Set 2 Environmental Questions and Answers 80GSFC20R0005.pdf

Environmental Services RFP 80GSFC20R0005

Questions and Answers Set 2

June 8, 2020

(Responses below are identified in bold and italics)

1. Enclosure 1, pg. 69, L.27, Instructions state that an important prerequisite for award is the

Prime Offeror must have an accounting system that has been deemed adequate by the cognizant administrative office for accumulating and reporting incurred costs. Most small businesses, especially those without an existing prime cost-plus contract, have not had their accounting systems audited by the Federal Government. To our best knowledge, DCAA does not come to audit contractors' systems when requested by contractors unless directed and paid by another Government agency. This RFP requirement, for an 8(a) small business set-aside contract, will eliminate otherwise qualified 8(a) firms from responding to this solicitation. In order to allow for the greatest extent of competition, while still providing NASA a means to evaluate Contractor Responsibility per FAR Part

9-106, we request that NASA consider requiring contractors to submit a completed “Pre-

Award Survey of Prospective Contractor Accounting System” checklist. This checklist is available on the dcaa.mil website. If this is not an acceptable solution, please provide direction to small business contractors on how they can initiate an accounting system audit with NASA.

A revised Enclosure 1 – RFP Clauses will be posted to update Provision L.24 (52.215-

203) Offer Volume and incorporate Enclosure 8 - SF1408. Below is the updated L.24 language identified in bold and italics.

FAR 16.301-3 requires that a contractor's accounting system be adequate for determining costs applicable to the contract prior to the award of a cost-reimbursement contract. The

Offeror shall provide evidence of an adequate accounting system as determined by the cognizant administrative office for accumulating and reporting incurred costs. If an

Offeror is relying on the accounting system adequacy of a Joint Venture team member, sister company, or any other affiliated company’s accounting system, they must specifically assert such an intended reliance for the performance of this contract and must demonstrate a convincing basis for using that system as a source for determining their own adequacy in this proposal volume. Offerors who do not have an adequate accounting system determination from a cognizant administrative office shall provide evidence of any independent audit and system approvals as well as documented system ability to segregate and accrue costs by contract. An offferor may submit Enclosure 8 -

Preaward Survey of Prospective Contractor Accounting System SF1408-14b from an independent accounting firm as evidence of an adequate accounting system. An adequate accounting system is not an evaluation criterion. It is a basic contract requirement with a pass/fail determination. A contract may only be awarded to the

Offeror(s) who are determined to have an adequate accounting system.

2. The equipment identified in Attachment C, Wallops IAGP, does not include much of the equipment identified in the corresponding library documents (e.g., Wallops Lab Work

Instructions, Sampling Plan for WW, SW, and DW). There are many field sampling requirements in 1.3.3 with no corresponding equipment. Is that an indication that the list is incomplete or that the equipment will not be provided?

The equipment identified in Attachment C, Wallops IAGP, is the government equipment located at Wallops Island, VA, that is classified “Controlled Equipment” to be made available for use on the contract. Additional equipment that is classified as

“Administratively Controlled Equipment” (generally items having an acquisition cost of less than $5,000) is also available. An updated Attachment C, Wallops IAGP, will be posted.

3. FAR 52.219-14 Limitation of Subcontracting is dated July 2019 but references the

Deviation. The clause itself was updated March 2020 to include the deviated clause language which allows for similar situated entities. It also requires the CO to state how

Limitation of Subcontracts applies (i.e. by year, by order, by total contract). Would you please confirm that similar situated entities are included in the Limitation of Subcontract calculation? Will you clarify the second part of the clause to state how/when the calculation will apply to this contract?

Clause I.118 (52.219-14) Limitations on Subcontracting (Deviation)(July 2019) has been deleted and replaced in its entirety in Enclosure 1 – RFP Clauses with the below:

I.118 (52.219-14) LIMITATION OF SUBCONTRACTING (MAR 2020) (DEVIATION)

(a) This clause does not apply to the unrestricted portion of a partial set-aside.

