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REQUEST FOR PROPOSAL (RFP) RFP: 006-21

Vendor Fiscal/Employer Agent (VF/EA)

Financial Management Service (FMS)

Council on Aging

4601 Malsbary Road

Blue Ash, Ohio 45242

Proposal Due Date: October 22, 2021, by 5:00 pm Eastern Daylight Savings Time

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TABLE OF CONTENTS PART I.......................................................................................................................................... 4

GENERAL INFORMATION.............................................................................................................. 4

I-1 Purpose ......................................................................................................................................... 4

I-2 Goal ............................................................................................................................................... 4

I-3 Agency and Program Background ................................................................................................. 5

Council on Aging ............................................................................................................................. 5

Elderly Service Program (ESP) ......................................................................................................... 5

Consumer Directed Care (CDC) Service .......................................................................................... 5

Target Populations and Geographic Service Area .......................................................................... 6

I-4 Contract Dates............................................................................................................................... 6

I-5 Rejection of Proposals ................................................................................................................... 6

I-6 Incurring Costs............................................................................................................................... 7

I-7 Questions and Answers ................................................................................................................. 7

I-8 Response Date............................................................................................................................... 7

I-9 Integrity of the Procurement Process ........................................................................................... 7

I-10 Future of Consumer Directed Care ............................................................................................. 7

PART II ......................................................................................................................................... 8

PROPOSAL REQUIREMENTS ......................................................................................................... 8

II-1 Submission Process ...................................................................................................................... 8

II-2 Proposal Outline ........................................................................................................................... 8

PART III ........................................................................................................................................ 9

CRITERIA FOR SELECTION ............................................................................................................. 9

III-1 Evaluation .................................................................................................................................... 9

III-2 Evaluation Criteria ....................................................................................................................... 9

III-3 Invoicing, Payment Procedures, & Compensation .................................................................... 10

III-4 VF/EA FMS Readiness Review Process ...................................................................................... 11

III-5 Financial Viability ...................................................................................................................... 12

III-6 Bidder’s Information Forms ...................................................................................................... 13

III-7 BONUS POINTS Technical/Additional Opportunity ................................................................... 18

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home52’s Home Health Aide App ................................................................................................ 18

PART IV ..................................................................................................................................... 19

SCOPE OF WORK ........................................................................................................................ 19

IV-1 Intent .......................................................................................................................................19

IV-2 Scope of Work .........................................................................................................................19

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CALENDAR OF EVENTS

To avoid a bifurcated tax year, we are expediating the RFP process.

Request for Proposal Number Proposal Name 006-21 Vendor Fiscal/Employer Agent (VF/EA)

Financial Management Service (FMS)

Important Dates Last Day to Submit Questions 9/27/21 Last Day for COA to Answer Submitted Questions

10/1/21

Proposal Due Date 10/22/21 by 5 pm Eastern Daylight Savings Time

Estimated Award Date Week of November 8, 2021

Estimated Information Exchange & Readiness Review

Week of November 1, 2021

Tentative Contract Start Date 12/1/2021

PART I

GENERAL INFORMATION I-1 PURPOSE Council on Aging of Southwestern Ohio (COA) is seeking an authorized Vendor Fiscal/Employer Agent

(VF/EA) Financial Management Services (FMS) Entity to serve Clients enrolled in the Consumer Directed

Care option of the Elderly Service Program (ESP) as their employer agent under Section 3504 of the IRS

code and IRS Revenue Procedure 2013-39. These Clients participate in an existing service COA provides

called Consumer Directed Care (CDC). This service model allows Clients to directly employ an individual

of their choosing to be their Home Health Aide.

I-2 GOAL The goal of this RFP is to contract with the highest quality VF/EA FMS Entity for the lowest cost while

meeting the requirements and demand for VF/EA FMS provided for Clients enrolled in the CDC service

option of ESP. ESP is funded by county tax levy funds.

COA embraces the principle of person-centered long-term service and supports (LTSS) delivery and has

implemented a self-directed service delivery option within ESP. Person-centered LTSS

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delivery places Client’s needs and preferences at the forefront of service delivery and improves

the Client’s homecare experience.

COA is accepting proposals from qualified Bidders interested in contracting with COA to provide VF/EA

FMS for eligible Clients enrolled in the self-directed service option under the Elderly Service Program

(ESP). This RFP for VF/EA FMS is for VF/EA FMS delivery in Butler, Hamilton, and Warren Ohio Counties.

COA desires to partner with a VF/EA FMS Entity that is within the continental United States. COA retains

that all work, data, and service remain in a cloud interface and/or the United States. Presenting an

understanding of Ohio state and local tax, labor, and workers compensation insurance requirements is

essential.

I-3 AGENCY AND PROGRAM BACKGROUND

COUNCIL ON AGING The Council on Aging (COA) of Southwestern Ohio was established in 1970 and was incorporated as a

nonprofit agency in December 1971. In 1974, COA was designated by the Ohio Commission of Aging,

now the Ohio Department of Aging (ODA), as the Area Agency on Aging (AAA) for Butler, Clermont,

Clinton, Hamilton, and Warren Counties. These five counties comprise Planning and Service Area

Number 1 (PSA-1) in the State of Ohio.

COA, providing service to older adults for more than 50 years, is Southwestern Ohio’s AAA. Our mission

is “Enhance lives by assisting people to remain independent through a range of quality services. These

include advocacy, caregiver support, counseling, health promotion, home and community-based

services, legal assistance, nutrition, senior centers, and transportation.” A VF/EA FMS Entity that is

selected through this RFP will contract with COA but will be providing vendor fiscal/employer agent

(VF/EA) financial management services (FMS) to COA and the Clients involved in their designated

programs. More information about COA can be found at www.help4seniors.org.

ELDERLY SERVICE PROGRAM (ESP) ESP helps older adults remain safe and independent in their homes by providing senior home care

services such as personal care, housekeeping, meals, transportation and more. ESP expands care

seniors may already receive from family and friends and prevents unnecessary nursing home placement.

COA administers the Elderly Services Program in Butler, Clinton, Hamilton, and Warren Counties. These

programs are funded by county tax levies.

CONSUMER DIRECTED CARE (CDC) SERVICE ESP provides Clients with long term supportive services to assist with tasks like cleaning, bathing,

shopping, and transportation. A case manager/care coordinator meets with the Client to assess their

needs and authorizes a set number of units for supportive services. These services are either provided

through a traditional home health agency or through CDC.

