REQUEST FOR INFORMATION

September 10, 2021

Issued by GSA OAS Office of Internal Acquisition

This is a Request for Information (RFI) from the interested vendors solely for marker research purpose.  No proposals/offers/quotations should be submitted in response to this RFI.

Interested vendors shall submit their corporate capabilities statement that includes information on the experience performing similar requirements for the federal and non-federal customers and current personnel that had performed the tasks set forth in the draft Statement of Work below. No proposals/offers/quotations should be submitted in response to this RFI.

Submissions shall be made via email to cocacq.request@gsa.gov

GSA OFFICE OF THE CHIEF FINANCIAL OFFICER 

DRAFT STATEMENT OF WORK 

FOR PAYMENT RECAPTURE AUDIT SERVICES

BACKGROUND

The Office of the Chief Financial Officer (OCFO) of the General Services Administration (GSA) formulates financial management policies for the agency. These policies include: (1) implementing accounting standards and principles; (2) implementing internal control standards; (3) defining cash management operations; and (4) providing financial management support to the service and staff offices.

The OCFO is also responsible for (1) recording budget authority; (2) recording obligations and related disbursements; (3) collecting revenues; (4) financial statements and reports required by the Office of Management and Budget (OMB), and the Department of the Treasury; and (5) performance management measurements for financial systems.

Agencies are continually striving to comply with performance reporting Acts. These Acts include: (1) The CFO Act of 1990; (2) the Government Performance and Results Act of 1993; (3) the Government Management Reform Act of 1994; (4) the Federal Financial Management Improvement Act of 1996; (5) the Information Technology Management Reform Act of 1996; (6) the Debt Collection Improvement Act of 1996; and (7) Payment Integrity Information Act of 2019 (PIIA) (Public Law 116-117).  The Improper Payments Elimination and Recovery Act of 2010. The Improper Payments Elimination and Recovery Act of 2012 (IPERIA; Public Law 112-248) amended the Improper Payments Elimination and Recovery Act of 2010 (IPERA; Public Law. 111-204) and the Improper Payments Information Act of 2002 (IPIA; Public Law. 107-300). These laws require agencies to conduct payment recapture audits (also known as recovery audits) for each program and activity that expends $1 million or more annually if conducting such audits is  cost-effective. In addition, agencies are required to complete a separate, annual report to the Office of Management and Budget (OMB) and Congress, that describes any recommendations identified by the payment recapture audit on how to mitigate conditions giving rise to overpayments, and any corrective actions the agency took during the preceding fiscal year (FY).

Guidance on the implementation of Recovery Auditing is presented in the Circular OMB A-123, Appendix C. The Reporting requirements of Recovery Auditing are defined OMB Circular A-136. Guidance for Executive Order 13520: Reducing Improper Payments Appendix C, Part III.

OBJECTIVE

This Statement of Work (SOW) requires the Contractor to support the GSA Office of the Chief Financial Officer in the examination of Accounts Payable (AP) and contract processes to identify overpayments and under deductions that are recoverable from commercial vendors. The period of performance of this contract will be May 27, 2021 to May 26, 2022 and may be renewed annually for four additional years. This SOW requires the Contractor: (1) to identify lost funds due to overpayments; (2) work with Federal Shared Service Provider (FSSP), USDA both Financial Services Divisions to finalize all claim collections to vendors in accordance with the Debt Collection Improvement Act of 1996; (3) define the reasons for the  

overpayment; (4) develop suggestions and/or observations for preventing future overpayments, and (5) report the results to GSA Management. The Contracting Officer’s Representative (COR’s) for this contract is Phyllis Lam, and the alternate COR is Jeff Bowman (BGI).

3. SPECIFIC TASKS

Task 3.1 Attend Project Kick-off Meetings

Upon contract award, the Contractor shall review appropriate background information of the AP and contract processes. The kick-off meeting will include appropriate GSA project staff and other relevant personnel to discuss the AP and contract evaluation and clarify project expectations. The Contractor shall come prepared to: (1) request additional information needed to accomplish tasks in this SOW; and (2) discuss the concept for accomplishing the remaining SOW tasks.

3.1.1 Entrance Conferences and Exit Conferences

Each recovery audit starts with an Entrance Conference. Contractor will coordinate with the COR to conduct the Entrance Conference for each region. This meeting will be held before the audit is conducted.  During the Entrance Conference, the contractor will describe the audit process to the regional stakeholders, and management buy-in is obtained. After all questions are answered and any concerns are addressed, the contractor starts the recovery audit.  After the audit is completed, the Contractor will coordinate with the COR to conduct the Exit ConferenceAt the Exit Conference, Contractor will present the results of the audit, and potential claims to the Region. 

