Veterans Affairs



FedBizOppsSources Sought Notice*******CLASSIFICATION CODESUBJECTCONTRACTING OFFICE'S ZIP-CODESOLICITATION NUMBERRESPONSE DATE (MM-DD-YYYY)ARCHIVE DAYS AFTER THE RESPONSE DATERECOVERY ACT FUNDSSET-ASIDENAICS CODECONTRACTING OFFICE ADDRESSPOINT OF CONTACT(POC Information Automatically Filled from User Profile Unless Entered)DESCRIPTIONSee AttachmentAGENCY'S URLURL DESCRIPTIONAGENCY CONTACT'S EMAIL ADDRESSEMAIL DESCRIPTION ADDRESSPOSTAL CODECOUNTRYADDITIONAL INFORMATIONGENERAL INFORMATIONPLACE OF PERFORMANCE* = Required FieldFedBizOpps Sources Sought NoticeRev. March 2010RBudget & Insurance Model Internal Control20006VA101V-17-N-014604-30-201730N541611Department of Veterans AffairsVeterans Benefits AdministrationOffice of Acquisition1800 G. Street N.W.Washington DC 20006Department of Veterans AffairsContract Specialist Ross ByrneDepartment of Veterans AffairsVeterans Benefits Administrationross.byrne@REQUEST FOR INFORMATION (RFI) – SOURCES SOUGHTINTRODUCTIONTHIS IS NOT A SOLICITATION. The Department of Veterans Affairs (VA) is issuing this Request for Information. This RFI is issued solely for information and planning purposes only and does not constitute a solicitation; therefore, do not submit a quote. There is no obligation for the Government to acquire any products or services described in this RFI. No funds have been authorized, appropriated, or received for this effort. The information provided may be used by the Department of Veterans Affairs (VA), Veterans Benefits Administration (VBA) in developing its acquisition strategy and to revise the Statement of Work (SOW). Interested parties are responsible for adequately marking proprietary, restricted or competition sensitive information contained in their response. Only electronic responses to this RFI will be accepted. The Government will not pay for any time expended or information submitted in response to this RFI. Eligibility in participating in a future acquisition does not depend upon a response to this notice.BACKGROUNDThe Government has a requirement for a Contractor to provide model risk management tasks on the VBA mortgage loan budget models and associated documentation. The model risk tasks shall be consistent with risk management principles from applicable supervisory guidance and industry practice; for example, Federal Financial Accounting and Audit Technical Release (TR) 6. The Contractor shall the tasks to resolve audit findings by the Veterans Affairs (VA) external financial auditor 2016. The Contractor shall also assess the amount of the VGLI Reserve as of 30 June 2016, including the underlying assumptions, and provide an opinion as to whether the VGLI Reserve can be lowered while supporting the liabilities of the program, and without increases to the current premium scale, provided that holding a lesser reserve would not violate generally accepted actuarial principles and practices.NAICS: 541611 - Administrative Management and General Management Consulting Services – Financial Management Consulting Services.QUESTIONS AND CRITICAL CONSIDERATIONS FOR INTERESTED CONTRACTORSResponses are solely treated as information for the Government to consider. Direct or Indirect costs incurred in response to this RFI are at the expense of the vendor, not the Government. In accordance with the Federal Acquisition Regulations, responses to this notice are not offers and cannot be accepted by the Government to form a binding contract. Any contract that may be awarded will not be based on information received or derived from this RFI, but rather on the outcome of a subsequent competitive process. It is requested that all vendors interested in participating in this effort note their interest by responding to the areas identified in the “Company Details", and "Capabilities Statement”, sections below. COMPANY DETAILSThe page limit for responses to this section is 1 page.Provide company point(s) of contact information (name, email address, address, telephone, and fax numbers).Identify if your company are any of the following business concern statuses (include all that apply): Small Business (SB); Certified Small Business Administration (SBA) 8(a) firm; Small Disadvantaged Business (SDB); Service-Disabled, Veteran-Owned Small Business (SDVOSB); Veteran-Owned Small Business (VOSB); Economically Disadvantage Women-Owned Small Business (EDWOSB); Woman-Owned Small Business (WOSB); Historically Underutilized Business Zone (HubZone) Small Business; Large Business.Provide contracting vehicles your company holds, such as GSA schedules.CAPABILITIES STATEMENTThe page limit for responses to this section is 5 pages.Provide an overview of your firm’s capabilities to fulfill the requirements of the SOW, to include organizational and staff capability and experience. Provide a brief narrative summary of your technical approach to meet VA’s high-level requirements in the attached draft SOW. Provide an examples of development and use of predictive and actuarial models; econometric analyses including maximum likelihood estimation, simulation modeling, database analysis.Describe your experience in combining and assimilating multiple data sources, including VA, public use, and non-public data and development of comprehensive, combined analytic files.???? Provide up to two (2) contracts that your company has performed for the same or similar requirement and of comparable size, complexity and scope. Describe scope and similarities and differences as pertinent. Identify tools that were part of your solution, emphasizing econometric, actuarial, and simulation tools. Please be specific and provide a complete reference to include: contract number, contract title, description, period of performance, and award amount; as well as identify whether you performed as a prime contractor, sub-contractor, teaming partner, or as a project manager.??? RESPONSE SUBMISSIONPlease submit responses via email to ross.byrne@ by 3:00 p.m. (ET), 30 Apr 2017. VA reserves the right to not reply to any emails, responses, and/or materials submitted.