SECHQ1-14-R-0028_-_Revised_Solicitation_Body_Redlined.pdf

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SOW for EDGAR Modernization Business Process Re-Engineering

SECTION B - SUPPLIES OR SERVICES AND PRICE/COST

This is an Indefinite Delivery/Indefinite Quantity contract consisting of a two-year base period followed by three option years. Fixed price and labor hour task orders will be issued under this contract. For the base period, the SEC intends to exercise CLINs 0001, 0002, 0003, and 0004. At the completion of CLIN 0003, the SEC may exercise CLIN 0005 for follow-on support during the base period. At the completion of CLIN 0004, the SEC may exercise CLIN 0006 for follow-on support during the base period.

If option year 1 is executed, the SEC will execute CLIN 0007 and at least one of the other CLINs in the grouping. In conjunction with CLIN 0007, the SEC may exercise CLIN 0008, may exercise CLIN 0009, may exercise CLIN 0010, or may exercise any combination of CLINs 0008, 0009, and 0010.

If option year 2 is executed, the SEC will execute CLIN 0011 and at least one of the other CLINs in the grouping. In conjunction with CLIN 0011, the SEC may exercise CLIN 0012, may exercise CLIN 0013, may exercise CLIN 0014, or may exercise any combination of CLINs 0012, 0013, and 0014.

If option year 3 is executed, the SEC will execute CLIN 0015 and at least one of the other CLINs in the grouping. In conjunction with CLIN 0015, the SEC may exercise CLIN 0016, may exercise CLIN 0017, may exercise CLIN 0018, or may exercise any combination of CLINs 0016, 0017, and 0018.

Base Period – First 2 years or until tasks expire

CLIN Description Qty Unit Unit Price Total Price 0001 Program Management Labor Hour 0002 Business Process Re-Engineering

0002A Business Process Re- Engineering – Tier 1

TBD Process

0002B Business Process Re- Engineering – Tier 2

TBD Process

0002C Business Process Re- Engineering – Tier 3

TBD Process

0003 Electronic Disclosure Requirements and Process Review

Labor Hour

0004 Technical Review Labor Hour Optional Base Period Tasks (may be executed upon completion of base year tasks above)

0005 Electronic Disclosure Requirements and Process Review Support

Labor Hour

0006 Technical Review Support

Labor Hour

Option Period – Year 1 CLIN Description Qty Unit Unit Price Total Price 0007 Program Management Labor Hour

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0008 Business Process Re-Engineering 0008A Business Process Re-

Engineering – Tier 1 TBD Process

0008B Business Process Re- Engineering – Tier 2

TBD Process

0008C Business Process Re- Engineering – Tier 3

TBD Process

0009 Electronic Disclosure Requirements and Process Review Support

Labor Hour

0010 Technical Review Support

Labor Hour

Option Period – Year 2 CLIN Description Qty Unit Unit Price Total Price 0011 Program Management Labor Hour 0012 Business Process Re-Engineering

0012A Business Process Re- Engineering – Tier 1

TBD Process

0012B Business Process Re- Engineering – Tier 2

TBD Process

0012C Business Process Re- Engineering – Tier 3

TBD Process

0013 Electronic Disclosure Requirements and Process Review Support

Labor Hour

0014 Technical Review Support

Labor Hour

Option Period – Year 3 0015 Program Management Labor Hour 0016 Business Process Re-Engineering

0016A Business Process Re- Engineering

TBD Process

0016B Business Process Re- Engineering – Tier 2

TBD Process

0016C Business Process Re- Engineering – Tier 3

TBD Process

0017 Electronic Disclosure Requirements and Process Review Support

Labor Hour

0018 Technical Review Support

Labor Hour

Business Process Re-Engineering Tiers 1- 3 Tier 1 is equivalent to a small sized process, the criteria of which will be defined by the Offeror.

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Tier 2 is equivalent to a medium sized process, the criteria of which will be defined by the Offeror.

Tier 3 is equivalent to a large sized process, the criteria of which will be defined by the Offeror.

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SECTION C - STATEMENT OF WORK

While EDGAR has performed admirably over the years, it has grown in complexity and functionality over that time. This solicitation is the first phase of a larger multi-phase Modernization effort to update Electronic Disclosure at the SEC. This phase focuses on re-engineering the processes, reviewing the technology solutions currently deployed, and reviewing the electronic disclosure requirements and process that support electronic disclosure. This Business Process Re-Engineering (BPR) solicitation does not require development efforts, but is for pre-planning efforts to review and analyze the current environment and recommend improvements that lead to the elimination of complexities and redundancies. The outputs of this contract will be used by the SEC to make decisions and plan the design of a new modernized Electronic Disclosure model at the SEC, which will be implemented by separate contract(s).

C.1 Background

C.1.1 The Electronic Data Gathering, Analysis, and Retrieval (EDGAR) System The Securities and Exchange Commission (SEC) was created by the Securities Exchange Act of 1934 as an independent regulatory agency. The SEC administers statutes that protect the investing public by providing full disclosure of required SEC filings, regulating the nation’s securities markets, and policing and preventing fraud and manipulation in the securities and financial markets. A primary means of sustaining a fair and open market is to ensure full disclosure of corporate-related information.