CDC is a service option in ESP that allows the Client to become an employer and hire their own

employees. An employee must be age 18 or older, willing to undergo a criminal background check, and

legally allowed to work in the United States. The employee can be a friend, neighbor, or family Client,

but cannot be the spouse of the Client. If a Client is unable to act as an employer, they may elect to

have an authorized representative who can act on their behalf as the employer. Employer authority is

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offered to Clients but not budget authority. Under employer authority, the Client or their authorized

representative is responsible for recruiting and hiring the employee, determining the employee’s

training requirements, work schedules and wage rates, managing the employee’s daily activities, provide

feedback to the employee on their performance and should circumstances warrant, terminating the

employee.

The goal of the CDC service option is to provide more independence and increase Client satisfaction,

while using ESP resources more effectively. Currently ESP does not require agencies to use an electronic

visit verification system (EVV) to capture service delivery. However, we are looking to incorporate a

method of electronic service delivery in the future.

TARGET POPULATIONS AND GEOGRAPHIC SERVICE AREA COA provides in-home supportive services to Clients in a Butler, Clinton, Hamilton, and Warren Counties

in Southwest Ohio. While enrollment criteria varies slightly by county, most Clients are over the age of

70, female, and seniors, who live on their own. Seniors who enroll in this program are frail enough to

require some degree of assistance, however, generally do not meet the physical requirements to receive

care in a nursing home nor are they able to privately pay for in-home assistance on their own.

At present, 498 Clients are enrolled in the CDC Program through COA. The average number of eligible

Clients enrolled each month is approximately 17.5.

Either the Clients, or their authorized representative, employs a Home Health Aide who assists the Client

with their in-home needs. A breakdown of the number of Clients currently enrolled in the CDC Program

is listed in the table below.

County Client Total

Butler County ESP 163

Clinton County ESP 16

Hamilton County ESP 255

Warren County ESP 64

Grand Total 498

I-4 CONTRACT DATES COA’s objective is to contract with a VF/EA FMS Entity effective January 1, 2022 (the last payroll in 2021

that is the first payment in 2022). The contract period is December 1, 2021, to December 16, 2022, with

four (4) additional one (1) year renewable options.

I-5 REJECTION OF PROPOSALS COA shall award a Service Agreement to the bidder(s) who submits the best proposal(s) based on

evaluation of all bids as determined by COA, its sole discretion, unless COA rejects all bids. COA reserves

the right to reject any or all bids, any part or parts of any bid, and the right to waive any informality in

any bid. Any bid which is conditional, obscure, or which contains additions not requested, or

irregularities of any kind, may be rejected.

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I-6 INCURRING COSTS COA is not liable for any costs incurred by the preparation, submission, and response to the proposal, in

participating in the RFP process or in anticipation of award of the Agreement.

I-7 QUESTIONS AND ANSWERS All questions regarding the RFP must be submitted digitally to: Provider_Services@help4seniors.org

Submitted questions must reference RFP 006-21. Only questions submitted in writing to this e-mail

address will receive a response. All questions must be submitted no later than September 27, 2021.

Responses to questions submitted will be posted on COA’s website at

https://www.help4seniors.org/Service-Providers/Elderly-Service-Program/ESP-Request-

Proposals.aspx no later than October 1, 2021

I-8 RESPONSE DATE To be considered, each Bidder must submit a signed TECHNICAL PROPOSAL (electronic signature is acceptable) which includes all information listed in Part III of this RFP and a signed COST PROPOSAL which includes all information listed in Part III of this RFP. The uploaded files must be submitted as *.pdf

documents. Bidder must include on the submitted files the following: Submitter Name, Company name,

Phone, Email, RFP 006-21, and name of proposal submitted (technical or cost). For confidentiality purposes, financial information can be marked “proprietary” or “confidential”. The file can be uploaded

to https://rfp.help4seniors.org/.

All bids must be received no later than 5:00 pm Eastern Daylight Savings Time on Friday, October 22,

2021.

No late bids will be accepted. COA is not responsible for, and will not open or consider, proposals

arriving after the deadline because of any cause.

I-9 INTEGRITY OF THE PROCUREMENT PROCESS During the procurement process, Bidders interested in responding to the solicitation may submit

questions via email (provider_services@help4seniors.org) only to the Provider Services team

regarding procedural matters related to the RFP, or requests for clarification or modification of this

solicitation, no later than the due date and time as set forth in the RFP. Questions or requests

submitted after the due date and time will not be answered.

The prospective Bidder shall not contact any COA personnel (except for the Provider Services team),

board or advisory council members, or program funders, including elected officials, for meetings,

conferences, or discussions that are specifically related to this RFP at any time prior to any Notice of

Intent to Award a contract. Unauthorized contact with any COA personnel, board or advisory council

members, or its funders, including elected officials, may be cause for rejection of the vendor’s proposal.

I-10 FUTURE OF CONSUMER DIRECTED CARE COA is looking to grow the CDC program utilizing technology-based solutions. We are currently working

to develop a mobile application referenced as the Home Health Aide App (HHAA) to capture and

enhance all components of the CDC service and are looking for Bidders who can demonstrate the ability

to grow into this environment with us. For more information on additional opportunities to work with

COA towards the enhancement of the CDC program, please see Part III-7 of this RFP.

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PART II

PROPOSAL REQUIREMENTS

II-1 SUBMISSION PROCESS Each Bidder must submit a signed TECHNICAL PROPOSAL (electronic signature is acceptable) which includes all information listed in Part III of this RFP and a signed COST PROPOSAL which includes all information listed in Part III of this RFP. The uploaded files must be submitted as *.doc or *.pdf

documents. Bidder must include on the submitted files the following: Submitter Name, Company name,

Phone, Email, Proposal title, and RFP 006-21 and name of proposal submitted (technical or cost). For confidentiality purposes, financial information can be marked “proprietary” or “confidential”. The file(s) can be uploaded to https://rfp.help4seniors.org/. COA reserves the right to make changes in program requirements, procedures, and terms after the bids have been submitted, opened, and reviewed to maximize delivery of services consistent with the goals of the RFP and COA. COA reserves the right to apply any of the following, if warranted, in COA’s sole opinion:

• Negotiate price.

• Award to multiple VF/EA FMS Entities

• Eliminate any term or condition that is not advantageous to COA, its Clients, or funders.

• Set ceiling/maximum rates for services provided resulting from this RFP.