**DRAFT ** STATEMENT OF WORK GENERAL INFORMATIONTitle of Project: Budget & Insurance Model Internal Control Scope of Work: The Contractor shall provide all resources necessary to accomplish the deliverables described in the Statement of Work (SOW). HousingThe Contractor shall perform model risk management tasks on Veterans Benefits Administration (VBA) mortgage loan budget models and associated documentation. The model risk tasks shall be consistent with risk management principles from applicable supervisory guidance and industry practice; for example, Federal Financial Accounting and Audit Technical Release (TR) 6. The Contractor shall perform the tasks to resolve audit findings by the Veterans Affairs (VA) external financial auditor in 2016. InsuranceThe Contractor shall assess the amount of the Veterans’ Group Life Insurance (VGLI) Reserve as of June 30, 2016, including the underlying assumptions, and provide an opinion as to whether the VGLI Reserve can be lowered while still supporting the liabilities of the program, and without increases to the current premium scale, provided that holding a lesser reserve would not violate generally accepted actuarial principles and practices. The Contractor, their personnel, and their subcontractors shall be subject to the Federal laws, regulations, standards, and VA Directives and Handbooks regarding information and information system security as delineated in this contract. The C&A requirements do not apply, and Security Accreditation Package is not required. Background: Housing The contract work required is in response to the audit findings by the VA financial auditor. The auditor determined that:1) Lack of a defined and documented process for engaging and involving senior leadership outside of the Budget office for critical decisions and oversight over various modeling activities, including; model development, risk assessment, assumption development and review, and model validation.2) No evidence of management reviews of analysis of the model’s assumptions and outputs to include an actual estimate analysis.3) Models consistently show significant differences between the model forecasts and actual program performance that lead to concerns about the reliability of the model estimates.VBA needs the contract work completed to resolve the audit findings by September 2017.The VBA budget models’ objective is calculating annual estimates of federal loan subsidies for VBA housing program mortgages. The estimates are prepared through a joint effort between the budget, finance, and program offices at VBA. The mortgage programs issue federal loan guarantees (private sector is the lender) and direct loans (government is the lender) for the target borrowers. Most of the borrowers are Veterans, Servicemembers, and Reservists that rely on conventional 30-year fixed rate mortgages for home purchase and refinance borrowing activities. The housing loans rely on four loan budget financial models for subsidy estimation: Guaranteed Loans, Direct Vendee Loans, Direct Acquired Loans, and Loan Sale Securities (a guaranteed loan program). The models produce estimates for the following VBA functions:Financial reporting-loan liabilities and subsidy allowancesBudgeting-federal subsidiesLegislative proposal scoring-costs and benefitsFinancing account interest-U.S. Treasury flowsAll the financial models are implemented as spreadsheet models with macros (Visual Basic for Applications, VBA, codes). The spreadsheet models consist of multiple linked spreadsheets that display their four components: an administrative component, which shows headings, purpose, and macros; an information input component, which delivers assumptions and data to the model; a processing component, which transforms inputs into estimates; and a reporting component, which translates the estimates into useful business information. The components are tightly integrated with the workings of the government present value calculator tool and 10-year financial plan spreadsheets or database (MAX). The calculator tool and MAX database are requirements that are maintained by the Office of Management and Budget (OMB) with inputs from federal agencies; for example VBA. OMB and VBA senior management have oversight responsibility over all VBA loan financial models. That is, all VBA model assumptions and data are subject to OMB review and approval. The financial model outputs and reports are shared with the Congressional Budget Office (CBO) and financial auditors annually. Based on the above-mentioned VBA mortgage types, the financial model cash activities or categories are primarily as follows:Loan default claims and property expensesProperty sales proceeds, funding feesLoan disbursementsLoan unpaid principal balancesBorrower paymentsLoan sales proceedsOther transactions with the U.S. TreasuryThe existing models and their user guides and program and finance documents provide detailed information on these activities. The models’ key input assumptions and data are VBA historical cash flows, various interest rates, home price