Attachment 2 - Evaluation Criteria (Amendment 2 Version).pdf

Pension Benefit Guaranty Corporation Fixed Income Investment Services

Attachment 2: Evaluation Criteria

1. General

a. Basis for Award. PBGC will award contracts resulting from this solicitation to the responsible offerors whose proposals, conforming to the solicitation, will be most advantageous to the Government, price and other factors considered.

PBGC anticipates making seven (7) contract awards but may award more or fewer than this as determined to be in the Government’s best interests.

PBGC may select for award offerors that do not offer the lowest prices if it finds their proposals to be technically superior to those of lower-priced competitors. It may also select for award offerors whose proposals are not considered to be technically superior, but who nevertheless provide better values by virtue of their lower prices.

PBGC may, at its discretion, incorporate any portion of a successful offeror’s proposal into the contract.

b. Factors. The evaluation factors and rating methods that will be applied are summarized in the following table:

c. Importance of Factors. PBGC considers Factor 4 to be the most important. Non-price factors, when combined, are significantly more important than price.

Although the price factor has no numerical weight or adjectival rating, it is a criterion in the overall evaluation of proposals. As proposals become more technically comparable, price will become increasingly important in the agency’s award decision.

d. Evaluation Phases. PBGC will evaluate proposals in the following two phases:

i. Phase I – Pass/Fail Assessments (Factors 1 and 2): Offerors must meet the minimum criteria to proceed to Phase 2. Any offeror that does not

Factor # Title Rating Method

1 Proposal Compliance Pass/Fail 2 Offeror Qualifications Pass/Fail 3 Offeror Capability Confidence Rating 4 Strength of Product Offering Confidence Rating 5 Price N/A (Price Analysis) meet the minimum qualifications will be removed from further consideration for contract award. PBGC will notify offerors of the Phase 1 results.

ii. Phase 2 – Technical and Price Proposal Assessments (Factors 3 – 5):

PBGC will provide offerors who pass Phase 1 an invitation to submit their technical and price volumes by dates to be specified at that time. Upon evaluating these volumes, PBGC anticipates creating a competitive range composed of the highest rated proposals. Any offeror excluded from the competitive range will be removed from further consideration for contract award. PBGC will notify offerors of the Phase 2 results.

e. Negotiations. PBGC will invite offerors within the competitive range to participate in discussions (i.e., negotiations) at a mutually agreeable date and time. Discussions with non-incumbent offerors will occur in-person at the offerors’ facilities. Discussions with incumbent offerors may occur virtually or in-person, at the Government’s discretion.1

In addition to negotiating the contents of proposals, PBGC will use in-person meetings to observe aspects such as offeror personnel, subject matter expertise, written policies and procedures, and systems. If any in-person findings conflict with or in any way undermine the information in an offeror’s proposal, PBGC may adjust its rating accordingly and, if appropriate, remove the offeror from the competitive range.

Upon concluding discussions, PBGC will request revised proposals from offerors and establish a common cut-off date for final revisions. Upon considering the revised proposals against all evaluation factors, PBGC will select the awardees.

f. Incorporation of Proposals into Contracts. PBGC reserves the right to incorporate any portion of an offeror’s proposal into the final contract. Any portions not incorporated will not be part of the contract.

g. Evaluation Support Services. PBGC will utilize a contractor (Mercer, Inc.) to assist with analyzing proposals. If a proposal or any portion thereof is marked as “proprietary” or “confidential,” the Contracting Officer (CO) will ensure that a

1 The reason for this distinction between treatment of incumbent and non-incumbent offerors during discussions relates to the agency’s ability to confirm certain proposal details. Because PBGC already inspects incumbent contractors’ facilities and meets with contractor personnel in person on an annual basis, there is no need for PBGC to separately visit these contractors during negotiations unless their proposals indicate meaningful change in these areas, in which case PBGC may decide to conduct negotiations in person.

fully executed non-disclosure agreement (NDA) exists between Mercer and the offeror before permitting Mercer to review the offeror’s proposal information.

If a proposal contains such markings but no NDA is executed between the parties, the CO will make reasonable efforts to obtain one on a timely basis. If an offeror is unwilling to execute the NDA or otherwise unable to come to timely agreement with Mercer as to the terms of the NDA, the CO will prohibit Mercer from viewing the proposal and remove the offeror from further consideration for award. (Once the deadline for receipt of proposals has passed, the time remaining in which to complete an NDA will be at the Government’s discretion.)

If a proposal does not contain such markings, the CO will assume that the offeror consents to sharing proposal data with Mercer without an NDA. In such a case, Mercer would still be bound by existing procurement integrity and conflict of interest guidelines.