II-2 PROPOSAL OUTLINE Bidders must submit their proposals in the format outlined below. Each proposal shall consist of

the following submittals:

a) Technical Proposal Submittal

b) Cost Proposal Submittal

c) Financial Viability

d) Bidder’s Information Form

e) Bonus Points - Technical/Additional Opportunity

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PART III

CRITERIA FOR SELECTION

III-1 EVALUATION COA has developed an internal committee of qualified personnel to review and evaluate timely

submitted proposals. COA will notify in writing of its selection for negotiation the responsible bidder

whose proposal is determined to be the most advantageous to COA as determined by COA after taking

into consideration all of the evaluation factors. Then, based on that negotiation, COA will execute a

contract with the selected bidder.

The following evaluation criteria will be used in evaluating each timely submitted proposal.

• Weight of Technical Proposal – 60%

• Weight of Cost Proposal - 40%

• Bonus Points - Additional Opportunity

III-2 EVALUATION CRITERIA The following criteria will be used in evaluating each proposal:

Technical – 60%

Cost- 40%

The evaluation will be based upon the following order of importance.

• Understanding of the Problem

This refers to the Bidder’s understanding of the needs that generated the RFP, of COA’s

objectives in asking for the services and the nature and scope of the work involved.

• Soundness of Approach

This refers to the Bidder’s approach to manage specific tasks, sequence of relationship of major

steps, techniques for collecting and analyzing information and understanding the state of the art

and industry practice in the areas covered by the RFP.

• Bidders Qualifications

This refers to the ability of the Bidder to meet the terms of the RFP, especially operating under

Section 3504 of the IRS code and Revenue Procedure 2013-39, federal department of labor and

US Citizenship and Immigration Status requirements; state tax, labor and workers’

compensation insurance requirements and locality tax requirements, as applicable; the time

constraint and the quality, relevancy, and recently projects completed by the bidder.

• Personnel Qualifications

This refers to the competence of professional personnel who are assigned to the project.

Qualifications of professional personnel will be measured by experience and education, with

reference to experience providing VF/EA FMS similar to that described in this RFP. Emphasis is

placed on the qualifications of the Program Manager and lead VF/EA FMS staff.

• Available Facilities

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This refers to the Bidders availability of adequate physical facilities for staff to accomplish the

work required in the RFP, as well as the administrative and logistical support requirements.

For a Bidder to be considered responsible for this RFP and therefore eligible for selection for best and

final offers or selection for contract negotiations:

1) The total score for the technical submittal of the Bidder’s proposal must be greater or equal to

70% of the available technical points, and

2) The Bidder’s financial information must demonstrate that the bidder possesses the financial

capability to assurance good faith performance of the Contract.

III-3 INVOICING, PAYMENT PROCEDURES, AND COMPENSATION Invoicing

The VF/EA FMS Entity shall, at minimum, comply with the following invoicing requirements set by COA:

• COA tracks services authorizations from the Client’s care plan in a care management system. On

or around the 12th of each month, the VF/EA FMS Entity is required to import a csv file to COA

for service units used in the prior month. The file shall include individualized Client record of

authorized units billed (in 15-minute increments) and service cost as authorized in the care plan.

Units only include direct labor hours of home care assistance provided. COA will provide

instructions and training on the csv file format and import process.

• ON or about the 12th of each month, the VF/EA FMS Entity shall provide monthly invoice(s),

separated by Client’s County of residence, to COA accounting for costs beyond service units

incurred in the prior month. The invoices shall include taxes, background checks, and service

fees and shall be itemized to clarify the aggregate cost of each item.

• Attached to each county invoice, the FV/EA FMS Entity shall provide supporting documentation

that includes the individual Client’s name, ID number, month, and itemized balance due for

taxes, background check(s), and service fees.

• All invoicing shall be received by the assigned cutoff date, on or around the 12th of the month

for the prior month’s service in order to receive payment by the end of that month.

• Invoicing requirements are subject to change as needed to meet the needs of COA internal

systems and processes.

Compensation

The compensation under the Contract shall consist of the following pricing structure:

One time Startup and Monthly Per-Member-Per-Month (PM/PM) VF/EA FMS Payment

• A One-time Start up payment for Client Enrollment.

• A PM/PM payment for the services and Deliverables described in this RFP.

• The PM/PM payments shall be the sole compensation to the Contractor for all Work on FMS performed pursuant to the Contract awarded from this RFP.

• If COA’s Client record is not updated reflect death or suspension of the previous month by the 1st of the PM/PM month calculation. COA can make an adjustment for any payment issued.

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• Through negotiations and a bi-lateral contract amendment process, COA may modify the PM/PM in subsequent Contract years.

Reimbursement of Aide Payments

• The VF/EA FMS Entity shall submit all claims to COA electronically, following COA’s standard fee-for-service claims transaction process.

• COA will process the claims in their system and shall pay the VF/EA FMS Entity through their system for the transactions that pass the claim edits. Payments made to Aides by the VF/EA FMS Entity which are not in compliance with 10 CCR 2505-10 § 8.510 shall not be reimbursed to the VF/EA FMS Entity.

• If the VF/EA FMS Entity believes that the calculation or determination of any payment is incorrect, including denial of claims submitted, the VF/EA FMS Entity shall notify COA of the error within thirty (30) days of receipt of the payment, or notification of the determination of the payment, as appropriate. COA will review the information presented by the VF/EA FMS Entity and may make changes based on this review. The determination or calculation that results from COA’s review shall be final. No disputed payment shall be due until after COA has concluded its review.

• Notwithstanding anything to the contrary in the Contract, all payments for the final month of the Contract shall be paid to the Contractor no sooner than ten (10) days after COA has determined that the VF/EA FMS Entity has completed all of the requirements of the Closeout Period.

Payment Procedures

• COA will pay the VF/EA FMS Entity a per-member per-month (PM/PM) payment, based on approved funding, for each active Client enrolled in the VF/EA FMS Entity ’s plan on the first day of each month.

• COA will calculate the number of active Clients enrolled in the VF/EA FMS Entity ’s plan based on the enrollment information.

• COA will remit all PM/PM payments to the VF/EA FMS Entity through their system within the month for which the PM/PM payment applies.

• In the event that the VF/EA FMS Entity is not compensated for a Client in a month for which the VF/EA FMS Entity should have been compensated, COA will compensate the VF/EA FMS Entity for that Client retroactively for a period not to exceed one (1) year.

