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Office of Personnel Management FPM Letter 792-12
Federal personnel Manual System Published in advance
FM Let 792-12 of incorporation in FPM
SUtgECT: Cooperative Employee Counseling Services Program RETAN UNM SUKmsmED
Washington, D. C. 20415
May 20, 1980
Heads of Departments and Independent Establishments:
1. Public Laws 91-6161 and 92-255,2 as amended by Public Law 93-282,3 require Federal
9 departments and agencies to develop and maintain appropriate prevention, treatment
apd rehabilitation programs and services for civilian employees with alcohol or drug
problems, respectively. Office of Personnel Management (OPM) guidelines for implementing
these programs are in FPM Subchapter 792-5, FPM Supplement 792-2 and FPM Letter 792-8
Sof August 25, 1977.
S2 Pulic Laws 91-j16 and 92-255 were further amended on January 2, 1980 by Public Laws
906180' and 96-181, respectively. These amendments authorize agencies to extend program
services, where feasible, to:
a. Families of employees with an alcohol or drug problem, and
b.' Employees with family members) with an alcohol or drug problem.
3. Public Law 79-658 authorized agency establishment of health service programs to
H promote and maintain the physical and mental fitness of Federal employees. Implementing
a I guidelines are in ONEMB Circular A-72 of June 18, 1965, FPM Chapter 792-1, FPM Supplement
: J1792-1, and FPM Letter 792-9, of May 23, 1979.
SSC 4541 et.,seq. Comprehensive Alcohol Abuse and Alcoholism Prevention, Treatment,
and Rehabilitation Act of 1970, approved December 30, 1970.
i21 USC 1180 et seq. Drug Abuse Office and Treatment Act of 1972, approved March 21,
S 3Public Law 93-282 of May 14, 1974 governs the confidentiality of client records.
Sihe Act has been incorporated in the Code as amendments to 42 USC 4541 et seq. Of
particular concern are sections 122 and 303 of P.L. 93-282 which amend sections 333
Sof 'P.. 91-616 (42 USC 4582) and 408 of P.L. 92-255 (21 USC 1175) respectively.
Axi Act to revise and extend the Comprehensive Alcohol Abuse and Alcoholism Prevention,
Treatment and Rehabilitation Act of 1970; approved January 2, 1980.
An Act .to amend the Drug Abuse Office and Treatment Act of 1972, and for other purposes;
2i approved January 2, 1980.
5 USC 7901.
haquries: Workforce Effectiveness and Development Group, Employee Health Services Branch
Codes 792- Federal Employees Occupational Health Program
4. Based on the above, several agencies have incorporated their Federal Civilian "
Employee Alcoholism and Drug Abuse Programs into an Employee Counseling Services
Program -- or a broader management system for assisting employees with job problemda
stemming from a wider range of emotional-behavioral problems. Such programs ha..
proven useful and effective, if skilled counselors are available to help employees:
identify the nature of their problem, and refer them to appropriate community tr-.e.t..
5. Consonant with OMB Circular A-76, agencies may obtain such skills and services, |
one of the following ways, outlined in OMB Circular A-72:
a. By utilizing professional staff or facilities existing in the
department or agency at locations where adequate; or; ...
b. Where an agency's staff or facilities are not adequate, by .
entering into an appropriate agreement with another Federal
department or agency at locations where that department or
agency has available adequate professional staff or facilities;
c. -Where neither the agency nor another Federal department or
agency has adequate staff or facilities available, by establishing
the department's or agency's own professional staff or facilities
or by entering into an appropriate agreement with qualified private
or public sources for professional services, including consulting
services, or facilities.
6. Since the requisite skills and services are often not available within the aex
staff of many agencies, they are increasingly using the other alternatives indicate
above. Particularly, they are pooling resources to jointly contract for the needed :i
skills and services.
7. Agency expenditure of appropriated funds for the procurement of diagnostic and.
preventive psychological counseling services for employees has been clearly author
by Comptroller General Decision B-187074, dated November 7, 1977. Such services she...
not include treatment, but rather problem identification, referral for treatment or
rehabilitation and follow-up to aid an employee in effective readjustment on the job::'
during and after treatment.
8. Agency decisions to obtain services through agency vs. contract personnel should .
also be governed by revised OMB Circular A-76 dated March 29, 1979. It provides that
where needed services can be provided by the private sector and there are no override" !
factors requiring in-house performance, the most economical means of obtaining the
services should be used. Thus A-76 provides that services should be obtained by con-
tract, unless no satisfactory commercial source is available, or the Government can
provide the service at a lower total cost than a private purveyor.
9. Joint agency use of central support services, such as health units, is also a lonu:t!
established and encouraged practice.7 The General Accounting Office has favorably
reviewed some early joint agency counseling programs. In their report to the Congress: ^
entitled "Most Agency Programs for Employees with Alcohol-Related Problems Still
Ineffective" (B-164031(2)), dated September 7, 1977, GAO states that: I
7See Public Law 79-658, 0MB Circular A-72, and 34 CFR 271, which superseded 0MB .
FFPM Letter 792-12 (3)
A cooperative program is one in which a number of different agencies
combine to establish an effective program to serve the employees of
each agency. In our opinion, this approach is particularly advantageous
in situations where there are many agencies in the same general area
but each agency does not have a sufficient number of employees to justify
the appointment of a well-trained coordinator who would be able to spend
substantial time on the program .
We recommend that CSC (now OPM) and 0MB support the development of
consolidated employee assistance programs through FEBs. Since FEAs are
not as formally established as FEBs we further recommend that OMB urge
FEAs to consider establishing cooperative programs where applicable.
Finally, in areas where FEBs and FEAs do not exist, we recommend that
the department and agency heads take the initiative and play an active
role in establishing cooperative employee assistance programs to better
serve employees in those locations.
10. This issuance transmits guidelines for developing cooperative interagency Employee
Counseling Services Programs. The attached guidelines were developed in consultation
with the Secretary of HEW, selected Federal agencies, and the national labor organi-
zations. They are purposely broad, suggesting several alternative approaches; this is
to encourage the development--in varying workforces and in varying geographic locations
--of programs most likely to provide effective rehabilitation opportunities for em-
ployees with job problems stemming from emotional-behavioral problems.
11. Federal policy is to encourage agency establishment and use of cooperative-programs/
when increased efficiency and economy will result, and neither program effectiveness nor
essential internal administration of the agency will be hampered. Establishment of co-
operative programs will be preceded by consultation with the Division of Federal Employ-
ee Occupational Health of the Public Health Service.