With the increasing complexity and volume of filings under Federal securities laws in the 1970s and 1980s, the SEC realized that the existing paper filing system was inadequate to meet the objectives of the full disclosure program. To address the problem, the SEC initiated a pilot program in 1984 to investigate the feasibility of filing corporate information electronically. Based on the success of the pilot program, the EDGAR system was initiated as the Electronic Disclosure platform for the SEC. Congress authorized the development and implementation of an operational EDGAR system in 1987. The goals of EDGAR included: facilitating efficient filings and providing support for one-stop filing; enhancing the timeliness and availability of filings to the public; and increasing the effectiveness of SEC personnel in performing their review and auditing functions. The EDGAR system became operational in 1992.

EDGAR is a system developed to automate the filing, processing and dissemination of some 125 million pages of registration statements, reports and other filings received by the SEC each year. These submissions currently are received from over 28,000 registered entities and hundreds of thousands of individual filers.

Electronic Disclosure, of which EDGAR is the primary platform, has been in existence at the SEC for over 30 years. The current EDGAR manifestation has been in existence since 2001 with the exception of the addition of new hardware and software and a lot of new functionality. However, EDGAR is growing by leaps and bounds. Over the last 8 – 10 years, the number of filings made on EDGAR has tripled, submission size has more than doubled, and total data received has quadrupled without significant changes to the system, other than adding processor power.

EDGAR was designed as a stand-alone system to include all hardware, applications, and systems software. Contractor support services are currently being used for development of new functionality, systems operation and monitoring, and for hardware and software maintenance.

The major functions of the electronic filing life cycle supported by EDGAR are the following:

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• Preparation and submission by filers

• Receipt and acceptance by SEC

• Data storage and retrieval

• Data dissemination to the public

• Analysis and review by SEC staff

Goals and Objectives for the larger modernization effort, which are also important to this contract, can be found in Attachment J-1, “EDGAR Modernization Goals and Objectives”. A background description of the current EDGAR system, its use and operation is further defined in Attachment J-2, “EDGAR Submissions”, Attachment J-3, “EDGAR Architecture, Subsystems, and Services.” Figure C-1, “The EDGAR Worlds” on page C-3 describes the three phases of the EDGAR system.

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C.1.2 The Goals for EDGAR Modernization

Attachment J-1 consists of important information that will guide the execution of this contract. It is the Contractor’s responsibility to familiarize itself with Attachment J-1 and include the concepts in Attachment J-1 throughout their execution of this contract.

The set of objectives in Attachment J-1 that pertain to the larger Modernization of EDGAR are important to this task in the sense that any work performed and recommendations made by the contractor as part of the execution of this contract must NOT exclude, constrain, or conflict with any of the larger modernization objectives. They are listed in Attachment J-1 to clearly distinguish them from the requirements and objectives of this contract and to provide the contractor with a foundation by which their analysis must be bounded. Any recommendation, improvement, or decision made that may add risk or deviate from the objectives that pertain to the larger Modernization of EDGAR must be fully documented as part of this effort.

The main goals for the larger EDGAR modernization that also pertain to this contract are to:

• Reduce complexity (such as technical, rule, process, data, etc.),

• Reduce costs to the agency, such as:

o Staffing costs, o Equipment costs, o Development costs, o Operational costs, both business operations and Information Technology.

• Reduce costs and burden to the filing community while providing more services and assistance,

• Reduce costs and burden to the data provider community while providing more data in easier to use formats, and

• Seek greater advantages from automation for all EDGAR stakeholders than currently exist.

The SEC intends to pursue these main drivers through innovative ideas, solutions, and recommendations that will help revolutionize Electronic Disclosure at the SEC. Innovative thinking, with focus on the main goals, will reduce costs to the filing community, data provider community (and, in turn, the investment community), and the SEC. Here are some examples of topics that are on the table to be analyzed during the period of this contract to help reduce complexity and burden:

• Reduction in the number of form types,

• Reduction in the duplication of information collected,

• Reduction in the number of acceptable data formats,

• Simplification of the fee collection and balance management process, which, in turn, will help reduce complexity and resources spent on backend account management function,

• Review of the timing of filings, late filings, hardships, and deadlines to manage such inputs more efficiently or with automation,

• Integration of more commercial products to replace existing custom code, and

• Other innovative ideas that the contractor will bring to the table and that the contractor will identify in their interviews with stakeholders.

On the functional innovation side, the SEC intends to pursue improvements in input and output, communications between filers and SEC staff, and functional look and feel tailored to a better filer experience and investor experience. Listed below are some examples of innovative thinking in this area:

• A question and answer input mechanism. Currently, filers must know the appropriate form type when filing on EDGAR. This leads to many filings coming into the Commission using the wrong form type when a filer doesn’t know the exact form type and they guess incorrectly. Modernized

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EDGAR is envisioned to assist the filer by walking them through a series of questions that leads them to the correct form type. Of course, there will also be a path that allows more experienced filers to quickly traverse through the questions.