III-4 VF/EA FMS READINESS REVIEW PROCESS The primary purpose of the VF/EA FMS Readiness Review is to provide COA with the reasonable

assurance that the VF/EA FMS Entity selected through their RFP process has the knowledge, experience,

and capacity to provide VF/EA FMS for ESP CDC option and in accordance with federal, state and local,

as applicable, tax, department of labor citizenship and legal alien status and workers’ compensation

insurance and program rules and in an accurate and timely manner.

Approval upon completion of the readiness review will grant advancement to the next step of the RFP

process.

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III-5 FINANCIAL VIABILITY The technical proposal must describe how the VF/EA FMS Entity shall ensure adequate financial

viability by successfully completing or providing at a minimum the following:

a) Provides prior year’s tax return (including all schedules) and prior year’s statement of revenue and

expenses.

b) Provides dated statement from a contracted CPA or an internal officer confirming that all federal,

state, and local income and employment tax payments are current and paid through the most

recent tax year.

Proposal outlines:

c) Strong financial management experience (i.e., managing large contracts or grants).

d) Minimum of three (3) years providing fiscal technical assistance and issuing contracts.

e) Functioning computer/accounting system that can operate through the app for this program.

Minimum of three (3) months of cash reserves as demonstrated by financial statements.

Maintain books, records, documents, and other evidence of expenditures in with generally

accepted accounting principles (GAAP); and make all books, records, and documents available

for inspection by COA without prior notice.

Bidder’s Identifying Information Form for RFP: 006-21

1. IDENTIFYINGINFORMATION

1. Legal Name of Bidder: 2. Federal Tax ID #:

3. Doing Business As (d.b.a.) if applicable:

4. Sites doing business in this service area:

Point of Contact:

Street: City, State, & Zip:

Phone #: FAX #:

Email address:

5. Ownership:

Private

Charitable/Religious

Private/Non-profit

Public/ Government

Publicly Traded

Other

6. Legal Structure:

Sole Proprietorship

S Corporation

Partnership

Non-Profit Corporation

Corporation

Voluntary

Corporation

2. STATEMENT OF UNDERSTANDING

The bidder affirms that the information contained in their proposal is true to the best of their knowledge and belief. The

bidder assures that it currently provides the services for which it is bidding. The bidder also affirms that the Request

for Proposal (RFP) has been read and understood and Provider will be in compliance with all requirements prior to

contract execution. Including: All Vendor Fiscal/Employer Agent (VF/EA) Financial Management Service (FMS) Scope of Work found within the RFP.

Signature: Title:

Printed Name: Date:

III-6 BIDDER’S INFORMATION FORMS

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BIDDER’S CERTIFICATION OF PAYMENT OF PERSONAL PROPERTY TAX

STATE OF COUNTY

Before me, a Notary Public, in and for said County and State, personally appeared

who, being duly sworn that he/she is the owner or an officer

vested with the authority to commit said company

to contractual obligations and having been awarded a public contract let by

competitive bid, and that by this statement, states that at this time neither he/she nor the

corporation is charged with any delinquent personal property taxes on the general tax list of personal

property of any county, or that attached hereto is a list of all delinquent personal property taxes

charged against him/her of the corporation.

Name of Company

By

Signature

Sworn before me and signed in my presence the day of , 20 .

Notary Public Signature

This certification is in compliance with Section 5719.042 of the Ohio Revised Code which requires a certification of delinquent personal property tax by any successful bidder prior to the execution of the contract of a political subdivision; and in the event there are any due and unpaid delinquent taxes, a copy of this statement shall be transmitted to the County Treasurer within 30 days.

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DEBARMENT, SUSPENSION, INELIGIBILITY AND EXCLUSION CERTIFICATION

I certify that the entity identified below has not been debarred, suspended, or otherwise found ineligible to receive funds by any organization of the executive branch of the federal government.

I further certify that should any notice of debarment, suspension, ineligibility, or exclusion be received by the organization, Council on Aging of Southwestern Ohio will be notified immediately.

Entity:

Type name of person authorized to sign Title

Signature Date signed

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AFFIDAVIT OF CERTIFICATE OF AUTHORITY

STATE OF

COUNTY OF SS.

being first duly sworn, deposes and

says that he/she is of

(sole owner, partner, president, etc.)

the party making the foregoing proposal or bid; affirms that the aforementioned business is either

registered with the Ohio Secretary of State or has obtained a certificate of authority to conduct business in

the State of Ohio.

AFFIANT

Sworn to and subscribed before me this day of 20 .

NOTARY PUBLIC

My commission expires:

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NON-COLLUSION AFFIDAVIT

STATE OF

COUNTY OF SS.

being first duly sworn, deposes and

says that he/she is of

(sole owner, partner, president, etc.)

the party making the foregoing proposal or bid; that such bid is genuine and not collusive or sham;

that said bidder has not colluded, conspired, connived, or agreed, directly or indirectly, with any bidder

or person to put in a sham bid, or that such other person shall refrain from bidding and has not in any

manner, directly or indirectly, sought by agreement or collusion, or communication or conference, with

any person, to fix the bid price affiant or any other bidder, or to fix any overhead, profit or cost element of

said bid price, or of that of any other bidder, or to secure any advantage against Council on Aging of

Southwestern Ohio or any person or persons interested in the proposed contract; and that all statements

contained in said proposal or bid are true; and further that such bidder has not, directly or indirectly

submitted this bid, or contents thereof, or divulged information relative thereto any association or to any

member or agent thereof.

AFFIANT

Sworn to and subscribed before me this day of 20 .

NOTARY PUBLIC

My commission expires:

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III-7 BONUS POINTS TECHNICAL/ADDITIONAL OPPORTUNITY

HOME52’S HOME HEALTH AIDE APP home52 is a subsidiary of COA. Leveraging nearly 50 years of experience, home52 and COA are experts

at helping individuals, families, and caregivers manage complex medical and long-term care needs.

home52 offers services that align with COA’s mission to help individuals remain independent in their

homes and communities. Under this subsidiary home52 is developing the Home Health Aide App

(HHAA) which gives Aides and Clients autonomy over their schedules, allows for transparent

communication between everyone involved in the care plan, and empowers Clients and their

families/caregivers to have more control over their care. It also helps COA staff more quickly identify

critical gaps in care. Currently, ESP does not require agencies to use an electronic visit verification

system (EVV) to capture service delivery. The HHAA will capture service delivery by utilizing an electronic

GPS system.

Following the framework of CDC as a baseline, the app allows the Client to become an “employer” and

hire their own “employees”/”Home Health Aide.” It is an alternative to the traditional option of

procuring a home care agency. The “employee” provides the same services that would be available

through the home care agency, including help with chores and transportation. The goal of the HHAA

option is to provide more choice, independence, and increase Client satisfaction while using ESP

resources more effectively and increasing the Home Health Aide workforce.