12. In addition, agencies should ensure appropriate involvement of recognized labor
organizations. As in all areas of dealing with employee welfare, the benefits of em-
ployee acceptance and participation are greatly enhanced through early and positive
13. Development of cooperative agency programs first requires a survey of interest in
participation among Federal installations located in close proximity in a given geo-
graphic area. In locations where a Federal Executive Board or Association exists, OPM's
Regional Offices will work with them to complete such a survey and establish programs
as appropriate. In other locations, department and agency heads are encouraged to
initiate such a survey and establish appropriate cooperative programs for employees in
their location. OPM's Regional Offices are responsible for providing technical assis-
tance in all phases of developing and maintaining these programs.
Jule M. Sugarman
S .:ii i
Attachment to FPM Letter 792- 12
I. Cooperative Program Model
II. Alternatives for Operating an Employee Counseling Services Program
A. Single Federal Agency Program
B. 'Cooperative or Multiple Federal Agency Program
1. Using Another Federal Agency's In-house Capability
2. Using Contract Capability, Obtained in Cooperation with
Other Federal Agencies
III. Developing and Administering a Cooperative or Multiple Federal Agency
Program with Contract Capability
A. Pre-award Functions
1. Identifying requirements
2. Ensuring funding
3. Developing a request for proposals
4. Obtaining proposals
5. Evaluating proposals and awarding the contract
B. Post-award functions
1. Contract changes and supplemental agreements
2. Monitoring and evaluating contractor performance
a. Responsibilities of the Contracting
b. Responsibilities of the Agency Management
Appendix A: Sample Memorandum of Agreement
Appendix B: Request for Proposals: Sample Materials and Other
Factors to Be Considered
Appendix C: Responsibilities of the Contracting Officer's
Attachment to FPM Ltr. 792-12 (2)
I. Cooperative Program Model
A. The same basic tasks must be carried out in any employee services
counseling program -- regardless of whether the program serves the
employees of one or several agencies. These tasks are identified n ..
FPM Sub Chapter 792-5, Sections 5-3 and 5-4, and include the following:
Policy and program design and establishment
Employee education ..
Training appropriate management officials (including supervisory,
safety, and security personnel)
Developing and maintaining counseling capability (whether personnel,
medical, and/or other counseling resources)
Establishing liaison with community education,treatment and reha-
Evaluating the program and reporting to management on results and
To accomplish these, FPM subchapter 792-5 requires designation of a
program administrator at the headquarters level to direct the program
on an agency-wide basis and of a coordinator at each field installation
to administer local operations. The agency administrator and local co-
ordinator are to be organizationally placed so as to have an overview
of how the program is being carried out -- by personnel, counseling,
medical, and other functions assigned program responsibilities.
B. In a cooperative agency program model, the installation coordinator also
has management responsibilities, primarily ensuring that the appropriate
services are delivered by the provider selected.
1. The specialized skills and service delivered by a provider may
Consulting on agency program and policy development
Conducting employee education programs
Training appropriate management officials
Advising managers, supervisors and union officials on
the handling of specific employee cases
Counseling employees who are management, union or self-
referred. This includes assistance in problem definition,
referral to an appropriate community treatment resource and
follow-up to insure that the employees receive appropriate
help and make any necessary adjustments in job performance
Within the requirements of the confidentiality regulations,
providing feedback on employee progress to the referring
Establishing liaison with appropriate community resources -
identifying those where services are covered by employee
Assisting in program evaluation
Attachment to FPM Letter 792-12 (3)
2. The management responsibilities of the installation program
coordinator may include:
Developing installation policy and program design
Evaluating installation program results
Serving as a liaison between the service provider and
the installation's pertinent management systems
Selecting and monitoring the service provider
In cooperation with the provider, preparing necessary
II. Alternatives for Operating an Employee Counseling Services Program
As indicated in OMB Circular A-72, an agency may consistent with OMB
Circular A-76 provide employee health services in a variety of ways.
Outlined below are various program alternatives, detailed in subsequent
Single Federal agency program, with the specialized
skills and services provided by:
In-house capability, or
Cooperative or multiple Federal agency program, with
specialized skills and services provided by:
Another Federal agency's in-house capability, or
Contract capability, with responsibility for con-
tract leadership assumed by:
A participating Federal agency, or
Public Health Service, or
Office of Personnel Management
Before determining which alternative should be used at an installation,
an agency needs to consider carefully the characteristics of the employee
population to be served--including its size, demographic characteristics,
geographic dispersion, and nature of the work performed. Once an assess-
ment has been made about the type of program which will most effectively
reach that population, one of the above alternatives should be selected
based on thp criteria identified in OMB Circular A-76.
However, the differences between these alternatives relate to the means
through which specialized skills and services are delivered--not to the
overall administration of the program. Ultimate responsibility for
developing and maintaining an effective program for employees always
rests with the employing agency.
A. Single Federal Agency Program
Many characteristics of a given work population may lead an agency
to conclude that it is most desirable to continue a program which
serves only its own employees and their families. The specialized
skills and services may, however, be provided either by a qualified
contractor or by qualified agency personnel (already in the workforce
or specifically hired).
Attachment to FPM Letter 792-12 (4)
For example, an agency may rightly conclude that one of its large,
geographically isolated installations would be best served by an
on-site, in-house program. After examining the installation's
annual counseling report results and other available measures of
program effectiveness, the agency may also conclude that the
installation has been able to maintain staff with the necessary
skills to operate the program efficiently and in a cost-effective II
Conversely, an agency may conclude that with a large, but widely
dispersed and mobile employee population, a centrally located
program will not be effective. Examination of the annual counseling
reports may substantiate that program efforts to-date have not been
effective in reaching employees. The agency might therefore conclude
that more effective services could be delivered by a series of
counseling sites scattered throughout areas where employees normally
work, or by regional "hotlines" staffed by counselors skilled in
telephone interviewing and conversant with treatment resources in a
wide geographic area. Further assessment might indicate that agency
support staff cannot, practically, be de-centralized to provide
services at numerous counseling sites and/or that existing agency
personnel do not have requisite skills to effectively operate the
program. The agency might therefore conclude that the necessary
services could be best provided either by a series of small contractors
distributed throughout the work territory; or a contractor with satellite
locations; or by one contractor, skilled in the operation of "hotline"
The potential program variations are numerous, and many installations
have developed excellent single-agency programs for their employees.
