ChBA Phase 1_QA_2026-02-27.pdf

Accelerated Transformation of Legacy Applications and Systems (ATLAS) Challenge Based Acquisition (ChBA)

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer 1 Section 5.a.i, Factor 1 The FAA's requirements may allow other companies who may have less experience than us to qualify. For example, we have completed such projects for $250K that could be used for reference. Another company may have an IDIQ with a ceiling of $10M per year and completed a reference project for only $50K and still qualify. Effectively the other company would be accepted with a $50K project and our company would be excluded for its $250K project.

The FAA's evaluation criteria and process for Factor 1 were carefully selected and will not be changed except as noted in the updated Announcement. All corporate experience examples must be recent and relevant per the requirements in Section 5.a.i. Also, Footnote 3 defines how Offerors must calculate the Annual Dollar Amount for ordering vehicles (e.g., IDIQs).

2 Section 5.a.i, Factor 1

Would the FAA consider restructuring Factor 1 as a pass/fail threshold (e.g., a minimum validated score of 30,000 points) rather than only accepting the (10) highest scoring Offerors? Offerors meeting the threshold would have their Factor 2 Concept Papers evaluated; those that do not would be eliminated.

No. Factor 1 will not be restructured to pass/fail.

3 Section 5.a.i, Factor 1

Would the FAA consider allowing Offerors to include experience from a “significant subcontractor”, defined as performing at least 20% of the ATLAS effort, subject to reasonable limits that maintain prime accountability?

The Offeror itself will have privity of contract with the FAA and will solely be responsible for contract performance. Therefore, it is essential for the FAA to assess the Offeror’s experience to ensure the Offeror can perform this highly complex project successfully.

However, the FAA has updated the Announcement based on feedback received. Offerors may now utilize experience performed by proposed subcontractors, teaming partners or affiliates (including parent companies or wholly owned subsidiaries), but such experience may only constitute a maximum of 25% of the total points claimed and earned by the Offeror in Factor 1. Additionally, to claim and earn points for experience that is not the Offeror’s direct experience, the Offeror must include a separate narrative that adequately demonstrates meaningful participation by the proposed subcontractors, teaming partners or affiliates (including parent companies or wholly owned subsidiaries) on the ATLAS program. Offerors must also complete Column F in the updated Attachment 2 – Self-Score Model to clearly indicate which entity performed the cited contract or task order example.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer 4 Section 5.b, Down-select Decision Given that Phase 2 and Phase 3 are weighted more heavily and are technical in nature, would the FAA consider increasing the relative weight of Factor 2 in the Phase 1 down-select to ensure the Offeror pool advancing to Phase 2 reflects the strongest technical approaches, not just the largest corporate portfolios.

The Announcement has been updated to clarify how the FAA will make the Phase 1 down-select decision.

5 Given the SOO’s emphasis on achieving Continuous Authorization to Operate (cATO) by embedding security controls natively into the development and operational fabric and the Phase 1 requirement to demonstrate ‘tools and approach,’ is FAA seeking: (1) primarily a systems integrator to build and operate a modernization factory, (2) a software platform that agencies will use as part of ATLAS, or (3) a combined solution where the SI brings or integrates such a platform?

The FAA anticipates a combined solution in which the Offeror demonstrates both the capability to operate a modernization factory and integrate or provide enabling platform that supports DevSecOps. Offerors should describe their proposed operating and tooling approach.

6 Will FAA accept OSCAL-formatted artifacts (e.g., SSP, POA&M, SAR) and pipeline-generated evidence as part of our cATO approach now and in later phases/demos?

This information is not relevant to Phase 1. The FAA is not requesting evidence for Factor 2 approaches in terms of artifacts or attachments. Instructions for later phases will be provided only to those invited to participate.

7 What minimum continuous monitoring metrics should be surfaced?

Active cyber defense expectations? Boundary strategy preference?

Shared services as common control providers?

Offerors should address these topics at an enterprise architecture and operating model level as part of their Phase 1 concept paper. The Offeror should provide their approach to integrating continuous monitoring, security boundaries, and shared services into rationalization, modernization and enterprise architecture, data excellence strategies.

8 Section 5.a.i, Factor 1

Would the Government consider permitting offerors to include relevant commercial corporate experience alongside federal, state, and local past performance when such experience demonstrates delivery of comparable scale, complexity, security, and innovation aligned to this requirement? Doing so broadens competition, highlights proven modern delivery practices matured in the commercial sector, accelerates access to emerging technologies and industry best practices, and reduces performance risk through demonstrated success across diverse yet mission relevant environments.

The Announcement has been updated to permit Offerors to include commercial contracts in Factor 1.

9 Section 5.b, Down-select Decision

Relative Weighting: Phase 1 down-select considers Factor 1 and Factor 2 “equally weighted.”

The Announcement has been updated to clarify the Phase 1 down-select decision.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer

Can the Government confirm whether the final Phase 1 invitation to Phase 2 is a best-value judgment across the two factors, or a mechanical combination of rank/ratings?