Task 3.2 Obtain In-Depth Knowledge of Federal Shared Service Provider, USDA, FW & KC Financial Services Division

Attachment 1 describes the Financial Services Divisions (USDA) to be evaluated under this SOW. To gain a thorough knowledge of the Financial Services Divisions, the Contractor shall: (1) meet with relevant project staff; (2) review additional documentation as required; and (3) visit the Financial Services Divisions as needed. The Contractor shall provide to GSA the consolidated documentation gained through the review of GSA’s disbursement processes.  This documentation should identify the processes used for each type of payment, relevant systems and key controls. GSA will provide the Contractor with existing documentation from internal reviews of these processes.

Task 3.3 Prepare Project Plan for Recovery Audit

Based on the results of Task 3.1 and Task 3.2, the Contractor shall prepare and deliver a Recovery Audit Evaluation Project Plan at the 20th day of the beginning of every period of performance. The Evaluation Project Plan can be viewed as a plan for conducting a detailed audit of AP and contract processes. Initial delivery of the Project Plan shall be delivered in the form of a draft. The Contractor shall incorporate the GSA’s comments into the final document. The Evaluation Project Plan should include, at a minimum, the following subtasks:

Develop a description of AP process(es) to be evaluated;

Develop a description of Contract process(es) to be evaluated;

Develop a strategy for identifying lost funds including, but not limited to, (a) the review of utility payments and (b) the review of Recovery Act payments;

Identify, Calculate, and Recommend Debts for Government Posting;

Establish an Electronic Record (in a format defined by GSA) to track claims;

Categorize errors;

The requirements for each subtask are discussed below.

Develop a Description of AP Process(es)

The description of the AP process(es) to be evaluated shall include a description of: (1) process inputs, (2) activities performed within the processes including systems used and key controls, (3) process outputs. The description of AP processes should define the processes performed in the Financial Services Divisions under evaluation (see Attachment 1). GSA will provide the Contractor with existing documentation from internal review of these processes.

3.3.2 Develop a Description of Contract Process(es)

The description of the contract process(es) to be evaluated shall include a description of: (1) process inputs, (2) activities performed within the processes including systems used and key controls, and (3) process outputs. The description of contract processes should define the processes performed in the Financial Services Divisions under evaluation (see Attachment 1).

Develop a Strategy for Identifying Lost Funds

The strategy for identifying lost funds should address all tasks required to identify GSA’s lost funds due to overpayment. At a minimum, these tasks include: (1) develop plan to be used for auditing the AP processes, (2) acquire and verify the electronic/paper files in the possession of the Financial Services Divisions (USDA), and GSA Contracting Officer or delegate; (3) reconfigure financial data into format required to conduct the audit; (4) develop criteria and guidelines for analyzing discrepancies; (5) review invoice processing procedures; and (6) outline the audit process. The Contractor shall provide GSA with the attribute test plan used to evaluate the accuracy of payments for each payment type.

Audit Process

The audit process shall include pulling documents and analyzing discrepancies between invoices, purchase orders (when available from the Financial Services Division (USDA) and the actual GSA payments. GSA and the Contractor will determine a mutually agreeable method for obtaining the required documents to be reviewed. The GSA will provide access to the Contractor for pulling the documents to be reviewed and the Contractor shall pull the appropriate documents and information to be reviewed. Examples of other audit tasks and subtasks include: (1) reviewing paid invoices to assure correct computation and tariff rates; (2) comparing receiving documents (when available) to amounts paid; (3) reviewing similar invoices for duplicate payments; (4) reviewing invoices for improper tax payments; (5) reviewing invoices for improper transportation charges (excluding those items normally audited by the GSA Office of Transportation Audits); (6) reviewing contract files to identify contractual payment discrepancies, and review leases to ensure the lessor is not passing on improper utility payments, and (7) identifying payments to an ineligible recipient (i.e., debarred contractors).  The audit process will be in compliance with GSA policy and directives.

Identify, Calculate, and Recommend Debts for Government Posting

The Contractor shall identify all lost funds, discrepancies, improprieties and shall calculate the proper amount to be collected, in a form of a claim. The Contractor shall provide a list of recommended debts  

to be posted by GSA into the agency’s accounting ledger. The contractor will only submit claims that are $500 or greater. This is the material threshold provided by GSA as cost-beneficial to the government to defray the cost of setting up a claim.  The Contractor is encouraged to submit all claims to GSA for consideration regardless of claim amount.

For each claim amount recommended, the Contractor shall:

Provide documentation justifying that a debt is owed to GSA.

Capture the accounting classification used on the overpayment, i.e., these data elements include, but are not limited to, fund code, organization code, budget activity, general ledger, object class, cost element, Pegasys Document Number, ACT number, and function code; this accounting classification must be provided to GSA Finance (FSSP) for each claim submitted to Finance and/or GSA Contracting offices. The contract shall apply to the table of organization provided by GSA to identify Portfolio, Business line and Program/Office associated with each claim.