COA hopes to include the prospective Bidder in the development of the application by integrating its

VF/EA FMS system directly (or in partnership with a software provider) into the HHAA. However, an

inability to collaborate on the HHAA project is not an exclusionary consideration for contract for the

VF/EA FMS entity. Minimally the integrated Application Programming Interface (API) will need to include

the following components:

• Provides API with the following functionality:

o Create/Update/Delete Employer (Client)

o Create/Update/Delete Employee (Aide)

o Create/Update/Delete Time entry

o Create/Update/Delete pay periods.

• Execute payroll run for period.

• All appropriate taxes are withheld and paid.

• Generates and files all tax documents.

• Able to generate appropriate documents for Household Employee Payroll (per IRS

requirements)

• Execute payroll via direct deposit.

• Work with financial requirements set by COA.

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PART IV

SCOPE OF WORK

IV-1 INTENT The VF/EA FMS entity (“Contractor”) selected shall provide authorized Vendor Fiscal/Employer Agent

(VF/EA) Financial Management Services (FMS) in accordance with Section 3504 of the IRS code and IRS

Revenue Procedure 2013-39, for Clients enrolled in the consumer directed care (CDC) option of the

Elderly Service Program (ESP) and referred by the Council on Aging of Southwestern Ohio (COA) to the

VF/EA FMS entity.

IV-2 SCOPE OF WORK

1. GENERAL REQUIREMENTS FOR SERVICE DELIVERY

The Contractor shall provide the general requirements for Service Delivery as described herein:

1.1. Shall complete a Vendor Fiscal/Employer Agent (VF/EA) Financial Management Services (FMS)

Readiness Review prior to implementation of program effective January 1, 2022, (the last payroll

in 2021 that is the first payment in 2022).

1.2. Shall provide VF/EA FMS to eligible Clients enrolled in the self-directed service option of ESP.

2. SPECIFIC REQUIREMENTS FOR VF/EA FMS DELIVERYThe Contractor shall perform as a Vendor Fiscal/Employer Agent (VF/EA) Financial Management Service

(FMS) Entity in accordance with Section 3504 of the IRS code and IRS Revenue Procedure 2013-39 for

eligible Clients enrolled in the Consumer Directed Care (CDC) option of the Elderly Services Program

(ESP) and their authorized representative, as appropriate. The Contractor shall provide VF/EA FMS as

described herein:

2.1 Receive Veteran referrals from COA Case Manager.

2.2 Receive and maintain Client Service Authorizations and care plans and updates and assure that a

Client’s service authorization and care plan is followed for the designated services as prepared

by the COA Case Manager.

2.3. Establish a customer service system that is culturally and linguistically competent.

2.4 Perform as a mandatory reporter.

2.5 Develop and maintain a system for the receipt and distribution of program funds and

tracking any balances.

2.6 Establish and maintain current and archived Veteran/representative-employer, employee

(aide) and VF/EA FMS Entity files in a secure, confidential, and

timely manner in accordance with HIPAA, federal and state tax, labor, US CIS and workers’

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compensation insurance recordkeeping requirements and the HITECH Act.

2.7 Develop and periodically test a disaster recovery plan for electronic files.

2.8 Enroll eligible Clients into the Contractor’s VF/EA FMS system including preparing, distributing

and collecting the completed contents of the Client/Authorized Representative-Employer

Enrollment Packets and processing contents including, but not limited to, the IRS Form 2678, IRS

Form SS-4, IRS Form 8821, State and Locality Employer Account Registration forms, State and

Locality Limited Power of Attorney form, as applicable; Designated Representative Authorization

Form, Fraud Acknowledgement Form, worker’s compensation application, vendor

reimbursement form, aide timesheets and instructions, aide timesheet due date and pay day

schedule, and the Client/Representative-Employer Handbook and Packet Checklist.

2.9 Enroll eligible Aides into the VF/EA FMS system including preparing, distributing and collected

the completed contents of the Aide Employment Packets including, Aide Hiring Application, IRS

Form W-4, OH Form W-4, document to collect information about the relationship of the Aide to

the employer for determining FICA, FUTA/SUTA or both exemptions, US CIS Form I-9, Emergency

Backup Worker Designation Form, Fraud and Abuse Statement, direct deposit authorization,

Timesheet and Instructions, Timesheet due date and payday schedule, EVV Timesheet

Application, as applicable; criminal background check form, and Aide Enrollment Packet

Checklist.

2.10 Provide assistance with COA Care Managers, to the Client/Authorized Representative-Employer,

as needed to complete the contents of the Client/Authorized Representative-Employer

Enrollment Packet and Aide Enrollment Packet.

2.11 Disenroll Client/representative-employers from the VF/EA FMS’ system, as necessary, when a

Client disenrolls from the CDC option of the ESP.

2.12 Process the required federal and state background checks, as applicable on each direct

Aide candidate the employer chooses to hire. If an aide candidate

has lived in Ohio less than five years, it is recommended that a federal criminal background

check be conducted.

2.13 Verify that the aide candidate can be hired based on the results of the background checks.

2.14 Process the US Bureau of Citizenship and Immigration Services (BCIS) Form I-9 and certify

that the Aide candidate is a US citizen or has legal alien status.

2.15 Determine the relationship of the Aide to the employer to determine if an Aide is

exempt from FICA, FUTA/SUTA, or both.

2.16 Verify all Aides’ social security numbers.

2.17 Report newly hired Aides in accordance with Ohio New Hire Reporting System.

2.18 Verify that wage rates paid to employees are in accordance with Federal, State and locality,

(as applicable) wage and hours rules, as appropriate.

2.19 Collect and process aides’ timesheets.

2.20 Withhold, file and deposit Federal income tax withholding and FICA (Medicare and Social

Security) taxes using the IRS Forms 941 in the aggregate with the VF/EA FMS Entity’s

separate FEIN and the appropriate Schedule R and Schedule B, as appropriate, per IRS

rules.

2.21 Withhold, file and deposit Federal Unemployment Insurance Taxes (FUTA) using the IRS

Form 940 in the aggregate with the VF/EA FMS Entity’s separate FEIN and appropriate

Schedule R per IRS rules.

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2.22 Withhold, file and deposit state income tax (SITA) withholding per Ohio Department of

Taxation rules.