growth rates, loan production, and loan age. The sources of the input data are VBA, OMB, and somewhat the Federal Housing Administration, FHA, with no use of externally sourced data. The input data are transformed into estimates and business information using mathematics, statistics and computer code that form the financial models, based on guidance from TR6. Moreover, the choice, testing and safekeeping of the mathematics, statistics, and computer code in the models have evolved over 25 years. Similarly, the choice of inputs, calibration of the model, and related documentation has evolved (as evidenced by a model change spreadsheet). These choices represent the intellectual labor and assumptions of a few key people (government employees and external consultants) to create the existing budget model internal control structure. VBA external consultants performed an independent review of the models in 2012, and the government made subsequent model changes. The models were redesigned in 2007 with model audit in 2009 by independent consultants for risk management. Some related documents on model development, implementation, use, validation, governance and control are available. These documents and relevant supervisory guidance should be reviewed during model risk management work to improve model internal control structure. InsuranceThe Servicemembers’ Group Life Insurance (SGLI) and Veterans’ Group Life Insurance (VGLI) programs are administered by Prudential Insurance Company under the terms of a Group Life Insurance Policy and supervised by VA. SGLI was established in 1965 to provide term insurance protection to Servicemembers. VGLI became available in 1974 to provide for the conversion of SGLI to five-year term insurance after a Servicemember’s separation from service, and was made renewable for life in 1992. Veterans have one year and 120 days after separation to apply for VGLI without underwriting; however, if they apply beyond 240 days after separation, they must provide evidence of good health. The SGLI/VGLI programs are required by law to be self-supporting. VGLI premiums increase in five-year age brackets, but are capped at the age 75 rate of $4.60 per month per $1,000. The VGLI Reserve acts as a mechanism to pre-fund future premium deficiencies. There are two major drivers of the VGLI reserve. First, when a conversion privilege such as VGLI exists, one can reasonably expect that a disproportionate number of those in poor health will exercise it. This “adverse selection” by insureds results in mortality experience that is higher than standard. Consequently, VGLI premiums are not completely sufficient to cover the cost of claims and expenses during the early years after issue. Second, the capping of VGLI premiums at the age 75 rate essentially changes the renewable term coverage to level premium term for life coverage. This premium rate will not completely cover the future cost of claims and expenses.The VGLI Reserve is calculated as the present value of future claims and expenses less the present value of future premiums. This calculation is performed in an Excel spreadsheet model developed by Prudential and modified by VA Insurance Service Actuarial Staff. The reserve assumptions include historical mortality and lapse data for the ages and durations for which there is experience, combined with estimates for the ages and durations for which no or insufficient data exists. An interest rate assumption based on the expected long-term rate of return for program investments is utilized. SGLI/VGLI program reserves are invested in Prudential’s Group Insurance segment along with the reserves held for Prudential’s other group insurance clients. VA Insurance Service actuaries review the assumptions annually and update them for each policy year-end (June 30) calculation as needed. Prudential updates the VGLI in force as of each June 30th. As of June 30, 2016, the $3.1 billion of VGLI Reserve represented 4.4 percent of the $70.9 billion face amount of insurance provided by the VGLI program. If the methodology currently employed for setting and updating the underlying reserve assumptions is maintained, the VGLI Reserve will continue to grow due to the aging of the inforce and the increasing face amount of coverage in force.4. Performance Period: Base year plus four (4) option years depending on the needs of the Government. Tasks will be completed within 120 days from date of award. The Government’s standard workweek and hours of operation are Monday thru Friday, 8am – 5pm. Work at the Government site shall not take place on Federal holidays or weekends unless directed by the Contracting Officer Representative (COR). If the Contractor proposes an earlier completion date, and the Government accepts the contractor’s quote, the Contractor’s proposed completion date should prevail. The work shall begin within five workdays of award, unless otherwise specified. 5. Type of Contract: Firm Fixed Price. 