All proposed claims based on suspected overpayments must be submitted to the appropriate GSA Contracting Officer in accordance with 41 U.S.C. § 605(a) of the Contract Disputes Act. The contracting officer shall have the final say in pursuing any claim under a contract. GSA will review and verify any claims within 60 days in accordance with current GSA policy.

Recommend the posting of the debt to GSA.

The contractor must report to the GSA and GSA’s Office of the Inspector General credible evidence of fraud or vulnerabilities to fraud, and conduct appropriate training of contractor personnel on identification of fraud.

Establish an Electronic Record to Track Claims

The Contractor shall establish an electronic record with approval from the contracting officer’s representative or contracting officer to track all debt identification, and collection activity. The minimum required information for this record will be defined by GSA. The record must track each debt from posting through collection of final payment or debt closeout.  GSA also uses this data for the OMB Improper Payments Reporting.  The claim data must comply with all requirements of the Debt Collection Improvement Act (DCIA) of 1996.

The contractor will provide details of outstanding claims and collected claims.  In addition, the contractor will provide a report to the COR upon request.

Categorize Errors

To analyze errors resulting in overpayment of AP, the Contractor shall categorize each GSA overpayment into error classes. The Contractor shall record the error associated with each debt to generate AP performance statistics and related information.

Error Classes

Error classes include but not limited to: (1) invoice containing incorrect

mathematical calculations; (2) incorrect payment of invoice; (3) multiple payments of one invoice; (4) multiple invoices for a single charge due to different invoice numbers; (5) multiple invoices for a single charge due to multiple addresses; (6) multiple invoices for a single charge with inconsistent product description; (7) multiple invoices for a single charge due to inconsistent dates; (8) invoice containing improper taxation; (9) invoice containing improper transportation charges; (10) non- receipt of product contained in the invoice; (11) cash discounts; (12) open credits (which are postings to vendors’ accounts receivables in excess of billed amounts); (13) contract type errors; (14) incorrect utility rate class; and (15) incorrect application of correct utility rate class.

Identification of Root Causes

Contractor must identify root causes of improper payments to avoid future mistakes.  An example of error measurement includes documentation and administrative errors caused by the absence of supporting documentation necessary to verify the accuracy of a payment or by incorrect inputting, classifying, or processing of payments.

Task 3.4   Implement the Project Plan for Evaluating AP and Contract Processes

Upon GSA approval of the final Project Plan for Evaluating AP and Contract Processes, the Contractor shall implement the Project Plan. The Project Plan shall be an evolutionary document that is subject to revision throughout the project. The Contractor shall, as needed, will update the project plan as directed by the GSA. The details of the AP Evaluation and process may be changed, as long as the Project Plan remains within the scope of this contract.

The contractor’s quality control program must comply with the requirement of the contract.

The Contractor shall prepare an internal Quality Control Plan (Business Plan) to ensure: (1) the highest level of performance and compliance to be achieved from the identification of debts through the processing of payments; (2) all information is tracked to ensure resolution of all accounts.

The Quality Control Plan shall define quality control procedures to assist the Contractor in: (1) monitoring the efficiency of the collection procedures; (2) monitoring the daily effectiveness of collection operations; (3) defining quality standards that will be established and applied; (4) recording how problems are identified and managed; (5) ensuring compliance with the DCIA; and (6) identifying how backlogs will be reduced.

Task 3.5 Develop Recommendations for Enhancing the AP Process and Contract

Payment Processes

The Contractor shall review the error analysis data, and the results of the evaluation, to develop recommendations for enhancing the AP process(es) and contract process(es) as necessary.

Task 3.6 Prepare Status Reports

The Contractor shall prepare and deliver written annual reports to the GSA Central Office, Internal Control Division (BGI). The Contractor shall be prepared to brief the GSA management on the contents of the report. At the minimum, contractor shall prepare report to include the number of claims submitted, the amount of claims submitted, the number of claims approved by GSA, the

amount of claims approved by GSA, the actual recovery amount, pursuing collection amount, and the dollar amount and the cumulative amount of claims reviewed by the Contractor. GSA will approve the reporting formats. Recovery Audit reporting requirements may be found in the OMB Circular A-136.

The Contractor shall prepare and deliver, no later than October 30th of each year, a Recovery Audit Annual Management Report covering the prior fiscal year ending September 30th. The report will document the audit process, and data of the recovery.

Task 3.7 Performance Measures and Quality Expectations

Completeness: Deliverables will be 100% complete based on the incorporation of GSA provided comments. The results of all recovery activity shall be included in a single report. 

Accuracy: Deliverables shall be 100% accurate based on the incorporation of GSA provided comments.

Timeliness: All deliverables will be on time and within schedule.