10 Element 1 - Size and Scale

What is the annual dollar amount for the SSD contract? ATLAS is a new contract requirement with a similar scope to the current SSD contract but differs in magnitude and complexity. The FAA will not be releasing details of the current SSD contract.

11 Element 2 - Portfolio Volume Management

How many applications and shared service platforms are in the current SSD contract?

ATLAS is a new contract requirement with a similar scope to the current SSD contract but differs in magnitude and complexity. The FAA will not be releasing details of the current SSD contract.

12 Element 3 - Data Estate Scale

How many databases are in the current SSD contract? What is the total storage volume?

ATLAS is a new contract requirement with a similar scope to the current SSD contract but differs in

13 Element 4 - Human Capital

What was the staffing levels in terms of simultaneous development staff FTE under the current SSD contract?

ATLAS is a new contract requirement with a similar scope to the current SSD contract but differs in

14 Element 5 - Rationalization Success

How many applications have been successfully rationalized under the current SSD contract?

ATLAS is a new contract requirement with a similar scope to the current SSD contract but differs in

15 Element 6 - Cloud- Native Transformation

How many applications have been successfully migrated to a cloud-native architecture under the current SSD contract?

ATLAS is a new contract requirement with a similar scope to the current SSD contract but differs in

16 Element 7 - Demonstrated

What percentage of application cost reduction was observed post-modernization under the current SSD contract?

ATLAS is a new contract requirement with a similar scope to the current SSD contract but differs in

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer Application Cost Reduction

17 Element 8 - Production Artificial Intelligence (AI) Implementation

Was Generative AI/ML deployed for code refactoring/testing on the current SSD contract? If so, for how many systems?

ATLAS is a new contract requirement with a similar scope to the current SSD contract but differs in

18 Element 9 - Safety Critical Context

Did the current SSD contract include modernization experiences that meet your expectation of safety-critical and/or life-safety systems?

ATLAS is a new contract requirement with a similar scope to the current SSD contract but differs in

19 General Is there a summary of the application languages, deployment environments (mainframe, cloud, desktops) and database technologies (vendor, SQL vs NoSQL, etc.) that can be provided to illustrate what is represented in the future ATLAS scope?

Offerors should reference Attachment 4 for details on the current state legacy application landscape.

20 Will the FAA provide Offerors an extension, affording industry the opportunity to build the detailed packages the FAA requires to support Phase 1?

The Phase 1 due date has been extended. Phase 1 responses are now due by March 13, 2026 at 5PM (ET).

21 Will the FAA consider expanding the Attachment 3 page allocation, from 2 pages to 3 pages, allowing Offerors to thoroughly address elements?

The announcement has been updated to increase the page limit to three (3) pages for each Corporate Experience Form (Attachment 3).

22 Element 8 Element 8 instructs Offerors to demonstrate experience with “deployment of generative AI/ML for code generation/refactoring/testing on a production government system.” The evaluation criteria in Section 5.a.i further describe qualifying AI as “production-grade, repeatable AI deployment beyond isolated pilots or single-use AI-enabled tests.” Does qualifying AI experience under Element 8 encompass the deployment of AI/ML capabilities for operational use cases on production government systems such as predictive analytics, intelligent workflow automation, anomaly detection, or AI-assisted decision support, or is Element 8 strictly limited to AI deployed specifically for software code generation, refactoring, and testing functions?

Qualifying experience must demonstrate AI capabilities that are operationalized beyond isolated pilots or one-time demonstrations, with evidence of secure deployment, governance, and repeatable use.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer 23 The Announcement states that Phase 1 responses are due March 10, 2026, and that Offerors invited to Phase 2 must be prepared to participate in an Industry Day within one to two weeks of notification and submit a Phase 2 response within two to three weeks of the Industry Day.

Can the FAA provide an approximate timeframe within which Phase 1 down-select notifications will be issued following the March 10, 2026 submission deadline?

The FAA intends to make its down-select decision within approximately 3-5 weeks from receipt of proposals.

24 The Statement of Objectives (Attachment 1) describes a mission support portfolio encompassing approximately 200 applications and 3,000 databases, but does not provide detailed information about the current portfolio composition, technology stack distribution, application criticality classifications, or data architecture. Does the FAA intend to provide Phase 2 participants with additional technical data about the current FAA application and data portfolio, such as a portfolio inventory, application profiles, or architecture documentation, prior to or in conjunction with the Phase 2 Industry Day? If so, will any such data be provided in advance of the Industry Day to allow Offerors adequate preparation time?

Yes. Additional technical data will be provided to Phase 2 participants although the timing is still to be determined.

25 To allow for ease of evaluation, will the Government allow a glossary of acronyms to be included as an appendix outside of page count?

No. If an Offeror elects to include an appendix for acronyms then this will be included in the page count limits as prescribed in the Phase 1 announcement.

26 General Can the Government identify for Offerors when in the phases that pricing will be required to be submitted?

The FAA intends to formally request price proposals during Phase 4. As noted in Section 6 of the Announcement, the FAA may discuss potential pricing arrangements with Offerors during Phase 2 and/or Phase 3.

