program communications.

• Procure the required software and licenses to support the non-PECS and Correspondence Management capability development.

3.1.2 Government Furnished Information

• Data related to the Voluntary Education Program such as total enrollment, participating institutions, expenditures, completion rates, attrition rates, PECS complaints, and other information deemed necessary for successful implementation of the ICP. Note:

This information could include data to which privacy laws apply. All handling of such materials will be in accordance with applicable statutes and policies to include the handling of confidential and sensitive data/information in a manner consistent with requirements of the Privacy Act.

• DoD MOU requirements matrix and detailed information outlining the applicable compliance requirements under the ICP, to include official interpretations of relevant policies and guidance.

• Defined frameworks and program documentation for the DoD VolEd Institutional Compliance Program

• Compliance Data Collection Tools and associated instructions for use, scoring, and evaluation. Note: all government furnished information related to this PWS is solely for use in this particular work. Further, the government owns all methods, information, and data created under the ICP and retains the initial denial authority for all products and information under this PWS.

• Existing draft updated policy language and other materials to support policy revisions.

3.2 Services: The government will provide basic services to phones, desks, utilities, information technology, and general office supplies) while working in Government facilities.

3.3 Facilities: Basic facilities such as work space and its associated operating requirements (i.e., phones, desks, utilities, information technology, and general office supplies) will be provided while working in Government facilities. Tele-workers will only use government furnished equipment to remotely access the WHS network.

3.4 Equipment: The Government will provide will provide basic services to phones, desks, utilities, information technology, and general office supplies) while working in Government facilities. Tele-workers will only use government furnished equipment to remotely access the WHS network.

PART 4

CONTRACTOR FURNISHED ITEMS AND SERVICES

4. CONTRACTOR FURNISHED ITEMS AND RESPONSIBILITIES:

4.1 General: The Contractor shall furnish all supplies, equipment, facilities and services required to perform work under this contract that are not listed under Section 3 of this PWS.

4.2. Materials: NA

4.3. Equipment: NA

PART 5

SPECIFIC TASKS

5. SPECIFIC TASKS: The contractor shall execute requirements in accordance with the tasks outlined in paragraph 5.1 through 5.9 for DoD VolEd ICP Support Services.

5.1. Basic Services (DoD VolEd): The contractor shall provide DoD Voluntary Education Support Services, to include technical, administrative, and professional services, for the purpose of implementing the ICP.

5.1.1 Compliance and Evaluation Program Management

The contractor shall develop and conduct efficient and effective compliance program and evaluation management. This includes the management and oversight of all activities performed by contractor personnel, including subcontractors, to satisfy the requirements identified in this Performance Work Statement (PWS). The contractor shall identify a Program Manager (PM) by name who shall provide management, direction, administration, quality control, and leadership of the execution of this TO. This task shall include the development of key planning documents (i.e., Program Management Plan, Evaluation and Analysis Plan), as well as a set of required project activities (i.e., project kickoff, annual data collection kickoff), and the support of continuous program and process improvement. (Option years only).

5.1.2. Program Planning and Management

The contractor shall create and establish a Program Management Plan to stand up and manage all aspects of an operational compliance program to support DoD VolEd in ensuring that educational institutions are actively abiding by the DoD MOU, POE, and DODI 1322.25 compliance and policy development/review requirements. The PMP deliverable shall include details on how the contractor will perform program management and administration, program risk management, program communications, team organization and staffing management, deliverable delivery and quality assurance review processes, and continuous program/process improvement and transformation, used by the contractor in support of the program. The PMP will be delivered for government review and feedback within 30 days from the scheduled Project Kick-off Meeting. The PMP is an evolutionary document that the contractor shall, at a minimum, update annually for government approval. The contractor shall work from the latest Government-approved version of the PMP.

At a minimum, the contractor shall ensure that the Program Management Plan include the following sections:

• Program Management and Administration Methods

• Staffing Management Plan

• Master Schedule of Program Activities

• Program Communications Plan

• Program Risk Management

• Quality Assurance Plan

• Program Improvement Plan

5.1.3. Evaluation and Analysis Plan

The contractor shall develop and implement an Evaluation and Analysis Plan specifying their technical approach and methodology for supporting the evaluation and analysis of institutional compliance in support of the DoD VolEd ICP framework and objectives.

This plan will detail the contractor’s formalized approaches to compliance evaluation and management, risk-based analysis methodology, data collection and management, application of industry and government best-practices, as well as the inclusion and support of applicable technical standards and governmental policies (e.g., GPRA, GAO’s 2012 Designing Evaluations Report, AEA, GAO’s Internal Controls, etc.). The Evaluation and Analysis Plan will be delivered for government review and feedback within 45 days from the scheduled Project Kick-off Meeting. The Evaluation and Analysis Plan is an evolutionary document that shall be, at a minimum, updated annually for government approval. The contractor shall work from the latest Government-approved version of the Evaluation and Analysis Plan.