2.23 Withhold, file and deposit state unemployment insurance taxes (SUTA) per Ohio

Department of Job and Family Services, Office of Unemployment Insurance Operations

rules.

2.24 Withhold, file and deposit locality-related employment taxes per locality rules.

2.25 Process mandatory paid family medical leave per eligible Aide per the Ohio Family Medical

Leave Act. Per the Act, full and part-time permanent employees who work 30 or more hours per

week are entitled to up to six (6) weeks of leave for birth or adoption. Leave may not be more

than six (6) continuous weeks, which include four (4) workweeks or paid leave for full-time

employees and a pro-rated amount of paid leave for part-time employees.

2.26 Process garnishments, liens and levies against aides’ pay, as required,

2.27 Prepare and issue aides’ payroll in accordance with Ohio Payday

Requirements and Prompt Payment rules.

2.28 Process and distribute IRS Forms W-2 annually per IRS requirements for VF/EA FMS entities.

2.29 Manage the receipt and renewal of workers’ compensation insurance (WCI) policies, payment of

premiums from Client’s budget funds, provide wage information to WCI insurers to determine

aides’ benefits and be the site of the annual WCI audit.

2.30 Process and pay the employer and employee portions of over collected FICA for eligible

employers and employees annually per IRS requirements (employee portion refunded directly

to eligible Aides and employer portion refunded to COA per their procedure.

2.31 Prepare periodic reports for Client/representative-employers and Case Manager (i.e., monthly

spending report to the COA Case Manager and Client/representative-employer) and for COA

(i.e., fiscal accounting reports to the COA, monthly service report for each Client/representative-

employer) and ad hoc reports as required by COA. See Section 8.0 in this Scope of Work.

2.32 Invoice COA for direct Aide services rendered to Clients.

2.33 Invoice COA for one time employer startup fee and monthly PMPM VF/EA FMS.

2.34 Manage invoices for Aide and VF/EA FMS rendered each Client receiving CDC.

2.35 Process returned payments per Ohio’s Unclaimed Property Laws.

2.36 Provide support and assistance to Client/representative-employers, as needed, including the

provision of customer service.

2.37 Establish and maintain a system for receiving tracking and addressing communications (i.e.,

phone calls, emails, faxes) including complaints from Clients and their authorized

representatives.

2.38 Establish and maintain system for reviewing the VF/EA FMS Entity’s performance including

conducting an annual Client/Representative-Employer Satisfaction Survey analyzing and

reporting results to COA.

2.39 COA will be alerted to updated forms 60 days prior to implementation.

3.0 KEY AND LINE STAFF, AND ORGANIZATIONAL STRUCTURE

3.1 The Contractor shall provide knowledgeable and experienced management in providing VF/EA

FMS and working with older adults and persons with disabilities and chronic conditions.

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3.2 The Contractor shall maintain knowledgeable and experienced Key Personnel to carry out the

required services including at a minimum the positions identified in their organizational plan

provided to COA.

3.3 The Contractor shall provide knowledgeable and experienced line staff in providing VF/EA FMS

and working with older adults and persons with disabilities and chronic conditions including at a

minimum the positions identified in their organizational plan provided to COA.

3.5 The Contractor shall obtain written results of criminal history clearances for all employees

providing VF/EA FMS within 30 days from the date the entity initiates VF/EA FMS to enrolled

Clients and their authorized representatives.

3.6 The Contractor shall maintain an organizational structure to successfully provide the required

services.

3.7 The Contractor shall provide an organization chart for the organization overall and for

providing VF/EA FMS for COA and the Consumer Directed Care option of the ESP.

4.0 OFFICE SPACE

4.1 The Contractor shall have a physical plant and the equipment that is appropriate and

supports the provision of VF/EA FMS. This includes supplying meeting rooms and normal

office space for personnel, including equipment, Microsoft® Office Software, network

connectivity, supplies, clerical assistance, and administrative support needed to perform this

engagement at its headquarters and any satellite offices.

4.2 The Contractor shall ensure its office space is compliant with the provisions

of the Americans with Disabilities Act.

4.3 The Contractor shall have a toll-free number, secure fax, and email address and a TTY

service available to Clients and authorized representatives with hearing impairments to

communicate with the VF/EA FMS entity.

4.4 VF/EA FMS (Contractor) staff will be available to respond to calls, emails, and faxes from 8:30 am

to 5:00 pm Eastern Standard Time with voice messaging available. All communications received

must be responded to within one (1) business day of receipt.

5.0 INFORMATION TECHNOLOGY

5.0 The Contractor shall develop and implement an information system to manage

VF/EA FMS-Entity, Client/representative-employer, and aides-related records and files in an

accurate and confidential manner and in accordance with HIPAA, federal and state tax, labor,

USCIS and workers’ compensation insurance recordkeeping requirements and the HITECH Act.

5.1 The Contractor shall develop and periodically test a disaster recovery plan for electronic files.

6.0 VF/EA FMS POLICIES AND PROCEDURES MANUAL

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6.1 The Contractor shall prepare and maintain, in written and electronic formats,

a comprehensive VF/EA FMS Policies and Procedures Manual. The manual shall include policies,

procedures, and internal controls for providing VF/EA FMS to Clients enrolled in the CDC option

of ESP and their authorized representatives, as appropriate. The manual shall be approved by

COA and updated at least annually and more frequently, as needed.

7.0 REPORTING REQUIREMENTS

7.1 The Contractor shall, at minimum, comply with the following reporting

requirements set by COA:

7.1.1 Monthly Client Spending Report provided to each Client and their COA Care Manager. Content

to be negotiated with COA and the VF/EA FMS Entity but should include:

• Name of Client and their unique identifier

• Name of COA Care Manager

• Client’s total Authorization Amount as specified in Client’s Care Plan

• Client’s Monthly authorization amount

• Client’s Spending for current reporting month by Aide and in total

• Clients Spending for Authorization year-to-date in total and by Aide

• Total Authorization amount and percent remaining

7.1.2 Monthly Client Overspending and Underspending Report provided to COA senior staff and Care

Managers. Contents to be negotiated with COA and Contractor but should include:

• Generate a report when a Client spends over their Monthly Authorization Amount.

• Generate a report when a Client spends less than 50 percent of what their Monthly

Authorization Amount.

7.1.3 Monthly Overtime Report provided to COA senior staff and Care Managers Contents to be

negotiated with COA and Contractor but should include:

• Generate a report monthly that reports by Client and in total any overtime paid, the amount

by Aide and in total.