6. Place of Performance: Work may be performed at the Contractor’s office. At the Governments discretion and if deemed necessary to facilitate the progress of the project, services may also be performed at the Government’s site:VA Regional Office & Insurance Center5000 Wissahickon AvenuePhiladelphia, PA 19144B. CONTRACT AWARD MEETINGThe Contractor shall not commence performance on the tasks in this SOW until the COR has conducted a post award conference at the VBA, 1800 G St, Washington, DC or has advised the Contractor that a post award conference is waived.C. GENERAL REQUIREMENTS1. For every task, the contractor shall identify in writing all necessary subtasks associated costs by task, and together with associated sub milestone dates. The contractor's subtask structure shall be reflected in the technical proposal and detailed Project Management Plan (PMP).2. All written deliverables will be phrased in layperson language. Statistical and other technical terminology will not be used without providing a glossary of terms.3. Where a written milestone deliverable is required in draft form, the VBA will complete their review of the draft deliverable within 10 calendar days from date of receipt. The contractor shall have 10 calendar days to deliver the final deliverable from date of receipt of the Government’s comments.D. SPECIFIC MANDATORY TASKS AND ASSOCIATED DELIVERABLES Description of Tasks and Associated Deliverables: The contractor shall provide the specific deliverables described below within the performance period stated in Section A.4 of this SOW to resolve the audit findings.Task One: The Contractor shall provide a detailed PMP and briefing for the VBA project team, which presents the contractor's plan for completing the tasks/contract work and resolving the audit findings. The contractor's plan shall be responsive to this SOW and describe, in further detail, the approach to be used for each aspect of the task order as defined in the technical proposal. At a minimum, the PMP shall include the risk, quality and technical management approach, work breakdown structure (WBS), detailed schedule, cost requirements, and proposed personnel. The Contractor shall keep the PMP up to date throughout the period of performance. Deliverable One: A detailed PMP and briefing given at VBA to complete contract work and resolve the audit findings. Task Two: The Contractor shall perform validation of VBA loan budget financial models and associated documentation based on applicable supervisory guidance and industry practice for model risk management; i.e. Office of the Comptroller of the Currency relevant guidance. Deliverable Two: The contractor shall produce a detailed model validation report with appropriate proposed changes that is commensurate with VBA’s risk exposure, business activities, and complexity and extent of its model use, including total fixed-price costs and benefits of the model validation report and changes. Task Three: The Contractor shall make appropriate and practical changes to the models to include any relevant new data and techniques and update the models’ user guides while retaining current model capability and simplicity as appropriate with automatic integration with the government calculator (CSC2) and 10-year financial planning tools. Any upgraded model documentation should include results from testing of the upgraded model adequacy to resolve the audit findings based on TR6. Deliverable Three: The Contractor shall produce final upgraded models and user guides and files, with results from the model validation and audit findings and application of TR6, that are commensurate with VBA’s risk exposure, business activities, and complexity and extent of its model use, including total fixed-price costs and benefits of the model and user guide updates. The deliverable should include validation of the adjusted model CSC2 inputs and output, resolution of the audit findings, and preservation of the model capabilities to support existing financial and budgetary reporting. Task Four: The Contractor shall update existing or develop new documentation on model development, implementation, use, and validation based on applicable supervisory guidance, industry experience, and laws and regulations (e.g., OMB Circular No. A-123), and audit findings. The existing models, user guides, and supporting budgetary documents contain information on model development, implementation and use. The updated internal control documentation shall encourage effectiveness and efficiency of operations, reliability of financial reporting, and compliance with applicable laws and regulations, and resolve the audit findings.Deliverable Four: The contractor shall produce a final updated model internal control documentation, standard operating procedures (SOPs), based on Circular No. A-123 including total fixed-price costs and benefits of model development, implementation, use, and validation to resolve the audit findings. Task Five: Insurance-The Contractor shall gain thorough knowledge and understanding of the financial operations of the SGLI/VGLI programs through the information and materials provided by VA Insurance Service Actuarial Staff. The Contractor shall become familiar with the current VGLI Reserve Model developed by Prudential and VA Insurance Service Actuarial Staff. In assessing the actuarial liability of the VGLI program, the Contractor should use this model or one that performs the same functions and provides comparable results. Deliverable Five: Insurance-Written certification that the Contractor is fully knowledgeable regarding the SGLI/VGLI programs and the workings of the VGLI Reserve Model and ready to assess the amount of the VGLI Reserve in order to provide Deliverable Five.Task Six: Insurance-The contractor shall perform an independent assessment of the amount of the VGLI Reserve as of June 30, 2016, as representative of the actuarial liability of the program for VGLI insureds covered as of that date. For this assessment, the Contractor shall review the VGLI Reserve model and the underlying assumptions for mortality, lapse, and interest rate as prescribed by VA Insurance