2. Evaluation Methodology

In evaluating each factor, PBGC will consider the information described below.*

*Amendment 2 note: PBGC has already evaluated all proposals submitted in December 2025. Therefore, if an offeror who previously submitted a proposal decides to submit an updated proposal under Amendment 2, PBGC will only evaluate the information the offeror indicates is new or changed within the cover letter. This is the case even though PBGC is instructing these offerors to resubmit their entire proposals, including documents that are unchanged. The reason PBGC is instructing these offerors to resubmit unchanged documents despite the fact that it does not intend to re-evaluate them is to preclude the possibility of errors that could occur if PBGC were to attempt to reconstruct each proposal using changed and unchanged documents.

a. Factor 1 (Phases 1 and 2) – Proposal Compliance. PBGC will assess proposal compliance at each phase with each new volume submission. This includes ensuring that:

i. The offeror is fully registered in the System for Award Management (SAM), has no active exclusions, and has completed all representations and certifications (www.sam.gov);**

ii. For each volume there is a cover letter that includes, at a minimum, the following information found at Section 8.a. of Attachment 1 – Instructions to Offerors:

A. The name, address, and telephone number of the offeror;

B. A statement identifying which financial products the offeror is proposing (minimum of two, up to one per category): Core, Credit, Global, and/or Emerging Markets Debt;

C. (For offerors updating their previous proposals only) Which documents, pages, sections, language, and/or data is new or changed from your firm’s previous proposal;

D. The following statement, completed as indicated: “I, [name of cover letter signatory], certify that [company name] leadership has reviewed the solicitation in full, understands the Government’s requirement, including the standards for acceptable performance, and believes [company name] to be fully capable of satisfactorily performing this requirement. In http://www.sam.gov/ addition, [company name] leadership has either participated in or reviewed all aspects of this proposal. The information contained herein is accurate and complete to the best of my knowledge and belief.”; and

E. The signature of a senior company official with authority to enter the offeror into a contract for this work, as well as the signature date (each cover letter requires a new signature and date).

iii. The required volumes and supporting material folders are present;

iv. All required PBGC forms and templates are submitted; and

v. If an organizational conflict of interest (OCI) is identified in the cover letter, there is an OCI Risk Mitigation Plan.**

An offeror that fails to meet any of the above will be eliminated from the competition and not considered for award.

**Offerors have until submission of Volume 3: Price Proposal to complete the items marked with an asterisk. PBGC will not eliminate an offeror upon receiving Volume 1 or Volume 2 simply because the offeror is not registered in SAM or because the offeror has indicated that an OCI may exist but has not yet produced a mitigation plan. However, PBGC will immediately eliminate any offerors that have not completed these actions concurrent with or prior to submitting their price proposals, regardless of any strengths PBGC has identified in their proposals to that point.

b. Factor 2 (Phase 1) – Offeror Qualifications. PBGC will ensure offerors have responded affirmatively to each prompt pertaining to the offeror itself and for at least two (2) products, and that the required supporting documentation is present and supportive of the offeror’s responses. PBGC may conduct additional research to confirm the accuracy of offeror responses. If the agency’s findings conflict with an offeror’s responses, the agency may request clarification from the offeror before rendering a decision; however, the offeror will not be permitted to revise its response.

An offeror that fails to meet the criteria of the Offeror Qualifications Form or that meets the criteria for less than two (2) Product Qualifications forms will be eliminated from the competition and not considered for award. For offerors that remain in the competition after Phase 1, PBGC will continue to evaluate all proposed products, including any that did not meet the Factor 2 criteria. Each contract award will include all products proposed by that offeror at fair and reasonable prices. (See Section 2.e., below, for more on price analysis.)

c. Factor 3 (Phase 2) – Offeror Capability. PBGC will review responses to the

Offeror Capability Form to assess the strength of the offeror’s business and its ability to perform this work. Each offeror considered under this factor will receive a factor-level confidence rating.

d. Factor 4 (Phase 2) – Strength of Product Offering. PBGC will review responses to the Product Attributes and Past Performance Forms to assess the people, decision-making process, and features underpinning the proposed products; the total range of products offered; and the historical performance results of the proposed products. PBGC will first assess each proposed product based on its attributes and past performance. Once it has completed its assessment of each product, PBGC will then also consider the total range of products offered and determine an overall factor-level confidence rating.

e. Factor 5 (Phase 2) – Price. PBGC will consider price using two processes to achieve distinct objectives.

First, PBGC will analyze the undiscounted price per product to determine whether the proposed rates are fair and reasonable. To determine the price per product, the agency will apply standard hypothetical allocations to each product proposed by each offeror and analyze the resulting undiscounted fees for each contract year plus the six-month extension authorized by 52.217-8. (For purposes of evaluating the six-month extension, PBGC will halve the result of the tenth contract year.)

If an offeror proposes a product with unreasonably high rates, PBGC will not include the product in any subsequent contract award unless the offeror agrees to reduce its rates for that product during discussions. Furthermore, if PBGC removes a product with unreasonably high rates from award consideration, and, as a result, an offeror is left with fewer than two qualifying products, that offeror will be ineligible for award unless PBGC includes the offeror in the competitive range and the offeror agrees to reduce its rates to reasonable level.

Second, in determining which proposals represent the best values to PBGC, the agency will calculate an overall price per proposal that covers all proposed products. To do this, PBGC will begin by applying a standard hypothetical allocation to each proposal, which will be apportioned among proposed products based on the Government’s internal estimates of future investment levels.2 At this point, PBGC will calculate the average effective rate (inclusive of all discounts) by product across all proposals, then each offeror’s variance from

2 Unlike under the first price analysis, here PBGC will consider any discounts triggered by the selected investment levels.

the product average for each product proposed by that offeror, and finally each offeror’s weighted average variance across all products proposed by that offeror.

The result will be a single figure per proposal that will enable PBGC to compare proposed prices regardless of the quantity or types of products proposed.