(b) Definition. “Similarly situated entity,” as used in this clause, means a first-tier subcontractor, including an independent contractor, that—

(1) Has the same small business program status as that which qualified the prime contractor for the award (e.g., for a small business set-aside contract, any small business concern, without regard to its socioeconomic status); and

(2) Is considered small for the size standard under the North American Industry

Classification System (NAICS) code the prime contractor assigned to the subcontract.

(c) Applicability. This clause applies only to—

(1) Contracts that have been set aside for small business concerns or 8(a) participants;

(2) Part or parts of a multiple-award contract that have been set aside for small business concerns or 8(a) participants;

(3) Contracts that have been awarded on a sole-source basis in accordance with subpart

19.8;

(4) Orders set aside for small business concerns under multiple-award contracts, as described in 8.405-5 and 16.505(b)(2)(i)(F), if the order amount is expected to exceed the simplified acquisition threshold;

(5) Orders competed among 8(a) participants in accordance with subpart 19.8 under multiple-award contracts, as described in 8.405-5 and 16.505(b)(2)(i)(F), regardless of dollar value;

(6) Contracts using the HUBZone price evaluation preference to award to a HUBZone small business concern unless the concern waived the evaluation preference; and

(7) Orders issued directly to small business concerns or 8(a) participants under multiple-award contracts as described in 19.504(c)(1)(ii).

(d) Independent contractors. An independent contractor shall be considered a subcontractor.

(e) Limitations on subcontracting. By submission of an offer and execution of a contract, the Contractor agrees that in performance of a contract assigned a NAICS code for—

(1) Services (except construction), it will not pay more than 50 percent of the amount paid by the Government for contract performance to subcontractors that are not similarly situated entities. Any work that a similarly situated entity further subcontracts will count toward the prime contractor’s 50 percent subcontract amount that cannot be exceeded.

When a contract includes both services and supplies, the 50 percent limitation shall apply only to the service portion of the contract. Other direct costs are excluded to the extent they are not the principal purpose of the contract and cannot be obtained from small business concerns;

(2) Supplies (other than procurement from a nonmanufacturer of such supplies), it will not pay more than 50 percent of the amount paid by the Government for contract performance, excluding the cost of materials, to subcontractors that are not similarly situated entities. Any work that a similarly situated entity further subcontracts will count toward the prime contractor’s 50 percent subcontract amount that cannot be exceeded.

When a contract includes both supplies and services, the 50 percent limitation shall apply only to the supply portion of the contract;

(3) General construction, it will not pay more than 85 percent of the amount paid by the

Government for contract performance, excluding the cost of materials, to subcontractors that are not similarly situated entities. Any work that a similarly situated entity further subcontracts will count toward the prime contractor’s 85 percent subcontract amount that cannot be exceeded; or

(4) Construction by special trade contractors, it will not pay more than 75 percent of the amount paid by the Government for contract performance, excluding the cost of materials, to subcontractors that are not similarly situated entities. Any work that a similarly situated entity further subcontracts will count toward the prime contractor’s 75 percent subcontract amount that cannot be exceeded.

(f) A joint venture agrees that, in the performance of the contract, the applicable percentage specified in paragraph (e) of this clause will be performed by the aggregate of the joint venture participants.

(g) The Contractor shall comply with the limitations on subcontracting as follows:

(1) For contracts, in accordance with paragraphs (c)(1) and (2) of this clause—

[Contracting Officer check as appropriate.]

X By the end of the base term of the contract and then by the end of each subsequent option period; or

X By the end of the performance period for each order issued under the contract.

(2) For orders, in accordance with paragraphs (c)(3) and (4) of this clause, by the end of the performance period for the order.

(End of clause)

4. Would the government provide a comprehensive list of ODC's or the historical ODC costs on the current contract to allow price to be more competitive among all bidders?

The government has provided costs for waste disposal and permit fees, other ODC’s are to be proposed by the Offeror based on the technical approach.