27 Element 9 In reference to the Safety-Critical Context: Is the Safety-Critical Systems experience restricted to the development role for that system or is a broader experience acceptable as long as the $10M threshold is met, i.e.

program development, requirements, system analyses, etc.?

The Announcement has been updated to clarify that experience modernizing must be in a development role specifically supporting the software development lifecycle.

28 The SOO emphasizes portfolio-wide rationalization, AI-enabled analysis, governance dashboards, DevSecOps acceleration, and factory-based modernization at scale. May the FAA clarify whether it would consider a Small Business Prime Offeror whose core responsibility is operating a centralized Innovation/Modernization Factory governance framework, This ChBA will be unrestricted (i.e., “full and open competition”). All Offerors, both large and small companies, will be evaluated in accordance with the Phase 1 Announcement.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer including intake triage, rationalization scoring, AI-enabled portfolio analysis, DevSecOps pipeline standardization, and modernization orchestration, while competitively assigning execution work to appropriately scaled integrators under structured tasking?

29 Will the FAA consider allowing Offerors to identify and utilize proposed subcontractors or teaming partners in support of Factor 1 and/or Factor 2 responses, including for purposes of enhancing self-scoring points, providing suitable project experience references, and supporting the Concept Paper?

See the answer to Question #3.

30 Does the FAA anticipate a single-award production vehicle, or multiple-award construct, to support the portfolio-wide modernization objectives described in the SOO?

The FAA has not yet determined if this ChBA will result in one or more awards.

31 Can this requirement be considered for a Small Business set-aside, either in whole or in part, and if not, did the FAA conduct a small business capability or market research assessment to determine whether sufficient qualified small businesses exist to perform this requirement as a prime contractor?

The FAA has planned this acquisition strategy consistent with the Acquisition Management System (AMS). This ChBA will be unrestricted.

32 The current self-scoring worksheet appears to emphasize discrete, cumulative contract attributes that may favor very large firms and discourage ample competition. Given the FAA’s need for delivery of complex, mission-critical IT systems, would the Government consider revising the past performance evaluation approach to focus on a limited number (e.g., three) of large-scale ($100 TCV), highly relevant programs, with narrative descriptions of scope, complexity, outcomes, and modernization impact related to the other 8 Elements, rather than a predominantly binary scoring construct? We believe this approach may better enable the Government to assess the depth of capability, integration complexity, and demonstrated mission outcomes, consistent with best-value trade-off principles.

The FAA has thoroughly researched and carefully constructed the Phase 1, Factor 1 Self-Scoring construct. The FAA does not intend to change this approach except as noted in this document.

33 The current scoring criteria in several elements, most notably Element 2 (Portfolio Volume Management), Element 5 (Rationalization Success), and Element 6 (Cloud-Native Transformation), use raw application counts as the primary unit of measurement, which inadvertently disadvantages offerors whose experience is concentrated in modern cloud-native, microservice-based architectures and who have

The FAA will validate Offeror self-scoring submissions against the definition in Footnote 4 to ensure excluded artifacts are not counted. Please refer to Footnote 4 which describes the acceptable definition of an application.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer demonstrated higher-order portfolio management capabilities such as legacy consolidation, rationalization at scale, and cloud-native re-platforming. Specifically, consider an offeror who has consolidated 25 legacy systems into a single cloud-native application comprising 30 independently deployed microservices. Such an offeror has demonstrably performed portfolio rationalization (Element 5), cloud-native transformation (Element 6), and portfolio volume management (Element 2) at significant scale — yet the current raw application count metric may not fully credit this experience because the unit of measure does not account for the architectural reality of modern cloud-native delivery. Given that Elements 2, 5, and 6 all use application counts as a proxy for portfolio management scale and complexity, how will the government ensure that offerors demonstrate cloud native transformation experience on an equal footing, while avoiding counting of technical assets such as web forms, SharePoint sites, reports, dashboards, etc., as “applications”?

34 Factor 1, Element

Would the FAA consider revising Element 4 - Human Capital to allow one example demonstrating at least 100 FTEs for 1,000 points and one example demonstrating at least 200 FTEs for 2,000 points, rather than requiring higher thresholds? While we understand the FAA intends to verify an offeror's ability to orchestrate large-scale modernization, retaining the current high-headcount thresholds inadvertently penalizes efficient, modern integrators and contradicts the core objectives of the ATLAS requirement. We recommend this revision based on the following two factors:

1) Alignment with ATLAS Subfactor 1 Objectives - The ATLAS Phase 1 Announcement states that the FAA will evaluate Offerors in Subfactor 1 based on their evidence of a factory model that shifts from headcount-based staffing to automation, standardization, and reuse. Adjusting the scoring to the 100-200 FTE range ensures the FAA is evaluating the orchestration of modernization factories rather than bloated legacy programs.

