Rev1_ACC_APG_S3CoE_Cost_RealismSymposiumSummary9Mar18.pdf
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- ACC-APG-S3CoE-FY18-02
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ACC-APG S3CoE Cost Realism Evaluation Information Symposium on 5 Mar 18 Key Information Summary
Rev 1
There were 79 Industry registrants; 77 Industry partners and 55 Government partners attended for a total of 132 participants. We started at 9:00 am and ended at 11:00 am.
The S3CoE welcomed the attendees, outlined the agenda, provided the ground rules and fundamental principles, stated the objectives, provided an update on the outstanding action items from the 14 Dec 17 symposium and discussed the briefing slides as attached.
The four (4) panel members consisted of highly experienced ACC APG Cost/Price Analysts.
There were questions asked during the presentation of the briefing slides and during the panel discussions; the summarized questions, responses and outstanding action items during the symposium are listed below.
1. Industry question: Can we delve deeper in how you do cost realism?
Government response: The information related to some of the ways the Government may evaluate cost realism was discussed as annotated on the briefing slides 8 and 9.
2. Industry question: Can we release up front the methods used? ACC should share if they are using BLS, Salary.com, etc. up front.
Government response: It is the Government’s responsibility to independently analyze offerors’ proposed costs for their performance based approaches to satisfy the solicitation requirements.
3. Industry question: When establishing methodology are the technical teams involved?
Government response: Yes there are integrated product teams (IPT).
4. Industry comment: Are you using historical data from proposals or actual contracts? Concern is using proposed rates.
Government response: The Government may use actual rates from previous contracts and or task/delivery orders for the same and or similar supplies and services.
5. Industry question: How would the SSA determine technical proposal risk?
Government response: The information related to SSAs’ responsibilities were discussed as annotated on briefing slide 10.
6. Industry question: Talk about how you evaluate labor rates in accordance with compensation plans.
Government response: The Government evaluates compensation plans in essence to ensure proposed talent is retained for duration of contract performance. FAR clause 52.222-46 was referenced by panel.
7. Industry question: Share how a determination of unbalanced pricing is made.
Government response: Costs are evaluated to ensure properly distributed as appropriate for items procured. Post symposium reference FAR 15.404-1(g)(1).
8. Industry question: Is it possible for the incumbent to propose BLS and be outstanding?
Government response: A proposal can be rated technically outstanding and have probable cost adjustments; costs realism analysis do not have an adjectival ratings.
9. Industry question: Has APG considered providing IGCE and budget information like your sister organization in the south?
Government response: Some teams have provided budget information for major weapon systems etc.
due to funding availability caps. The government will follow up on this suggestion.
10. Industry question: Do you consider clearances, etc. when evaluating price? BLS does not include SCI – how is it considered?
Government response: Security clearances are covered and evaluated under the non-cost factors; not cost realism. The government may also look at actual historical labor rates for same and similar supplies and services that may have had security clearances.
11. Industry question: How are proposal cost narratives used and what tips do you have to make them more useful? How does it map to cost realism assessment?
Government response: It is always helpful to do a crosswalk from the BOEs to the labor categories prior to proposal submissions and after discussions. If you have cost data from various sources please provide those details that will assist the Government to understand your proposal. Please check to ensure information is updated and not copied and pasted from previous proposals due to company changes and verify formula accuracy.
12. Industry question: How do you go about evaluating past performance linked with cost? For example, how does a contractor with a history of overruns get evaluated?
Government response: The cost realism evaluation is independent of the past performance evaluation.
The government does evaluate CPARS in the past performance area when evaluating recent and relevant information which is provided to the SSA in accordance with solicitation requirements.
13. Industry question: How do you look at proposals with discounted indirect rates and no fee?
Government response: The government does not prescribe how offerors’ propose fixed fee rates; the government would be leery; it was noted that there are prescriptions in the FAR related to cost type contracts and statutory limits regarding fee.
Post symposium reference: Cost contracts FAR 16.302 and CPFF contracts 16.306.
14. Industry question: Under Better Buying Power we are using FPRA/FPRR on indirect rates. How do you evaluate a cost realism without approved rates or accounting system?
Government response: The cost narrative is helpful looking at actual pools; we may also request historical data for the last three (3) years.
15. Industry question: What is the standard deviation mean (implied from slide 9 example)?
Government Response: if we see a rate that is close to the 10% of the standard deviation we do take a closer look.
16. Industry question: Labor category experience required (e.g. 15-20 years vice 1-2 yrs) what do we need to have in mind?
Government response: It is important that you follow what is requested in the solicitation.
17. Industry question: How do you evaluate uncompensated overtime?
Government Response: It is accounted for in FPRR/FPRA. FAR part 37 discourages uncompensated overtime; but if it is proposed with an explanation, a discussion may be held to determine why it may be necessary.
18. Industry question: Do you evaluate Basis of Estimates? What does your team look for?
Government Response: Technical evaluation may ask if it is realistic.
Post symposium reference: Please refer to solicitation requirements.
19. Industry question: Per recent trends, please explain binding prices in CPFF for Division E effort?
Government Response: The government sometimes has a CPFF contract or task order and may have CLINS that are binding (priced). The government stated that without looking at the specific effort we could not answer at this time and would follow up with the answer.
20. Industry question: We hate to not learn from cost. What goes into the debriefing?
Government Response: We like to be very complete in our responses explaining realism in debriefings.
21. Industry question: What happened to evaluations based on above and below the IGCEs to determine if you were out (above or below a certain amount from the IGCE)?
Government response: Some IGCEs are based on incumbent historical cost/price data so the rates measured are not really competitive. We encourage you to convey technical experience in terms of tradeoff. Statistical analyses are done thoroughly but it is not the end-all be-all.
22. Industry question: How far back does the historical data go?
Government response: That will vary with the requirement, but the IDIQ orders and other contracts are used and may go far back years.
23. Industry question: How do you perform cost realism if one bidder provides a proposal that is much less than the other offerors?
Government response: Cost realism is performed for each offeror based on their performance based approach.
24. Industry question: Are unaudited sub-contractors with no approved systems required to send a sealed bid package?
Government response: Prime contractors may want to rely on the instructions in the solicitation and request their subcontractors to provide as much detail and information as possible.
25. Industry question: How is an acceptable escalation determined?
Government response: Typically 2% for every year but it would also vary with the offeror information and different sources for example Global Insight.
Below are the questions that the Government will provide updated from the symposium (restated from above) and post symposium questions received.
1. Industry question: Per recent trends, please explain binding prices in CPFF for Division E effort?
(previously stated above)
2. Industry question: Has APG considered IGCE and budget information like your sister organization in the south? (previously stated above)
3. Industry question: Our example with SSA debriefs on unsuccessful efforts is that we receive the final score of technical value, past performance and total cost (sometimes adjusted). Any thoughts to elicit any further insight to help future proposals are declined because of proprietary data from winning proposal? Frustrates and seldom helpful. (post symposium question received)
4. Industry question: With a shift to commercial software requirements to meet Army specific needs, how does the government ensure a level field of the overall operational requirements vs.
meeting a lab requirement adjusting cost realism? (post symposium question received)
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