5. The RFP section L.27, (3) Government Pricing Model (GPM), requires the use of

Enclosure 5 for the GPM-specified Non-Management hours. The hours in Enclosure 5 are only provided for the Offsite location. The Cover letter of the RFP and Section F.3 state that the place of performance will the Wallops Flight Facility, GSFC, other NASA

Centers where GSFC has environmental responsibility, and contractor's facilities. Is

Enclosure 5 correct? Will offerors need to plan to house all employees in contractor-provided facilities?

Yes, Enclosure 5 only includes pricing for offsite staffing. Only offsite employees need to be housed at a contractor facility.

6. L.27, page 76. BOEs are required to be submitted by the Prime and Significant

Subcontractors, to explain Program Management, Administrative Support, and how subcontracts were estimated in the GPM BOE, and for the Core Requirements at the

WBS Level 3. Assuming the WBS Level 3 in Attachment F, there are 9 WBS Level 3 that require a BOE, plus the required GPM BOE elements to explain in only 16 total pages for the total prime and subcontractor component. Would the Government allow either an increased page count, or 16 pages per prime and each subcontractor, in order allow sufficient space to fully explain and justify the elements required by the RFP?

The Government has considered this request but believes the allotted pages for the

BOEs are adequate for the offeror’s response.

7. L.27, page 73. The instructions tie Exhibits 2A-2D to the sites they are included on in

Exhibit 1A. Since there are only GPM hours provided for Offsite Non-Management

Labor Categories, Exhibit 2A would only be provided for this one site, for example. How does the Government intend for the Direct Labor Rates for other sites to be developed for purpose of using on the Core Requirements and including in the

Attachment H IDIQ Rate Matrix?

The Labor Categories shall be classified as either onsite or offsite. The RFP requires offerors to provide onsite and offsite rates in Attachment H IDIQ Rate Matrix.

According to the RFP, Onsite is defined as NASA Goddard Space Flight Center and

Wallops Flight Facility. Offsite is defined as the Contractor’s facility.

8. RFP Section L.27, page 69, instructions state that an important prerequisite for award is the Prime Offeror must have an accounting system that has been deemed adequate by the cognizant administrative office for accumulating and reporting incurred costs. Most small businesses, especially those without an existing prime cost-plus contract, have not had their accounting systems audited by the Federal Government. And to our best knowledge, DCAA does not come to audit contractors' systems when requested by contractors unless directed and paid by another Government agency. This RFP requirement, for an 8(a) small business set-aside contract, will eliminate otherwise qualified 8(a) firms from responding to this solicitation. In order to allow for the greatest extent of competition, while still providing NASA a means to evaluate

Contractor Responsibility per FAR Part 9-106, we request that NASA consider requiring contractors to submit a completed “Pre-Award Survey of Prospective Contractor

Accounting System” checklist. This checklist is available on the dcaa.mil website. If this is not an acceptable solution, please provide direction to small business contractors on how they can initiate an accounting system audit with NASA.

Refer to the response to question 1 above.

9. L.27, page 71. The instructions require offerors and significant subcontractors provide one separately packaged copy of their Cost Volume proposal marked "Enter correct RFP number/NASA Proposal Evaluation Material" which the Government may use for audit support purposes. As this RFP requires total electronic submission, does this requirement still stand and if so, how would the Government like these additional files delivered?

The proposals are being submitted electronically through LFT, therefore, the separate

Cost Volume for audit support purposes is no longer required. This paragraph is being deleted from the RFP, “Offerors, including proposed significant subcontractors, shall provide one separately packaged copy of their Cost Volume proposal marked

“Enter correct RFP number/NASA Proposal Evaluation Material,” which the

Government may use for audit support purposes.” A revised Enclosure 1 – RFP

Clauses will be posted to delete this paragraph. The correction will be identified in bold and italics.