2) Alignment with Broader Federal Efficiency Mandates - The current administration’s emphasis on efficiency and fiscal responsibility, along with recent Department of Government Efficiency (DOGE) directives, The Factor 1 self-scoring criteria has been carefully selected and will not be changed except as noted in this document.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer strongly discourages inflated contractor headcounts. By adjusting the Element 4 thresholds to 100 and 200 FTEs, the FAA still mandates proof of significant human capital orchestration and enterprise capability, but avoids disproportionately favoring mega-integrators based on labor hours.

35 Factor 1, Element

The instructions to offerors state, “Cloud-native transformation must include application refactoring or re-architecture to leverage cloud-native services and patterns”. Please confirm whether the FAA requires offerors to demonstrate experience with the fundamental attributes of cloud-native transformation, as outlined in NIST SP 800-145 and SP 800- 190, including on-demand self-service, broad network access, resource pooling, rapid elasticity, and measured service. Unlike lift-shift or simple rehosting migrations to the cloud that run legacy software on cloud infrastructure (IaaS), cloud-native applications are specifically architected as portable, distributed, and containerized workloads. This approach abstracts the underlying physical infrastructure via OS-level virtualization (containers) and uses automated orchestration to enable dynamic scaling and resilient, independent service management.

In Section 5.a.i., Table 2, Element 6 states that lift-shift or simple rehosting migrations do not apply.

36 Factor 1, Element

Would the FAA consider adjusting the scoring thresholds to 10, 20, and 40 applications to reflect better the depth and complexity of true cloud-native refactoring efforts, rather than emphasizing volume alone? While we understand the FAA’s intent to evaluate large-scale capabilities, the current thresholds of 25, 50, and 100 applications conflict with the FAA’s definition of cloud-native transformation and penalize successful portfolio consolidation. Achieving 100 true cloud-native transformations on a single experience example is a rare industry scenario. It incentivizes offerors to stretch the definition of transformation to include basic lift-and-shift containerization to meet the volume requirement, which defeats the FAA's evaluation intent.

The Factor 1 self-scoring criteria has been carefully selected and will not be changed except as noted in this document.

37 Would the FAA consider increasing the number of Phase 1 down-selected offerors to 20 (from 10) while reducing the subsequent Concept Paper length to 10 pages (from 15)? This approach would broaden competition and increase access to innovative solutions, while maintaining a comparable, or potentially reduced, evaluation burden.

Although additional offerors would advance, each submission would be

No.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer shorter, resulting in a similar overall review volume while encouraging concise, focused responses aligned with the stated evaluation criteria.

38 Attachment 3 requires Government COR/CO/PM signatures, along with supporting documentation, to validate Corporate Experience narratives.

Coordinating these certifications involves identifying the appropriate official, routing documentation for review, incorporating feedback, and securing formal signature approval, a process that can require multiple follow-ups and is largely outside the offeror’s control. Given the time required to gather evidence and obtain the necessary Government validations, would the FAA consider granting an extension to allow sufficient time to complete this certification process and ensure fully compliant submissions?

The Phase 1 due date has been extended. Phase 1 responses are now due by March 13, 2026 at 5PM (ET).

39 Given that certain federal agencies are currently operating under partial shutdown conditions (e.g., DHS components), which may impact responsiveness for verification and signature requests, would the FAA consider an extension to ensure fair and complete submissions from all offerors?

The Phase 1 due date has been extended. Phase 1 responses are now due by March 13, 2026 at 5PM (ET).

40 Will the FAA consider increasing the Corporate Experience Form (Attachment 3) page limitation from two (2) pages to not-to-exceed three

(3) pages, given that the current limit may constrain offerors’ ability to both clearly describe the scope of work performed and adequately substantiate any claimed experience (or points) in alignment with the evaluation criteria?

The announcement has been updated to increase the page limit to three (3) pages for each Corporate Experience Form (Attachment 3).

41 Would the government consider adding transition risk, institutional knowledge, and operational continuity to the Phase 1 evaluation, given that Objective 8 emphasizes seamless service transition?

No. The FAA has carefully and deliberately chosen the evaluation criteria and process for Phase 1.

42 Can the FAA confirm that the evaluation criteria have been assessed for potential unintended competitive impacts, including disproportionate advantage to very large integrators, consistent with AMS procurement integrity principles?

The FAA has carefully and deliberately chosen the evaluation criteria and process for Phase 1.

43 In accordance with AMS Section 3.2.1 (Public Announcements and Competition Requirements), which emphasizes maximizing competition and avoiding unnecessarily restrictive criteria, how does the current Phase 1 scoring construct ensure that the annualized ceiling-based thresholds do not unduly restrict competition to only the largest firms?

See the answer to Question #46.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer 44 AMS best value principles emphasize selecting the contractor most likely to meet the Agency's objectives. Would the government consider an alternative approach to self-scoring sheets that emphasizes qualitative modernization capability demonstrated through past performance write-ups?

No. The FAA has determined that the evaluation criteria and process set forth in Phase 1, and those planned for subsequent phases of this ChBA, will result in the selection of the Contractor(s) that will provide the best value and are most likely to meet Agency objectives.