All too frequently however, where the workforce is not large enough
to support employment of a skilled full-time program coordinator,
other alternatives have not been developed. In such situations an II
agency should consider the following possibilities:
(1) Hiring a part-time coordinator
(2) Retaining a consultant on a limited basis
(3) Contracting on a per capital basis with a
nearby community resource which already
provides the needed services (this might
include buying into a consortium serving
other Federal, State, or local government
agencies and/or private businesses)
A fourth option for the agency to consider is pooling resources with
other Federal agencies to form a cooperative program.
B. Cooperative or Multiple Federal Agency Program
This model may be appropriately used in numerous sites -- most
frequently where the installation does not have a workforce large
enough to support its own professionally run program, and has program
needs which are compatible with those of other nearby employee groups.
Once this model is selected, an agency must then determine the best Y:
way in which the needed skills and services can' be obtained:
1. Using Another Federal Agency's In-House Capability
In some locations, there may be a Federal installation which has
a sufficiently large workforce to support investment in qualified
Attachment to FPM Letter 792-12 (5)
personnel to operate their own employee counseling services
program. Consonant with OMB Circular A-76, smaller neighboring
installations may wish to explore the possibility of using that
agency's staff as the service provider for their own employees.
0MB Circular A-72 authorizes any agency, that provides and
maintains Federal space occupied with other agencies where ade-
quate health facilities are not provided by a tenant agency, to
provide occupational health services for the employees of all such
agencies. Likewise 34 CFR 271 provides that central supporting
services may be established in Federal office buildings occupied
by a number of executive departments and establishments and
operated, where appropriate, by GSA or other agencies. Such
interagency arrangements may be initiated by either the larger
or the smaller agency, and formalized by an interagency support
agreement, such as that contained in Appendix A. Consonant with
34 CFR 271, reimbursements for such services shall conform to
existing law, and normally shall be made, except where the cost
is nominal or where reimbursement may not be practical.
In such arrangements, the smaller agency must still appoint its
own program coordinator; however, the division of responsibilities
between that coordinator and the larger agency program staff could
be modeled after those described above in Section I. In any case,
a "tenant committee" should be established to assist the agency
providing the service with the administration or coordination of
the facility/service. Such committees should be composed of
program coordinators, at least, and may include such other respon-
sible officials as the participating agencies deem appropriate.
2. Using Contract Capability, Obtained in Cooperation with Other
In many locations, there may be no single Federal agency program
which can act as a service provider for other smaller neighboring
installations. However, the combined employee populations of
several local installations may be sufficiently large to support
a contract for a cooperative program.
Organizing and administering such a program generally involves
standard contracting procedures. However, because of the co-
operative or joint nature of the program, one agency must be
picked to serve as the principal contracting agent for all of the
participating or purchasing agencies. The participating agencies
are then bound to the contract with the service provider through
a memorandum of agreement with the contracting agent.
The agency which serves as the contracting agent/broker may be
one of three listed below:
a. One of the participating or purchasing agencies
b. Public Health Service (Division of Federal
Employee Occupational Health)
In locations where PHS health units are operated
and attended by a full-time PHS physician, DFEOH
is willing to consider sub-contracting for the
specialized services and skills required to
operate an ECSP. Although the sub-contractor
would work under the general direction of the
health unit physician, participation in the
sub-contract would not be limited just to those
agencies which utilize the health unit
c. Where neither of these options are feasible,
Office of Personnel Management
Attachment to FNM Letter 792-12 (6)
Regardless of which of the above is ultimately selected, OPM's
regional offices are responsible for providing technical
assistance, as requested, throughout the development and ad-
ministration of the resulting cooperative programs.
III. Developing and Administering a cooperative or multiple Federal Agency program
with contract capability.
The following outline may be a helpful guide in developing and admin-
istering cooperative programs. It is intended as an overview not a
detailed instruction. Applicable contracting laws and regulations must
be consulted. These may vary slightly depending upon which agency is
selected as the contracting agent; as in all other contracting situations,
ultimate authority and responsibility remain with the duly authorized
A. Pre-award Functions
1. Identifying requirements
Once agencies interested in participating have been identified,
they need to reach agreement on the services which they want
delivered by the service provider. Section I identifies most
of the tasks which might be required. Agencies should also agree
on such matters as desired program location, possible services
to remote locations, intake and referral procedures, hours of
program operation, etc.
To facilitate this agreement, it may be useful to form an advisory
group of agency program coordinators or other officials who will
serve as the liaison between their agency and the service provider
ultimately selected. They need to ensure that installation policy
statements are compatible with the program structure agreed upon,
and that management also supports the program. Obtaining the
endorsement of the local Federal executive group can often facilitate
gaining management support.
2. Ensuring funding
Based on the requirements agreed upon, total contract costs must
then be estimated. This presupposes some familiarity with the
types of providers generally available, the salaries skilled
personnel might command and possible overhead cost. Since all of
these items may vary according to location each potential cooperative
program should form its own estimates. Once total contract costs
are calculated, then total costs per agency can be estimated.(1)
While precise figures cannot be established, a cost range must be
estimated for each agency and such funds certified available by
each agency before a request for proposals may be issued. A memo-
randum of agreement may be used for this purpose (See Appendix A for
a sample agreement.)
(1) There are several ways this can be calculated. Two of the more frequently used
methods for determining total costs per agency are:
(a) Straight Per Capita Cost Method
Agency's Total contract cost Agency's total
cost Total employee popu- x employee population
lation of all partici-
(b) Set-up Cost plus Reduced Per Capita Cost Method
Agency's Initiation +
(Total contract cost total initiation fees x Agency's total)
(Total employee population of all participating employee pop. )
Attachment to FPM Letter 792-12 (7)
Should the combined costs of the participating agencies be equal
to or greater than $100,000 annually, the agency serving as the
principal contracting agent should conduct a mode of performance
review in accordance with OMB Circular A-76.
3. Developing a request for proposals
Based on the program requirements identified, a statement of work
must be developed and evaluation criteria established. A request
for proposals can then be developed in coordination with the respon-
sible contracting officer from the agency acting as contracting
agent. (Appendix B suggests sample language for the technical
portions of an RFP as well as some other programmatic factors to be
considered. Language covering the contracting/business aspects of
an RFP should be provided by the responsible contracting officer.)