At a minimum, the Evaluation and Analysis Plan will include the following:

5.1.3.1. The contractor shall document their formalized methodologies, plans and approaches to implementing and supporting data collection and analysis for the ICP. The plan will detail how their approach will be executed during the given contract year, to include a detailed schedule of data collection and analysis activities.

5.1.3.2. This plan will need to identify the required data and information to support the compliance evaluation and analysis process, as well as the contractor’s methods for effectively and securely managing collected data on learning and workforce development providers. The contractor shall apply processes to provide for secure data collection and storage and ensure the proper safeguarding of data in compliance with Privacy Act and applicable secure data handling standards. The contractor shall conduct quarterly data quality checks on all data received and managed to support the DoD VolEd ICP evaluation and analysis effort.

5.1.3.3. The contractor shall provide a defined approach for conducting risk-based analysis, as well as methods for random sampling. This will include how those methods will be operationalized to identify and prioritize what institutions will be included for evaluation within a given contract year.

5.1.3.4. The contractor shall include a Data Collection Instrument Deployment and Logistics plan, specifying processes that will be followed for finalizing, testing, deploying, and supporting collection of external data, web-based checklists, and forms that will be deployed under the DoD VolEd ICP. Prior to deployment, the contractor shall apply these processes to conduct data testing and verify educational institutions and compliance analysts are able to use and complete the tools and that the data is properly and accurately collected.

5.1.3.5. The contractor shall update this plan for government approval on an annual basis; to include refinements based upon lessons learned and identified program/process improvement opportunities.

5.1.4. Data Collection and Analysis Kick-off Meeting

The contractor shall schedule and conduct an annual Data Collection and Analysis Kick-off Meeting within 60 days from the scheduled Project Kick-off Meeting at the location designated by the Government, which may be either in the national capital region or conducted virtually. The meeting will involve reviewing the contractor’s prescribed Evaluation and Analysis approaches, plans, processes, to include plans and timelines for conducting data collection and analysis for a given contract year. At a minimum, the attendees shall include all Key contractor Personnel, DoD VolEd government representatives, and other relevant Government personnel as required. The contractor shall provide the following at the Kick-Off meeting:

5.1.4.1. Data Collection and Analysis Kickoff Presentation

5.1.4.2. Evaluation and Analysis Plan, to include Data Collection Instrument Deployment and Logistics Plan

5.1.5. Continuous Program and Process Improvement

The contractor shall support continuous program and process improvement through the formalized capture of lessons learned to identify and implement refinements in support of the DoD VolEd ICP. The contractor shall apply a defined approach to continuous process improvement to identify and incorporate applicable best practices from across government and industry to improve the effectiveness and efficiency of the compliance program. The contractor’s approach to continuous program and process improvement shall be documented within the PMP and include at a minimum the following:

5.1.5.1. Defined approach and methodology for continuous program and process improvement

5.1.5.2. Quarterly capture and documentation of formalized lessons learned pertaining to the compliance program framework, supporting methods and tools, and associated processes

5.1.5.3. Annual program evaluation and continuous program / process improvement report that summarizes lessons learned, identifies opportunities for improved program effectiveness and efficiency, and recommendations for improving program communications and training of stakeholders

5.1.5.4. Updating and refinement of relevant program and evaluation management plans, as well as supporting processes and procedures to incorporate identified program and process improvements

5.1.5.5. , the contractor will review and recommend approaches that integrate a review of Service-level policies, processes, and programs into DoD’s Compliance Program. As each Service is responsible for administering the VolEd program, a fully effective VolEd compliance program will review Service-level policies and procedures in addition to oversight of educational institutions. The review will examine policy linkages across the enterprise and estimate the degree to which Service-level VolEd programs are supporting DoD VolEd’s strategic objectives, as well as leverage data and data integration, interoperability, and management as well as best practices of ICP’s continuous program and process improvement efforts. The contractor will deliver a range of analytical approaches and implementation strategies for Service-level review processes, along with descriptions of the data and information that could be required to implement such processes. The contractor shall first assess the current environment, in terms of researching the existing policies.

Implementation of the DoD VolEd ICP is based on executing a logical series of steps that will employ multiple data collection instruments, compliance analyses, strategic communications, and collaboration with educational institutions. The resultant outcome of these activities will be a set of recommendations for the institutions and opportunities for them to improve their level of compliance with the tenets of their MOU.

5.2.1 Select Institutions

The first step in each annual ICP cycle is to select a subset of 250 institutions from the overall population to participate in the annual assessment cycle. This will be done using a combination of risk-based analyses, random selection, business rules regarding institutions repeating their participation, and special selections, if applicable.

5.2.1.1 Risk-Based Analyses

The…

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