Private Collection Agency

New Q & As under revised SOW/RFQ

1. Q The revised RFQ sections B.5.1 and B.5.2.2. sent 11/14/08 added an administration resolution payment alternative that would allow ED to pay $150 for all administrative Resolutions. However, our concern is not that the fee is a single rate, but rather that is will be higher than the GSA approved fees for most contractors. If ED exercises this option, most contractors will be limited by the GSA contract amount and not be able to receive the proposed fee. Will ED consider revising this proposal to conform with the AR Unit approach?

A. The RFQ sections referenced, along with SOW section 3.4, have been adjusted. The new RFQ and SOW versions sent out 11/18/08 indicate that under the second alternative pricing for administrative resolutions, all administrative resolutions would be paid on the basis of 3 AR units.

2. Q Section H.5(b) and a later reference in section H.6(e) seem to have confusing if not conflicting statements. Section H.5(b) reads "Approximately nine months after the first placement of accounts, the Government shall conduct the first CPCS to measure the relative performance of each PCA contractor during the CPCS surveillance period. This first CPCS surveillance period will run from the first placement of accounts through September 30, 2009." [emphasis added]

Based upon this language, the current delay of the award and change in the RFQ for a 90 day implementation period, the first transfer of accounts could be made as late as March or April 2009. If this is the case, "9 months after the first placement of accounts" would indicate a period through December 2009 at the earliest. Is it ED's intent to keep the September 2009 date as steadfast date or was it the intent of ED to have a 9 month evaluation ramp up period with the specific evaluation date identified based upon the first transfer of accounts?

A. The RFQ section H.5 (b) has been revised to indicate that "several" months after the first transfer of accounts, ED plans on conducting the first CPCS evaluation. ED anticipates keeping the September 30, 2009 deadline as the end of the first CPCS surveillance period.

Please note: This question and answer addressed similar issues raised by different offerors.

3. Q Section 2.3.1. the second paragraph states: "Unrestricted" contractors shall provide ED the capability to remotely monitor all "collection calls" by accessing automated call recordings of collection calls through a secure web-based portal. However later in this section, paragraph 7 states: Remote call monitoring through agency phone systems must allow ED monitors the ability to listen to individual contractor staff or randomly listen to the next available call. We are asking that you please clarify if there is a preference to real time or recorded calls and if real time monitoring of next available call is the preferred or could be required, what protocol (i.e. web-based portal, VPN, etc) would be required.

A. Under remote call monitoring SOW section 2.3.1, ED is requiring all "unrestricted" PCAs to record calls (there is no option to substitute with real-time monitoring). However, small businesses have an option to record calls or use real-time phone monitoring for the first 2 years of the contract. After 2 years, the small businesses must also record all calls (option is removed). SOW section 2.3.1 paragraph 7 explains some real-time monitoring protocols for those PCAs allowed to use real-time monitoring (only the small businesses and only for the first 2 years), while the SOW section 2.3.1 paragraph 6 explains specific protocols for those PCAs required to record calls.

4. Q In the SOW section 3.2.A, we have noted that we are to verify " ,,, email address" in addition to other information. Currently, we do not receive this information from ED on the transfer file. Will this be added to the transfer file? Are we to acquire the email information and provide update to ED on the email address of the borrower to ED in daily update files we send to ED? If this is correct does ED anticipate changing the update file layout to accommodate this?

A. The e-mail address was added to take into consideration new borrower technology and increased avenues of communication. Although the e-mail address is not currently on the transfer file it may be added at a future time. Verification of an e-mail address will not be possible until the government's system can hold the data.

5. Q In the SOW section 5.1 Priority B, it appears that the first Physical Access Review is to be completed and submitted with the final version of the Disaster Recovery plan which is 30 days following the approval of the Draft Disaster Recovery plan by ED. After that initial submission of the Physical Access Review, subsequent Physical Access Reviews are to be done on an annual basis and submitted no later than the anniversary date of the Task Order Award. Is this correct or is there some other time table ED would prefer? Additionally in regards to the Physical Access Review, are the items to be audited, reviewed and validated those items identified in Section 6.2.4 Physical Security or are the requirements for the Physical Access Review located in some other document or circular mentioned within the SOW?

A. The SOW section 5.1 B (first reference of Physical access review under the disaster recovery plan) is referring to the PCAs' plan or procedures to conduct a Physical Access Review. As part of or with the final Disaster Recovery Plan submission (30 days after ED's approval of the draft), PCAs should submit their Physical Access Review procedures. The second reference under section 5.1 B labeled Physical Access Review is referring to the time frames of the actual Physical Access Review. The first review conducted by the PCAs must be completed within one year of the Task Order award and then annual thereafter (within one year from the previous review). In addition, ED will review and/or conduct their own physical access reviews while on-site. Please note that Physical Access Reviews are not intended to be labor intensive but a means of documenting basic safety and access measures to ensure protection of property, equipment, data, and staff.

Physical Access Reviews are general reviews of the physical working areas to ensure that building and workspaces conform to federal, state and local safety regulations including, but not limited to, fire suppression systems, fire extinguishers, exit signs and security measures, etc. Those areas listed in SOW section 6.2.4 are key areas, along with guidance from NIST 800-53 ("Physical and Environmental Protection" standards outlined in Appendix D and F) which will be used to help determine the audit processing details for this review. Additional information will be provided within the updated Agency Review Guide and future ED policy guidance.

6. Q Under SOW section 6.2.3 (c), is publication NIST 800-35 the correct reference for a description of security services for ED's purposes for the 2008 Collections Contract SOW ? If NIST 800-35 is not the correct reference for security services, will you advise us on the proper reference. Finally, if NIST 800-35 is the correct reference for security services as part of a Contingency Plan, will you consider adding that publication to the list of Special Publications in the revised SOW?

A. NIST 800-53 and 53A are the publications specific to security. In addition, SOW 6.2.3 (c) has been updated to be more descriptive of what we are looking for. The new language states..."include an executive overview of how the security processes will be maintained within the contingency plan to ensure continuous protection of PII data so that the PII data is not compromised, lost or breeched." Please note that it is still up to the contractor to decide how to create their contingency plan.