16-Q-0070_Q_and_A_8-24-2016.docx

Solicitation # SP4703-16-Q-0070 ASL Interpreter Service Questions and Answers

Q1. Typical cancelation policies would allow for billing of the complete job duration for cancelations made with less than 2 business days notice.

A1. In the Performance Work Statement, Section E-9 Cancellations: If any time requirement/task is cancelled by the Government, the Government is responsible for payment of cancellation fees for any requirement/task cancelled less than 2 business days before the scheduled start of the requirement/task (Standard 2 hour minimum paid for general requests, 4 hour minimum paid for any requirement/task scheduled for 8 hours or more) Ex. 1 Assignment for Friday at 0900-1000 is scheduled/assigned/confirmed. COR/COTR cancels the assignment on the Wednesday prior to the assignment at 1300. Contractor may bill a 2 hour minimum for the last minute cancellation (less than 2 business days).

Ex. 2 A week long training has been scheduled/assigned/confirmed to begin on Monday at 0800. Contractor receives notice that the training with 2 interpreters assigned has cancelled the Thursday prior at 1100. The contractor may invoice for 4 hours for each interpreter assigned for Monday and Tuesday of the training week. This equates to 16 total hours can be invoiced for the cancellation in lieu of the full 80 hours the assignment would have incurred.

In Ex. 1 the requirement is for one hour of service. The bulk of our requirements fall in this category. In E-6 of the PWS, a one-hour requirement is billed at a 2-hour minimum (covering interpreter travel). So a cancellation with less than 2 business days’ notice would be billed at a 2-hour minimum (industry standard).

In Ex. 2, week long trainings are not a common occurrence. When they do occur, they typically do not cancel last minute. Most often what will happen is that they will end early and the contractor will continue to bill as scheduled. (Ex. A week long 0800-1600 request- the training may end early each day at 1500 or may end half a day on Friday- Contractor will bill for the full time) Some of the tradeoff here for contracting with the Government is that you will be the sole provider for the award you receive. Regularly billing a 2 hour minimum for a 1 hour requirement will be most typical and will be to the benefit of the Contractor. Paying a half day for 2 days for 2 interpreters each of a cancelled week-long requirement is a fiscally responsible action for the government for a service that was not rendered but requested. It is a good faith measure on an infrequent occurrence.

Any submission of rates on the solicitation should take this into consideration and should be made to cover your operational requirements.

Q2. Section E-9 provides a cancellation policy that is not in line with industry standards. Industry standards allow for full payment to the interpreter for any cancellation less than two full business days in advance. When any entity does not follow industry standard, reputable agencies will usually not make an offer and they almost always end up working with substandard agencies and interpreters. Will the Government change this requirement to state, “If any time requirement/task is cancelled by the Government, the Government is responsible for payment of the full originally scheduled time for any day of a requirement/task cancelled less than 2 business days before the scheduled start of the requirement/task.”

A2. At this time, the Government is not considering a language change to reflect this type of statement. The Government also has a responsibility for good stewardship of the taxpayers money. This issue can be re-examined if necessary depending on the results of the solicitation.

Q3. Section E-10 implies that the vendor will not be paid for the difference in time changes, even if made with less than 2 business days’ notice if an assignment time changes. If an assignment is moved from 0900-1100 to 0800-1000 as provided in the example, it is entirely possible that the original interpreter will not be able to accommodate the change in time, which means the vendor will need to pay the original interpreter the full scheduled time, and locate a replacement interpreter who will also bill the vendor for the full time. In situations where the originally scheduled interpreter is able to make the time adjustment, s/he will bill from the new start time to the originally scheduled end time, in accordance with industry standards. Will the Government change this section to read, “Assignment is scheduled for Thursday 0900-1100. On Tuesday afternoon the contractor receives notice that the requirement/task has changed to 0800-1000. If the originally scheduled interpreter can make the adjustment for an earlier start time, then the invoice would reflect 1 hour of emergency rate/fee (0800-0900) and two hours of regular rate/fee 0900-1000. If the contractor must replace the originally scheduled interpreter, the invoice would reflect 2 hours of emergency rate/fee and 2 hours for the original assignment at the regular rate/fee.”