10. L.26, page 66, A.8. The instructions for the Position Qualifications require written descriptions for each specific labor category proposed for contract performance. It states that per the directions in the Cost Volume Instruction, these position qualifications should be included in the Cost Volume. Can NASA confirm if the Position Qualifications should be included in Volume II (with 1 page per position) and in Volume IV. Also, should the

Position Qualifications include both onsite and offsite labor categories?

The position qualifications should be submitted in the Cost Volume III as part of

Attachment H. The position qualifications should not be part of Volume II Mission

Suitability or Volume IV Past Performance. Below is the corrected matrix. A revised

Enclosure 1 – RFP Clauses will be posted to correct the matrix. The correction will be identified in bold and italics. Yes, position qualifications should be submitted for all labor categories.

11. L.26, page 69, Section B5. Please verify that if the contractor intends to operate the lab, does that make the contractor a tenant subject to tenant fees? If so, please provide information about these fees.

NASA facility space provided to the Offeror for use in accomplishing the requirements of this contract will not result in tenant fees.

12. Is there a commercialization clause?

Proposal Component Volume Reference Page Limitations

Offer Volume I L.24 None

Mission Suitability Volume II L.26 40 Pages

Cover Page, Indices, SOW

Compliance Matrix, Total

Compensation Plan, Phase-in Plan, List of Acronyms, Safety and Health

Plan, and Quality Assurance Plan

Excluded

Core Contract Hours and Skill Mix Excluded

Cost Volume III L.27 Mixed

(a) Direct Labor Rates, Indirect Rates, and Fee Matrices (Attachment H)

None

(b) Cost Exhibits None

(c) Basis of Estimates 16 Pages**

(d) Position Qualifications 1 Page per Position

Past Performance Volume IV L.28 Mixed

(a) Information from the Offeror 30 Pages**

(b) Cover Page, Indices, Customer

Evaluations, Termination/Descope information, and List of Acronyms

Excluded

No, there is no commercialization clause in this RFP.

13. Please verify that the Mission Suitability, Subfactor B.3 Core Contract Hours should be provided for the Base Year only.

The CORE contract hours should be provided for the base year and all option years.

14. Enclosure 8, Contract Historical Data Direct Labor Incumbent Rates. Please confirm that all labor categories for incumbents and the levels have been provided.

No. The historical data provides representative data and rates from current contracts.

15. We would like to request clarification regarding the past performance project size standards. Can relevant projects be submitted if the project value is less than $750,000?

No. The minimum average annual cost/fee incurred for recent and relevant past performance is $750,000. Anything submitted less than the $750,000 will not be rated as relevant.

16. The government previously advertised intent to hold two site visits (one for each site).

Such an event was held on the previous procurement. We request the government hold a virtual site visit/pre-proposal conference to best communicate the intents of the procurement and the contract and proposal requirements.

At this time the Government is not going to conduct a virtual site visit or a pre-proposal conference.

17. Attachment C, Goddard Installation Accountable Government Property: In the column labeled “Number of Items, some of the government property listed shows values of zero.

Please confirm these zero quantity items are not required to be used on the contract.

A corrected Attachment C, Goddard Installation Accountable Government Property, will be provided.

18. Attachment C, Wallops Installation Accountable Government Property: No quantities are provided for the items shown. Please confirm the quantities are one each for the equipment listed.

In Attachment C, Wallops Installation Accountable Government Property, each line is an individual item.

19. Enclosures 1 and 5 make reference to Manufacturing Sites. Attachment D does not require reporting based on manufacturing site requirements. Please clarify the manufacturing site cost accounting and reporting requirements for the contract.

The contract is not being used for manufacturing.

20. Please confirm the base year period of performance is February 1, 2021 through January

31, 2022.

Confirming that the base year period of performance starts February 1, 2021 through

January 31, 2022. Services at the Wallops Flight Facility shall be provided beginning

April 1, 2021.