• A single use document. Currently, for some form types, such as 10-Ks, filers must create multiple document files with all of the same data to satisfy requirements for its use. One file is sent to the print shop to print glossy copies for shareholders. Another file is created for use on the company website. Another file is sent to the SEC for filing purposes. Each of these files has to be reviewed by attorneys, accountants, and corporate officers to ensure it is accurate and consistent. The SEC is anticipating the exploration of the concept of a single use document, where filers create one file to be reviewed by attorneys, accountants, and corporate officers that can be used to satisfy the formats for all three user groups.

• Mergers and acquisitions. Currently, the SEC does not link companies as they are purchased by or merge with other companies. Modernized EDGAR is envisioned to be able to trace the history of companies easily through the phases of its life cycle of ownership and affiliation.

• Automation and Analytics. Currently, EDGAR resembles a paper process that has been automated. It gathers, stores, and allows review of documents using computers as if they were paper, much like a large document library system. The SEC is anticipating that modernized EDGAR will take advantage of technology by performing analytics in real-time or near real-time as documents are coming into EDGAR, then routing them to the appropriate SEC staff for review or comment. Modernized EDGAR may store structured data instead of documents, where it makes sense, to allow better and more frequent analysis of that data, tailored output of the data, and better analysis for a company from one year to the next or for a number of companies grouped together for comparison. Better back end tools are envisioned to assist SEC staff in their review and comparisons as well, such as red-lining and exportation of the data.

The bullet lists in this section are not exhaustive. The SEC is looking for innovative ideas for its EDGAR Modernization from the successful Offeror. During this contract, contractors will be required to interview stakeholders who have a good understanding of and experience with electronic disclosure at the SEC on both the producing and consuming sides, as well as SEC staff who have a good understanding of the internal workings of how EDGAR helps them to do their jobs and how it might be improved to assist further.

C.1.3 Acquisition Strategy

This modernization acquisition is to support the SEC in making functional and business decisions that will affect the modernization of functionality for EDGAR related functions. This contract is not a development or implementation contract. It is a contract for analysis and recommendations. (A subsequent acquisition for implementation of EDGAR modernization is anticipated.)

C.1.4 Acronyms

ASCII American Standard Code for Information Interchange BPR Business Process Re-Engineering CF Division of Corporation Finance CI Configuration Item CIL Configuration Item List CLIN Contract Line Item Number CM Configuration Management CMM Capability Maturity Model

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CMMI Capability Maturity Model Integration CMP Configuration Management Plan CORBA Common Object Request Broker Architecture COTR Contracting Officer’s Technical Representative COTS Commercial Off The Shelf CPU Central Processing Unit CRD Central Registration Depository DAB Data Administration Board DBA Database Administrator DBMS Database Management System DERA Division of Economic and Risk Analysis DML Data Maintenance Log DR Deficiency Report DR Disaster Recovery DSD Database Specification Document ECP Engineering Change Proposal ECR Engineering Change Request EDGAR Electronic Data Gathering, Analysis, and Retrieval EDR Enterprise Data Repository EFH Except Federal Holidays ENF Division of Enforcement ERS EDGAR Requirements Subcommittee EVM Earned Value Metrics FAR Federal Acquisition Regulation FBI Federal Bureau of Investigation FH Federal Holidays FRD Functional Requirements Document GAO Government Accountability Office GFE Government Furnished Equipment GFI Government Furnished Information HA High Availability HCCB Hardware Change Control Board HML Hardware Maintenance Log HTML HyperText Markup Language ICR Internal Change Request MSR Monthly Status Report NARA National Archives and Records Administration NDI Non-Developmental Item O&M Operations and Maintenance OCIE Office of Compliance Inspections and Examinations OCOI Organizational Conflicts of Interest

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ODC Other Direct Costs OFM Office of Financial Management OMB Office of Management and Budget OPM Office of Personnel Management PCAOB Public Company Accounting Oversight Board PCR Programming Change Request PDS Public Dissemination Service PDS Public Dissemination Subsystem PM Program Manager PMC Performance Metrics Committee PMP Program Management Plan PMR Program Management Review QA Quality Assurance QMP Quality Management Plan RFI Request For Information RFP Request for Proposals RFRD Release Functional Requirements Document RRP Rolling Replacement Plan SAD Systems Architecture Document SCCB Software Change Control Board SDLC Systems Development Life Cycle SDP Systems Development Plan SEC Securities and Exchange Commission SEPG Software Engineering Process Group SLOC Source Lines of Code SME Subject Matter Experts SML Software Maintenance Log SPR Software Problem Report SSP System Security Plan T&M Time and Materials T&M Division of Trading and Markets TI Technical Instruction TIS Technical Instruction Statement TMP Transition Management Plan TMS Text Management Subsystem TO Task Order WBS Work Breakdown Structure

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C.2 Objectives The overall objective of the disclosure process, and thus the EDGAR Modernization effort at the Commission, is as provided by the securities laws and regulations to promote the full disclosure of material information regarding the activities of publicly traded corporations and to support SEC regulatory responsibilities. Under that objective for modernization, the overall objective of this contract is to analyze the current processes, Electronic Disclosure Requirements and Process environment, and technical environment to make recommendations and suggest improvements so that the SEC can simplify and improve its electronic disclosure processes and technology for its filers, SEC staff, data consumers, and investors.