4. Obtaining proposals
Because of the competitive nature of the procurement and the dollar
amounts which will typically be involved, proposals may be solicited
from all such qualified sources as the contracting officer may
decide necessary to assure full and free competition. This may
include publishing a synopsis of the RFP in the Commerce Business
Daily and prior identification of public or private service providers
who might be potential bidders.
Due to the relatively innovative nature of cooperative employee ser-
vices counseling programs, it may also be desirable to hold a pre-
proposal conference at which potential bidders can raise any necessary
5. Evaluating proposals and awarding the contract
Proposals must be evaluated from two perspectives. Assessment of
the business or financial aspects are the responsibility of the
contracting office. The program aspects will be evaluated by a
technical panel. Such a panel may be composed of a least 3-5
persons with personnel or programmatic expertise, selected by the
participating agencies. Negotiations, if required will be conducted
by the contracting office. Following submission of best and final
offers, selection of the service provider and final preparation of
the contract documents will be made by the contracting office.
B. Post-Award Functions
1. Contract changes and supplemental agreements
In any contract modification whether by unilateral order or bi-
lateral agreement the contracting officer is the sole party
authorized to change the terms and conditions of the contract on
behalf of the government.
2. Monitoring and evaluating contractor performance
a. Responsibilities of the contracting officer's
representative. A suggested list of responsibilities
is contained in Appendix C
b. Responsibilities of the agency management committee
As indicated in Section I, each participating agency
must designate a program coordinator to perform certain
management functions. These coordinators shall form a
standing management committee to perform the coordinator
functions in Section I. The committee shall work in
close cooperation with the contracting officer's rep-
resentative. Independently, each coordinator must
evaluate the effectiveness of their installation's
total ECSP program, assessing how useful a part the
cooperative program plays in the total effort.
Attachment to FEN Letter 792-12 (8)
SAMPLE MEMORANDUM OF AGREEMENT
1. Pursuant to the 42 U.S.C. 4541 (PL 91-616, as amended) 21 U.S.C. (PL 92-255,
as amended), and 5 U.S.C. 7901, the (Lead:..gency) and
the (Participating Agency) hereby enter into an agreement for an
Employee Counseling Services Program, effective ______.......
This agreement will continue until or until cancelled
by either party.
2. This agreement is entered into by the (Lead Agency) for :i'
the operation of an Employee Counseling Services Program, as described below,
for the employees of the (Participating Agency) .
2. This agreement is entered into by and
to procure the program services described below, which will be shared by agencies
participating in the financial support of the procurement. (Lead Agency)
will contract on behalf of all participating agencies for these services in .
accordance with Federal Procurement Regulations.
3. The first two Acts cited above provide that Federal agencies shall be re-
sponsible for developing and maintaining appropriate prevention, treatment and
rehabilitation programs and services for Federal civilian employees with alcohol
or drug problems. Where feasible, these program services should be extended to
families of employees with such problems, and to employees with alcohol or drug
dependent family members. 5 U.S.C. 7901 provides that occupational health programs
may be established to promote and maintain the physical and mental health fitness
of Federal employees. In order to accomplish these objectives, an Employee
Counseling Services Program will be established to provide counseling and other
assistance to the employees and family members of Federal agencies which partici-
pate in the financial support of this program. The range of problems to be
covered includes any emotional-behavioral problem -- especially those related C
to alcohol/drug use -- which may adversely impact on job behavior or perfor-
mance. Services shall include: (1) acceptance of management, union, or self
referrals where professional counseling is necessary, (2) evaluation of presenting
problemss, (3) referral to appropriate community treatment resources, (4) indi-
vidual counseling at the site as appropriate, (5) monitoring of employee progress,
(6) management consultations as requested, (7) training agency officials and
employees, (8) statistical reports to participating agencies.
A. Policy concepts
The policy concepts under which the program will operate are contained
in Federal Personnel Manual Chapter 792-5, Federal Personnel Manual
Supplement 792-2, Federal Personnel Manual Letter 792-8 dated August 25,
1977, and Federal Personnel Manual Letter792-9 dated May 23, 1979.
Attachment to FPM Letter 792-12
B. Scope of Work
1. See Appendix B to FPM Letter 792-_ Section C. "Scope of Work."
2. Managers and/or personnel officers of participating agencies will
provide advice and assistance in the application of policies, procedures
and guidelines of the Employee Counseling Services Program. This
includes the referral of employees for assistance, and the administration
of appropriate personnel actions when indicated.
3. The service provider shall annually provide each participating agency
with the statistical information required by the U.S. Office of Personnel
C. Program Administration
1. Administration of the Program shall be the responsibility of the
(Lead Agency) Administrative expenses shall be borne
by the (Lead Agency) and shall (or shall not) be charged
to participating agencies. Each participating Agency shall designate by
name and/or title no more than one person who will represent that Agency
concerning the program, its services and operations, and the negotiations
concerning such with the (Lead Agency)
2. The funds transferred to the (Lead Agency) shall be
used to support expenditures required in the operation of the program.
Title to and ownership of property purchased from funds transferred under
this Agreement shall reside with the (Lead Agency)
for joint use of the participating agencies.
3. The estimated cost for the operation of the Employee Counseling
Services Program for each Fiscal Year shall be furnished annually and
will be considered a supplement to this Agreement. Billing shall be
made in advance for the entire amount due from each Agency in accordance
with budgetary requirements. Costs are allocated to each Agency as
4. Provided funds are available, the agency (or agencies) for which the
services are provided agree to make a further transfer of funds to the
extent it is mutually determined that unanticipated exigencies such as
pay adjustments, and unusual payments for sick or annual leave of employ-
ees assigned to the Employee Services Counseling Program cannot be ab-
sorbed within the limit of funds already transferred.
5. The (Participating Agency) shall be solely responsible, with
regard to compliance with the Privacy Act of 1974 (5 U.S.C. 552a), for
records pertaining to their employees, including responding to general
inquiries, specific requests for access or amendment made by a participant,
and third party requests for records and for identification of these
records in the participating agency's Federal Register notice for the
system of records covering them.
6. This Agreement may be amended by mutual written agreement. It may
be terminated by the participating parties upon 30 days' written notice,
provided that such termination does not require substantial additional
financial support of the program by the remaining participating agencies
for the rest of the Fiscal Year.