21. Enclosure 1, Page 67, A.10 Phase-In Plan states” The Offeror shall provide a detailed phase-in plan that will ensure continuity and a smooth transition with the incumbent

Contractor during the 30-day phase-in period.” Attachment A, Page 8, 1.3

ENVIRONMENTAL PROGRAM CORE REQUIREMENTS states "The following services shall be provided to GSFC’s Greenbelt and Wallops Flight Facility campuses, including local, non-contiguous locations, throughout the period of performance of this contract. For the Wallops Flight Facility (Wallops), services shall be provided beginning April 1, 2021.” These requirements imply the successful offeror must complete two, separate, 30-day phase-in periods for each NASA site. If so, please clarify Enclosure

1, Section L.26 (c) A.10.

There is only one phase in plan and phase in period for the contract. The phase in plan should include everything including how the Offeror will address when Wallops

Flight Facility starts in April 1, 2020. The phase-in-plan period may be longer than 30 days. Below is the corrected A.10 Phase-in-Plan. A revised Enclosure 1 – RFP

Clauses will be posted to clearly define the phase-in-plan.

A.10 Phase-in Plan

The Offeror shall provide a detailed phase-in plan that will ensure continuity and a smooth transition with the incumbent Contractors during the 90 day phase-in period.

The phase-in plan shall clearly demonstrate an ability to assume full contract responsibility on the effective date of the contract at Greenbelt (February 1) and at

Wallops (April 1). The phase-in plan shall also specifically address how ongoing work will be transitioned, the proposed management organization, schedule, orientation and training of personnel. If the effort involves onsite performance, the Offeror shall address its preparation for the timely processing of the Personal Identify Verification (PIV) requirements. If the phase-in plan assumes any dependency upon the incumbent contractor, please identify. Also, specify the extent of involvement of NASA personnel during this period. The phase-in period will be accomplished through the issuance of a separate firm fixed-price contract vehicle. The proposed phase-in plan will become an attachment and contractual requirement for the separate phase-in contract.

22. Enclosure 7, Page 7, 1.3.1.7 Greenbelt Findings Management shows the workload indicator as "XXX waste program findings per year.” Please provide the actual historical/average value(s).

This was addressed with Amendment 1 with a corrected Enclosure 7.

23. Enclosure 8: Please provide the applicable contract timeframe dates for the rates shown.

The contract at Greenbelt is a 5-year contract that ends on 1/31/2021. The contract at

Wallops Island is a 5-year contract that ends on 3/31/2021.

24. Exhibit 6 contains a column labeled “Personnel to be Obtained from Incumbent.” The numbers of incumbent personnel by labor category are not provided in any enclosures.

What are the quantities of incumbent personnel by labor categories?

This information is not available.

25. Are any incumbent employees represented under a collective bargaining agreement

(CBA)? If so, please provide the CBAs applicable for both the Greenbelt and Wallops sites.

The incumbent employees related to this RFP are not represented by CBAs.

26. Exhibit 12 requests travel costs by trip. No historical data is historical data is provided from the incumbent requirements

27. ‘. How does the government want the offeror to estimate the costs of travel trips to be incurred on the contract? If historical data best reflects the requirements of the new contract, please provide historical trip data to include the number of trips, people traveling per trip, and number of travel days per trip.

It is up to the offeror to propose its travel based on the technical approach.

28. Requirements for the OCI Plan in Enclosure 1, L.21 do not match Enclosure 3 OCI Plan

Outline. For example, Enclosure 1 requires that the offeror address access to sensitive information, and this is not in the Enclosure 3 outline. Many of the other requirements cannot be directly mapped to the outline. Please confirm whether we should use

Enclosure 3 or Enclosure 1 L.21 to frame our OCI Plan.

The Offeror’s OCI Plan shall include all of the elements required in L.21 and

Enclosure 3 as applicable to their proposed OCI Plan.

29. Please verify that the labor categories provided for WFF match the years of experience of incumbent staff, if retention of incumbent staff is desirable.

The historical data provides representative data and rates from current contracts.

The following question is still being reviewed by the Government:

30. For the Wallops drinking water sampling, will third-party data validation be required?

Validation typically is required, but there was no mention of it in the RFP. If so, what level of validation will be necessary?