C.2.1 Objectives for This Contract

1 – Simplify the Electronic Disclosure Requirements and Process surrounding EDGAR

• Recommend improvements to the existing rule structure and organization.

• Recommend improvements to synchronize the rule writing process with the software development process.

• Recommend improvements in governance and enterprise coordination for the existing rule writing system being administered by multiple Divisions within SEC.

• Recommend improvements to the interfaces for rule writing.

• Ensure recommendations directly relate to the delivery of solutions that are technically sound, efficient, and effective.

2 – Simplify the technical complications that exist today in EDGAR

• Recommend improvements over existing technical issues so that the issues are not repeated in future rule writing and solution delivery.

• Identify and recommend resolutions to complexities that exist in the current implementation.

• Identify and recommend resolutions to design deficiencies and deployed issues that should be simplified and/or removed.

3 – Improve the business processes that are identified for Business Process Re-Engineering

• Diagram and improve current business processes that are involved in the Commission’s electronic disclosure and review activities.

• Look for enterprise-wide economies of scale and functional similarities that would improve business process flow and cut down on coding differences between business functions.

• Develop enterprise-wide business functions.

4 – Simplify and Improve cross-cutting processes

• Recommend changes to synchronize the rule writing process with the release development process to avoid implementation risks to schedule, budget, and functionality.

• Ensure problems/issues identified in one task are vetted completely in the other tasks (for example, a technical problem/issue identified may have roots in the rule writing process (Electronic Disclosure Requirements and Process Review) and/or the business process (Business Process Re-Engineering), therefore proper coordination amongst all three tasks is paramount.)

C.2.2 Overarching Strategy For Determining Modernization Requirements

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This contract represents the first phase in determining the requirements of the larger Modernization effort.

In order to achieve the goals of this phase, which are to reduce complexity, scope, duplication, and improve processes, the SEC wishes to procure services for the following tasks:

• Business process re-engineering for filer and SEC staff,

• Electronic Disclosure Requirements and Process Review of rules surrounding EDGAR functionality,

• Technical Review of current trouble spots,

• Support to assist with educating and vetting the Electronic Disclosure Requirements and Process

Review results/recommendations amongst SEC staff, and

• Technical Review Support to assist with educating and vetting the technical review results/recommendations amongst SEC staff.

The prime activity of this contract (to be completed during the base period) is to provide the groundwork analysis and recommendations for SEC decision-making to shape the future modernization effort. The results of the prime activity must be explained to and vetted by stakeholders throughout the SEC for consideration and decision-making. The optional CLINs (0005 and 0006, and corresponding CLINs in the option periods) assist the SEC in the education and vetting process and the facilitation of decision-making that will shape the future of EDGAR modernization. The contractor must frame the recommendations and create documents and slide decks so that they are usable by the SEC in the education and vetting process and for decision-making.

• The Contractor is to supply program, policy and technical knowledge and experience to the SEC.

While no prior experience with the SEC is necessary, the requirements call for experience and/or demonstrated expertise with federal rules, IT systems similar to EDGAR, and electronic disclosure. The SEC is not requiring SMEs on SEC business functions, rule writing processes, or internal SEC particulars. SEC SMEs will be available to provide details on internal SEC operations.

Tackling complexity, scope, duplication, and process issues requires a ground up approach, starting with the underlying business processes that the system was created to support. For EDGAR, this includes the following:

• SEC staff functions from the Divisions of Corporation Finance (CF), Investment Management (IM), Enforcement (ENF), Trading and Markets (T&M), Economic and Risk Analysis (DERA) and the Office of Compliance Inspections and Examinations (OCIE) and the Office of Financial Management (OFM), and

• External functions such as Filer, Filing Agent, Software Developer, and Public Disseminator (to include data brokers, end users, data extractors, etc.)

For each of the processes identified, the successful Offeror shall:

• Document the current process,

• Identify drivers for improvement,

• Identify and analyze improvements, including policy changes,

• Document the improved process and any policy change recommendations,

• Document cost savings associated with deciding to implement the recommendations, and

• Develop a Concept of Operations (each process needs to be addressed, however, multiple processes may be combined).

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Executing this for each functional process will give the SEC the necessary documentation to make decisions on improving those processes and incorporating those improved processes into the functional baseline of a new EDGAR system. The development and implementation of a new EDGAR system is not within the scope of this contract.