Service actuaries. The assessment should address whether the model is correctly specified and whether the assumptions are appropriate. Specifically, the Contractor shall opine as to whether a lesser amount of VGLI Reserve can be maintained to cover the liability of the insurance program that is in accordance with accepted actuarial principles and practice, and that does not require significant modification (rate increases) of the premium scale. If it is the Contractor’s opinion that maintaining a lesser amount for the VGLI Reserve is actuarially acceptable, the Contractor shall provide their estimate for this amount and their supporting calculations, recommendations, and documentation for how this amount was determined.Deliverable Six: Insurance- The contractor shall deliver a detailed independent assessment report regarding the amount of the VGLI Reserve liability that addresses whether the amount of the VGLI Reserve can be lowered subject to the parameters and conditions specified in the Scope of Work.Task Seven: The Contractor shall participate in appropriate agency meetings and discussions in 2017 at times to be determined to resolve the audit findings.Deliverable Seven: Attend in person and/or by phone agency’s meetings and discussions on model validation, development, implementation, use, governance, and control to ensure resolution of the audit findings. E. SCHEDULE FOR DELIVERABLES1. The Contractor shall complete the Delivery Date column in Attachment A for each deliverable specified. 2. Unless otherwise specified, the number of draft copies and the number of final copies shall be the same.3. If for any reason the scheduled time for a deliverable cannot be met, the contractor is required to explain why (include the original deliverable due date) in writing to the Contracting Officer’s Representative (COR), including a firm commitment of when the work shall be completed. This notice to the COR shall cite the reasons for the delay, and the impact on the overall project. The CO will then review the facts and issue a response in accordance with applicable regulations. F. CHANGES TO STATEMENT OF WORKAny changes to this SOW shall be authorized and approved only through written correspondence from the CO. A copy of each change will be kept in a project folder along with all other products of the project. Costs incurred by the contractor through the actions of parties other than the CO shall be borne by the contractor. G. REPORTING REQUIREMENTS1. The Contractor shall provide the COR with monthly written progress reports (original plus two copies). These are due to the COR by the second workday following the end of each calendar month throughout the project's duration. 2. The progress report shall cover all work completed during the preceding month and will present the work to be accomplished during the subsequent week. This report shall also identify any problems that arose and a statement explaining how the problem was resolved. This report will also identify any problems that have arisen but have not been completely resolved with an explanation. H. GOVERNMENT PROVIDED EQUIPMENT/INFORMATIONThe Government will provide access to the models, program documentation, and office space for two Contractor employees, including a telephone and computer.I. CONTRACTOR EXPERIENCE REQUIREMENTS – KEY PERSONNEL R?SUM? The Contractor shall provide experienced and relevant technical knowledge with financial modeling skills, audit and internal controls, risk management, Microsoft Excel with Visual Basic for Applications (VBA), Word and Access, standard computer (statistical) packages, all relating to budgeting and financial accounting for federal guaranteed and direct loan housing programs to ensure resolution of the audit findings. Minimum experience: A Certified Public Accountant (CPA) preferred with 10 years of experience. The Contractor shall provide qualified key personnel that are able to eliminate the audit findings. Familiarity is necessary with federal financial requirements and computer systems capabilities and development. The Contractor shall possess excellent writing skills to revise model documentation and a familiarity with applicable regulatory requirements and industry standards is desirable but not required. Independent consultant group or a Contractor for risk management or a certified public accountant auditor is preferred. The Contractor agrees that the key personnel shall not be removed, diverted, or replaced from work without approval of the COR.Any personnel the contractor offers as substitutes shall have the ability and qualifications equal to or better than the key personnel that is being replaced. Requests to substitute personnel shall be approved by the COR. All requests for approval of substitutions in personnel shall be submitted to the COR within 30 calendar days prior to making any change in key personnel. The request shall be written and provide a detailed explanation of the circumstances necessitating the proposed substitution. The contractor shall submit a complete résumé for the proposed substitute, any changes to the rate specified in the order (as applicable) and any other information requested by the COR needed to approve or disapprove the proposed substitution. The COR will evaluate such requests and promptly notify the Contractor of approval or disapproval thereof in writing.J. SCHEDULE OF DELIVERABLESSee Appendix A K. SECURITYInformation System SecurityThe Contractor shall ensure adequate LAN/Internet, data, information, and system security in accordance