A3. At this time, the Government is not considering a language change to reflect this type of statement. The Government is offering to increase the payment for this change by allowing the emergency rate to be billed for the hour change, and the standard rate for the second hour. The Government also has a responsibility for good stewardship of the taxpayers money. This issue can be re-examined if necessary depending on the results of the solicitation. Additionally, the Government is not determining the agreements that you the contractor make with your staff or subcontractor. The terms that you choose to follow on your end is solely between you and the staff/subcontractor. Your rate submission for hourly and emergency rates should take this scenario into consideration.

Q4. Asked in 2 ways:

Also mileage and or portal to portal fees are standard in some of these locations and a fixed hourly rate would need to incorporate the worst case scenario for coverage and would be better if actual cost was allowed for travel.

and Under section I, the requirement states that travel to and from the location will not be reimbursed. Much of this work is located in areas where Portal to Portal and mileage fees are standard. Will the Government change the requirement to allow for Portal to Portal and/or mileage fees where necessary, to be billed as incurred with pre-approval by the COR?

A4. While this statement is correct, our contract must consider all locations. In an effort to streamline the billing process, we are asking contractors to consider your actual costs in the worst case scenarios and to submit your fees based on that situation. Your hourly and emergency rates should reflect what the market you serve would expect and should include your operational expense. If you are bidding for a local area and for an area outside of your local area, your rates submitted do not have to be the same. If you expect to subcontract for the outside area, you should submit your pricing based on that market and your operational expense. This contract may be awarded to multiple vendors so you may receive some or all of your areas you have bid on depending on what is received once the solicitation window has closed and the submissions have been evaluated.

Q5. Section E-8 states that an interpreter may need to be replaced within 24 hours. With the limited resources available in the areas served by this contract, this may often not be possible. Can the Government clarify if the inability to find a replacement in such a short time would result in poor ratings of the vendor’s performance?

A5. A one-time incident is not going to result in a poor performance rating. A recurring issue with the same situation will have an impact on the Contractor’s rating. The COR on the contract is an RID Certified Interpreter (CT & CI) with an MAI from Gallaudet and over 10 years’ experience in the field and is well aware of the scarcity of resources. The COR will evaluate each situation on an individual basis, but our primary objective is to ensure that accessible communication is achieved for the Government consumers. It is not just in the best interest to the Government to ensure this objective is met, but it is also in the best interest of the Deaf and Hearing consumers whose livelihoods depend on this access.

Q6. In section E 6 it states that interpreters must arrive 30 minutes prior to the scheduled assignment. By Federal regulations we are not permitted to require interpreters to arrive prior to the paid time of the assignment. Based on the Federal wage and hour requirements, is the Government willing to add an additional 30 minutes to the beginning of assignments to allow for this early arrival?

A6. The 30 minutes is stated because the Interpreter must gain access to the base in which the requirement occurs. Each base has different procedures for gaining admittance. If the interpreter cannot get to the designated location timely, if this is a pattern this will result in a poor performance rating for the contractor. As stated previously, the terms of work agreement between the contractor and their staff/subcontractor is solely outside of the Government’s purview. This is another situation in which the contractor needs to consider their terms with the staff/subcontractor and the Government’s stipulation and determine the hourly and emergency rate to account for this scenario.

Q7. Can the Government please provide historical information based on the past year on the types of requests usually made by DLA: How many requests at each location are for 3 hours of service or less? How many requests at each location are for 6 hours or more?

A7. Refer to below chart:

*Ogden has a requirement for 3 days a week, 4 hours a day for staff support. This only requires one interpreter as the services are on-call, as needed in the window of time.

The remaining sites on the contract (Cherry Point, NC; Jacksonville, FL; North Island, CA; Philadelphia, PA; Warner Robins, GA) do not currently have a requirement for services. In the event of a new hire, the initial coverage may be high due to initial training needs, but would then level off. If someone transfers to these areas that needs services, we would need to fulfill the requirement as well. Conversely, if the requirement ends due to retirement, transfer, etc. then the requirement would no longer be needed.