Another output of this contract will be a discussion of the Cost Savings envisioned for the modernization effort. Costs surrounding this effort are directly related to the decisions that are made concerning the process, policy, and technical improvements identified in the review documentation. The contractor deliverable will outline potential costs savings based on recommendations and improvements that are envisioned for the system. Depending on which recommendations the SEC approves and which process changes the SEC accepts, the savings could be substantial. For example, if the SEC accepts bold changes analyzed and outlined in the review documents, then the savings are going to be huge. If the SEC only embraces minor changes, then it will reap that much less in savings, flexibility, and agility. However, potential cost savings attached to recommendations will allow the SEC to have valuable information at their fingertips when deciding the next generation of EDGAR.

Costs for the new system are going to be dependent on the documentation from this task as well as the decisions that are made on policy, process, and technical changes as well. Once the decisions are made, the SEC will have a much better picture of what the new EDGAR functionality is going to be. The document produced from this contract shall outline the potential savings/costs associated with the recommendations and improvements.

Once the BPR work is complete, the SEC will have what it needs to be able to shape the future system.

The technical, policy, and process drivers will have been identified, as well as alternatives, so that the SEC can make decisions on which changes to pursue and their priority. Once the decisions on technical considerations, policies, and processes are made, the SEC will begin to document the requirements for the larger modernization effort (which is not within the scope of this contract). Also, from the documentation prepared for this contract and the subsequent decisions made by the SEC, the SEC can begin to document the requirements and to determine the costs for the new modernized system (which is also not within the scope of this contract).

C.3 Scope The scope of this contract encompasses the following major areas:

• Program Management across all subtasks,

• Business Process Re-engineering of business processes,

• Electronic Disclosure Requirements and Process Review of the rules and laws supporting electronic disclosure,

• Technical review of problem areas currently embedded in the EDGAR system,

• Electronic Disclosure Requirements and Process Review support to assist with educating and vetting findings with SEC management and staff and continuation of analysis and research, and

• Technical Review support to assist with educating and vetting findings with SEC management and staff and continuation of analysis and research.

C.4 Task Requirements The Contractor shall be responsible for completing all tasks of this contract. The Contractor shall comply with all related requirements of Section C. The following sections provide specific task requirements.

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C.4.1 Modernization Concepts Along with Attachment J-1, the following modernization concepts must be consistently considered during this contract so that the decisions and recommendations that are made during this contract follow these concepts. The Contractor shall consistently consider each concept when making decisions and recommendations during this contract. Work product resulting from this contract (contractor and SEC supplied) will add new concepts to this list that are intended to enhance the modernization effort.

The SEC is looking for innovative ideas and recommendations on a variety of topics, both introduced by the SEC and the Contractor. Some of the topics under current discussion include the following:

C.4.1.1 Technical Modernization.

• Expand the use of virtualization, modular design, and the ability to provide a more secure, hardened environment to improve availability;

• Modernize the Public Dissemination Service;

o Migrate data format from SGML to XML;

o Review and improve the current architecture;

o Review and improve the current model for providing data fairly to all;

o Review and improve the current financial model for subscription services;

• Simplify the Entity and Filing models currently used;

• Design a solution for returning the file number database field to a single use field;

o Look for other database violations or issues ripe for improvement during re-design;

C.4.1.2 Business Modernization.

• Create an easy to use, question and answer-like interface for filers to guide them to form types with a simple question tree;

o Include a fast path directly to the form type for mature filers;

o Analyze current form types to improve current model;

Minimize the number of form types;

Look for English names to replace current form type nomenclature;

• Update the path for software developers to file SEC-determined formatted filings;

• Incorporate pay.gov as a payment mechanism for filers;

• Use currently identified improvements to the fee subsystem already underway;

• Merge XBRL pre-viewer on www.sec.gov with the EDGAR filing process;

• Merge report website with EDGAR Workstation (or create a single secure website for all

EDGAR data reporting);

• Develop XML on-line solutions for those form types that lend themselves better to tagging;

• Develop on-line solutions for attaching camera ready print copies of documents;

• Include mergers and acquisition functionality;

• Incorporate new Federal unique identifiers (Legal Entity Identifier (LEI));

• Put all check boxes in the header and store those values in the database tables;

• Develop SEC staff alerts for lateness, anomalies, peak information, etc.;

o Create a dashboard.

o Graphical view of submission life cycle o Graphical view of review life cycle

• Develop filer alerts for lateness, upcoming events, deposits, etc.;

• Provide SEC staff ability to send notifications to filers; and

• Provide SEC staff ability to easily compare original filings with amendments (Redlining).

http://www.sec.gov/

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C.4.1.3 Technology Investigations.

Explore the integration of the following technologies as part of the Technical Review:

• XML repositories and management systems to handle an ever-increasing number of XML documents;

• XBRL validation engines to process XBRL filings;

• Simplification of data formats (the number and type);

• Linkage of historical data and modernized data (backwards compatibility), especially with respect to simplifying the data formats; and

• Analytics in flight to support the review process and alert SEC staff of anomalies.

• Outsourcing the form submission process similar to the IRS.