Attachment to FEM Letter 792-12 (10)
The (Participating Agency) agrees to reimburse the
(Lead Agency) for the year beginning
(a set-up cost of $ plus)
$__per capital for each employee located within the greater
Agency population within this area is employees.
Therefore the (Participating Agency) agrees to reimburse
the (Lead Agency) $ ._
BILLING ADDRESS FOR PARTICIPATING AGENCY:
Attachment to FPM Letter 792-12 (11)
Request for Proposals: Sample materials and other factors to be considered
Language detailing the contracting and business aspects of a Request for Proposals
will be provided by the responsible Contracting Officer.
The following two sections suggest:
Sample statements on standard program or technical items for use
in an RFP
Additional program or technical factors which must be considered in
developing an RFP
I. Sample statement on standard program or technical items
A. Background and Objective
42 U.S.C. 4541 (Public Law 91-616, as amended) and 21 U.S.C. 1101 (Public
Law 92-255, as amended) provide that Federal agencies shall be responsible
for developing and maintaining appropriate prevention, treatment and re-
habilitation programs and services for Federal civilian employees with
alcohol or drug problems. Where feasible, these program services should
be extended to families of employees with such problems, and to employees
with alcohol or drug dependent family members. 5 U.S.C. 7901 provides
that occupational health programs may be established to promote and maintain
the physical and mental health fitness of Federal employees. In order to
accomplish these objectives, an Employee Counseling Services Program will be
established to provide counseling and other assistance to the employees and
family members of Federal agencies, which participate in the financial
support of this program. The range of problems to be covered includes any
emotional/behavioral problem -- especially those related to alcohol/drug
use -- which may adversely impact on job performance or behavior.
Services shall include (1) acceptance of management, union or self referrals
where professional counseling is necessary, (2) evaluation of presenting
problemss, (3) referral to appropriate community treatment resources, (4)
individual counseling at the site as appropriate, (5) monitoring of employee
progress, (6) management consultations as requested, (7) training of agency
officials and employees (8) statistical reports to participating agencies.
Acting on behalf of the participating agencies, the (Lead Agency)
seeks the services of a qualified professional Counselor, hereinafter
referred to as the Contractor or principal Counselor, who shall provide
these services by a contract under management of the (Lead Agency)
B. Policy Concepts
The policy concepts under which the Program will operate are contained in
the above cited statutes and in the Federal Personnel Manual Chapter 792-5,
Federal Personnel Manual Supplement 792-2, Federal Personnel Manual Letter
792-8 dated August 25, 1977, and Federal Personnel Manual Letter 792-9
dated May 23, 1979.
Attachment to FPM Letter 792-12 (12)
These concepts include the following:
1. The Federal Government as an employer, recognizes emotional
disorders, alcoholism or other drug abuse as treatable health
problems. ..... ...
2. Employees having one of these health problems should receive
the same careful consideration and offer of assistance that is J
presently extended to employees having any other illness or health
problem. i ,
3. Agencies are not concerned with an employee's use of alcohol
or other drugs except when it interferes with the employee's efficient
and safe performance of his/her duties, reduces his/her dependability,
or reflects discredit on the employing agency. In such situations,
the Federal manager concerned will take action in the form of (1)' ma-
disciplinary procedures under which the employee will first be offered
rehabilitative assistance; (2) failing response which results in
acceptable work performance, invoking regular, disciplinary procedures
for dealing with a problem situation, and (3) apprising law enforcement
officials when an employee's problem also involves criminal conduct
potentially harmful to others.
4. The confidential nature of the medical/counseling records maintan i'
in the operation of the Employee Counseling Services Program will be
protected in accordance with requirements of Public Law 93-282 and the
implementing Federal regulations, as well as Public Law 93-579 (Privacy
5. Sick leave will be granted to employees for the purpose of treat-
ment or rehabilitation as in any other illness or health problem in-
accordance with regulations of the U.S. Office of Personnel Management.
6. Employees of Federal agencies who themselves feel they may be ,.i
suffering from emotional disorders, alcoholism or other drug problems,
shall be encouraged to voluntarily seek counseling and information an
a completely confidential basis by contacting the Employee Counseling
Services Program directly.
7. The Employee Counseling Services Program shall refer the troubled
employee to his/her personal physician, or established community
resources and facilities, as available, for treatment and rehabilitative
8. The role of management is regarded as critical and will be stressed
in implementation of the Employee Counseling Services Program. As
specified in Part C below, training will be provided to managers by.
the contractor, who will encourage them to consult with the program |
counseling staff for advice in handling problem situations. .2.1
9. The support and active participation of labor organizations will be
a key factor in the success of any Employee Counseling Services Program.
Therefore, agencies are reminded of their obligations under 5 USC 71, to
negotiate, when appropriate, with those unions which have been accorded :
exclusive recognition, or consult, when appropriate, with those unions N
which have consultation rights, in formulating and implementing ECS
policies and programs.
Attachment to FPM Letter 792- 12 (13)
C. Scope of work
The participating organizations include about Federal agencies,
or components thereof, with an aggregate population of approximately
employees. The Provider proposing to purvey this program
should consider staffing so as to allow for case acceptance at regular
times on every workday of the employee population at _
It shall be the responsibility of the contractor to determine the need
for regular or occasional part-time, associate counselors, counseling
aides or other related health specialists, as well as for one principal
counselor and clerical support.
The Provider shall be responsible for establishing and coordinating
the program in close collaboration with and under the general oversight
of the (Lead Agency) and a committee of participating
agency representatives. The Provider will plan, develop, use, maintain
and manage a record system in accordance with applicable laws and
regulations relating to alcohol and drug prevention,. treatment and
rehabilitation; the Privacy Act of 1974; and other applicable laws,
regulations and guidelines governing confidentiality of medical coun-
seling records, and will be subject to the penalties imposed by such
laws for improper disclosure.
The Provider shall develop and conduct an initial three hour training
program for each of the following audiences from every agency parti-
cipating in the support of the program: supervisors/managers and union
officials, security and guard forces, medical personnel, personnel and
EEO staff. Such training shall be designed to help these groups use
the program effectively in the performance of their responsibilities.
Training programs will include all of the above listed personnel; no
one session shall include more than 35 attendees. In addition, the
Provider shall develop and conduct general employee education programs,
designed to educate employees about alcohol and drugs; dependency and
addiction; and its impact on the family. All of the above courses --
when delivered by a contractor (vs. a Federal agency Provider) -- are
subject to the approval of the Government, prior to the performance of
The Provider will accept management, union or self-referrals, as well as
referrals from health units and medical personnel providing occupational
health services to agencies participating in this cooperative program.