7.1.4 Hourly Wages Paid – As Requested by COA. A report provided to COA senior staff reporting the

lowest, highest, and average wage paid to Aides for the period specified by COA.

7.1.5 Summary Employer Portion of FICA Refund Report provided to COA with check for refund

amount annually. Contents should include:

• Name of each eligible employer and unique identifying number

• Applicable Calendar Tax Year

• Amount of FICA refund due to each eligible employer for the applicable calendar tax year.

• Total amount of total FICA refund being submitted to COA.

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7.1.6 COA tracks services authorizations from the Client’s care plan in a care management system,

Care Director. No later than the 12th of each month, the Contractor is required to import a csv

file to COA’s provider application of Care Director (Provider Portal) for service units used in the

prior month. The file shall include individualized Client record of authorized units billed (in 15-

minute increments) and service cost as authorized in the care plan. Units only include direct

labor hours of home care assistance provided. COA will provide instructions and training on the

csv file format and import process.

7.1.7 On or around the 12th of each month, the Contractor shall provide monthly invoice(s),

separated by Client county of residence, to COA accounting for costs beyond service units

incurred in the prior month. The invoices shall include taxes, background checks and service fees

and shall be itemized to clarify the aggregate cost of each item.

7.1.8 Attached to each county invoice, the FV/EA FMS Entity shall provide supporting documentation

that includes the individual client’s name, ID number, month, and itemized balance due for

taxes, background check(s) and service fees.

7.1.9 All invoicing and reporting shall be received by the 12 of the months for the prior month’s

service in order to receive payment by the end of that month.

7.1.10 Invoicing and standard and ad hoc reporting requirements are subject to change as needed to

meet the needs of COA internal systems and processes.

8.0 VF/EA FMS IMPLEMENTATION PLAN

8.1 The Contractor bidding shall include as part of its proposal, an implementation plan, beginning

with the date of notification of contract award within five (5) days of the start of the VF/EA FMS

Readiness Review.

8.2 Such an implementation plan should include the following elements:

8.2.1 A detailed timetable for the implementation period. This timetable should be designed to

demonstrate how the Contractor will be operational from the date of notification of award.

8.2.2 The Contractor’s plan for the deployment and use of management, supervisory or other key

personnel during the implementation period. The plan should show all management,

supervisory and key personnel that will be assigned to manage, supervise, and monitor the

Contractor’s implementation of the contract within the mobilization period.

8.3 The Contractor’s plan for recruitment of staff required to provide all services required by the

RFP on the contract start date at the end of the implementation period.

8.4 The Contractor’s plan for the purchase and distribution of equipment, inventory, supplies,

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materials, etc. that will be required to fully implement the contract on the required start date.

8.5 The Contractor’s plan for the use of subcontractor(s) other than a reporting agent, if any, on this

contract. Emphasis should be on how any subcontractor identified will be involved in the

implementation plan.

NOTE: The Contractor shall clearly identify management, supervisory or other key staff that will be

assigned during the implementation period.

9.0 VF/EA FMS CONTRACT TURNOVER AND CLOSEOUT PLAN

9.1 At the expiration or termination of the contract, COA will notify the current VF/EA

FMS (Contractor) of the need for turnover. Such notice will be provided by COA in writing at

least sixty (60) calendar days prior to the date the Contract will expire or terminate. Upon

expiration or termination of the contract, the current Contractor shall provide for a smooth and

timely turnover and closeout of its services to COA and its new Contractor, as applicable. The

turnover and closeout process will commence immediately upon such notification, based on the

Turnover and Closeout Plan prepared by the current Contractor, and approved by COA during

the VF/EA FMS Readiness Review process, and shall, at no additional cost to COA, continue past

the date of the termination or expiration, if, due to closing out the current calendar tax year or if

due to the actions or inactions of the Contractor, the turnover process is not completed before

that date. In addition, the Contractor must:

9.1.1 Provide an initial contract Turnover and Closeout Plan within five (5) days of the start of the

VF/EA FMS Readiness Review for COA approval. A final detailed description of the contract

Turnover and Closeout Plan must be submitted to COA for approval and initiated sixty (60) days

prior to the last day of the Contract. At a minimum, the contract Turnover and Closeout Plan

must include a detailed plan for moving all Clients enrolled in the CDC option of ESP from the

current Contractor to the new, awarded Contractor within thirty (30) days of contract award.

9.1.2 Describe how it will establish and maintain communication with COA to allow for the exchange

of information and data from the current payroll processing entity without disruption to the

program.

9.1.3 Cooperate with COA and supply COA and/or its designee with all information required by COA

and/or its designee during the transition process.

9.1.4 Pay all costs related to the transfer of materials and responsibilities as a normal part of doing

business with COA.

9.2 The only payments for which the current Contractor will be eligible during

the turnover to a new Contractor will be services specified by COA.

9.3 In the event that the newly awarded Contractor is unable to assume operations on the planned

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date for transfer, the current Contractor shall continue to perform the VF/EA FMS function on a

month-to-month basis for up to six (6) months beyond the planned transition date. COA will

withhold final payment to the current Contractor until the turnover to the newly awarded

Contractor is complete. If delays in the turnover process are due solely to the actions or inactions of

COA and or COA’s newly designated Contractor, COA and the current Contractor may negotiate, at

COA's discretion, a contract addendum to permit turnover completion. The current Contractor shall

be liable for all payroll claims and the VF/EA FMS responsibilities incurred up to the date of

expiration/termination.

9.4 The current Contractor shall perform the tasks associated with the turnover to a newly awarded

Contractor as contained in its COA-approved contract Turnover and Closeout Plan. COA will review

the contract Turnover and Closeout Plan, and the current Contractor shall revise it accordingly and

resubmit updated versions to COA within five (5) business days from the request.

9.5 Sensitive information may need to be transferred from other agencies or shared

with the Using Agencies during the Contractor’s contract, and/or transitioned to another vendor at

the conclusion of the contract. The Contractor shall follow COA procedures for information

handling and sharing. The Contractor shall ensure that all records are properly retained for at least

six (6) years after becoming fully inactive or until the disposition of court hearings, audits and

appeals are complete. The Contractor is responsible for following record retention procedures for

all applicable federal, State, and local government agencies.

10 GLOSSARY OF TERMS AND ACRONYMS

10.1 Aide (Home Health Care Aide): An assistant to a Client. A personal aide through COA,

will assist a Client with personal care and homemaking tasks or assistance to complete tasks within

the community. Services provided will be designated and authorized by the employer and/or Care

Manager who will authorize specific units based on clinical justification of needs. The aide may also

be referred to as “employee.”