C.4.2 Program Management (Base Period and Option CLINs) (CLINs 0001, 0007, 0011, 0015) The Contractor shall plan, monitor, coordinate amongst tasks, and control technical performance, cost, and schedule for all tasks. The Contractor’s program management responsibilities include all activities necessary to ensure the accomplishment of timely and cost effective support performed in accordance with standards of quality that equal or exceed the requirements contained in this Statement of Work.

At a minimum, the Contractor’s approach to program management shall include:

• A trained, experienced PM staff focused on ensuring adherence to schedules and resources and communicating effectively amongst its tasks and with clients, customers, and staff.

• A trained, technically-proven staff, current in the systems, technologies, and services employed by the SEC.

• A high degree of awareness of advances in information technology having potential impact on electronic disclosure computing environments as well as the impact and advantages of such advances in information technology.

• An effective program for problem identification, assessment, escalation to the COR, mitigation, and resolution to ensure that positive and timely actions, at all levels of the Contractor’s organization, occur to address known and anticipated problems.

• An effective program for risk identification, assessment, escalation to the COR, mitigation, and resolution to ensure that positive and timely actions, at all levels of the Contractor’s organization, occur to address known and anticipated risks.

• An effective program for timely, flexible response to SEC needs as determined by the COR.

• An effective program for communicating and coordinating amongst all of the tasks in this contract to ensure decisions made in one task are coordinated throughout.

• A feedback process to monitor, assess, and act upon those aspects of contract performance requiring corrective action or redirection or otherwise needing attention by either the Contractor’s or the SEC’s staff.

• A quality management program that:

• Provides for quality management of overall contract performance, including relationships with subcontractors and vendors, and all other contractual obligations;

• Monitors the performance of work and reports problems, issues, risks immediately to the SEC

COR;

• Coordinates the performance of work amongst the tasks of the contract and prevents duplication and idleness;

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• Establishes and maintains clear and effective procedures to ensure the quality of the products delivered to the SEC;

• Ensures delivery of all products in accordance with the requirements of this Statement of Work and individual Technical Instructions; and

• Includes resource-loaded schedules reporting progress against base-lined schedules and risk mitigation.

• Planning and coordination of all contract activities.

• A plan and schedule of hardware, software, licenses, personnel, and budgetary resources with notification to the SEC COR on a regular basis of any hardware, software, licenses, personnel and budgetary variances.

• An effective program coordinating resources and knowledge and structure for the many concurrent tasks underway.

C.4.2.1 Organization and Responsibilities.

The Contractor shall establish and maintain a program management organization that manages, supervises, and oversees the activities of all Contractor support personnel, including subcontractor(s) and vendor(s). The Contractor shall establish a program management organization in accordance with the intended allocation of work, technical approach, reporting requirements, and management practices. The Contractor shall appoint a Program Manager (PM) who will be responsible for the Contractor’s performance on all tasks. The PM shall be the primary interface between the COR and the PM’s corporate management on all matters relating to the program. The PM is key personnel on the contract.

The Task Managers for each process and each sub-task are also key personnel on this contract.

C.4.2.2 Program Management Plan (PMP).

The Contractor shall develop, maintain, and execute a PMP which shall include the policies, procedures, standards, instructions, forms, or checklists needed to establish project organization, structure, authority, roles, responsibilities, and internal reporting relationships; define interfaces between the Contractor and subcontractors (if applicable); establish reporting requirements; define a WBS; and perform project oversight and control. The Contractor shall provide an initial PMP with the response to this Statement of Work. The SEC will provide comments on this initial PMP within fifteen (15) business days after contract award. The Contractor shall revise the initial PMP in response to SEC comments and deliver the revised PMP to the SEC within fifteen (15) business days after receiving comments. The Contractor shall update the PMP at least semiannually thereafter.

It is the responsibility of the Contractor to create, manage, and maintain sub-contractual and teaming relationships. Sub-contractual relationships will be approved by the SEC and any changes to sub-contractual relationships must be approved by the SEC. All key personnel that are subcontractors are bound by the key personnel requirements.

The Contractor shall deliver the Program Management Plan as part of the proposal. It will consist of the living document from which the Contractor manages the program. The PMP shall contain the policies, procedures, schedule (with high level milestones outlined), work breakdown structure, organization, and methodologies necessary for conducting the BPR1 as well as the technical and electronic disclosure requirements/process reviews. The PMP shall be updated 60 days after award and shall be updated every 6 months after that to incorporate any changes or to update concepts, processes, etc.

1 The contractor must identify any differences in methodology between Tier 1, Tier 2, and/or Tier 3 processes.

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The PMP should also contain the following:

• roles and responsibilities (teams, subs, all parties),

• assumptions, constraints, risks and risk mitigation, and dependencies,

• resource management,

• subcontractor management,

• quality management,

• document change management, and

• personnel management (including training, orientation, and reach back).

C.4.2.3 Program Management Review (PMR).

The SEC will schedule PMRs on a quarterly basis, at a minimum, and as otherwise needed as determined by the COR. The first PMR will occur no later than the second quarter after start of performance. Each PMR shall address: contract financial status, contract schedule status, proposed changes to the system, issues, risks, technical accomplishments, planned technical activities, and risk mitigation activities. The PMRs shall be conducted at the SEC Headquarters or as determined by the SEC.