The Provider will consult with the referring party, providing guidance
where appropriate, in confronting the employee's job behavior or per-
Direct counseling will be offered to employees; the counselor's activities
will be directed toward initial evaluation and when necessary, referral
of the employee to community or other resources in such a manner as
will permit appropriate and skillful management of the problems presented.
The Provider must therefore develop and maintain close working relation-
ships with community resources which offer treatment and rehabilitative
assistance. Likewise, counselors must possess the necessary skills to
enable them through interviewing employees to determine the nature of
their problems. If necessary the counselor shall also refer the em-
ployee for further medical evaluation, diagnostic workup and such other
health or psychiatric information as will permit appropriate case
management official of the employee's progress in treatment, as-
sisting where possible in Job adjustment.
2. Specific procedures for case handling
(a) Management-initiated referral
(1) Supervisors should:
Be alert, through continuing observation, to, changes in
the work or job behavior, or both, of assigned employees..
Document specific occasions when an-employee's work
performance, behavior or attendance fails to meet
minimum standards or where the employee's pattern of
performance appears to be deteriorating.
Advise medical or counseling staff, or both, of the
employee's problem, and the possibility of a referral
to them. Supervisors must be able to describe job
behavior to the counseling staff but should not attempt
to diagnose or draw conclusions. This is a medical or
Conduct an interview with the employee focusing on poor
work performance and inform the employee of available
counseling services if poor performance is caused by any
personal or health problem.
If the employee refuses help, and performance continues
to be unsatisfactory, provide a firm choice between
accepting agency assistance through counseling or pro-
fessional diagnosis of his or her problem, and cooperation
in treatment if indicated, or accepting consequences
provided for unsatisfactory performance.
(2) Program counselors should:
Interview management officials, as requested, and provide
them with guidance in confronting employees with job per-
formance or behavior problems. Advise management officials
regarding client confidentiality requirements.
Interview the employee and, with the employee's knowledge
and written consent, obtain the appropriate information
including medical history, if necessary, to determine the
nature of the employee's problem.
Attachment to FPM Letter 792-12 (15)
Determine the nature of the health problem, and if
necessary, make referrals to the health unit or local
community resources as may be necessary for further medical
evaluation, diagnosis and/or rehabilitative assistance.
After professional assessment of the case, advise the
employee of appropriate, available community treatment
resources, help make arrangements for utilizing them and
encourage the employee to participate in a rehabilitation
Maintain on-going contact with the community 'treatment
program to which the employee is referred, and on-going
contact with the employee.
Throughout the treatment program, as allowed by the
confidentiality requirements, be available to the super-
visor to discuss rehabilitative efforts and their relation-
ship to job performance; to the family; to the Health Unit's
professional staff; or other treatment resources, for
maintenance of a well coordinated rehabilitation program.
(b) Employee-initiated referral
(1) When an employee self-refers to the Program, he/she
will receive counseling and be referred to community
resources or facilities for such assistance as is
appropriate or necessary.
(2) In such self-referral situations the confidentiality
requirements will be strictly observed and the employee
will not ordinarily be asked to sign a consent releasing
information to his/her supervisor.
(3) If an employee drops out of a treatment program, documenta-
tion of the case file should show that this has taken
place and no further action shall be taken.
(4) Should a voluntary referral case be in progress and the
employee's supervisor contacts the counseling staff of
program with documentation of the employee's work perfor-
mance deterioration or aberrant behavioral patterns at
work, the Employee Counseling Services Program will confer
with the supervisor, as in Part C2(a)(l) above, but will
adhere to the confidentiality requirements strictly,
giving no indication of the employee's previous self re-
ferral. The employee may then, if appropriate, be
contacted and advised of the potential need to sign a
consent to give information to the supervisor.
Attachment to FPM Letter 792-12 (16)
D. Managers Relationship to the Employee Counseling Services Program
Managers are responsible for careful and consistent evaluation of the performance
of their employees. They should feel free to seek the guidance of the Program
staff in dealing with employee problem situations. They should unhesitatingly
offer employees information on available health and counseling services, and,
with the cooperation of personnel specialists, should seek to assist employees
who may initially refuse help even though their work performance and behavior
continues to be unsatisfactory.
Specific recommended management action is detailed above in Part C2(a)(l).
E. Program Coordinators Relationship to the Employee Counseling Services Program
Program Coordinators are the officials designated by each of the participating
agencies to administer the Program for their respective employees. As such,
they are ultimately responsible for the effectiveness of their agency's Program,
even though many of the skilled services are provided by a contractor. Where
that is the case, the responsibilities of an agency's program coordinator may
Developing installation policy and program design
Evaluating installation program results
Serving as a liaison between the service provider and the
installation's pertinent management systems
With the other participating agency representatives, selecting
and monitoring the service provider.
In cooperation with the provider, preparing necessary management
Although program coordinators do not provide day-to-day supervision of contractor
personnel, a close and cooperative working relationship must be maintained. As
indicated by the confidentiality regulations, program coordinators are part of
their respective agency's alcohol and drug abuse prevention function; they and
the contractor personnel are therefore equally subject to the confidentiality 7.
requirements, and the exchange of client information between them does not
constitute disclosure under those regulations.
F. Role of Personnel Offices
Personnel offices of the agencies which participate in the cooperative Employee
Counseling Services Program, will provide advice and assistance in the application
of the policies, procedures and guidelines of the Program. This includes referral
to the Program and the administration of appropriate personnel actions when in-
The staff of servicing personnel offices as well as officials designated for
Privacy Act matters should be included among those who are assigned to attend
training and educational sessions provided by the Contractor. They will also
assist in the presentation of training and educational programs to other super-
visory personnel of their agencies on a supplemental basis.
Attachment to FPM Letter 792-12 (17)
Personnel Offices will:
1. Foster union cooperation in program development and implementation.
2. Provide statistical and other supporting information about their work
3. Provide resources and other assistance in regard to the training and
education of their supervisors.
4. Work closely with the principal Counselor and/or his staff in resolving
job related problems of employees participating in the program.
5. Ensure that steps have been taken to foster rehabilitation of employees
before processing disciplinary actions against them.