with VA standard operating procedures and standard contract language, conditions laws, and regulations. The contractor’s firewall and web server shall meet or exceed the government minimum requirements for security. All government data shall be protected behind an approved firewall. Any security violations or attempted violations shall be reported to the VA project manager and the VBA Headquarters Information Security Officer as soon as possible. The Contractor shall follow all applicable VA policies and procedures governing information security, especially those that pertain to certification accreditation.Security Training 1.All Contractor and subcontractor personnel requiring access to VA information and VA information systems shall complete the following before being granted access to VA information and networks: ?Sign and acknowledge understanding of and responsibilities for compliance with the National Rules of Behavior related to access to VA information and information systems.?Successfully complete VA Information Security Awareness training and annual refresher training as required.?Successfully complete VA Privacy Awareness training and annual refresher training as required.?Successfully complete any additional Information Security or Privacy training as required for VA personnel with equivalent information system access.2.The Contractor shall provide to the COR a copy of the training certificates for each applicable employee within one week of the initiation of the contract and annually thereafter, as required. These online courses are located at tms.. To self-enroll, click the “Create New User” button on the red bar and complete the assigned training. The COR will provide the contractor with the appropriate information to complete self-enrollment. Technical issues with TMS should be directed to the TMS help desk at vatmshelp@ or 1.866.496.0463.3.Failure to complete this mandatory training within the timeframe required will be grounds for suspension or termination of all physical and/or electronic access privileges and removal from work on the contract until such time as the training is completed. All contractor employees and subcontractors under this contract or order are required to complete the VA's on-line Security Awareness Training Course and the Privacy Awareness Training Course annually. Contractors must provide signed certifications of completion to the CO. This requirement is in addition to any other training that may be required of the contractor and subcontractor(s). Due to the threat of data breach, compromise or loss of information that resides on either VA-owned or contractor-owned systems, and to comply with Federal laws and regulations, VA has developed an Information and Information Technology Security clause to be used when VA sensitive information is accessed, used, stored, generated, transmitted, or exchanged by and between VA and a contractor, subcontractor or a third party in any format(e.g., paper, microfiche, electronic or magnetic portable media).Contractor Personnel SecurityAll Contractor employees who require access to the Department of Veterans Affairs' computer systems shall be the subject of a background investigation and must receive a favorable adjudication from the VA Security and Investigations Center (07C). The level of background security investigation will be in accordance with VA Directive 0710 dated May 2, 2016 and is available at: (VA Handbook 0710, Appendix A, Tables 1 - 3). Appropriate Background Investigation (BI) forms will be provided upon contract (or task order) award, and are to be completed and returned to the VA Security and Investigations Center (07C) within 10 days for processing. Contractors will be notified by 07C when the BI has been completed and adjudicated. These requirements are applicable to all subcontractor personnel requiring the same access. If the security clearance investigation is not completed prior to the start date of the contract, the employee may work on the contract while the security clearance is being processed, but the contractor will be responsible for the actions of those individuals they provide to perform work for the VA. In the event that damage arises from work performed by contractor personnel, under the auspices of the contract, the contractor will be responsible for resources necessary to remedy the incident.The investigative history for contractor personnel working under this contract must be maintained in the databases of either the Office of Personnel Management (OPM) or the Defense Industrial Security Clearance Organization (DISCO). Should the Contractor use a vendor other than OPM or Defense Security Service (DSS) to conduct investigations, the investigative company must be certified by OPM/DSS to conduct contractor investigations.1. Background InvestigationAll Contractors, subcontractors, and third-party servicers and associates working with VA information are subject to the same investigative requirements as those of VA appointees or employees who have access to the same types of information. The level and process of background security investigations for contractors must be in accordance with VA Directive and Handbook 0710, Personnel Suitability and Security Program. The Office for Operations, Security, and Preparedness is responsible for these policies and procedures. The position sensitivity impact for this effort has been designated as LIMITED Risk and the level of background investigation is NACI. ................
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