The Contractor shall prepare an agenda in conjunction with the SEC Project Manager, develop necessary presentation materials and supporting data, and provide the key personnel necessary. The Contractor shall document the proceedings of the PMR and shall deliver the PMR Minutes and Action Items to the SEC within five (5) business days after the PMR. The Contractor shall document the status of all completed and outstanding action items resulting from the PMP in Monthly Status Reports.

C.4.2.4 Monthly Status Reports (MSR).

The Contractor shall provide a written MSR, which contains sufficient detail to identify the progress, status, problems, dependencies, and similar issues for all tasks. The MSR shall list each task, who performed the work under each task, and the hours expended by each staff person working on the task.

The Contractor shall report on internal process improvement activities and status in the Quality Management section of the MSR. The Contractor shall report summary information for each task and significant findings/work performed. The Contractor shall deliver the MSR to the COR on the fifteenth (15th) business day of each calendar month. The Contractor shall construct the MSR with a three (3) month window of events, documenting the past month’s accomplishments, identifying current month’s activities, and identifying planned activities for the coming month.

C.4.2.5 Weekly Status Report (WSR).

The Contractor shall provide weekly status report briefing slides to the COR and present the contents of those slides in a weekly status meeting.. The main purpose of this meeting is to bring the team (SEC and Contractor) together to go over current status, highlight future events, make decision, discuss pain points, analyze topics, coordinate activities, and other oversight activities. The contents of the meeting and report shall be:

• Action item list to be carried over from meeting to meeting;

• Minutes from last WSR meeting;

• Program status;

o Accomplishments;

o Radar screen;

o Risks;

o Issues;

o Special notes; and o Plans;

• Staff changes and badge status;

• Administrative status;

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• Payment status;

• Billing status;

• Tasks status;

o Accomplishments;

o Risks;

o Significant findings;

o Decisions needed to be made

And background information in order to make the decisions;

o Issues; and o Plans;

• Deliverable schedule and status;

• Process and Quality activities; and

• Special projects status.

These weekly meetings are the one time during the week that both the Contractor and the SEC are in the same room together. These meetings are intended to be working sessions between the SEC management team and the Contractor. At this meeting, the Contractor must be prepared to provide necessary information to the SEC so that maximum coordination and participation are efficient.

C.4.2.6 Coordination, Communication, and Cooperation Amongst Tasks Some of the topics and functions that are part of this contract WILL span one or more CLINs. The Contractor shall ensure that the appropriate coordination, communication, and consistency exist between working teams so that these cross-cutting topics are developed sufficiently to incorporate all of the details from each area seamlessly. In other words, topics that span multiple areas should not be stove piped into one of the above areas of concern. They should be treated as enterprise topics that receive the appropriate consideration from all areas to fully address the topic. Thus, the need for coordination, communication, and cooperation is necessary to ensure that each topic is fully fleshed out giving the SEC all of the information that is needed down the line to make fully informed decisions.

The Contractor shall ensure that:

• All tasks are coordinated;

• Interviews and time allotted with SEC Division staff and other SMEs are minimized;

• Information is shared amongst all tasks;

• Decisions made are shared immediately and become part of each task;

• Decisions made are reflected in all task deliverables;

• Areas that span tasks are fully coordinated;

• Ideas and concepts from Appendix J-1 are imbedded in all tasking and coordinated; and

• Technical writing and deliverables are coordinated and minimized.

C.4.2.7 Deliverables At the end of this contract, all of the deliverables shall make up one large report, titled Re-Imagining Electronic Filing, Analysis, and Disclosure at the SEC. Each of the deliverables called out in this contract shall constitute a portion (chapter) of the overall report and be incorporated into the report. Once a section of the report is delivered, it may require update. The Contractor is responsible to ensure that each section of the report is updated to reflect the most current information.

At the end of the contract, the Contractor shall deliver one complete report for all of the output in this base task. As sections/chapters are completed, the Contractor shall deliver drafts to the SEC according to the Contractor’s schedule. Once the SEC has had an opportunity to review and comment on drafts, the Contractor shall deliver final drafts according to its schedule. The SEC has 10 business days to review

Page 22 of 7273 SECHQ1-14-R-0028 final drafts. Briefing slides that allow SEC or the Contractor to brief SEC staff must be delivered along with the final drafts as well.

The report must be severable so that the SEC can split it up into the pieces that are valuable to a particular audience. For example, the SEC may want to provide a Division with only the information that pertains to that Division, such as the Introduction, Background, Scope, Executive Summary, Overarching Themes, Division Processes, and the Business Case. The Contractor can improve upon this report outline by providing its alternative as part of this solicitation process; however, the Contractor must ensure that all of the pertinent sections and material is present in their alternative outline.

Contractor shall provide SEC with a draft of each section of the report and provide 10 business days for review and comment.