45 AMS competition standards promote fair and equitable treatment of Offerors. How has the FAA assessed whether the portfolio size and annual revenue thresholds may create de facto barriers to mid-sized firms, despite those firms demonstrating relevant, complex modernization experience aligned to ATLAS objectives?

The Factor 1 self-scoring criteria has been carefully selected and will not be changed except as noted in the updated Announcement. All Offerors will be treated fairly and evaluated against the criteria set forth in the Announcement.

46 How does the current Phase 1 scoring structure align with AMS principles requiring full and open competition and avoidance of unnecessarily restrictive evaluation criteria?

The ATLAS ChBA will be unrestricted (i.e., “full and open competition”).

The FAA has carefully and deliberately selected the evaluation criteria for Phase 1. Consistent with the AMS, the ATLAS acquisition team has identified key areas of importance and emphasis to be considered in the Phase 1 down-select decision that will truly differentiate the Offerors.

The Factor 1 self-scoring model is not a pass/fail factor.

Offerors will be differentiated quantitatively based on relevant experience in the elements identified by the FAA. Each element is reasonably connected to the performance outcomes required, and Offerors with more experience in these areas are more likely to be successful in performing any resultant contract.

Offerors are not required to possess the maximum number of examples permitted in each element in the self-score model.

Section 5.a.i. describes the minimum qualifications for each corporate experience example provided (e.g., performed within the last 3 years, annual dollar amount of $10M, etc.). Each of these minimum

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer requirements was carefully chosen to ensure the cited examples were recent and relevant. These minimum requirements are not unnecessarily restrictive.

47 Given that AMS emphasizes best value determinations, how does a mechanically sorted, top-ten self-score model ensure that qualitative differentiation is not prematurely eliminated?

The Announcement has been updated to clarify the Phase 1 down-select decision. The FAA has determined that the evaluation criteria and process set forth in Phase 1, and those planned for subsequent phases of this ChBA, will result in the selection of the Contractor(s) that will provide the best value and are most likely to meet Agency objectives.

48 Factor 1, Element

Element 5 currently scores offerors for rationalizing at least 20% (Example 1) and 50% (Example 2) of a portfolio containing at least 100 applications. Will the FAA revise these tiers to credit instead offerors that have fully rationalized (100%) a portfolio of at least 20 applications (Example 1) and at least 50 applications (Example 2)? Completed rationalization of a scoped portfolio is a stronger indicator of execution capability than partial rationalization of a larger one. The current thresholds allow offerors to satisfy the criteria by selectively retiring only the easiest, lowest-complexity applications while leaving harder, mission-critical systems untouched. Full rationalization—regardless of portfolio size—demonstrates end-to-end program management, stakeholder coordination, data migration, and compliance closeout skills directly aligned with the FAA's ATLAS objectives. The proposed revision also broadens competition consistent with the ChBA's goal of fostering innovative solutions.

49 To ensure that offerors have the time necessary to compile a complete and accurate response – and to modify their responses based on the Government’s answers to questions – would the Government please extend the due date to March 24?

The Phase 1 due date has been extended. Phase 1 responses are now due by March 13, 2026 at 5PM (ET).

50 Section 5.a.ii The evaluation criteria for the Concept Paper states that “Factor 2 will be evaluated based on the three (3) subfactors and the respective criteria listed below,” referring to three subfactors that each have four topics.

However, the Instructions begin by stating that “Offerors must provide a concept paper that demonstrates the Offeror’s concept for a technical solution that satisfies the FAA’s objectives as stated in the Statement of

The Phase I Announcement, Section 5.a.ii is revised to clarify the Factor 2 evaluation. Note: Fully compliant proposals do not automatically equate to high confidence ratings.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer Objectives (Attachment 1) and specifically addresses the three (3) subfactors below.” A possible interpretation of the instructions is that within the 15-page limit, FAA intends for Offerors to structure their responses not only on the three subfactors [comprising 12 subtopics], but also the eight Objectives [comprising 30 Outcomes] as stated in the Statement of Objectives (Attachment 1). Can the Government please confirm that if Offerors provide a response that follows the structure of Subfactors 1-3 they will then be providing a fully compliant response that can potentially achieve a High Confidence rating?

51 Section 5.a.iii The instructions state that Offerors must submit a completed version of the self-score worksheet (Attachment 2) in MS Excel version along with a signed version. Please confirm that two versions of the Excel self-score worksheet (Attachment 2) are required: an unsigned version and a signed version.

Yes, Offerors must provide a “soft copy” in MS Excel along with an electronically signed version.

52 Will the Government confirm corporate experience completed by a wholly owned subsidiary of the offeror will be accepted?

See the answer to Question #3. For this ChBA, the term “affiliates” includes parent companies and wholly owned subsidiaries.

53 As a wholly owned subsidiary under a large business parent company, will the Government confirm corporate experience completed as the prime contractor by a subsidiary of the parent company is deemed acceptable?

See the answer to Question #3. For this ChBA, the term “affiliates” includes parent companies and wholly owned subsidiaries.