6. Advise in the administration of disciplinary actions if these become
G. Role of the Contracting Officer's Representative
The agency signing the contract with the provider will designate a Contracting
Officer's Representative (COR) who,working closely with a management committee
of participating agencies, will monitor the performance of this contract on its
behalf. The COR will provide no supervisory or instructional assistance to
Contractor personnel. His/her function is primarily to provide the Contractor
with working data. The COR is not empowered to make any commitments nor is
he/she authorized to make any changes which affect the contract price, terms,
or delivery. Any such proposed changes shall be brought to the immediate atten-
tion of the Contracting Officer for action. The acceptance of any change by
the Contractor without the specific approval and written consent of the Contrac-
ting Officer will be at the Contractor's own risk.
H. Case Files
The Contractor will be responsible for maintaining complete, individual case
files for every employee who is referred for assistance. Such case records
will be maintained in accordance with the confidentiality requirements of PL
93-282 and the implementing Federal regulations (particularly section 2.11(n),
of 42 CFR Part 21 as well as PL 93-579 (Privacy Act).
All records of the Employee Counseling Services Program are considered to be
under the jurisdiction of the agency for which the employee works. The Provider
is a qualified service organization, as defined in Sec. 2.11(n). Upon ter-
mination of this contract for whatever reason, the records shall be surrendered
to the Employee Counseling Services Program Coordinator of the agency.
I. Contractor Liability
The Contractor shall be liable for any loss or damage to any material serviced
under the contract which is caused by the Contractor's failure to exercise
such care in regard to said materials as a reasonable careful owner of similar
materials would exercise.
Attachment to FPM Letter 792-12 (18)
The Contractor also assumes all legal and professional responsibilities and
liabilities attendant on the professional practices in the rendering of health
The Contractor will submit evidence of liability insurance to the Government.
J. Rights in Data
The Contractor shall not publish or disseminate any data obtained, or information
resulting from work pursuant to this contract without prior written approval
of the Contracting Officer.
K. Privacy Act
1. The contractor agrees:
a. To comply with the Privacy Act of 1974 and the rules and
regulations issued pursuant to the Act in the'design, devel-
opment, or operation of any system of records on individuals in
order to accomplish an agency function when the contract spe-
cifically identifies (i) the system or systems of records
and (ii) the work to be performed by the contractor in terms
of any one or combination of the following: (A) design,
(B) development, or (C) operation;
b. To include this solicitation notification contained in
this contract in every solicitation and resulting subcontract
and in every subcontract awarded without a solicitation when
the statement of work in the proposed subcontract requires
the design, development, or operation of a system of records
on individuals to accomplish an agency function; and
c. To include this clause, including this paragraph c., in
all subcontracts awarded pursuant to this contract which require
the design, development, or operation of such a system-of
2. In the event of violations of the Privacy Act, a civil action may be
brought against the agency involved where the violation concerns the
design, development, or operation of a system of records on individuals
to accomplish an agency function, and criminal penalties may be imposed
upon the officers or employees of the agency where the violation concerns
the operation of a system of records on individuals to accomplish an
agency function. For purposes of the Act when the contract is for the
operation of a system of records on individuals to accomplish an agency
function, the contractor and any employee of the contractor is considered
to be an employee of the agency.
3. The terms used in this clause have the following meanings:
1. "Operation of a system of records" means performance of
any of the activities associated with maintaining the system
of records including the collection, use, and dissemination
of records including the collection, use, and dissemination
Attachment to FPM Letter 792-12 (19)
2. "Record" means any item, collection, or grouping of
information about an individual that is maintained by an
agency, including, but not limited to, his education,
financial transactions, medical history, and criminal or
employment history and that contains his name, or the
identifying number, symbol, or other identifying particular
assigned to the individual, such as a finger or voice print,
or a photograph.
3. "System of records" on individuals means a group of
any records under the control of any agency from which in-
formation is retrieved by the name of the individual or by
some identifying number, symbol, or other identifying par-
ticular assigned to the individual.
II. Additional program or technical factors to be considered in developing an
A. Preproposal Conference
Given the relative newness of cooperative Employee Counseling Services
Programs among Federal agencies, a preproposal conference with prospective
offerors may be useful. The purpose of such a meeting is to provide
information concerning the Government's requirements which may be helpful
in preparation of proposals, and to answer any questions which prospective
offerors may have about the solicitation.
B. Qualifications of the Contractor and/or Counselors
The above Section IC, "Scope of Work" outlines the tasks to be performed
by the provider. These tasks require expertise in:
training and education
and problem definition and referral to appropriate
community treatment resources
Moreover, expertise is required in:
performing these tasks in a work setting.
dealing effectively with a broad range of behavioral
problems -- particularly addiction and dependency, and
its impact on the family.
Potential providers will present evidence of their capacity to perform
these tasks through a combination of:
appropriate formal education and training
directly relevant experience
and references which can attest to their effectiveness
providing the required services in a work setting.
Attachment to FPM Letter 792-12(20)
In selecting staff, potential providers should take note of Section I.I.
above, relating to contractor liability.
C. Substitution of Personnel
1. The Offeror agrees to assign to any contract resulting from this
solicitation those persons whose resumes were submitted with his/her I
proposal who are necessary to fill the requirements of the contract.
No substitutions shall be made except in accordance with this clause. 1
2. The Offeror agrees that during the first ninety (90) days of the
contract performance period no personnel substitutions will be permitted
unless such substitutions are necessitated by an individual's sudden
illness, death, or termination of employment. In any of these events,
the Contractor shall promptly notify the Contracting Officer and provide
the information required by Paragraph (c) below. After the initial nneaty
(90) day period, all proposed substitutions must be submitted, in writing,
at least fifteen (15) days, (thirty (30) days if a security clearance is
to be obtained), in advance of the proposed substitutions to the Contrac-
ting Officer, and provide the information required by Paragraph (c) below.
3. All requests for substitutions must provide a detailed explanation of
the circumstances necessitating the proposed substitutions, a complete
resume for the proposed substitute, and any other information requested
by the Contracting Officer needed by him/her to approve or disapprove the
proposed substitution. All proposed substitutes must have qualifications
that are equal to or higher than the qualifications of the person to be
replaced. The Contracting Officer or his authorized representative will
evaluate such requests and promptly notify the Contractor of his/her
approval or disapproval thereof.
D. Financial Disclosure Statement of all Contractor Personnel
Included in all proposals will be signed financial disclosure statements
from the contractor and all subordinate personnel proposed to perform under
the contract, detailing the extent of their financial interest in any
community treatment facility or other resource to which employees might
be referred as a result of this program.