10.2 Aide Employment Packet – A packet of employment-related forms produced by the Contractor and

distributed to Case Managers by the Contractor. Case Managers distribute the Participant-

directed Aide Employment to Client /representative employers that are hiring new aides and assist

them, as in completing the required forms and submitting them to the VF/EA FMS for processing.

10.3 API. API stands for Application Programming Interface. It is the way for an application to interact

with a certain system/application/library/etc.

10.4 Audit. An official inspection of a Client's or organization's account, typically by an

independent body.

10.5 Authorization. Refers to the approval of services by the Care Manager. An

authorization must be in place prior to delivery of services.

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10.6 Authorized Representative or Representative. An individual authorized by the Client to

assist in completing their CDC tasks. The representative may also be common law employer of

the Client’s case managers.

10.7 Background Check. A background check is a process a person or company uses to

verify that a person is who they claim to be and provides information about a person's criminal

record, education, employment history, and other activities.

10.8 Bid/Bidder. The submission and submitter to this RFP.

10.9 Care Plan. After a Care Manager has completed assessment and eligibility of a

Client’s needs, a Care Plan is established to maintain service authorizations. The care plan is this

established plan that includes authorized units of service and frequency of support.

10.10 Caregiver. The unpaid Client(s) who helps care for and support the Client. This

person is typically a relative or close friend.

10.10 Care Manager. A Care Manager, also often referred to as a Case Manager, is a staff

Client who is responsible for reviewing eligibility and program authorizations through Council on

Aging of Southwest Ohio or an Independent Case Manager.

10.11 Certificate. The process of providing someone with an official document testing to a status or

level of achievement.

10.12 Client. A Client who receives services through COA authorized by a Care Manager. An

authorization must be in place prior to delivery of services. May be used interchangeably with

Senior or Client. The Client is the employer of the case manager (employee).

10.13 Client/Representative-Employer Enrollment Packet – A packet of program and employer related

forms produced by the Contractor and distributed to Case Managers by the Contractor. Case

Managers distribute the Client/Representative-Employer Enrollment Packet to

Client/representative-employers who wish to be the common law employer of the Client’s aides

and enroll with the Contractor and receive VF/EA FMS.

10.14 Common Law Employer. A Client or their authorized representative under common

law rules has the right to direct and control how a person (engaged by a Client/organization)

performs the services provided. This control refers not only to the result to be accomplished

(outcome) by the work but also the means and details by which results are accomplished, even

if the employer gives the person, he/she engages freedom of action.

10.15 Contractor. Refers to the selected Bidder.

10.16 Consumer Directed Care (CDC). A person-centered, self-directed service option and

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model offered under the Elderly Service Program (ESP) that allows a Client or their authorized

representative-employer to self-direct the Clients home care services including hiring,

determining terms and conditions of work and work schedule and wage rate for their aides and

oversee their aides’ day-to-day activities, provide feedback on aide’s performance, and

discharge the aide as necessary.

10.17 Council on Aging of Southwestern Ohio or COA. Refers to the agency.

10.18 Eligibility Standards. Criteria set to determine if a Client is eligible for using Elderly

Service Programming.

10.19 Employer. COA Client or their authorized representative.

10.20 Employee. An aide that can be certain family Clients, excluding spouses and legal

guardians, to be hired and paid as the Aide or an individual that is not previously known to the

Client or their authorized representative.

10.21 Elderly Service Program (ESP). Ohio's ESP is a non-Medicaid program that assists

older adults to remain living at home or within their community. This program allows certain

family Clients, excluding spouses and legal guardians, to be hired and paid as the Aide.

10.22 ESP Applicant. A Client who has applied to receive ESP services as a COA Client.

10.23 Fraud: Fraud is an intentional deception or misrepresentation made by a person

with the knowledge that the deception could result in some unauthorized benefit to himself or

some other person. It includes any act that constitutes fraud under applicable Federal or State

law.

10.24 HHAA. Refers to the Home Health Aide Application or reference name for the

project.

10.25 HIPAA. The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a

federal law that required the creation of national standards to protect sensitive patient health

information from being disclosed without the patient’s consent or knowledge.

10.26 HITECH Act. The Health Information Technology for Economic and Clinical Health Act

(HITECH) is part of the American Recovery and Reinvestment Act (ARRA) of 2009 and creates

incentives related to health care information technology, including incentives for the use of

electronic health record (EHR) systems among providers.

10.27 Internal. Refers to the group of employees of COA who decision makers or actors in

are the function of CDC.

10.28 Interview. A designated meeting (in person, telephone or virtual) to review the

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prospect and/or informed decision of employment.

10.29 Oversight. “Oversight” of a system or process is the responsibility for making sure

that it works efficiently and correctly.

10.30 Payment. The action or process of paying someone or of being paid.

10.31 POC. Refers to Point of Contact.

10.32 Rating. The classification or ranking of someone or something based on a

comparative assessment of their quality, standard, or performance.

10.33 IRS Revenue Procedure 2013-39. Describes and updates the procedure for

requesting the IRS to authorize an agent under Section 3504 of the Internal Revenue code and

Section 31.3504-1 of the Employment Tax Regulations for purposes of FICA tax, RRTA tax, FUTA,

collection of income tax, and general provisions related to employment taxes.

10.34 Section 3504 of the IRS code. An employer may appoint an agent under §3504 of the

Code to perform acts such as the withholding, reporting, and paying of federal employment

taxes with regard to wages paid by the agent on behalf of the employer.

10.35 Service Need. To demonstrate clinical justification for a service, a Client must

demonstrate a need for the service which is clinically justified based on physical barriers and

limitations. A service need also cannot be supplanted if another community support is able to

provide the service.

10.36 System. A set of procedures according to which something is done, an organized

scheme or method.

10.37 Training. The action of teaching a person a skill required for their employment

position.

10.38 Vendor Fiscal/Employer Agent (VF/EA) Financial Management Service (FMS) Entity.

An entity that serves as a source of financial management services for Clients and their

authorized representatives, if applicable, to support their use of self-directed service. The

Contractor operates as the agent to the common law employer (i.e., Client or authorized

representative) in accordance with §3504 of the IRS code and Revenue Procedure 2013-39 to

perform acts such as the withholding, reporting, and paying of federal employment taxes with

regard to wages paid by the agent and for state and locality employment-related taxes and the

management of program funds and payment of goods and service vendors for services rendered

on behalf of the employer.