54 Factor 1, Elements 2, 5 and 6

To ensure the FAA accurately evaluates modern IT expertise, would the government consider refining the definitions for Portfolio Volume Management, Rationalization Success, and Cloud-Native Transformation. The current reliance on application counts inadvertently penalizes cloud-native architectures (for example, 20 legacy monoliths might be consolidated into a single platform of 30+ microservices).

Would the Government consider a unified definition of "application" that accounts for independently deployable microservices?

No. The FAA has carefully constructed the Phase 1 criteria to best exemplify the experience required to achieve the FAA’s strategic objectives.

55 Why are Objective 8 priorities (specifically transition risk, institutional knowledge, and mission continuity) excluded from Phase 1, given their critical importance to the stability of the National Airspace System?

Phase 1 evaluation is intentionally focusing on Offerors’ technical modernization approach and capability to execute the challenge-based objectives.

56 Subfactor 2 mentions considering user workflows and fragmented journeys in rationalization decisions. Will duplication in user workflows

Offerors should demonstrate how user experience, workflow efficiency, and reduction of fragmentation are

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer or inconsistent user journeys be a formal factor in Retain/Retire/Consolidate decisions?

incorporated into their analysis to support data-drive rationalization and modernization decision.

57 Objective 2 references alignment with FAA accessibility standards. Is accessibility simply a compliance requirement, or will demonstrated maturity in accessibility practices affect evaluation ratings?

Offerors are expected to submit a Concept Paper that is fully responsive to the Phase 1 Instructions and Evaluation Criteria as outlined.

58 The announcement states, “If the Offeror is a joint venture, the FAA will only consider examples performed by the joint venture itself or by the individual members of the joint venture.” Will the FAA reconsider allowing Joint Ventures to use the individual members’ experience for self scoring? Allowing newly formed JVs (who have never delivered together) to combine unrelated past performance artificially inflates scores and introduces avoidable performance risk. To ensure fairness and reduce risk, experience should only be credited when it was performed by the JV entity itself.

The FAA will not change the instructions as it pertains to joint venture Offerors. Note that all Offerors, including joint ventures, must be actively registered in the System for Award Management (SAM) at the time of Phase 1 submissions.

59 We respectfully request that the FAA clarify that each company may participate in only one ATLAS Phase 1 submission. Specifically, we recommend the following language be added to the solicitation:

- A company may not submit a proposal as a prime and simultaneously participate as a subcontractor or JV member on another proposal.

- A company may not participate on multiple teams in any capacity (prime, subcontractor, JV member, mentor/protégé partner, or affiliate).

-JV members may only appear in one proposal—either as part of the JV or as an independent offeror, but not both.

- Subcontractors may only support one prime offeror and may not provide “over/under” or contingent participation across multiple bids.

The announcement has been updated to confirm that Offerors must not submit more than one response. For instance, Offerors must not submit one response as a member of a joint venture and also submit a response independently.

60 What does success look like in the early years of the contract? (e.g., Year 2, Year 3, Year 4)?

Success in the early years will be demonstrated by establishing a scalable modernization operating model, delivering measurable rationalization outcomes and accelerating secure software delivery and achieving cost saving or cost avoidance. Early progress should reflect tangible reductions in technical debt and improved delivery velocity.

61 Are there mandated enterprise platforms (e.g., CI/CD, API gateway, observability, identity) that offerors must integrate with?

Offerors should refer to Attachment 4 for summary of current state legacy application landscape.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer

62 Are legacy mainframe-based systems included within the ATLAS modernization scope?

63 What are the preferred or mandated DevSecOps and security tooling stacks currently adopted by the FAA?

Offerors should refer to Attachment 4 for summary of current state legacy application landscape.

64 Are there restrictions governing the use of generative AI tools on FAA systems, codebases, or data (e.g., model hosting, FedRAMP requirements, data residency)?

AI generative tools must comply with current NIST and FAA security orders.

65 Is the FAA open to non-labor-based pricing constructs such as platform, service-based, or outcome-linked pricing models?

Yes.

66 Where supporting evidence is subject to confidentiality, privacy, or security restrictions established by our clients, will the FAA provide assurance of confidentiality or sufficient security controls as required by the supporting evidence (e.g., Secret, Top Secret)? If not, is it sufficient to describe the evidence and provide a client POC for FAA validation?

Offerors must not submit Secret or Top Secret documents in response to this ChBA. If all other verifiable evidence is impractical, the Offeror may submit a signed narrative as indicated in the Announcement.

67 Can the FAA provide a draft contract including key terms and conditions, or any preliminary contractual model terms that offerors should consider when developing Phase 2 and Phase 3 responses?

The FAA intends to provide this during later phases of the ChBA.

68 Will the FAA consider the experience of an affiliate, provided the affiliate have a meaningful role in performance of the contract?

See the answer to Question #3.

69 What FAA-approved AI/ML tools or platforms (if any) are already authorized for use, and what uses are authorized?

70 Please confirm that if multiple awards are made on the production vehicle, the anticipated contract structure will involve full-and-open competition among awardees for individual task orders — or, if a portfolio allocation model (where each awardee is assigned specific applications or domains) is being considered, confirm that as the envisioned approach so Offerors can tailor their Concept Papers accordingly.