E. Technical Proposal Evaluation Criteria
The following criteria are suggested for use in the proposal evaluation,
with each criterion weighted as indicated:
1. Qualifications of Personnel Performing 50Z
Training, Problem Evaluation, and
General counseling and problem evaluation
Attachment to FPM Letter 792-12 (21)
Specific counseling experience 20%
with alcohol and drug dependent
persons in an occupational setting
Specific counseling experience with 10%
families of alcohol or drug dependent
2. Technical Approach: Understanding the Problem 25%
a. Knowledge of employee counseling services
program concepts, policy and operation
b. Knowledge of principles of counseling in
c. Methods of maintaining required confi-
dentiality of client information and
problems which may be encountered
d. Knowledge of needs and any special
requirements of the organizations to
e. Knowledge and use of existing area
3. Realistic Plan and Schedule 151
a. Planned program, including training,
counseling, and on-going collaboration
with client agency administrators
b. Completion of training in early months
c. Suitability and accessibility of office
4. Proposed methodology of performing required 10%
a. Prior relevant training experience
b. Availability of training materials
c. Means for reinforcing initial training
Offerors shall submit information sufficient to evaluate their proposals
based on the detailed criteria listed above. Failure to provide the
information required in order to evaluate the proposal may result in
rejection of the proposal without further discussion. Offerors shall
submit their proposal organized in a technical quality on a 100 point
scale for a total rating of 0 to 100 points.
Attachment to FPM Letter 792-12(22)
Equal weight will be given to the business/cost aspects of the
F. Program Initiation
The Contractor for the Employee Counseling Services Program will initiate
the program by providing training sessions for key employees of the
agencies to be served including personnel, EEO, and medical officials;
security and guard forces; and 152 of the supervisors and interested
The training of these officials about the Employee Counseling Services Pro- |
gram, as herein described, shall include, but is not limited to the followlag
1. Availability of advice and consultation for supervisors
and other management officials
2. Definition of a problem employee
3. Supervisor's role in dealing with a problem employee
4. Need for client privacy and confidentiality
5. Self vs. management or union referrals
6. Method of providing feedback to referring official
The Contractor shall arrange a sufficient number of training groups and
training sessions to accomplish the training of approximately 15Z of
supervisors from each participating agency within the first 100 days of
the contract period; an additional 40Z within the next 100 days; and the
balance during the remainder of the first year.
Within the first 100 days, the provider shall also orient or otherwise
inform all employees covered by the Program of its operation.
G. Deliverables and Time of Delivery
The Contractor shall submit to the Contracting Officer's Representative
one copy of the following reports in the time periods specified below:
1. Monthly report of training/educational sessions held to
include not less than a summary of the training material
covered; the name and agency of all supervisors who
attended training sessions; samples of educational materials
2. A monthly report of all new cases referred by agency and
classification of.health problemss.
3. Monthly status report on all active cases including
information on number of employees counseled by agency;
classification of health problem; family involvement;
type of referral made and the resource to which the
employee was referred; prognosis, and disposition of
cases dropped and completed.
ases dropped and completed.
Attachment to FPM Letter 792-12 (23)
Responsibilities of the Contracting Officer's Representative
The principal areas of responsibility of the COR during contract performance
are summarized below:
1. Monitor the contractor's performance to assure compliance with technical
requirements of the contract.
2. Review and approve progress reports, technical reports, and other items
required for approval. Notify the Contracting Officer if said reports
or other items submitted are to be rejected and state basis for rejection.
3. If performance is not satisfactory or if problems are anticipated, notify
the Contracting Officer as to the cause and recommend a course of action
from a technical standpoint. Immediate notification is essential to assure
that the Contracting Officer takes appropriate action to protect the
Government's rights under the contract.
4. Advise the contractor that in the event he desires to propose a change, he
should submit his request in writing to the Contracting Officer and indicate
the effect the change will have on the contract terms and conditions. The
COR will be required to review the proposed change and advise the Contracting
Officer as to whether the proposal change should be incorporated into the
5. Assure that changes in work under a contract are not implemented before
written authorization or a contract modification is issued by the Contracting
Officer. Costs for work performed may not be allowed if not authorized under
the contract. Unauthorized changes embarass the Government as well as the
contractor. No change or commitment should be directed without prior written
authorization by the Contracting Officer.
6. Recommend in writing to the Contracting Officer changes desired in the
contract with justification for the proposed change.
7. Furnish technical advice relative to Contracting Officer approvals of sub-
contracts, overtime, travel to general purpose meetings, etc.
8. Keep the Contracting Officer informed on the context of communications with
the contractor in order to prevent possible misunderstandings or situations
that could affect contract terms and conditions and become the basis of future
claims against the Government.
9. Make site visit, when appropriate, to the contractor's facility and check
contractor performance to include the following:
a. Actual performance versus scheduled and reported
performance. Inform Contracting Officer of any
adverse conditions noted.
UNIVERSITY OF FLORIDA
II IAII I I l hA j |11 10 1 J 110 III) hi Oil JA1l
Attachment to FPM Letter 792-12 (24) 3 1262 08741 9015
b. Changes in technical performance which say affect
financial status, personnel or labor difficulties,
overextension of facilities, etc.
c. Verify that the employees charged to the contract ra :
actually performing work under the conttra4. ar .
example' if the contractor claims that t"' pera*' '**::
are assigned to the contract on a full time basis*,
there should be a determination that ten individAals
are performing work under this contract. sd6 the1 "::4
COR should evaluate whether the number of minsofeSI
assigned are in fact necessary to fulfill contract
10. At the completion of the contract, advise the Contraictin WWIfi i
a. All articles and services required to b-fuihedl *Ia
and/or performed under the contract have lMeail
b. Contractor disclosures regarding Patent and Pubi-
cation clauses of the contract.
c. Disposition of all property matters.
11. Provide liaison between the agency management neamidt ddt sigod tie
12. Facilitate liaison between the contractor and the age? .uui M:
13. Provide Federal policy guidance to both participating as WBTh
contractor, except in matters involving legal intemrpfattedS .: Si
situations, the contractor must assume responsibLU ftyf& 1uit'S |t
private legal guidance.
a Us. GOVERNMENTfPlMNTIGoo WPF M.-mtuqg ll!
private legal guidance.
a US. GOVERNMENTufInjNGU b WOPnM.-muqH !
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