The report must be created and maintained so that, upon completion of this contract, the SEC has the ability to update, maintain, and/or append changes to the report.

C.4.2.7.1 Outline of Re-Imagining Electronic Filing, Analysis, and Disclosure at the SEC

1. Introduction (1-2 pages)

2. Background (1-2 pages)

3. Scope (1 -2 pages)

4. Executive Summary (an encapsulation of the Electronic Disclosure Requirements and Process Review, Technical Review, and Overarching Themes, and Business Case with a short discussion of the Business Process Re-Engineering tasks)

5. Overarching Themes (the up-front part of the report that discusses themes that are common to all of the rest of the document.);

For each SEC Organizational Unit

6. Division of Corporation Finance For each process

a. Business Process Re-Engineering: Process __________

i. As Is;

ii. To Be;

iii. Gap Analysis;

iv. Recommendations;

7. Division of Investment Management For each process

a. Business Process Re-Engineering: Process ____________

i. As Is;

ii. To Be;

8. Division of Trading and Markets

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a. Business Process Re-Engineering: Process ____________

i. As Is;

ii. To Be;

9. Division of Enforcement

a. Business Process Re-Engineering: Process ____________

i. As Is;

ii. To Be;

10. Other SEC Offices and Division Processes (A separate section for each)

a. Business Process Re-Engineering: Process ____________

i. As Is;

ii. To Be;

11. Electronic Filer

a. Business Process Re-Engineering: Process ____________

i. As Is;

ii. To Be;

12. Disseminators

a. Business Process Re-Engineering: Process_____________

i. As Is:

ii. To Be:

12.13. Concepts of Operations2

a. To cover all new functions

13.14. Business Case3

a. Alternatives analysis

2 For each process or subset of processes, Contractors may create a single Concept of Operations for all of the processes as one deliverable chapter or they may create a Concept of Operations for each process or some subset of processes as part of the Business Process Re-Engineering effort consistent with their methodology, however, the Contractor shall declare which path it intends to take in their proposal.

3 The Business Case should focus on the savings associated with the improvements and recommendations made throughout the report so that the SEC can use that information when prioritizing and making decisions about those recommendations and improvements.

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14.15. Electronic Disclosure Requirements and Process Review (the details of the Electronic

Disclosure Requirements and Process Review task);

a. As Is;

b. To Be;

c. Policy Improvements;

d. Recommendations;

15.16. Technical Review (the details of the Technical Review);

a. As Is;

b. To Be;

c. Technology Improvements;

d. Recommendations;

16.17. Appendices (if necessary)

C.4.2.7.2 Meetings.

The Contractor shall conduct and/or participate in the meetings indicated in the “Title” column of Table F-3. The person indicated in the “Point of Contact” column shall be responsible for coordinating each meeting. The Contractor shall be prepared to hold the meetings periodically, as indicated in the “Frequency” column. Specific agendas for each meeting shall be determined in consultation with the Contracting Officer’s Representative (COR). The Contractor is responsible for the meeting minutes.

Title Point of Contact Frequency

Weekly Status Contractor Program Manager Weekly

Monthly Status Review COR Monthly

Program Management Review COR As needed

Interviews Contractor Program Manager As needed

Working Meetings Contractor Program Manager Weekly or as needed

Table C-1. Contract Meetings

C.4.2.7.3 Maintained Work Products.

As directed by the COR, the Contractor shall maintain the work products listed in Table F-2 as part of the execution of all tasks. These work products should be stand-alone so that they can be altered independently of the main report (then incorporated back into the main report). The process flows and concepts of operations should be part of the main report.

Title Frequency

Sub-task schedule Per sub-task

As Is process flows Per process

To Be process flows Per process

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Title Frequency

Concepts of Operations To be determined by Contractor

Meeting minutes Per meeting

Interview meeting notes Per interview

Weekly Status briefing slides Per meeting

Monthly Status briefing slides Per month

Program Management Review briefing slides Per review

Table C-2. Maintained Work Products C.4.2.8 Quality Assurance/Control Management

C.4.2.8.1 Quality Control. The Contractor shall develop and maintain an effective quality control program to ensure services are performed in accordance with this SOW. 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.

C.4.2.8.2 Quality Assurance. The Government shall evaluate the Contractor’s performance under this contract in accordance with the Quality Assurance Surveillance Plan (QASP). 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 following items should be identified in the plan:

1. The project processes subject to quality assurance.

2. The quality standards and stakeholder expectations for that process.

3. The quality assurance activity – e.g., quality audit or reviews, code review – that will be executed to monitor that project processes are properly followed.

4. The name of the person responsible for carrying out and reporting on the quality assurance activity.

C.4.2.8.3 Quality Assurance and Control Plan. The Contractor shall prepare the Quality Assurance Surveillance/Quality Control Plan (QACP) within 15 days of award. After COR acceptance of the QACP, it will become the document of record. Three copies of a comprehensive written QACP shall be submitted to the COR within 5 working days when changes are made thereafter.

C.4.2.8.4 The Contractor shall perform each task in full compliance with the approved QACP.