The FAA has not yet determined if this ChBA will result in one or more awards.

71 Please provide the required Phase 2 submission format, page limits (if any), and expected depth/level of effort for the Rationalization Approach response given the 2–3 week turnaround.

The FAA will address this question in the Phase 2 Instructions and Evaluation Criteria.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer 72 For Phase 3, will all participants execute against the same FAA-provided challenge system(s) for fair comparison, or will vendors receive different subsets? Please also provide the approximate scale/stack of the Phase 3 challenge system(s).

The FAA will address this question in the Phase 3 Instructions and Evaluation Criteria.

73 Factor 1, Element

Please confirm that Monthly Status Reports and/or other deliverable documentation submitted to the Government customer be accepted as sufficient evidence for elements claimed in the scoring matrix without needing Government signature on Attachment 3.

This question is too vague for a definitive answer. If the deliverable documentation is sufficiently detailed to adequately substantiate an element, then it may be deemed acceptable without the need for a signed narrative. The Offeror bears the burden of providing sufficient evidence to substantiate the claimed experience for each element.

74 Factor 1, Element

Please confirm that to claim credit for BPA annual value that Offerors may provide a sam.gov printout of the BPA as well as sam.gov printouts of the latest mod of each task order displaying task order values.

Yes.

75 Factor 1, Element

As FPDS will be decommissioned on 2/24/26, please confirm that element 1 may be satisfied by sam.gov contract award printouts.

Yes.

76 Factor 1, Element

Please confirm if a claimed task order POP on a BPA ends after BPA ordering period and the offeror is claiming the BPA and certain task orders as one performance, that POP for the purposes of deriving annual average value should be BPA start date to latest claimed task order end date.

In accordance with Footnote 3, the “number of years of performance of the ordering vehicle that have been completed by the Offeror” should include the latest claimed task order end date.

77 Factor 1, Element

The solicitation states on page 3: "Annual dollar amount is defined as the total contract ceiling value divided by the period of performance in years.

For ordering vehicles (e.g., IDIQs, BPAs, etc.), the annual dollar amount is calculated as the aggregated ceiling amount for all orders awarded to the Offeror divided by the number of years of performance of the ordering vehicle that have been completed by the Offeror." Please confirm that offeror may choose to use all orders awarded or just a subset of orders to calculate value.

In accordance with Footnote 3, Offerors must use all orders awarded under the ordering vehicle.

78 Factor 1, Element

The solicitation states on page 3: "Annual dollar amount is defined as the total contract ceiling value divided by the period of performance in years.

For ordering vehicles (e.g., IDIQs, BPAs, etc.), the annual dollar amount is calculated as the aggregated ceiling amount for all orders awarded to the Offeror divided by the number of years of performance of the ordering vehicle that have been completed by the Offeror." Please confirm that

The Offeror bears the burden of providing sufficient evidence to substantiate the claimed experience for each element. In this instance, the FAA would minimally expect a SAM.gov DataBank record showing the total ceiling value of each BPA Call and the record for the BPA itself showing the period of performance.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer offeror may submit an excel spreadsheet of contract numbers and total value of orders claimed under a BPA along with a sam.gov print out of contract award information for the BPA, and sam.gov print outs are not required for each individual order.

Offerors may also include a spreadsheet summarizing this data, but a spreadsheet alone is not verifiable evidence.

79 Factor 1, Element

Please confirm that to claim credit for Element 2, the 3 enterprise shared services platforms are a separate, cumulative requirement distinct from the application count threshold — meaning an Offeror must demonstrate both the minimum application count (100 or 200) and 3 enterprise shared services platforms, and the platforms may not be counted toward the application total.

Yes, the three (3) enterprise shared services platforms are a separate, cumulative requirement.

80 Factor 1, Element

Please confirm that to claim credit for Element 4, Human Capital, Offerors may provide a printout from their accounting system from the most recent complete contract period displaying number of hours charged to the contract during that period, which may be divided by 1920 to derive number of FTE provided under the contract as sufficient evidence to claim credit for this element without government signature on Attachment 3.

Yes. This would be acceptable supporting evidence for Element 4 assuming all other requirements were satisfied for the cited contract example.

81 Factor 1, Element

Please confirm that to claim credit for Element 4, Human Capital, Offerors may provide a copy of Service Contract Reporting data found at https://www.acquisition.gov/content/service-contract-inventory for the most recent GFY within the contract period of performance with file filtered to the Offerors contract and use the value in column AI "Total Full Time Equivalent FTE (Prime + Subs)" as sufficient evidence to claim credit for this element without needing government signature on Attachment 3.

Yes. This would be acceptable supporting evidence for Element 4 assuming all other requirements were satisfied for the cited contract example.

82 Factor 1, Element

Please confirm that to claim credit for Element 4, the term "development staff" encompasses not only software developers and engineers but also roles that directly support development activities — such as QA testers, DevOps engineers, data engineers, UX designers, business analysts, and scrum masters — or, alternatively, provide a definition or enumeration of which roles qualify.

Development staff encompasses resources supporting the full application lifecycle, including development, sustainment and operations and maintenance.

83 Factor 1, Element

Please confirm that for Factor 8, deploying a Generative LLM capability in a configuration that has enabled multiple production systems to integrate with it and gain the refactoring / testing benefits scores the same as multiple production systems each installing their own

Yes, Offeror may claim credit for Deployment of generative AI/ML accordingly.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer duplicative Generative LLM capability. Example: A single generative LLM is deployed integrated into the refactoring / testing process of over 100 FISMA systems at an agency. Offeror may claim credit for "Deployment of Generative AI/ML for code refactoring testing on greater than ten production government systems".

84 Please confirm that a Government COR/CO/PM signature on the Attachment 3 narrative form is required only when the narrative is the sole supporting evidence — and is not required when the Offeror provides verifiable documentary evidence alongside a narrative that contextualizes that evidence.

Yes.

85 Section 5.a.i, Footnote 1

Please confirm that the prohibition on double-counting in Footnote 1 applies only within a single ordering vehicle — meaning an Offeror may cite IDIQ-A as an aggregate example while also citing a separate task order from IDIQ-B as a distinct example, as long as no single ordering vehicle is simultaneously cited as both an aggregate and an individual task order.

Yes.

86 Section 5.a.i Please confirm that the same ordering vehicle cited as an aggregate example may be used across multiple elements without restriction — meaning an Offeror may use a single IDIQ as the experience example for Element 1 (Size and Scale), Element 2 (Portfolio Volume), and any other elements for which it qualifies, and that this does not constitute impermissible double-counting.

Yes.

87 Footnote 2 Please confirm that the 51% threshold for IT System Development, Operations and Maintenance, and/or Modernization services is measured by contract dollar value (rather than labor hours or another metric), and describe the acceptable method(s) by which an Offeror should demonstrate that threshold when a contract also includes significant non-IT elements.

Footnote 2 has been updated to indicate that the 51% threshold may be calculated by either the percentage of the total dollar amount or total labor hours. Offerors must provide sufficient evidence to demonstrate the cited contract example meets this threshold.

88 Please confirm that the FAA's preference is for Offerors to omit cover pages and tables of contents from the Factor 2 Concept Paper entirely — given that they are not requested and will count against the 15-page limit

— rather than this being merely a notification that such pages are not excluded from the count.

Section 5.a.iii of the Announcement indicates that cover pages and tables of contents are not requested and will count against the page limitations.

89 Please confirm that in the combined down-select decision, a qualitative Factor 2 rating (e.g., all "High Confidence" subfactor ratings) can offset a

The Announcement has been updated to clarify the Phase 1 down-select decision.

Phase 1 Questions and Answers - February 27, 2026

No. Reference Question FAA Answer relatively lower quantitative Factor 1 score — or conversely, that a very high Factor 1 score can offset "Some Confidence" Factor 2 ratings — and describe, to the extent possible, the methodology the FAA will use to normalize these fundamentally different rating scales.

90 For Phase 2 (Rationalization Approach), will FAA provide a representative dataset of the actual legacy portfolio (e.g., metadata for a subset of the 200 applications and 3,000 databases) for vendors to analyze, or are vendors expected to propose a methodology without access to portfolio data?

Yes. Additional technical data will be provided to Phase 2 participants.

91 Please confirm whether Phase 2 is a fresh evaluation (independent of Phase 1 confidence ratings), and clarify the Phase 2 down-select mechanics to Phase 3 (e.g., top-N, minimum confidence threshold, weighting of Phase 2 subfactors).

Phase 2 will be independent from Phase 1. The FAA will address the Phase 2 down-select criteria in the Phase 2 Instructions and Evaluation Criteria.

92 Please clarify whether Phase 3 results drive a direct transition to Phase 4 production awards (without a separate competition), or whether FAA intends a separate Phase 4 RFP/competition. If known, please provide anticipated contract type and ceiling range for Phase 4.

Phase 4 will be issued to the remaining Offerors participating in the ATLAS ChBA. There will not be a separate competition. The FAA anticipates ATLAS will primarily be a firm, fixed-price contract.

93 Please confirm that Offerors should proactively propose their own quantitative proxy metrics in the Phase 1 Concept Paper to demonstrate understanding of measurable outcomes — or, if the FAA prefers that Offerors describe their approach conceptually and defer specific numerical targets to QASP development upon award, please confirm that as the preferred approach.

The FAA prefers that Offerors describe their approach conceptually.

94 Please confirm that transition planning and transition risk need not be addressed in the Phase 1 Concept Paper and will instead be evaluated in a later phase — and confirm whether the FAA intends to provide the selected Offeror(s) with access to incumbent artifacts, documentation, and knowledge bases during the transition period to support the zero-performance-degradation objective.

The Phase I Announcement, Section 5.a.ii is being revised to clarify the Factor 2 evaluation.

Additional technical data will be provided to Phase 2 participants

95 Please…